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HomeMy WebLinkAbout94-05593 jl '-Jf ' I I , . 7i ., .,.,.,1 Ojl ~I j\ 'I ~ J \01 CJI l()1 to .:f;. -:C. .:..:. .It} .:c. -:c. .:c. .:C...*, .X...le> .:.;. .:.;. .:.;. .:c. .:.;. .:.;. .:.;. -:c. -:.;. :. .;1, .:c-;:-$;..,;c. .:eo .:c. .:eo ... ""'1' ~ I ----- --.- ----.---~--~'- - - ij ~! " ...( " ~l . I ~l .., '!II ~l ~I ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF _I'f' ............. "t i- .\~, . _ . .".r PENNA. ~ ~ CHRISTINE H. CAMPBELL, Plaintiff I ~ ~ ~ ., N ll. H.9..<I::5.!i.n. i 'I V crstl~ .j ~ GILBERT L. CAMPBELL, JR. , 'I Ii ,I IN DIVORCE ~ Defendant ~ ~ .j ~ DECREE IN DIVORCE ~ '.' ~l ~ AND NOW, ... .. ..... .8.'7.. . /.'I..~. .. 199.6..... it is ordered and decreed that ..... ~.~~!~.~~~~. .~ ~. ~!\.I-!P~~.~~. . . . . . . . . . . . ... . . ., plaintiff, and. . . . . . . . .~~~~.~RT. .~ ~ . ~~.~~~~!'.~ ~ . ~.R... . . . . . . . . . . . . . . ... . .. defendant, are divorced from the bonds of matrimony. t. ~ ~ ~ ~ " ;:> 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; ." ~ " " ~ ~ All issues resolved by Marriage Settlement Agreement dated .... ,............ ,_.... .......... .,....... ........... ......... .......... '0, ~ ~ ~ ~ ... ~ . . 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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q Ij - SSq 3 ~ -r-Uvh-J CHRISTINE H. CAMPBELL, Plaintiff GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE I ! NOTICB YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or othp.r 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 Corner of High and Hanover Streets Carlisle, Pennsylvania 17013 (717)240-€200 . CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . - NO. (1'1- S'S"'U Cwil I ~ v. GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE COMPLAINT 1. The Plaintiff is Christine H. Campbell, who currently resides in cumberland County, Pennsylvania with a mailing address of 85 W. Main Street, New Kingston, Pennsylvania. 2. The Defendant is Gilbert L. Campbell, Jr., who currently resides in Cumberland County, Pennsylvania with a mailing address of 806 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. plaintiff and Defenoant were married on April 24, 1982. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(C) and 3301(d), in that: al The marriage is irretrievably broken; bl The plaintiff and Defendant have lived separate and apart since September 6, 1994. c) In addition and in the alternative, Defendant over the period of their marriage, has offered such indignities to the ; ; person of Plaintiff as to render her condition intolerable and life burdensome. 8. The Plaintiff has been advised of the availability of counselling and of the Plaintiff's right to request that the Court require the parties to participate in counselling and does not request same. -9. Defendant is not a member of the armed services. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Count II - Eauitable Distribution 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from April 24, 1982, until September 6, 1994, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to the marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT III - ALIMONY PENDENTE LITE AND ALIMONY 14. Paragraphs 1 through 13 of this Complainc are incorporated herein by reference as though set forth in full. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 16. plaintiff requires reasonable support to maintain herself adequately in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony pendente lite until final hearing and thereafter to enter an award for alimony. COUNT IV - COUNSEL FEES AND COSTS 17. plaintiff has retained the Law Offices of Austin F. Grogan but she is unable to pay the necessary and reasonable attorneys' fees for said counsel. lB. Plaintiff may need to hire experts to appraise the marital property but she lacks funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. , COUNT V - CUSTODY 19. plaintiff seeks custody of the following children: Name Present Residence Age Andy L. Campbell B06 Hummel Avenue 12 Lemoyne, PA 17043 Otha J. Campbell B06 Hummel Avenue 11 Lemoyne, PA 17043 One child was born out of wedlock and the other was not. The children are presently in the custody of Gilbert L. Campbell, Jr., who resides at B06 Hummel Avenue, Lemoyne, Pennsylvania. During the children's lifetime, they have resided with the following persons and at the following addresses: Name Address Date Defendant B06 Hummel Avenue Sept. 14 - Lemoyne, PA 17043 Present Plaintiff Battered Woman's Shelter Sept. 6 - Sept. 14 Plaintiff and 806 Hummel Avenue Feb. 93 - Defendant Lemoyne, PA 17043 Sept. 94 Plaintiff and New Cumberland Army Feb. B9 - Defendant Depot, PA Feb. 93 ~he mother of the child is Christine Campbell, currently residing at 85 West Main Street, New Kingston, Pennsylvania. She is married, but separated from her husband. The father of the child is Gilbert L. Campbell, Jr., currently residing at B06 Hummel Avenue, Lemoyne, Pennsylvania. He is married, but separated from his wife. 20. The relationship of plaintiff to the child is that of mother. 21. The relationship of defendant to the child is that of father. 22. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 23. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 24. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 25. The best interest and permanent welfare of the child will be served by granting the relief requested because of the ongoing abuse by the father. 26. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant primary physical custody of the child to the plaintiff with partial custody in the defendant every other weekend from Friday at 6:00 p.m. until sunday at 6:00 p.m., and any other times that my be mutually agreed upon by the parties. Respectfully submitted, DATE: 9~~;&4 a~~~/ Austin F G 0 an, Esq. 24 North 3/1 Street Camp Hill: A 17011 (717) 737-1956 Attorney for plaintiff Attorney ijID 59020 VERIFICATION I, Christine H. Camphell, verify that the statements made in the foregoing Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are made subject to the penaltieo of 1B Pa. C.S. Section 4904. relating to unsworn falsification to authorities. (1z~~ p:' Ca~Df- ISTINE H. CAMPBELL O",e, r?6 f.; -:r ""'" - ~- -.., ....: I.ot l"'\.... ......... N' ~.. ~ ~fl1 ~:~ ~ "'" 'J <":> .Q t;;cl..; ~........ ~ ~ -:t- ~ ~ r- In - t- I""( -.3 - - -- ~~ ~J 0: ~ ":\;~ .. ~...'.:::; ~~~ C=l ,..~. ) "'- .,.. V'> rs.. ~ III rs.. ::i 0< .., r..l ~ A ...:l :z: .:1: ~ H .w ~ ~ .::S llIllot :I: ""ral o . ...:lPo A ~ ~~ ...:l . Z ral ..l H OZ !Xl ...:l ::s 'lI~J~~ OP ~ ral 00< ~ III ll. ~~~f~ r..OH Po X 0 A::i 0 X 0 .! ~d~ . 0< 0 ~Z> . > 0 Pl:l...:l 0:: ral D >- . 0 Ol>:(I) r..l ..l l>: OralZ Z 0 lIlZ H ~ > ral~ ral ~ llIl H 0:: ll. III W A ~O H III l>: ..l Z 0:: H H 0 Cl " !) . "ll/.l'll/l .7 //1'(.',/(/11 , - , 9. Admitted. COUNT II - EOUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 above are incorporated herein by reference. 11. Admitted with the exception that their date of marriage was April 24, 1981. 12. Admitted. 13. Admitted. COUNT III - ALIMONY PENDENTE LITE AND ALIMONY 14. Paragraphs 1 through 13 above are incorporated herein by reference. 15. Denied. The allegations of paragraph number 15 are specifically denied, and proof thereof is demanded. 16. Denied. The allegations of paragraph number 16 are specifically denied, and proof thereof is demanded. WHEREFORE, Defendant demands that Plaintiff's claims for alimony pendente lite and alimony be denied. COUNT IV - COUNSEL FEES AND COSTS 17. Admitted that Plaintiff has retained the law offices of Austin F. Grogan to represent her. As for the remaining allegations of paragraph number 17, they are specifically denied, and proof thereof is demanded. 18. It is specifically denied that Plaintiff lacks funds to pay the necessary and reasonable fees of any experts. As for the - 2 - remaining allegations of paragraph number 18, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and proof thereof is demanded. WHEREFORE, Defendant demands that Plaintiff's claims for interim counsel fees, costs and expenses and claims for any additional sums be denied. COUNT V - CUSTODY 19. It is specifically denied that the children are presently in the custody of Gilbert L. Campbell and that Gilbert Campbell resides at 806 Hummel Avenue, Lemoyne, Pennsylvania. It is also specifically denied that Christine Campbell currently resides at 85 West Main street, New Kingston, Pennsylvania. 20. Admitted. 21. Ad;nitted. 22. Admitted. 23. Admitted. 24. Admitted. 25. Denied. It is specifically denied that the best interest and permanent welfare of the children will be served by granting the relief requested. It is also denied that the father has abused the children at any time. On the contrary, granting primary physical custody to the father will be in the best interest and permanent welfare of the children. - 3 - -;;. 26. Admitted. WHEREFORE, Defendant demands that Plaintiff's request tor primary physical custody of the children be denied and that primary physical custody be granted to the Defendant. COUNTERCLAIM 27. The averments of Plaintiff's Complaint and Defendant's Answer thereto are incorporated herein by reference. 28. The marriage is irretrievably broken. 29. Defendant has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 30. During the marriage, the parties acquired marital property, and Defendant herein requests that the Court herein equitably divide, distribute or assign said marital property between the parties pursuant to the Divorce Code of 1980, as amended. 31. Defendant has insufficient assets and income to pay the costs and expenses that may be required by rules of court or otherwise for the within divorce action, and Defendant herein requests that Plaintiff be directed to pay those costs and expenses. 32. Furthermore, Defendant has retained an attorney to represent him in the pending litigation and has agreed to pay him a reasonable fee. - 4 - CIRTIPICATI O. SIRVICI AND NOW, on this ~ay of ~ Richard B. Druby, Esquil'e of Metzger, fCickersham, , 1995, I, Knauss &. Erb, attorneys for Defendant, Gilbert L. Campbell, Jr., hereby certify that I served the within Answer with Counterclaim this day by depositing the same in the United states mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Austin F. Grogan, Esquire 24 North 32nd street Camp Hill, PA 1.7011 H:r. -. -- "0 ...,. <'J (Y) r-- "'" - . ..:.:: III IX W I/l UI UI ~ ~ Z - · III:': 9 · . ; 5 r t'l ~ uxm..mz , <l( '" fA J( ~ a~p~g it IX III ~ o. · ew.e · ..JxQ%~w U ::l - .. :> . = .; ... % . " ~ IX · W III Cl it N · l:i ~ ~ t'l Cll o o , co o ~ > ;0 . . , CHRISTINE H. CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5593 CIVIL GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMIlERLAND I, Austin F. Grogan, hereby certify that I did mail a true and correct copy of the COMPLAINT IN DIVORCE in the above maller, by certified mail, return receipt requested, to the Defendant, GILBERT L. CAMPBELL, JR., on OCTOBER 5, 1994, at his last known address: 806 Hummel Avenue, Lemoyne, Pennsylvania 17043, which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403. The signed receipt acknowledging receipt on OCTOBER 7, 1994, is attached hereto. I understand that false statements are made herein are made subject to the penalties of Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 43o)l~w tlv4- } J Austin F. Grogal'l"; E& I ... . .r;:>;"'t~,Fg1~~:!!i~%~~!:l5:r/~i-\));/i'ir' <\';t:1'!i::;;l;:,,~':_'~:'/'A4--~}~i' 7~. / jJ~;tI{($ -\;-.~ .. _~;v :.,"< ."" '..:;:.".".1\",'" I.. lOItb We ,.. . ..... lI1lI' !1ft, ,.." . t. 0 ~'. "dOlt.... 2. 0 ...."Ic:18d DllIvery C_~ ootm lor ,... rtlcle NumIler "I".'J' > / , .. .,': ...Co','" , .'V,' 1!I!U11r.... ~-- --, EXHIBIT "A" c. liJ , ... z Ul..c ..c> ~>l - PoUl .... . .., tj Z~ .... ll:lQ ~ - -.... .,Ill ... OW ..1'" 'tl ~ ~'" ..1Q -Q 1:1 iii.... ..:I III o - C1l11l ..:I"" III 'a~J~~ u>< ..1 "'.... Will ~ ... ~'" !Xl A ... ~~ > Po 0 ~~~!~ ... t) . X 0 t) > ..c to .!~.~. ~t) u ... ll:l '" :t: ~ . ~!t: PA "'iii . OZ L(lt) iii ..:I U..c L(ll>' Z ... ..:I 10 .... ~ ... loll>' '<1'> ~ ll:l ~ :t:W "'... en r.l ~C1l A .... !Xl Z~ ll:l ..:I OZ :t: ... ...t) Z'" t) Cl ..... -. ~l{/.I'tiFl tT ,W(Wa/1 " - ; ~ CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5593 CIVIL GILBERT l. CAMPBelL, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 30, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in 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 thatlhe slatements 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. Sec. 4904 relating to unsworn falsification to aulhorities. 0'. -/. / /J J"t \1.' I ~. ...,-"""., . .~ ~ ~,~ ./. Christine H. Campbell ~-//-7/ /J-df 'j) II' '. . . . ., . .... Z U10< 0<> l<l...:l ...:1>- ... .., l1o(l) ... . C & ~ - Z .... Ill'" :Z::Z: .., '">'0 Ol&l ...:IC C ~p., ...:I.... . CII UI l&l'" ..:I... 8 o . Ill.... ..:ICII "4~J~ill U>- ..:I l1ol1o 101 A e-o .... ::E III lit ~~~~~ l<oZ > < l10 00 H U . ~ 0 ! ~ ~ J~ 0 u > .. e-oU U I>:: .., :r. ~ OA '" 101 . a o:z: It'l u 101 ..:I u< It'l I>:: :z: ...:I I 0 H Eo< ~ loll>:: ... > e-o I>:: lit :J:l<l '" H UI 101 ~ Eo<lXl A H III :z:~ . I>:: ..:I 0 Z :.c H He; z H U Cl ~ ~ ..... <"!> ~ .-, .' , ...., '-'''- '- '. .- u. '< ' \. , H :.: III 0( 0(> fWo-1 0-1)< ... .., ~ ~ llolll ... . s:: Z .... I>: III & Z:.: .., '>'0 OW 0-1S:: s:: IPo 0-1.... 'IU i'l fWlll 0-1'" -e~JB~ o . l%l~ o-1IU 8 U)< 0-1 Pollo WO ~~~~~ foo H ~ l%l r..:.: > . Po "" ~f;!R OP H U > ~ c z !~ 0 U . D fooU . U .. 1li l>l .., :c M PO t'lW . 110 0:': IOU W 0-1 i! uo( 10'" :.: 0-1 10 H foo M fW'" .,.> foo I>l "" :CfW O'lH III W "" fool%l 0 H l%l 0< zS I>l '" 0:': = H HU ZH U " ^~ "" ,. '" " . . ~ '1 , ~' :; ,., Z . III 0< 0 0<> 101 lolo-l ~ o-l>< .... ~ ~ "'Ill .... . Z .... 1>::.., ZZ ..., ..,e:: Olol o-le:: '" 101 ~'" o-l.... ''0 '1l~J~ia lol '" o-le:: 11I4 o . 1Xl.... o-llll 0 0>< o-l "'''' lol.... ,~~~~ ~ ,., ~ 1Xl1ll 011 ~~ > . P,A tJ .! ~ dg ,., 0 > ~ 101 0 U i ~U . U I>:: p, :I: PA 0I1ol . OZ LflU lol o-l 11I4 00< Lfll>:: Z 0 o-l 10 ,., ~ loll>:: '<1'> .. I>:: III :I:lol 01'" III lol Ilil ..1Xl A ,., IXl ~ zS I>:: o-l .... OZ :I: ,., .c "'U Z'" U Cl ...... .r.. . . ~ ..,.. -~ CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5593 CIVIL GILBERT l. CAMPBEll, JR., Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE 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 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ..... /t;~~,Y(1~~t.. Gilbert l. Campbell, Jr. Date: ~ 2./" I ... , . ~. . " :--... :'~.'" _0; . , , . . 'J 0< I-< Z .lIII.... U1O< OUlJ <> ~!~ ~~ ... ..., ~O p..U1 ... . C Iotl'l'lllll ~ ~ Z ... PlIO RI'I'lR ZZ .... ,",,'0 0 Oc.l ..:Ie c IotIlll.U ~p.. ..:I'" . QI 0 c.lnl ..:I"" III< III< lot III o . ~... H QI oot~ '8~I~~ 0>0 ..:I p..p.. c.lt:l E- I-< ;I: ~ 1Il~IIlO ~t:t)~~~ IooZ > .( . p.. CJ~CIl> 00 I-< 0 > X lot lot j~d~ 0 0 0< t gjR E-O . 0 PI '" :>:: :ti~~ Pt:l "'c.l . OZ 100 c.l ..:l 00< 10 PI Z O!lllllll< ..:I 10 I-< E- c.lPl ..,.> E- PI ClIlCIIIllO :>::c.l "'I-< UI c.l =IIlClll E-1Il t:l I-< III ClIlO z~ . PI ..:l lot III OZ :>:: I-< =~R ." "'" ;,d~ ~.., . .. . '" . CHRISTINE H. CAMPBELL Pla1nt1ff vs. GILBERT L. CAMPBELL, JR. NO. 94-5593 Civil Term 19 MOTION FOR APPOINTMENT OF MASTER .; . Gilbert L. Campbell, Jr., X!~!X a master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alilllony ( ) Alimony Pendente Lite (Defendant). moves the court to appoint <x) Distribution of Property ( ) Support <x) Counsel Fees <x) Costs and Expenses and in support of the mot10n states: (1) . Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) CtIllll~ appeared in (by his attorney. Richard B. Drubv (3) The stat!lrory ground(s) for divorce XXX){ the action ~ibk . Esquire) . (are)S3301Cc) or Cd). (4) Delete the inapplicable paragraph(s): bkX~"X~mlXM<JOO(x~i1l*l{ CtiXJ(!CUIX~X1x.u<Jblelll'{~jljK,*~li~liX'lA<~Jllt If>>llC~Jr\'~ (c) The action is contested with respect to the following claims: All claims. (ll)CXXL'f1>>X~lI.X~ltllB)(Jot4Ia.l(>>XKX~);X~n:~lIlt~~ ~X"~ (6) The hearing is expected to take 4-6 (7) Additional information. if any. relevant (hours) ~. the motion:None Date: "'J"'d t, - 9-S" ORDER APPOINTING MAS AND NOW ~~v, '\ '- ") r I .19.::LJ.....- \ c- J}L C is appointed master with respect to the following claillls: (Defendant) CL'v.Id" L-( N.... Esquire, S6.' ,;, 11 t.,.., , ,.i:, By t~court: .-- .II- !rt {L-J11:: ~ /) y- . J ...... ...... j,;,- - .n~ -:r:-' ., ,~ ";r. ::T 'J .r N' .' M ....- ,. ....... ~ ".., => '::<..:. -, ASSETS OF PARTIES Plaintiff, CHRISTINE H. CAMPBELL, marks on .the list below those items applicable to the case at bar and itemizes the assets on the following pages. (Xl 1. Real property (X) 2. Motor vehicles () 3. Stock, bonds, securities and options (I 4. Certificates of deposit (Xl 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes (I 8. Trusts () 9. Life Insurance policies (indicate face value, cash surrender value and current beneficiaries) ( 10. Annuities ( 11. Gifts ( 12. Inheritances () 13. Patents, copyrights, inventions, royalties (X) 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 (I 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) (Xl 19. Retirement plans, individual retirement accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) (X) 22. Military/VA benefits () 23. Education benefits (X) 24. Debts due, including loans, mortgages held () 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute . 26. Other MARITAL PROPERTY Plaintiff 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 Number Description of Property 1. B06 Hummel Avenue, Lemoyne, PA 17043 (Marital Home) 1994 Ford Escort L990 Ford Ranger VGLI Policy Pension with Dauphin County Nursing Home Military Retirement plan 2. 2. 22. lB. lB. 25. Living Room Furniture 25. Bedroom Furniture 25. Kitchen Appliances Names of All Owners Christine & Gilbert Campbell Christine Campbell Gilbert Campbell Gilbert Campbell Christine Campbell Gilbert Campbell Christine & Gilbert Campbell Christine & Gilbert Campbe 11 Christine & Gilbert Campbell PROPERTY TRANSFERRED Item Description of No. Property Date of Consid- Person to Transfer eration Whom Transferred N/A " UABILITIES Item Names of All Names of Number Description of Property Creditors All Debtors 24. Marital Home - Mortgage Ge Capital Christine &. <;Hlbert Cam be 11 24. Car Loan - Ford Escort Ford Credit Christine Campbell 24. VISA - Marital Bills MBNA American Christine Campbell IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA CHRISTINE H. CAMPBELL, Plaintiff v. No. 94-5593 CIVIL GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE PROOP OP SBRVles I, Austin F. Grogan, Esquire, hereby certify that on August 1B, 1995, I served a copy of the Plaintiff's Inventory by first claso mail, postage prepaid addressed as follows: Richard B. Druby, Esquire Metzger, Wickersham, Knauss & Erb P.O. Box 93 Harrisburg, PA 1710B-0093 aMiI Austin F. Gore 24 N. 32nd St e Camp Hill, PA (7171 737-1956 1.0. #59020 Attorney for Plaintiff IA - ".. .,3t,-' c....- ~~~~; ~ .- .. .~ _:: '~.j "4,,,:": E ... N M T .., r ...... u -"J ~;~' l/l 0( Col .... ... ... .... .c:: ~ - l>. .-< . III ...:I . ... D:'tI ;j Z>< . c:: "c:: ~~< ...:1.-< ell III ... III ..... l>. ::>H Col~ j21 ~~ ~~J8~ OO~ 1Ill>. UU ... ~ Col U ~~aa:~ :> H III >< "'0... :> . l>. D: . j~'~' O~~ H U > ~ O:c U ~ . ~!to. t'""Z . U ZCol D:Z M :z:: ColZ ;:JColCol "'Col . ~~ O~l>. lflU Col ... lflD: Z Hl/l U::> 10 H ... H ColU "":> ~ D: l>: :c "'H l/l Col :c ~ 0 H III U . l>: '"" Z OZ :c H H ZH U CI _,&utt/I .7" .i";rfW(1/I ASSETS OF PARTIES Defendant mark. on tho list below thoss items applicabls to the ca.e at bar and it.mizss the assets in the following pages. If an itsm ha. been apprai.ed, a copy of the appraisal report is attached. (X) 1. (x) 2. ( ) 3. ( ) 4. (x) 5. (x) 6. ( ) 1. ( ) 8. ( ) 9. ( ) 10. (x) 11. ( ) 12. ( ) 13. (x) 14. ( ) 15. ( ) 16. ( ) 11. (x) 18. (xl 19. ( I 20. ( ) 21. ( I 22. ( ) 23. (x) 24. (xl 25. ( ) 26. Real property Motor vehicles Stock., bond., securities and option. Certificat.. of depo.it Checking account., cash Saving. account., money market and .aving. certificate. Cont.nt. of .afe deposit boxes Trust. Life insurance policies (indicats face value, cash .urrender value and current bsnsficiaries) "nn..itiss Oitts Inhsritances Patents, copyright., inventions, royalties Psrsonal property outside the home Bu.iness (list all owners, including percentage officer/director positions held by a party with Employment termination benefits--.everance pay, compensation claim/award Profit Sharing plans Pens Lon plans (indLcate employee contribution and date plan vest.) Rstiremsnt plans, Individual Retirement Account. 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III ..: .. .. .... ~ ... ..c: 10 .. 0 i~d '" .. ..... .... .. s .... ... 00 a. 0 u III .. ~ :0: .... 10... Dl ... II ... n 'tl III 0 .. III ~ 0 w .. :J..,.... d d 0 "" d 0 III " 10 :Z:O " r.. :z:r..c> :0: III '" " .... .. .... ... .... ;\l .... 'tl ... . ~ 'tl "'11I 0 ...u '" d d,., 'tl .. III ~1:: .. .... :: e os 'tl 'tl U. III U III .. II 0 '" .. .. .... u .... 0 '" .. 0 0 ... .. .. '" .... 10 U... 1:: d d 'tl .. d .., .. '" fa .. '" " 10 .. .... d :J III'" il .9 .9 .. .... .9 'tl '" ao u > " 'tld ... dO 0 III.... m ..... . . . . . . . III U .. 0 .... N '" .. III '" ... a'" ...:z: 1II II: W l'l .., ~ en 0 III cD ::> ~ 0 ~ ! ~ ~ U1:': ~ ~ l'l ~ W ..:) a: en Z !:!2:IDJl ~ .. <(. ., '" % z t- ~ >! OIllIl:IP.~ J ~ 0 z j~Zh~ o ~ = . - w - u 3= % ~ . :l II: 10 '" !!! " ~ N ~ ti ~ ::E ~(d Q!,(ct..../ ~ . OFFICI OF DIVORCI MASTIR CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Slreel Carlisle. PA 17013 (717) 240-6535 ., Robert IlIcker, II Divorce Maslar Tracl 010 Colver Office Maneger/Reporter Austin F. Grogan, Esquire 24 North 32nd street Camp Hill, PA 17011 We.' Sho... 697-0371 Ex!. 6535 August 7, 1995 Richard B. Druby, Esquire METZGER, WICKERSHAM, KNAUSS , ERB P.O. Box 93 Harrisburg, PA 17108-0093 RE: Christine H. Campbell vs. Gilbert L. Campbell, Jr. No. 94 - 5593 In Divorce Dear Mr. Grogan and Mr. Druby: By order of Court of President Judge Harold E. Sheely dated August 1, 1995, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on September 30, 1994, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. I assume that both parties will agree to execute affidavits of consent; the parties have not been separated in excess of two years, the averment in Plaintiff's complaint being that the parties separated September 6, 1994. If, however, there is not an agreement with regard to the grounds for divorce by the filing of mutual affidavits of consent, please let me know immediately and I will schedule a hearing on grounds of indignities raised in the complaint. The complaint also raised the economic issues of equitable distribution, alimony pendente lite, alimony, and counsel fees and expenses. An answer and counterclaim were filed by the Defendant on July 27, 1995. Assuming that grounds for divorce are not at issue, I am directing each counsel in accordance with P.R.C.P. 1920.33(b) to file a pre-trial statement on or before Friday, September 1, CHRISTINE H. CAMPBELL, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 5593 CIVIL 1994 GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Austin F. Grogan Richard B. Druby , 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 5th day of December, 1995, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 9/6/95 E. Robert Elicker, II Divorce Master CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 5593 CIVIL GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING To: Christine H. Campbell Austin F. Grogan Gilbert L. Campbell, Jr. Richard B. Druby , Plaintiff , Counsel for Plaintiff . Defendant , Counsel for Defendant You are directed to appear for a hearing to testimony on the outstanding issues in the above divorce proceedings at the Office of the Divorce Hanover Street, Carlisle, Pennsylvania, on the take captioned Master, 9 North 2nd day place of April a.m., at which , 1996. at 9:00 and time you will be given tne upportunity to present witnesses anrt exhibitB in support of your case. By the Court, ~~~~ Harold E. Sheely, Date of Order and Notice: 12/5/95 By: Divorce Master IF YOU PO 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 1 <) 94 , vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 5593 CIVIL 1994 CHRISTINE H. CAMPBELL, Plaintiff GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Tuesday, December 5, 1995 Present for the Plaintiff, Christine H. Campbell was attorney Austin F. Grogan, and present for the Defendant, Gilbert L. Campbell, Jr., was attorney Richard B. Druby. A divorce complaint was filed on September 30, 1994, raising grounds for divorce of irretrievable breakdown and indignities. Counsel have advised that the parties will sign and file affidavits of consent prior to the hearing to be scheduled in these proceedings so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code. The divorce complaint also raised the economic issues of equitable distribution, alimony, alimony pendente lite, and counsel fees and costs. The Defendant filed an answer and counterclaim in response to the divorce complaint. In the Defendant's counterclaim he raised on his own behalf the economic issues of equitable distribution and counsel fees and costs. The parties were married on April 24, 1982, and separated on September 6, 1994. Counsel have advised that they will stipulate to the date of separation. There wer.e two children born of the marriage, Andy L. and Otha J. Andy is 13 years of age and Otha is 12 years of age. Both children currently reside with the mother. The Master has inquired as to whether we are going to have an issue with regard to the factor of marital misconduct as that relates to wife's alimony claim. Counsel have indicated that we may have testimony about conduct and, therefore, the Master will schedule a separate hearing on that issue prior to a hearing on the economic claims if counsel and the parties persist in pursuing the marital misconduct issue. Wife is 35 years of age and resides with the children at 806 Hummel Avenue, Lemoyne, Pennsylvania, which is , the marital home. She is a high school graduate and has been certitied as a nurses assistant. She is employed by the Dauphin County Nursing Home and has a net biweekly pay ot $406.72. She is receivin9 child support monthly trom husband in the amount ot $482.00 and spousal support monthly in the amount ot $100.00. Wite does have health insurance available to her with her employer. Wite does not complain ot any health issues. However, her counsel has pointed out that she is deat and it appears as it her hearing disability is not an issue with respect to her income ability. Husband is 41 years of age and resides at 27 West Main Street, Plainfield, Pennsylvania. Counsel for wite suggested he may be living with his former wife. Husband is a high school graduate and is retired from the United states Army. Husband retired as a staff sergeant (grade E-6). In addition to receiving military retirement pay, husband receives income from a clerk typist position with the Pennsylvania Department of Health. His biweekly net income from the Commonwealth of Pennsylvania is $502.29. The gross monthly income from the retirement benefit is $962.00. From the $962.00 husband has deducted a payment of $63.16 which represents a survivor benefit which inures to wife's benefit and also $246.00 which is a payment on account of a debt which is owed to the New Cumberland Federal Credit Union. The balance on that debt as of December 1, 1995, was $8,071.00. Husband has not raised any health issues. The marital home at 806 Hummel Avenue, Lemoyne, Pennsylvania, has a value as stipulated to by counsel of $71,900.00. There is a mortgage against the home in favor of GE capital with a payoff of around $71,500.00 leaving little equity in the home, if any. In any event, there would not be enough equity to pay a broker's commission and real estate transfer taxes if the home was sold. Wife is currently paying the mortgage monthly in the amount of $621.00 which includes taxes and insurance. Wife has a 1994 Ford Escort which counsel believe she may have purchased after the separation. However, there is some question as to whether or not she used marital assets to assist with the purchase of the vehicle. Mr. Grogan has indicated he is going to check with his client to determine what, if any, marital funds were used in the purchase of the Escort. Husband has a 1990 Ford Ranger and counsel have stipulated the value of the Ranger is $4,000.00. The Master inquired of counsel as to whether that value of $4,000.00 is exclusive of any liens against the vehicle, and counsel for husband is going to obtain that information. Listed on the pre-trial statement was a VGLF policy; counsel have advised that there is no cash value to the policy but the death benefit is $200,000.00. There is a question as to whether or not wite is the named beneficiary on that policy and counsel will obtain that intormation. Husband's counsel has indicated that he is not aware that the policy currently is in existence and counsel will have to make appropriate inquiries about the existence of the policy and whether or not wite is the beneficiary of the policy and how the premiums are being paid. wife has a pension plan with the Dauphin county Nursing Home; however, she has not been working long enough to be vested and there is a further question as to whether or not any contributions which she made wer~ made during the time the the parties were living together. Therefore, contributions which wife has made may all be nonmarital contributions. Counsel need to verify the status of wite's contributions and the times when those contributions were made with respect to the date of separation of the parties. As previously noted, husband is receiving a military pension and counsel have agreed that 12/20s of the monthly benefit would be the marital portion. Wife would like to retain a benefit in the pension; however; counsel need to do some computations to determine how that benefit is to be realized by wife in view of the tact that currently the cost of the survivor's benefit is deducted as well as the payment of a debt to the New Cumberland Federal Credit Union. with respect to the debt to the New Cumberland Federal Credit Union, counsel are going to determine when that debt was taken out and what the money was used for. The purpose is to verify that the debt is marital and that both parties received benefit from the monies received from the loan. In addition to the debt to the New Cumberland Federal Credit Union, counsel have noted that there is a debt to Montgomery Ward. Also noted on the pre-trial statement of husband are certain obligations owed to VISA, Beneficial, and Sears. Counsel are going to verify that these were post-separation debts of husband and that, therefore, wife will have no obligation for payment on those debts. There is an allegation by husband that at the time of separation wife took $2,100.00 from the parties' joint checking/savings accounts. Wife disputes this amount although it is verified that she paid $1,200.00 to Mr. Grogan on account of attorney fees around the time of separation. LAW OF"F"ICES METZGER. WICKERSHAM. KNAUSS & ERS CMl'lISTIAN S. E,.... ..;,., Ro.c,",1" i,. Yc rTC" J"'M". F: CARl,. Roac..r P. Reeo 1:0""""0 1;. KNAUS., N. ';."...0 L.. HOC" K""__",, R. HH.O....,...HD. R"::I>4A"'O a O,.uev STeveN P MIN." C""..." 0.....,11;,.... RAMONA C. CAl""'L.DI Mf!LI..ON BANK BUIl..DING III MARI'(! r STRl!!:.1! l' P. O. 80' 93 HARRISBURG. PENNSYLVANIA 17108-0093 '"AN''' 8. WtCI\C".H"M peee.IQI;3l W,C,,&It.....UIll , M&T.O." (lilI3.liI~.I) M.n:OIl" " W-c:"Il....H...,.. (IQiZ.IQ5Sl ""aTloe", WU:.CJIlI.H...,.. & KNAUS' C laS5-loe7) TCI..It"'HONlt (717) 23e-8187 TItI..ItCOPIl!:R (717) 234- Q478 September 1, 1995 .~.lItOC."ll'1I10'''C'VII.'''Il''LI._.l .... ....TIO.."1. -.o"1lG 0' '.''''1. ..ovoeac. Band Deliverv Robert E. Elicker, Esquire, II Divorce Master 55 West Church Avenue Carlisle, PA 17013 ael Caapbell v. Caapbell Wo. 9.-5593 civil Tera Dear Mr. Elicker: Enclosed for filing are Defendant's Pre-Trial Inventory and Appraisement. By copy of this letter, Plaintiff's counsel with a copy of those documents. Statement and I have served Very truly/70urs, /' . METZGE .~KE~\. ' KNAUSS t~t l6 J ~?~ ichard B. ;~ I & ERB RBD/ps Enclosure cc: Austin F. Grogan, Esquire (w/encs.) ~ l>: t.l a. o 0:: 0. ~ H ~ 0 '" c: 'V 1J 'V 1J 1J 1J 0 ... ) c: c: c: c: c: c: '" 0 0 0 0 0 0 0 . N c: c: c: c: c: c: c: ., .-i ... .I< 3... >0 ~ r- r- c: . :l jO~j ~. .-i V :l .... ~ " ., ~l o U c: "'0 0.... ~ v nl ., :l nl.... Onl > " ~ o ~ c: v > c: .... 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III .c:1Il .c:1Il z.o:o UIIlOU uu UU ..... 00 III .... .. .., 0 0 .... +J 0. 00 ..... III III '0 U '0 ~ s..... III .. Ill..... ~ c.l 0 ~ z.o:u 0 t>.. I': ), 0.., .... .. '0 .., III I': ~ 0.0. ..... III III .... 0 III oS U ~ ~ .., up.. 'rl III III 00 ~ S ~ 00 Ill.... III 0 III .... o 0 :E:I: U :> 0 ... .... ... Z N N N :ij .... H ~ Personal Prooertv No Agreement. Marital Debt,a, No Agreement. prooosed Resolution of Economic Issues Partner cannot agree on resolution of economic issues. Respectfully submitted, Esq. EXPENSES CONTINUED: Week Month Year (Fill in Appropriate Column) Loans Credit Union $ $ $ Miscellaneous Household help $ $ 30.Q,Q $ Child care . Papers/books/mag. 25.00 Entertainment Pay TV $ $ $ Vacation Gifts Legal fees Charitable contrib. Other child support Alimony payments Other $ $ $ TOTAL EXPENSES: $ $ 2.478.20 $ PROPERTY OWNED $ Value 95.00 OWNERSHIp. H W J X Checking Accts. Savings Accts. Credit Union Stocks/bonds Real estate Other Description TOTAL: $ . 95.00 EXPENSES CONTINUED INSURANCE Coverage. Company Policy No. H W C Hospital Blue Cross X X X Other Medical Blue Shield X X X Other Heal th/ Accident Disbility. Inc. Dental X X X Other X X X .H-Husband; W-Wife; J-Jointi C-Child Oopanment 01 the Treasury -- Inlerna! Revenue SeNlco Fo,m 1040 U.S. Individual Income Tax Return u.. L the . IRS e label. ~ Olher- Wise. ~ please . prim ~ or type. Pr..h:llnUal ... ElecUon Campaign , 1 2 3 4 Filing Status (Sea paga 12.) Chock only ono box. Exemptions (S.. paga 13.) ~a'II'I1 la' J." I-Olc.]I. 1'114. or 011"",,_ u, bl I","" ,'\114 ,'Hi," 1994 fO!)) IRS Un Only u OQ "01 ...,r,l, n, .i.ota,,, '1'111 tP'U. CHRISTINE CAMPBELL 806 HUMMEL AVE LEYMONE. PA 17043 ." OMB No. lil4S-0074 Vour .oclal 'ICUrity number 180-56-5525 spou..'. ."clal'lcurtty no. VI' No X NOI.: Chocking "'Yos" will not chango your lax or reduce your retund. 00 you Wlnl $:l10 go 10 this fund? . . . . . . . , , . , . . . , , . . . . . . , . . . . , . , . . , . . . . . . If I olnl relurn, daBS our 5 OUS8 want $3 to 010 lhis fund? , . , . , . , . , . . , . . . , . . . . Single For Privacy Act and Paperwork RlducUon Act NoUee. ..1 page 4. Mlmod filing joinl rolurn (oven If only ono had Income) M,H1ali Ilhng up 1'11" 'Ihlln. (nIl' IPOUII', 55N IDOVI .. fun nlma IIlrl, ~ Haad 01 household (wllh qualifying pa'eon). (500 pag. 13.) II qualifying pereon I. . child but not you, d.p.nd.nl, X enler child's name here. ... Quail In widow(er) with de endent child r,s OUll8 dlod"'19 Soe 8 e 13. X Youreett. If your plllont (or samoans el80) can chum you as . dependant on his/her tOX} No. at bo... ralurn, do not check bolC Sa. Bul be aUle to chock box on Une 33b on page 2 :~:~~14 on I. b ou......................................................,........ C Dlpendents: 2) CIIlI.. II IgI' 0' aida" 4) alplndanl'. (5 Ho. of If unda, dapenlianr. ,oClII"cU'lly ,.tlllon,IIl0 to o'~h'd In 1 Hlma(Ii,.I, lnlUII, Ind ...t nlma' sga I numb.. you ~~',ei::,a 5 6a ANDY CAMPBELL II mo,.'han six OTHA CAMPBELL dependents. sse page 14. 124 -72 - 3 755 SON 124-72-2746 SON Income Attach Copy B 01 your Fonn. W-2, W-2G, .nd 1099-R h.r.. II you did nol g.1 . W-2, sou paga lS. Enclose, bul do not anach, any p.ymont with your return. d e 7 If YOLlr clllld lildn't IIv. "'1111 you Dut I' c"lm.d.. you' dlplndant und.r 1 pra-lil15 Ig,..mant, ellaell. "It. ... Total number of exom tions claimed, , . . . . , . , , , . , . , . . . . . . . . . . . . . . . . . Wag... ....nu, tiPS. lie. Attacll Form/II W-2 1 No.ofyour clllldr.nllnlc w"o: 12 12 elivadWltllYOLl . dldn'lllvl.."lll youdulto dlvorel 0, IIP"lllon I'" pig' '4) 2 8a TOIbI.lnla'.Sllncomo (s.. pag.1S). Anech Schedul. B If ovar $400. . . . . . . . . . . . . . . . b T......mpllnt.'..t (SOU pg. 16). DON'T Includ. on IIn. 8a Bb 9 Dlvldand Incomo. Anach Sch.dule B II ov.r 5'100. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Taxable retunds. credits, or offselS of slale and local Income laxes (sue pego 16) .. . , , . . . 11 Alimony roc.lved. . .. . .. . . . .. . . .. . . . . .. .. . .. . .. . . . . .. . .. .. . , .. . .. .. .. . . . . . . 12 Busin...lncomo or (loss). Anach Sch.dul. C 0' C-EZ. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Capllal gain or (Iosa). II raqulr.d, anach Sch.dul. D (s.. pag. 18) .. . . . . . . . . . . . . . . . . . 14 Other gains 0' (losses). Anech Form 4797. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15a TolallRA dlstr1bullons .. ~ I b T..ebl. amount (so. pg. 17) 168 Tolalp.n"an..ndannultIU. ~ b TlUCable amount {sue pg. 17} 17 Renla1 real estate, royalties, partnerships. S corporations, trusts. otc. Anaeh Schedule E . . . 18 Fannlncomo or (loss). Anach Sch.dul. F. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Unemploymont compans.llon (s.. peg. 18). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 208 Social SQCunty benafits ~ I b T..able amounl (s.. pg. 18) 21 Olll.,lncomo. Oaplndlnllonlc nOilnlllldlbo"'l Addnumbar. an"radon IInlIIDo"'l ... 7 8a 14.848 9 10 11 12 13 14 15b 16b 17 18 19 20b 21 22 Add the amounts in the lar 11 hI column lor Unes 7 lhrou h 21. This is our lotallncome. ... 22 14 848 23a Your IRA daduction (sue paga 19). . . . . . . . . . . . . . . . . . . . 23a Adjustments b Spouse's IRA d.duction (sou paga 19) . . . . . . . . . . . . . . . . 23b to Income 24 MOVing expenses. Anach Form :l903 or 3903-F , . . , . . , . . 24 CauUon: See 25 One-halt 01 soli-employment lax. . . . . . 25 Inslructlons . . ~ 26 Sell-employed heallh insurance deducllon (soe page 21). . 26 27 Keogh reUrement plan & sell-employed SEP deduction . . , 27 28 Penalty on early withdrawal at savings. .....,..,..,. 28 29 Alimony paId. ROClplent's SSN'" 29 30 Add hnes 2Ja throuQh 29 These are vour total ad ustments ~ 30 Ad . Gr, Income 31 Subtract hne 30 Irom line 22 ThiS IS your ad usted ross Ir.come ~ 31 ..IU 10401 ",TO: 11'0 reparers dllJon ':ODy"g"' Fa'''''' SoH...,. O,,'y. Iii" ""I~ll, l"t. "'9.10401 CHRISTINE CAMPBELL Amount from Uno 31 (adjU610d gross mcome) . . . . . ., . Chock If: 0 You werQ e~Joldor, 0 Blind; 0 Spouse WI' 6~Joldor, 0 Blind. Add the numbOr 01 bOKOS checkod abOvo and I:ItlfOl the teta! horlJ . . . , . " ..,.. 338 tr b If your plle"1 (or IQm80nlJ also) can chum you 8:1 a depondant, chuck horo.. ... 33b C II you are marrlod fihnq sopaI.loly Ind your spouso nomloa doducllons or you ... 33c &1e . dual-status ahon, see pago 23 AnO ChOCk hero. , , . . , , , , . . . . . . . . . . . . . . { lIamlnd deducUonllrom Schedule A. ino 29. OR } 34 ~nler Stan d.1rd ded. ucu,on shown be 10 w for your fIling slatus. But If you checked 8 any bOK on line 33a or b, go 10 paqe 23 10 find your slandl1rd doducllon. larger If you checked box 33c, your 51AnaiVd doduction III ZOrr). 01 a Slnglo -- $3,600 a Hoad 01 hou.ohold -- sa,6oo your: _ Mamed flhng jomUy or Qualifying Wldow(or) -- S8,3~ . Mamed filing soparatoly .- $3.1 7!!l Subtract line 34 from tine 32. . . . . . . . . . . . . . . . . . . . , . . , . , . . . . . . . . . . . .. ......... If line 32 IS S8J.8M or less, multlplV $2,450 by the lotm "umbor 0' exomplions clalmod on line 60. 1I1Ino 32 IS OlJor 583,S50, 900 Iho worksheet on pago 24 for tho 'mounl to onler . . . . , . Tuable Income. Subtroct lino 36 Irom IIno 35. II Uno 38 IS more than lino 3~, onlor -0- . . . . Tax. Check If lrom 8 ~ Tax Table, b 0 Tax Ralo Schodul... C 0 Capllal Glln Tax Work- shool. or dO Form 8615 rUI pg. ~"l. Amount from Form(s} 8814". Additional taxo.. Check Illrom 8 0 Form 4970 b 0 Form 4972 .. . . . . . . . . . . . . . . , . . Add line. 36 and 39. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . ~ Credlllor child & dopondonl care expo Anach Form 2<<1 ..... 41 Credit lor tho elderly or Ihe dl.abled. Anach Schedule R . . . . .. 42 Foreign tax credl!. Anach Form 1116. . . . . . . . . . . . . . . . . . . . . 43 Other credits (s.. page 2a). Check Illrom 8 0 Form 3600 b 0 Form 6396 C 0 Form 6801 dO Form 44 Add Iin... 41 Ihrougn 44. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . Subtract line 4~ Iro", flne 40. II line 45 is more Ihan line 40. enter -0-. . . . . . , . . . . . . , . . . .. ... Sen-employmentlax. Ansch Schedule SE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Atternalive minimum tax. Anach Form 62~1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . Recapture lax... ChllClC n kom 8 0 Form 42a5 b 0 Form 6611 C 0 Form B826. . . . . . . SOcial security and Medicare tax on tip income not reported 10 employer. Anach Form 4137 . . . Tax on qualified retlrement plans, Including IRAs. II required, anach Form 5329 . . . . . . . . . . . . . Advance eBlned Income credit payments from Form W-2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Form 1040 (199") 32 338 To Compu- tation (S.. pago 23.) If you want Iho IRS to figure your tax, 100 pago 24. Credits (500 page 24.) O{her Tues (500 page 2a.) P8yments Anach Forms W-2, W-2G. and 1099.R on pagel. Refund or Amount You Owe Sign Here Keop a copy of thiS return lor your records. Paid Preparer's Use Only H1]) 01 3.5 36 37 38 39 40 41 42 43 44 45 48 47 48 49 50 51 52 53 54 55 56 Add line. 46 throuoh a2. Thi. Is vour lotal tax. . . .. .. . . .. .. . . . , . . . . . . . . . . . . . . . . . . .. ~ Fldlrallncomll.' .11""IIO.U .n'i111rom Form(11101lll, chick... ... U 54 1, 388 1994 e.tima1ed tax peymenl. & amt. applied Irom 1993 relurn. 55 Eamed Incoma cradllll required, anach Sch. EIC (see pg. 27). Nonlaxablo earnod Income: amt. po I 458 I " and type ~ MEDICAL 56 Amounl paid Wllh Form 4668 (o,"ension reque.l) . . . . . . . . . . . 57 Exce.. ooclal security and RRTA lax wllhheld (... page 32). ., 58 Other payments. Check If Irom 80 Form :1"111 b 0 Farm "'311. 59 Add Iin.. 54 Ih,ouoh a9. Th..o are vour lotal oavmanla . . . . . . . . . . . . . . . . . . . . . . . . . . .. ~ II line 60 Is more Ihan line 53. subttecl hne 53 kom line 60. Thl. I. 1he amoun1 you OVeRPAID~ Amounl 01 line 61 you want REFUNDeD TO YOU. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ Amount 01 line 61 you want APPLIED TO 1995 EST. TAX.. . ~163 I' II line 53 ill more Ihln line 60. subttaC1line 60 Irom line 53. Thlp is the AMOUNT YOU OWE. For delalls on how 10 pay, Including whallo wrtte on your paymenl. ... page 32. . . . . . . . . . . . Estlma1.d lax oenaltv (s.. oaoe 331. Also Includo on line 64. . . ~I 65 i 180-56-5525 32 Paoe 2 14,848 1,763 57 58 59 60 61 62 63 64 65 Date Spouse's occupation 34 7 261 Pr8p8rer'9~ Date .,gnalure' See Attestation 2/5/95 Firm'. nemo (0' your... H AND R BLOCK EASTERN TAX II soll-ompioyed) ,5072 A JONESTOWN RD andaddres. HARRISBURG, PA I'jTi=1I1\1 Check II selt-employed E.!. No, ZIP code 35 7,587 COlly";"1 ~O'1l'I1 Salt....." Only 1994~"r.:c, 11'1' 1'19'10"0:1 38 37 7.350 237 38 39 40 . 36 36 .,. ',' .. 45 48 47 48 49 50 51 52 ',.,. 53 .i.;, :: ii: .' .,., , 60 61 62 ... 36 36 3 151 3,115 3,115 64 , , . . " ' , .-;;-:c--cc: Under ponaltles of perlury, I declare that I have examned thiS return and accon:tPanVInQ schodules and statements, and to the best ~t my knowledge and beflel. they are true, correct. and complete. Declaration of preparer (other than taxpayer) IS based on IIf Informabon 01 which prepare1 has any knowledge. ~ Your signaturo Dato Your occupation , CNA ~ Spouse's slgnst'Jre. II a jOint relurn. BOTH must sIgn. Preparefs ooclalaecurl1y no. 577-68-0785 43-1632899 17112-0000 Prepar8f8 Edman CIl ..c ~ .... ~ ..:I .... . I:: ~ .... p.. . 'M . III >< ~ 0::'0 ZE-< . I:: ">1:: E-< OZ< ..:I'M Ql Z ~::>.... ...:llll ..... ~ OZ ~.-l j~ CIl "!l~l~~ ou< lXlp.. - ~ U :- ..:I p.. ~ t<o E-< ~~~~~ 0..:1 .... ~ lXl t<o ..c t<o~>< :- . p.. .... E-< o CIl .... U > ~ E-< CIl 3rt" E-<~~ u Z . U .... ~ . l1:!S O::~~ M :I: ..c 8~p.. '" ~ . ..:I .... II'l U ~ ..:I p.. c:: u::> II'l c:: Z E-< U I 0 .... E-< I ~ .. :- E-< c:: ~ :z: '" .... CIl ~ E-< 0 .... lXl p.. . c:: ..:I Z 0 Z :z: .... .... Z H U Cl ; vtlMII" ,C;Z: /?I'(Wll/1 . CHRISTINE H. CAMPBELL, plaintiff : IN THE COURT OF COMMON PLEAS Of : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 94 - 5593 GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE THE MASTER: Today is Tuesday, April 2, 1996. Present for a Master's hearing are the Plaintiff, Christine H. Campbell and her counsel Austin F. Grogan, and the Defendant Gilbert L. Campbell, Jr., and his counsel Richard B. Druby. A divorce complaint wes filed on September 20, 1994, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The Master has been informed that counsel and the parties will conclude the divorce under Section 3301(c) of the Domestic Relations Code and that affidavits of consent and any appropriate waivers will be filed within a week of tOday's date with the Prothonotary of Cumberland County. The divorce complaint also raised the economic issues of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Defend~nt, in response to the complaint and by way of counterclaim on his own behalf, raised the economic issues of equitable distribution and counsel fees and costs. The parties were married on April 24, 1982, and separated on September 6, 1994. They are the natural parents of two children, Andy and Otha. Both children currently reside with th. plaintiff. The Master has been informed that after negotiations the parties and counsel have reached an agreement with respect to the economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be the substantive agreement of the parties and not subject to any modification or changes except for correction of typographical errors made during the transcription. Therefore, that means that the agreement that you are going to state on the record here today will not be subject to any changes and we are going to ask you to return later this morning to review the agreement for typographical errors and if there are any typographical errors we will make those corrections and then we will ask you to sign the agreement by way of affirmation of the terms that have been reached here this morning in this conference. After the agreement has been reviewed for typographical errors and has been signed, then I will prepare an order vacating my appointment as Master, and then counsel can prepare a praecipe transmitting the record to the Court with the affidavits of consent and the appropriate documents requesting that the Court enter a final decree in divorce. Mr. Oruby. MR. DRUBY: 1. with respect to the claims of alimony, alimony pendente lite, and counsel fees, both parties waive and forego those claims as part of this settlement. 2. Additionally, with respect to the marital home, the parties agree that it will be listed for sale or returned to the Veteran's Administration, the option which will be choosen will be that option which is in the financial best interest of both parties. 3. Turning to the vehicles. The 1994 Escort which is currently in the possession of Mrs. Campbell will remain in her possession. She will assume whatever obligation there is to the extent that it is encumbered to make those payments. 4. With respect to the 1990 Ford Ranger which is currently in the possession of Mr. Campbell, that will remain in his possession and he will deal with that encumberance and that will be Mr. Campbell's obligation. 5. with respect to Mr. Campbell's pension, the parties have agreed first off that the survivor's benefit which are currently being deducted from the pension will be cancelled. In exchange, Mr. campbell has agreed to give to Mrs. Campbell a set dollar amount of $250.00 per month to terminate in the event of either parties' death. Mr. Grogan will prepare a Qualified Domestic Relations Order with those terms. 6. with respect to the marital debts, the Federal Credit Union loan which was taken out to consolidate bills, that payment is currently being made on that loan through the pension and will continue to be deducted from the pension until that loan is paid off. Mrs. campbell agrees to go into the New Cumberland Federal Credit union and sign whatever documents are necessary to release her from that Obligation. Mr. Campbell agrees that he will be solely obligated on the New Cumberland Federal Credit Union loan and that that debt will continue to be deducted from his military pension as it has been, and he will make whatever arrangements are necessary with the credit union to assume the obligation totally. 7. with respect to the personal property, it is agreed that whatever is currently in Mr. Cam~bell's possession, as is evidenced from the appraisal which was completed by Mr. Brumbach, will remain in Mr. Campbell's possession and will be his sole property. With re.pect to the item. currently at the .arital ho.e, again tho.e it... being apprai.ed by Mr. Brumbaoh, they will re.ain Mr.. Ca.pbell'. eole po.....ion with the exception of the Camelback trunk vhich eontaina Mr. Ca.pball'. military it.m. including photog raphe and family photo~raphe which will b. returnad to Mr. Campbell. Additionally, it it .till exi.t., either at the marital home or at Mra. Campbell'. mother'. re.idenee, a 1907 wooden California brewery .iqn will b. returned to Mr. Campbell and that will b.come hie .ole po.....ion. The partie. will make arrangement. tor the pickup of the two items .tated within the next thirty (30) day. at a mutually convenient time. a. With re.pect to Mrs. Campbell'. pen.ion at the Oauphin County Home, the partie. believe that that pen. ion wa. generated po.t-separation but in the event that that may not be the case, Mr. Campbell relinqui.h.. any and all rights he has to an inter..t in that pen.ion. 9. With respect to the partie.' chscking and .aving. accounts, th~ parties agree that the issue regarding di.bursement of those funds ha. been re.olved and .ach party waives request for further di.bur.ement by either party. 10. The parties agree that should either party breach the agreement that haa been set forth today, the breaching party will bear the costa and attorney fee. of the other party in any action that may be necessary to enforce the agreement. 11. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinqui.hes any and all right. h. or sh. may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other a8 a re.ult of the marital relationship including without limitation, .tatutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estats. Each will at the request of the oth.r ex.cute, acknowledge, and deliver any and all instrumente which may be necessary or advisable to carry into ettect thi. mutual waiver and relinquishment ot all such interests, rights, and claims. MR. DRUBY: Mr. Campbell , a few questions for you. Were you pre.ent during the entire time that we put the agreement on the record? MR. CAMPBELL: Oh, absolutely. MR. DRUBY: Did you understand all the terms of the agreement as I set them forth? MR. CAMPBELL: Yes, sir, I did. MR. DRUBY: Do you agree with the terms that we reached and put on the record today? MR. CAMPBELL: Yeah, I do. MR. DRUBY: You understood everything that was sald? MR. CAMPBELL: Yes, I did. MR. DRUBY: Do you have any questions regarding any particular points of the agreement before we close the record? MR. CAMPBELL: The only thing I have a question about is, is it okay for me to go in and look and see what kind of damage they have to be able to see if I can fix them before we even sell the house? MR. GROGAN: You will let Gilbert in the house to look to see if he can repair some of the damage? MR. CAMPBELL: I am a carpenter and I do do my work. MRS. CAMPBELL: Well, if he brings somebody with him and I am present and he has somebody else with him. MR. CAMPBELL: Would Marty be okay, my neighbor -- our neighbor? MRS. CAMPBELL: No. I would like to have a police otticer or somebody in that way. I would t.el more comtortable. MR. GROGAN: Would somebody other than a police otticer be all right, llke, may be your tather or MRS. CAMPBELL: Somebody that I teel comtortable with. MR. CAMPBELL: How about Cindy -- MRS. CAMPBELL: No. THE MASTER: Can you suggest 80meone that Y'ou would teel comtortable with having there? MRS. CAMPBELL: I can bring my neighbor over, the one I socialize with a lot and I'm triends with. THE MASTER: What is the neighbor's name? MRS. CAMPBELL: Her name is -- now my tongue is tied. THE MASTER: Take your time. MRS. CAMPBELL: Karen. I don't know her last n.... She lives right next door to me. THE MASTER: Hr. Campbell, would Karen, her next door neighbor, be all right to have there when you come in? MR. CAMPeELL: Not to have any arguments, because that'. not why I'm here. I'm here to get everything ironed out. I don't trust it and I'll tell you why. The last time I went to pick up the trunk there was a big tiasco. She had told m. -- THE MASTER: You don't want Karen there? MR. CAMPBELL: No, absolutely not. THE MASTER: Let's tind somebody else then. ott the record. (A discussion held ott the record.) THE MASTER: We had a discussion ott the record and Mr. Grogan is willing to go to the house when Mr. Campbell wants to make an inspection. Mr. Campbell needs to contact Mr. Grogan directly and make arr~ngements for the time that he is going to ~ve access to the property. Is that all right, Mr. Campbell. MR. CAMPBELL: Yes. (A discussion was held off the record.) THE MASTER: Now, Mr. Campbell, have your inquires been properly addressed? MR. CAMPBELL: I think so. HR. GROGAN: Christine, you were here during this conference today; is that correct? HRS. CAMPBELL: Yes. HR. GROGAN: Did you hear everything -- or is there anything that you are unsure of that you didn't hear correctly about how you're not going to receive any alimony payments but you are going to receive $250.00 a month of his pension, do you understand that? MRS, CAMPBELL: Yes. MR, GROGAN: That he is going to cancel the survivor'. benefits that would come to you in ca.e he died befors you, he is going to cancel that? MRS. CAMPBELL: Yes. MR. GROGAN: That you're going to keep your car; he is going to keep his truck, and that the marital home is going to be put up for sale or it's going to be returned to the VA, whichever is in your financial best interest and your husband's financial best interest? MRS. CAMPBELL: Yes. MR. GROGAN: And that the personal property that you have in your possession, you keep but for the trunk, the military and personal pictures in the trunk, and this California wooden sign that he describes as a 1907 brewery sign. If you have that, YOU'll give it back to him? MRS. CAMPBELL: If I have it. There's a couple of item~ that were destroyed, you know, my son has a lot of anger and he just picks up stuff and breaks it. MR. GROGAN: And you believe that California sign has been destroyed? MRS. CAMPBELL: Yes. MR. GROGAN: But you do have the trunk at home? MRS. CAMPBELL: Yes. MR. GROGAN: And your husband can come and get the trunk? MRS. CAMPBELL: Ve.. And I'll go through the picture. and give him his picture. that are his. MR. GROGAN: Okay. Did you understand everything else regarding your pension at the nursing home and the tact that whatever savings and checking accounts you had have been separated and you are equally happy with the separation there? MRS. CAMPBELL: Yes. THE MASTER: Mrs. Campbell, you're hearing impaired? MRS. CAMPBELL: Yes. THE MASTER: And your attorney has made an ettort here to go over individually the terms of this agreement, and have you understood and been able to hear to understand what we have done here today? MRS. CAMPBELL: Yes. If I didn't I would have asked. THE MASTER: You would have asked it you did not? MRS. CAMPBELL: Yes, I would. I acknowledge that I have read the above stipulation and agreement, that I understand the terms ot settlement as set torth herein, and that by signing below I ratity and attirm the agreement previously made and intend to bind myselt to the settlement as a contract obligating myselt to the terms ot settlement and subjecting myselt to the method. and . . procedure. of enforce.ent which may be i.po.ed by law and in particular Section 3105 of the Domestie aelations Code. WITNESS: DATE: ('/, . t.. \)J~~ ~in. H. Camp 11 t./,/~/""c, ~.. I~ .;/ , lLc&b (, l'~i.L R chard 8. Druby Attorney for Defe ant ,/p/ft ~f ~ f!//{/ / "G r L. Camp &Y , JIr CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET #94-5593 CIVIL IN DIVORCE GilBERT L. CAMPBEll, Defendant RETIRED PAY COURT ORDER AND NOW, thisn~ay of ,\...~ ' 1996, based on the findings set forth below in items one through five, IT IS HEREBY ORDER, ADJUDGED AND DECREED in items six through eleven: 1. Parties: The Parties hereto were husband and wife, and a divorce action is in this Court at the above number. This Court has personal jurisdiction over the parties. The parties were married on April 24, 1982 and divorced on May 14, 1996. 2. Military Member Information: The name, last known address, sociill security number, and date of birth of the plan "Participant" are: Name: Gilbert L. Campbell ("Participant") Address: 27 West Main Street, Plainfield, Pennsylvania 17081 Social Security Number: #166-46-3904 Birth Date: June 6, 1954 3. Alternate Payee Information: The name, last known address, social security number, and date of birth of the "Alternate Payee" are: Name: Christine H. Campbell ("Alternate Payee") Address: 806 Hummel Avenue, lemoyne, Pennsylvania 17043 Social Security Number: #180-56-5525 Birth Date: July 30, 1960 ., ""'~ , t" J.... l.t,c. <.,' f.~=; or c:'-. L.; _ fL:'" ,... L.- <': "- ~ :.. .,. '':-! "4-;' b >.; 'J';) '~;J ',-a q,; ~..") <\i ,. :-.: ". e.:> ~ _. , t..., C,- , , I.) The Alternate Payee shall have the duty to notify the Director of Defense Finance and Accounting Service in writing of any changes in her mailing address subsequent to the entry of this Order. 4. Plan Name: The name of the Plan to which this Order applies is the Military Retirement System (hereindfter referred to as "Plan"). The Participant is a participant in the Plan having served in the U.S. "'.rmy since July 26, 1974. The Participant has performed more than ten (10) years of creditable service in the Military Retirement System during the marriage to the Alterndte Payee. 5. Effect of This Order as a Domestic Relations Order: This Order creates and recognized the existence of an Alternate Payee's right to receive a portion of the Participant's benefits payable under the Plan. It is intended to constitute a Domestic Relations Order ("DRO") under the Uniformed Services Former Spouses' Protection Ad (USFSPA) of 1982, P.L. 94.252. 6. Pursuant to State Domestic Relations law: This Order is entered pursuant to the authority granted in the applicable domestic relations laws of Pennsylvania. 7. Amount of Alternate Payee's Benefit: This Order assigns to Alternate Payee an amount equal to Two Hundred Fifty Dollars ($250.00) of the Participants's disposable retired pay. 8. Benefit Commencement Date: The benefit established for the Alternate Payee under the Plan is to be paid directly to her commencing as soon as administratively feasible following the date this Order is approved as a Domestic Relations Order or on the date the Participant commences his benefits, whichever occurs first. Payments shall be paid monthly to the Alternate Payee for the remainder of Participants lifetime or until the death of the Alternate Payee. 9. Cost of living Adjustments: The Alternate Payee shall not receive any share, pro-rata share or otherwise, any cost-of.llving adjustments or other economic improvements made to the Participant's benefits on or after the date of his retirement. 10. Survivor Benefit Plan (SBP): Alternate Payee shall not be awarded a Survivor Benefit Plan Annuity under the Military Retirement System Plan. 11. Savings Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: (a) to provide any type or form of benefit option not otherwise provided under the terms of the Plan; (b) to require the Plan to provide increased benefits determined on the basis of actuarial value; or (c) to require the payment of any benefits to the Alternate Payee that are required to be paid to another alternate payee under another order that was previously deemed to be a DRO. (d) to make any payment or take any action which is inconsistent with any federal or state law, rule, regulation or applicable judicial decision. IT IS INTENDED that this Order shall qualify as a Domestic Relations Order under the Uniformed Services Former Spouses' Protection Act (USFSPA) of 1982, P.l. 97-252. The Court retains jurisdidion to amend this Order as might be necessary to establish or maintain its status. BY THE COURT: CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-S593 CIVIL GILBERT L. CAMPBELL, JR., Defendant IN DIVORCE PETITION TO MAKE ORDER OF COURT AND NOW, the Plaintiff, CHRISTINE H. CAMPBELL, by and through her attorney, Austin F. Grogan, Esquire, aver the following in support of this Motion: 1. The parties have agreed to enter a Qualified Domestic Relations Order to preserve Mrs. Campbell'slPlaintiff interest in Mr. Campbell's Military P1'lnsion. (Settlement Agreement Attached). 2. Attached is a Qualified Domestic Relations Order which will preserve Mrs. Campbell's interest in the Pension. WHEREFORE, the Plaintiff respectfully asks this Court to enter an Order ratifying Mrs. Campbell's pension interest in Mr. Campbell's Military Pension. Respectfully Submitted {L~J, Austin F. Grog ,Es 24 North )200 Street Camp Hill, PA 17011 717-737-1956 Attorney 10 #59020 Attorney for Plaintiff va. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - 5593 CHRISTINE H. CAMPBELL, Plaintitf GILBERT L. CAMPBELL, JR., Defendant . . :. IN. DIVORCE THE MASTER: Today is Tuesday, April 2, 1996. Present for a Master's hearing are the Plaintiff, Christine H. Campbell and her counsel Austin F. Grogan, and the Defendant Gilbert L. campbell, Jr., and his counsel Richard B. Druby. A divorce complaint was filed on September 20, 1994, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The Master has been informed that counsel and the parties will conclude the divorce under section JJ01(C) of the Domestic Relations Code and that affidavits of consent and any appropriate waivers will be filed within a week of today's date with the prothonotary of Cumberland County. The divorce complaint also raised the economic issues of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Defendant, in response to the complaint and by way of counterclaim on his own behalf, raised the economic issues of equitable distribution and counsel fees and costs. The parties were married on April 24, 1982, and separated on September 6, 1994. They are the natural parents of two children, Andy and Otha. Both children currently reside with the Plaintitt. The Master has been intormed that atter negotiations the patties and counsel have reached an agreement with respect to the economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be the substantive agreement of the parties and not subject to any moditication or changes except for correction of typographical errors made during the transcription. Theretore, that means that the agreement that you are going to state on the record here today will not be subject to any changes and we are going to ask you to return later this morning to review the agreement for typographical errors and if there are any typographical errors we will make those corrections and then we will ask you to sign the agreement by way of affirmation of the terms that have been reached here this morning in this conference. After the agreement has been reviewed for typographical errors and has been signed, then I will prepare an order vacating my appointment as Master, and then counsel can prepare a praecipe transmitting the record to the Court with the affidavits of consent and the appropriate documents requesting that the Court enter a final decree in divorce. Mr. Druby. MR. DRUBY: 1. with respect to the claims of alimony, alimony pendente lite, and counsel fees, both parties waive and forego those claims as part of thi~ settlement. 2. AQQitionally, with respect to the marital home, the parties agree that it will be listeQ for sal.or returned to the Veteran's Administration, the option which will be choosen will be that option which is in the financial best interest of both parties. 3. Turning to the vehicles. The 1994 Escort which is currently in the possession of Mrs. campbell will remain in her possession. She will assume whatever obligation there is to the extent that it is encumbered to make those payments. 4. With respect to the 1990 Ford Ranger which is currently in the possession of Mr. campbell, that will remain in his possession and he will deal with that encumberance and that will be Mr. campbell'S obligation. 5. With respect to Mr. campbell's pension, the parties have agreed first off that the survivor's benefit which are currently being deducted from the pension will be cancelled. In exchange, Mr. Campbell has agreed to give to Mrs. Campbell a set dollar amount of $250.00 per month to terminate in the event of either parties' death. Mr. Grogan will prepare a Qualified Domestic Relations Order with those terms. 6. With respect to the marital debts, the Federal Credit Union loan which was taken out to consolidate bills, that payment is currently being made on that loan through the pension and will continue to be deducted from the pension until that loan is paid off. Mrs. Campbell agrees to go into the New Cumberland Federal Credit Union and sign whatever documents are necessary to release her from that obligation. Mr. Campbell agrees that he will be solely obligated on the New Cumberland Federal Credit Union loan and that that debt will continue to be deducted from his military pension as it has been, and he will make whatever arrangements are necessary with the credit union to assume the obligation totally. 7. with respect to the personal property, it is agreed that whatever is currently in Mr. Campbell's possession, as is evidenced from the appraisal which was completed by Hr. Brumbach, will remain in Mr. campbell'S possession and will be his sole property. with respect to the items currently at. the marital home, aqain those items being appraised by Mr. Brumbach, they will remain Mrs. campbell's sole possession with the exception of the Camelback trunk which contaiQ~ Mr. Campbell'. military items including photographs and family photographs which will be returned to Mr. campbell. Additionally, if it still exists, either at the marital home or at Mrs. Campbell'S mother's residence, a 1907 wooden california brewery sign will be returned to Mr. campbell and that will become his sole possession. The parties will make arrangements for the pickup of the t~ items stated within the next thirty (30) days at a mutually convenient time. 8. with respect to Mrs. Campbell'S pension at the Dauphin county Home, the parties believe that that pe.nsion was generatad post-separation but in the event that that may not be the case, Mr. Campbell relinquishes any and all rights he has to an interest in that pension. 9. with respect to the parties' Checking and savings accounts, the parties agree that the issue regarding disbursement of those funds has been resolved and each party waives request for further disbursement by either party. 10. The parties agree that should either party breach the agreement that has been set forth today, the breaching party will bear the costs and attorney fees of the other party in any action that may be necessary to enforce the agreement. 11. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widcw's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. MR. ORUBY: Mr. Campbell, a few questions for you. Were you present during the entire time that we put the agreement on the record? MR. CAMPBELL: Oh. absolutely. MR. ORUBY: Did you understand all the terms of the agreement as I set them forth? MR. CAMPBELL: Yes, sir, I did. MR. DRUBY: Do you agree with the terms that we reached and put on the record today? MR. CAMPBELL: Yeah, I do. MR. ORUBY: You understood everything that was said? MR. CAMPBELL: Yes, I did. MR. ORUBY: Do you have any questions regarding any part.icular points of the agreement before we close the record? MR. CAMPBELL: The only thing I have a question about is, is it okay for me to go in and look and see what kind of damage they have to be able to see if I can fix them before we even sell the house? MR. GROGAN: You will let Gilbert in the house to look to see if he can repair some of the damage? MR. CAMPBELL: I am a carpenter and I do do my own work. MRS. CAMPBELL: Well, if he brings somebody with him and I am present and he has somebody else with him. MR. CAMPBELL: Would Marty be okay, my neighbor -- our neighbor? MRS. CAMPBELL: No. I would like to have a police otticer or somebody in that way. I would teel more comtortable. MR. GROGAN: Would somebody other than a police otticer be all right, like, may be your tather or MRS. CAMPBELL: Somebody that I feel comtortable with. MR. CAMPBELL: How about Cindy -- MRS. CAMPBELL: No. THE MASTER: Can you suggest someone that you would feel comfortable with having there? MRS. CAMPBELL: I can bring my neighbor over, the one I socialize with a lot and I'm friends with. THE MASTER: What is the neighbor's name? MRS. CAMPBELL: Her name is -- now my tongue is tied. THE MASTER: Take your time. MRS. CAMPBELL: Karen. I don't know her last name. She lives right next door to me. THE MASTER: Mr. campbell, would Karen, her next door neighbor, be all right to have there when you come in? MR. CAMPBELL: Not to have any arguments, because that's not why I'm here. I'm here to get everything ironed out. I don't trust it and I'll tell you why. The last time I went to pick up the trunk there was a big !iasco. She had told me -- THE KASTER: You don't want Karen there? MR. CAMPBELL: No, absolutely not. THE KASTER: Let's rind somebody else then. Off the record. (A discussion held or! the record.) THE KASTER: . We had a discussion or! the record and Mr. Grogan is willing to go to the house when Mr. Campbell wants to make an inspection. Mr. Campbell needs to contact Mr. Grogan directly and make arrangements for the time that he is going to have access to the property. Is that all right, Mr. Campbell. MR. CAMPBELL: Yes. (A discussion was held off the record.) THE KASTER: Now, Mr. Campbell, have your inquires been properly addressed? MR. CAMPBELL: I think so. MR. GROGAN: Christine, you were here during this con!erence today; is that correct? MRS. CAMPBELL: Yes. MR. GROGAN: Did you hear everything -- or is there anything that you are unsure of that you didn't hear correctly about how you're not going to receive any alimony payments but you are going to receive $250.00 a month of his pension, do you understand that? MRS. CAMPBELL: ~es. MR. GROGAN: That he is going to cancel the survivor's benefits that would come to you in case he died before you, he is going to cancel that? MRS. CAMPBELL: Yes. MR. GROGAN: That you're going to keep your car; he is going to keep his truck, and that the marital home is going to be put up for sale or it's going to be returned to the VA, whichever is in your financial best interest and your husband's financial best interest? MRS. CAMPBELL: Yes. MR. GROGAN: And that the personal property that you have in your possession, you keep but for the trunk, the military and personal pictures i~ the trunk, and this California wooden sign that he describes as a 1907 brewery sign. If you have that, you'll give it back to him? MRS. CAMPBELL: If I have it. '~here's a couple of items that were destroyed, you know, my son has a lot of anger and he just picks up stuff and br~aks it. MR. GROGAN: And you believe that California sign has been destroyed? MRS. CAMPBELL: Yes. MR. GROGAN: But you do have the trunk at home? MRS. CAMPBELL: Yes. MR. GROGAN: And your husband can come and get the trunk? MRS. CAMPBELL: ~es. And I'll go through the picture. and give him his pictures that are his. MR. GROGAN: Okay. Did you understand everything else regarding your pension at the nursing home and the fact that whatever savings and checking accounts you had have been separated and you are equally happy with the separation there? MRS. CAMPBELL: ~es. THE MASTER: Mrs. campbell, you're hearing impaired? MRS. CAMPBELL: ~es. THE MASTER: And your attorney has made an effort '~ere to go over individually the terms of this agreement, and have you understood and been able to hear to understand what we have done here today? MRS. CAMPBELL: Yes. If I didn't I would have asked. THE MASTER: ~ou would have asked if you did not? MRS. CAMPBELL: ~es, I would. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and SUbjecting myself to the methods and procedures ot entorcement which may be imposed by law and in particular Section 3105 ot the Domestic Relations Code. WITNESS: DATE: /} ,1: Ie.' c tt'#.r'd~e;r",,- Austin F 3--cGro'}an Attorney'to~laintitt iJ~ (./'/l/;'" ..Y.';" {-;/ 7,'/~/5'1..# . ( :. .~ ..,), ~"( .,. .!!. C'" il. : (i S. ... , I.. " '.1 . /. I.. ",'I'; .. l.~" .1 4 r . , I,:) ~ UI 0< W ~ ... ., ~ - '" ... l:l ..... '" Z .., 't) 0 0-1 0-1l:l l:l ~ ... 0-1... . III ;.. W", ~... 'll~J~~ o . ... lXl.... ~III ! 0>0 UJ&l "'''' WeI ~~~~~ E-< 0 X lXl M r..z ,.,~ 0( . '" .. ~~zt5 00 010 U > ~ M 0 "'> t . ! t: E-<Oo( "'~ . 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C<l ...:z: INCOME AND EXPENSE STATEMENT OF: Name Gilbert L. CamDbell. Jr. Date 8/31/95 INCOME Employer PennsYlvania DeDartment Address 2971 C North 7th Street Type or Work Clerk Tvpist II Payroll Number 451491 Pay Period (weekly, biweekly, etc.) Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding social Silcurity Local Wage Tax State Income Tax Retirement - Before Taxes Savings Bonds Credit Union Life Insurance Health Insurance Blue Cross/Blue Shield other (specify)Union Dues (monthly) ot Health Harrisbura biweeklv $705.00 $85.89 43.90 7.08 19.82 35.40 10.62 Net Pay per Pay Period $502.29 OTHER INCOME Interest Dividends Pension Annuity social Security Rents Royalties Expense Account Gifts Unamployment compo Workers' Compo $ (Fill in o Month appropriate $- Year column) $ Week 962.00 Befor~ o o TOTAL $ $ $ $ 1052.85 Self spouse and/or Children $ TOTAL INCOME EXPENSES Total Monthly $ 300.00 $ 10.00 ~ Mortgage/nmt Maintenance utilities Electric Gas oil Telephone Water Sewer 25..00 25.00 35.00 Emplovment Public Transportation Gas 200.00 Lunch 60.00 Taxes Real Estate Personal Property Income 600.00 300.00 Insurance Homeowners Automobile Life Accident Health other 208.67 every six months Automobile Payments Fuel Repairs Licenses/Registration Auto Club 200.00 20.00 45.0lL- Medical Doctor Dentist orthodontist Hospital Medicine special Needs (glasses, braces, orthopedic devices) N/A Education Private School Parochial School College Religious School Lunches Books/Miscellaneous N/A Personal clothing Food Barber/Hairdresser 60.00 200.00 8.00 Bank Accounts PNC 5080379008 PNC 5080041648 PNC CHECKING CHECKING SAVINGS UNKNOWN 1.284.00 UNKNOWN x..... x..... x..... Securities Automobiles SEE CHARTS Other Assets SEE CHARTS TOTAL $ .............**............*..*............*............**...**.. DlSURANCE Hospital Medical Health/Accident Disability Income Dental Other company BC/B5 Policy No. Coverage H W C x.........xx..... BC/BS ....x x..... x..... .........**..**.........*.**..**.*...*.....*......**.........**.. .H=Husband; W=Wife; J=Joint; C=Child . VERIFICATION I verify that the statements made in this Income and Expense Statement are true and correct. I understand that talse statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: t4'lf, - AdL/ ~~.6#ft- G1.lbert L. Campbell, Jr. " ,orm 1040 OtlQ<If1n'lenl or In. ~r.MUtV n ,mert'iAl R8'ienU8 5dfVlC8 U.S, Individual Income Tax Return i9G1 R3 'He 'J"'", M~ J~ 1101 ""'_1' Hao'. ,,, 11'11. Ill...... 1994 ::(If '''. t.V JMI. 'wO., ". ...... ",II'I."U .....,~. ,,",., '.... ,!'tot'" If OMS No. 1~-OO7" V""r _ -Illy nu_ 166-016-39001 SpouM'. - -Illy no. 11M , 11M . IllS i IMoeI. I 0_-' ~. Ii ~~~ ot~.' _lIaI lrrr.. - Campolllll r 1 2 3 4 GILBERT L ~~~99ELL t' 0 BOX 28 PLAINFIELD, t'A 17081 No..: ChecJ<lng ...,... ..... nol change YO"" tax or reduce your '.fUnd. V.. No X flIng Statua (Seepogo 12.) CMc:k only 0,. bOl. 00 YOU"OI1t saID go IllINo I',"cl? ... . . . . .. . . . . . ... . . . . . . . . . . . . . . .. . . . . . . . . . II. nt_m,_ , u.....ntS31O IDlhlolllncl1......... ........... SIngle ,.. Prlvocy Act IIIKI...._ II_on Act No_ _ _ 4- M_ IIHng joint nllUm (....... " only 0'" hocllnc:ome) iWwr1e. fl'''. ",".1. f'''''''. bill ..,ode'. UN ..1M..., full"'''1 ".,.... Had 01 houoo/lOlcl (Wll/l qullilf'llng !*IOn). (See page 13.) II quollf\;ing _n... cl1lkl but not YOU' ~cMn~ X onr. clUld'. n.",. __ . 5 au . ....n cMntcMcl ..diocl.'1 . See 13. : X V_'~:'~~(:~~~~~~~~~~~~~.~~~}:ii:~:" c o.p.tdIntII: ell_, If... I or '14_, OH.,.II""I No. or No. 01 yOW I' ~... d......_t. MfMj MlilUtty ftllIMM"ill bII OUt 11,.;: tltul""" ." Ia .. I l'Ml"''''' 'to" ," I ...,..: Exempdona (See pogo 13.) 1 1 ,...,...jfltn INial, &114 Lat'n.",.' ANDY L CAMPBELL 111I1ln1llan... OTHA J CAMPBELL clIpendon1I. _pogeI4. 124-72-3755 SON 124-72-2746 SON 12 12 ellWIlI-.i'It,... ..h....1M...ft ~" .". ~ dMlru. O,....,.UltfI(... ..... ,.. 2 O.,.deflte 0"" "01 enl..4 'HII' d If your Oftil. ~...t "'- "1ft '" tlull' ~...d.. 'tOut d.U....d..,I........' ..'....1... ............to onN. n... . Adlll ""lit"', Ifjt.....on IIn.. .DOII' . . TOIOl""_OI.. 110""01_........ 7 w...,.. M&.VI... tllI..'to. An&an 'ot~l w-z W~!liW: 7 88 WiJmJii 9 10 11 12 13 14 1Sb leb 17 18 19 2Gb 11""1'"", iil;l'+I" 21 22 2 3 Income 20 540 31 A_ Copy 101 your ;...... w-z. W-aG, IIIKI I_II lien. 88 T_in_'nc:omo(_poge 1~).AttacI1Scl18dullBllo_$400................ b Tu_-,I_C_pg.18). OON'Tlncludeon Un..,. 8b 9 OM_Inc:ome.AttacI1SChecluIeUo_$400................................. 10 T.._nof\jnclol,ctecl/1o,orolflalllol_ondlocali~lOlC"(_pogo 18) ........ 11 AIlrnony_.......................................................... 12 _...lnc:omeor(1o.).AIlOCI1 SC_IeCorC-EZ............................. 13 CoplIol!l'linor(1o.).lIroquirod, olI.ICh ScI1ed\JIIO (_page 18) ................... 14 0tIW g_ or 00-). AttacI1 Form 47V7. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . 1511 Tot.. IRA _budo"" .. ~ I b T.._ omotlnt C- pg. 17) 18a T........................ 188 b T"_lIT1CI\lnt (_ pg.l7) 17 R...... noaI_, rov-, plf1nera/1lpo, 5 corporOllono, lNalI, ell:. AttacI1 SoMalll E ... 18 Form_or(1oeo).Al!.tl<:hSc~IIF....................................... 19 Ullen'fllOyrTlOfllcofT1l""Ullon(_pogo 18)..................................... 20. _ oecur1ly be_ . ~I I b T.._amount (_ pg. 18) 21 0tIW Income. 7 040 II you clIclnol get.w-z._ poge'5. 1 286 Endo... bu1 do nol 011aCIt, 01'1'I p..,....,.. wIlh your noGJtn. 22 Adel "'" omoun1B In"'" I., 111 column ror linoo 71hrou h 21. ThIO.. 23a Vour IRA decluc1lon (_poge 19). ...... ....... ...... 23. b Spou..,.,RAcleclu<:8onC_pogo 18).... ......... ... 23b 24 MlMng __ Attach Form 3903 0' 3903-F . . . . . . . . . 24 2S O_hoII 0' MIt-">yrTlOflllOlC. . . . .. . . . .... . .. . . . . . 2S . 28 SeII-en'4lloyecl he_ in.",,,,,," _n (_ poge 21).. 28 27 Keogh _ plon & ..,,-_Ioyecl Sf? declucUon . . . 27 28 P.nl/lyon.....,'NI111dl......ol..Ylngo................. 28 29 AJImony pllicl. Reapoen1" SSN . 29 1'1oIllI_.. 2 325 AdJuatmenta 10 Income ~:See i1'llD'UC1kJ0I.. . 30 Add U_ ZI. lIYou h 29. n- .... Gr. ,_ 31 &lblrlCl U". 30 from Une 22. Tho III Income . . "1>1 NTII.r'0 C4'''''9"t'~So"...,.OftI.,. '....fol.rco.lIlCO ,.....,0401 \ .;: :~3:::(':' :.'-''1?3::::':' >;.; .," - 33'l-l I 3~ ;)aqe :;z '6 325 un . I I" ~ Tax ~ CnecK ;t o 'Iou .vw. rJ6/QIQIt. Of31lnd; o .sp,o..... Ilf'M d6Jold41 Oillind. Compu- Add m. numoer 01 be" Cneck~ jt)O~ &nd to'. :.... tOl" heI. .. 33. r ladon b Ir your PM.,,' (or tomlOM....) c.an..:JMT1 'foU II . <Mpena.nt. Ctl~K neff, .. 33b I'.... 'ii, C jf you .. ~ = _Alat*V &f'l1J 'fOur SOOuM IlafTJIlelI o.dt.LcUOna or you .. 33c ,'.., (See poge at. a dtJiIIi-,Iall!. , tel p~ Zl and cnec.c "<<.0 . . .. .. ... ... " Z1.) 34 {----~_._.,--~ } 1<11:...... ~.., 5-.:1 __ shown oeIow to, '/0"' ~I"'l "."'". IIu1 ~ you .-... iili:"':' :!:ii: ony ..... on _ 33e or D.;f.. to P~23 to ~nd '/Ou' "ondll'Q ,**,,;lIon. :i!;':,,' luger " you _110< J3G.' u,..on .,~ -..cuon .. lIrO. ~I . 51. -- S:UOO . H.ad 01 nou_d -- ta.1OO 34 7 731 your. . MIIITIId IlIIng JOlnllV 0' Qullllyinq WIdow(Il') -- 111.~ .-,;.,; . MIl'11Id NIt19 MPIl'.1IfI .- sa. '7' U;k,' 35 SUb~iIl:1 i". J4 from II"" 32. . ..... ..,. .......,....,......., 35 18.594 :Je II y". n <Ill $83._ 0' _ mumply $2.4M by lhe 10111 number 01 .._tiono _ on line ... 1111ne 32 i8 over sa:J.aeo, Me the '1lIOfUherIC on page a.. lot the amount ID en.. . . . . , . :Je 7.350 II you won. 37 T_ _ SUb~'" ine 38 from I"" 3S. II i". 38 '" "..,,.. "'an ino 35. an1lll' -0- . . . . . . . 37 11 244 /heIR"1D 38 Tax. CNcl< ~ from I ~ To T_. b 0 Till ROle Schedu... C 0 C"Iltlll a..n T.. WOlll- llgure YOU' sheeI. or dO Fomt "15 I... '. U~ Arnounl from Form(s} U1-4" . :Je 1.684 .... - p_24. 38 A_.. tu.. CNcl< Ham .0 Form <870 b 0 Form 4en . . . . . . . . . . . . . . . . . . . 38 40 Add I.. 3S and 3e. ..... ... ...... .. 40 1. 684 41 Ct_ lor .NId & depIndon' ..... exp. AlIacI1 Form 2441 .".. 41 lidl.;I.' Credlll 42 Ct_ lor lIlIlIOIr1y 0' .". _. AWon Sc/ledI.oIe R. . . . . . 4~ i~ilil::'i .illwi! (See poge 43 FO'eign tu CAdIl_n Form "18 ... ." . .. . . .. . . .... .. 43 1'1,111" :,:!r, a4.) 44 OtIw..odl1a (_ poge 25). CNcl< ~ from 10 Form 3110O 'i'I'II'I'1 b 0 Form &:leS c 0 Form 81101 dO Form 44 li!i/ I ,~j, "'1'<:", 45 Add i.. 4' I/lrougn 44.. . . . . . . . . . .............. ............ ................. 45 4e SublraCt ~ne .a from line 40. I' line 4S 18 more I".n line 40. In. -0-. . . . . . . . , . ... ..... .. 4e 1. 684 47 SeIl-.n'llloyment tu. AlIacI1 Schedule SE.. . .. . . . . . . . .. .. . .. .. . .. .. .. . .. . .. .. .. . . . . 47 Oth.r 48 ~naM ml'lf1'a.lm taIL Abch Form 8251 . . . . . . . . . . . ............. ................. 48 Tax.. 48 RecaplUr. lax... Check " from 10 Form~ bO FormA1' cO Form 1182I. .... .. 48 50 Sodll -=<Imy and M__. w on lip I...,.". 110' 'epGr1Ic1 ID .".,..,.,... Moen Form 4131 . . . 50 (SeeP. 51 Tax on qulllfted ......n1 pl.... inclUding IRAo. " _.IId. _ Form 533 . . . . . . . . . . . . . 51 25.) 52 Adv......_lncomoCl1ldll p.."..."from FormW-2. ............................. 52 lillfulliil 53 Add I.. 4lIl1VOugn 52. TNe 18 you, _ tu. ......... . . . . . . . . . . . ........ ....... .. 53 1 684 54 'ed."lncolfl. tu_.""eJd.Jt .".,'.t'OII' IIotM('ll09" cll.U . . . .u 54 1 026 ilill'l~ . jl',1 Paymem. 55 ,_ _ tu p"'flT*11a & IITlI. "IlPIIIId from ,&83 'etlJm . 55 1!!i;I! 58 !amecI_ ...- II _Ired. allacn Sch. EIC (_ pg. 27). '!i'ili"1 'illlillll!: Nonw_ .1l'T1Id Inc:omo: omI." I .J I: ~ i , II ~ AIleen Iii];::!::': liliill. Fomw W-2. ond type .. NO 58 !i!ir' W-2G. and 'i!III:!!. ,OIlII-R on 57 Nnounl plld WIII1 Form 4888 (_n 1IqIJ_) . . . . . . . .. . . 57 I![!iliii pllg<Il. 58 ex.:........ -=<Ir1lY and RATA tu WIII1h1i<l (_ P_ 32)... sa ! .[1, ~ I. "''I''r ""jl 58 Ottw p-vmen- Check "from . 0 110'''' 243. bOP'0,...4tM. 59 !ill'uli WI II' 80 Add ... ,.. ",",uan 58. n- .,..- w>u, Iolal . . . . . . . . . . . . . . . . . . . . . . . . , . . . ~ 80 1.026 81 " lne eo '" more "'an Yno 53. IIJb~ad inti 53 from lne llO. n.. '" .". _n1 you OVERPAJD~ 81 Rlfund or 82 Amount 01 Mno 81 you wan. REF\JNllED TO YOU. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... ~ 82 Amount 83 Nnounl 01 lno 81 you won. APPLIED TO tt1lll !ST. TAX. . ... I 83 I ;1Ihii;ll I.""., You OW. 84 " lne 53 18 more "'an lno eo. IIJlltJad lno 50 from I". 53. TNe 18 .". AMOUNT YOU OWl!. :!hlH[1 II~'" II For - on how 10 Prf. inclUding wI1<l1D - on YOU' p-r i poge 32. . . . . . . . . . . . 84 686 85 E_ ,.. _ 0_ J:l). Alto ,,'elude on lne "". .. 85 28 .l'LJiii:i; ;: : i';,i:iiijl:iiitj~iljillj(i,I,lil:1f!I;:!IHfHIiH>ia ~m !1J..o 11'}Q.41 J~ ""'" f rram In 11 .td $I~ 1ro. r'lCO~' Sign Hlr. ~acopy 01... retJm lor '/Our rocord& PIId PleplIltf' . U.. Only '-"l.J Undtr pen.ro. 01 J>It1UIV. I <led.,. "'all n_ ..amnod """ retlJrn ond lCCOfl'!lany1nq __ and _ _Ill "'" _ 0' "" kno~ and _. .".., .,. "".. corTlCl, and """1l-. lleclll'ltion of prep.. (0_ "'an llDlpeyw)18 _ on .. Inforinalton 01 wNch prep.. rsa any knowtedge. ta. You, :t*:;natur. 0.. VOtJI occupedon ,. RETIRED ~ Spou..', ttgnanJr.. If . pnl retUrn, BOTH tnJst Sign. 0... Spou.', occupadon Prop........ Oa.. signalUre ,. See Attestation 4/1/95 Ffm'1 n..... (or '/OU," .. !LAND R B LOCK EASTERN TAX h.ll-.n'llloylld) ,. 5072 A JONESTOWN RD Il'ldld_ HARRISBURG!?A "rll,711 Propll'''' oodll -=umy no. 209-46-0394 43-1632899 CNcl< ~ 11I/-""""" E.1. No. ZIP codlll 17112-0000 Prop... EdIIon C",.,."fU 110''''. Sottwv. Oftl.,. "... 1'11_,". I"C. """'00&02 . SCHEDULE A (Form 1040) AnlCl1mont uonce No. rn VOU, ..,.,... -...tIy 110. 166-46-3904 ';Ii:il,:" I'!I":,'I', ~"~! 1;1 :1 "lill,' ~. i\,III', !!I,illi" q~i!l~i: 4 SUb"*" 'ne 3 from Une 1. "'ne 3 II more tIlan Une 1. entor -0- . . . .. . . . . . . . . . . . . . . .. . . . . . 4 7 91 1III,lil'i~',I.i,' 413 !~I!di! 1371111111iil II !; 1~~I![lli 9 129 i~'I'III!!i, '11111 till 'II 11~I"II,il,li, 1111,; l'ln,: 'Ii 'II;I 1I1il!11' 1[11,11'" '[iI'llI! !iJuLUl: 14 III" [~,! 1,", I[ !I, d, 1211 1 Iii 249 111'11 I m lUJ 18 19 Schedule A -- Itemized Deductions Cop_I 01 TrtttUry IrfWn. Rev. ~ 99 NMnI(t) snoW" on Form 11)1&0 GILBERT L CAMPBELL Medical Cou1Ion: 00 nol indude .._ rtlll1bufMd or paid by ol/ltrl. and 1 Medic.. and denloi _ O.ntal EJrpe"... i!ill,;'i:i! '1"IIh'IL;' ):';1';'11 ;!;I~I!U/ 1 2 Enter amount tram Fonn 10<40. One Ja . . 2 3 Multfply One a IboYO by 7.5% (.o~) . . . . . .. . . .. . . . . . . . . . . .. .. . :jili:,liH: 3 5 Tax.. You 5 S1tlt and Ioctllnc:onw tu.. . . . . .. . . . . ... . . . .. . . .. .. .... .., PlIld 8 R..._.....(_pageA-a) ............................ (Set page A-I.) lnt...eat You PlIld (Set ptglI A-a.) -: _n.. inllNlt ia nol _bit. GlftlIlo Charity 8 7 7 _n" propeny Iu.. . . . . . . . . .. . . . .. . . . .. . .. .. . . . . .. . .. , "0_1". . ib:il!i!i:: 8 9 Addll_5IlWughS. ......................................................... 10 Home lTlClftgage in_ and polnll rtpo<1td 10 you on Fotm 1081 ., 10 6 11 Home rno<1Qtgt Inl_ nol repor1td 10 you on Fonn 1081. II plld 'III! 1," lia,'lllli: 10 ....., thaw thai pIiIOn'. "ami, 10 no., and Iddte81 .. Ilii!! Iii ::il!I'!!':!: IIII'I)!' ,;)11,1:1.1: 11 12 Polnll not repor1td 10 you on Fm loea. Set 1'9. A-3 tor sped" rulet 12 13 I_I I_tel II required. anech Fonn~. (Set page A-3.).. 13 14 Add N_ 10 Ihrou h 13 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . .. . . . . . . . . . . . .. . . .. . . . . 15 GIIII by ceah or chtcll II','!,'IIIII:', lllHII' '!'I'III'iI: llilllllliii: 15 Iryou~ : c= ~l 18 01htr lhtn by catI1 or chtcll. II eny gill 01 S250 or more. ... page II. _ ptgt A-J. II 0_ seoo. you MUST anech Fonn 82S3 . . . .. .. .. . . .. .. . . A-3. 17 CtIryovor from prior year . . .. . . .. . . . . ... . .... .. .. . . , . ...... i:~ii:i!iii! 18 17 18 Add 11_ 15 throu h 17 . . . . . . . . . . . . . . . . . . . . .. . . . . . . .. . . . . .. . . . . . . . .. . . . .. .. . . . . . c_. r'.11 19 CaJ or1htll1o .. AltICh Fomt4884. Set A-4............................. Job 20 u.v.........4 '11I'" ....If ,"u".4,.,o1l MUST """eft Fa'.. 210t or 210f-01Z. ... ,,\iilillli,',",i', ,1I1,!iI:1i Eind~Mna.. UNION DUES 169 iilliilif:ll: . oat ~ iil!iI i ~. 20 MI.cM- IlIneoua 21 TuPAPoratlon_.... ........... ........ ....... ........ ,21 Dedue:- 22 01htr _-- . '1III'!'t111; Uo".!illJ Iii,:; ~ 22 ptgtA-5tor 23 Add 1_20 lhRlugh2a ................................... 23 __10 24 Enttr amount from Fonn 10<40, line 3a .. 24 26 325 lliiJillilj! dtduC1 htre.) 25 Multfply lne 24 Ibo.e by :l% (.02). . . . . . . . . .. . .. .. . . . . .. .. .. .. 25 527 28 SUblrtct One 25 from line Zl. II Une 25 II more tIlan line Zl, enter-G-...................... 27 Moiling ___ inc:urTed _ 1_. AltICh Fonn 3llO3 or 3l103-F. (Set page A-5.)...... .. . 28 0Ihtr - tram IitI on ptgt A-5. UtI type and amount . oe- -- -. OW dtoHa 29 Ie Fonn 10<40, Wne Ja, 0_ S111.1IOO (0_ m.1lOO ~ mtIT1td IlIIng otpll'altIy)? NO. Vaur dtduc1Ion It nolllmltd. Add tilt amounllln tile III r1gIU column } lor 11_ 4lhrough 2lI. Alao. entor on Fonn 10<40, line 34, tile Iargtr 01 . . . . . . . . . Ihls amount or your standlld dtduC:UOn. YEs. Vour dtduC1lOn rMY be 1ImItd. Set plllJt A-5 tor tile amount 10 entor, For P__ R_ Act Noac.. _ FOflll104O lnauucuone. Hm A111a N" "" Preporen EdJ1Ion Total l1em1zed Oedue:- 110". C"yrtll'U 'OrM' So"..,. O"Iy. I'" ".IC4. I'" ~~CHA1 ;MB No: 154&-0074 1994 1 341 6 129 261 169 82 251 28 27 'III!!II'!!!!I IIllul" 28 o . 29 7 731 lil',"''''''''i,''',''::' "I","',''',''''''I'WI'llih,'I'i 'l'II'IJ'i'll jj!l!ii!;:::;':i}::::::::','Hi:Ji:;i,ii::1iiii!::ljl,1llllli!fllii _Ie" (FOflll 104011.... CBRTlrICATB or SBRVICB AND NOW, on this day of September 1, 1995, I, Richard B. Oruby, Esquire of Metzger, Wickersham, Knauss , Ern, attorneys for Defendant, Gilbert L. Campbell, Jr., hereby certify that I served the Defendant's Pre-Trial Statement within this day by depositing the same in the united States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Austin F. Grogan, Esquire 24 North 32nd Street camp Hill, PA 17011 1II II: W .., III en ~ ~ ~ z 0.. U1:': ~ .. l'l ! IlJ . ~ II II Z u 2: 01.': .. - 4( II' IIC > ~:rJ"'2~ o III ~ ~ . ~ ~II: $Oz )~Zjl1:r oL . - w - ~ 3= % :l . . II: ~ '" - Cl · N ~ ti 1 ::E l'l III o C? III o ~ . . 0' ~...... . . rJu. Ij q!I(t(\/" ~ . ... ~I ; VS. GILBERT L CAMPBELL, JR.. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA 94-5593 CIVIi. TERM CHRISTINE H. CAMPBELL, Plaintiff IN DIVORCE IN RE: PETITION FOR ORDER CLARIFYING AMBIGUITY IN IN MARRIAGE SETTLEMENT AGREEMENT ORDER AND NOW. this Z ')"" day of July. 1996. in consideration of the within petition. a rule is issued on the plaintiff to show cause why paragraph 2 of the Marriage Settlement Agreement. dated April 2. 1996, ought not to be amended as proposed. This rule returnable twenty (20) days after service. BY TIlE COURT. Austin F. Grogan, Esquire For the Plaintiff Richard B. Druby. Esquire For the Defendant _ ~...~ '1/A'Ilq~. ~ 'f'. :rlm .~~~ ) C!') L I : ( . . ( ! I - :i I j I 1 ) I " .. . , ~ ;) ~ .; ( , , .l .. ') . ". .. CHRISTINE H. CAMPBELL, Plaintirr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-5593 CIVIL TERM . , . . . . v. GILBERT L. CAMPBELL, JR., Derendant IN DIVORCE ORDBR AND NOW, this day or , 1996, upon consideration or Oetendant's Petition tor Order Clarifying Ambiguity in Marriage Settlement Agreement, it is hereby ordered and decreed as follows: 1. Paragraph 12 of the Marriage Settlement Agreement dated April 2, 1996, is amended to include the following language: "The net profit or loss on the option chosen will be distributed or borne by the parties on a 50/50 basis." 2. Plaintiff is ordered to pay the sum of Five Hundred ($500.00) Dollars to Defendant for attorney's fees incurred as a result of her unreasonable refusal to sign an Addendum memorializing the Agreement reached at the time of the Master's Hearing. BY THE COURT: J. cc: Austin F. Grogan, Esquire Richard B. Druby, Esquire . , . ( Master, the parties and counsel, was inadvertently not placed on the record. 6. The relevant portion of the Agreement is paragraph 2 which states: Additionally, with respect to the marital home, the parties agree that it will be listed for sale or returned to the Veteran's Administration, the option which will be choosen [sic] will be that option which is in the financial best interest of both parties. See Agreement attached hereto as Exhibit "A". 7. The term to which the parties agreed off the record and which clarified paragraph #2 stated: The net profit or loss on the option chosen will be distributed or borne by the parties on a 50/50 basis. 8. On AprilS, 1996, undersigned counsel discussed the inadvertent omission of the term with Plaintiff's counsel. Plaintiff's counsel stated during that telephone conversation that it was the parties' intention and agreement that any profit or loss on the property would be split on a 50/50 basis. Plaintiff's counsel also confirmed that the term was stated before the Master in the presence of the parties and counsel but that the term inadvertently was not part of the record. That telephone conversation was confirmed by letter of April 8, 1996, attached hereto as Exhibit "B". 9. Undersigned counsel, thorefore, forwarded an Addendum to the Agreement for Plaintiff to sign. Plaintiff's counsel was - 2 - . . directed to call undersigned counsel with any problems with the language of the Addendum or with the Addendum in general. Plaintiff's counsel never raised ~ny concerns or objection to the Addendum. ~ letter dated April 8, 1996, and attachments, attached hereto as Exhibit "B". 10. On April 22, 1996, undersigned counsel discussed with Plaintiff's counsel the status of the Addendum. Plaintiff's counsal indicated that he forwarded the Addendum to his client for her signature and that he would follow up with her to remind her to sign it and forward it to him. That telephone conversation was confirmed by letter of undersigned counsel on April 25, 1996, a copy of which is attached hereto as Exhibit "C". 11. After repeated requests to Plaintiff's counsel for the return of the executed Addendum, undersigned counsel, on June 27, 1996, wrote to Plaintiff's counsel regarding the status of the Addendum. Undersigned counsel once again noted that the parties were in agreement on the term as set forth in Addendum and that it would be unnecessary and costly to litigate the matter. Plaintiff's counsel did not respond to the June 27, 1996, letter, a copy of which is attached hereto as Exhibit "0". 12. On July 2, 1996, undersigned counsel once again attempted to confirm the status of the Addendum and questioned - J - < , why it would take nearly three months to obtain Plaintiff's siqnature since there was no dispute as to what the aqreement was at the time of the Master's Hearinq. Once aqain, Plaintiff did not respond in writinq to the July 2 letter which is attached hereto as Exhibit "E". 13. On July 12, 1996, undersiqned counsel was informed by plaintiff's counsel that his client was unwillinq to siqn the Addendum. Once aqain, Plaintiff's counsel confirmed that the parties did aqree at the Master's Hearing that any profit or loss on the disposition of the marital home would be split on a 50/50 basis. Regardless, his client was unwilling to sign the Addendum so that it would clarify the understanding and intent of the parties with reqard to paragraph 12. ~ copy of July 12, 1.996, letter attached hereto as Exhibit "F". 14. The Agreement, as written, is ambiguous since it does not state how profits or losses are to be divided between the parties once the desired option has been chosen. 15. A contract is ambiguous if it is reasonably susceptible to different constructions and capable of being understood in more than one sense. Walton v. Philadelphia National Bank, 376 Pa.Super. 329, 341, 545 A.2d 1383, 1389 (1988). 16. Upon finding an ambiguity, a court may examine the surrounding circumstances, such as extrinsic or parole evidence, - 4 - . . to ascertain the intent of the parties and resolve the ambiguity. lA. ~ AlIg DeWitt v. Kaiser, 335 Pa.Super. ~58, 484 A.~d 1~1 (1984). 17. It is impossible to determine the distribution of profit or loss on the disposition of the marital home without the inclusion of the above referenced term. 18. Defendant does not seek to materially change the Agreement as written but seeks only to clarify a provision in the Agreement through the inclusion of an already agreed upon term. 19. Since the parties previously agreed upon the term in the presence of the Master, and since Plaintiff has confirmed through her counsel that that term had been agreed upon, Defendant seeks counsel fees in the amount of Five Hundred ($500.00) Dollars from the Plaintiff for requiring Defendant to file this Petition due to Plaintiff's unreasonable refusal to sign the Addendum described above. WHEREFORE, Defendant, Gilbert L. Campbell, Jr., respectfully requests that this Honorable Court clarify, by amendment or otherwise, the Marriage Settlement Agreement reached April 2, 1996, by including the agreed upon provision that any profit or loss on the disposition of the marital home be split SO/50 between the parties. Furthermore, Defendant respectfully requests that this Honorable Court award him the sum of Five - 5 - , Hundred ($500.00) Dollars in attorney's te.. for Plaintiff'. unr.asonable refusal to siqn the Addendum memorializinq the Aqreement reached durinq the Ma.ter'. Hearinq. Respectfully , ERa By R chard B. Druby, Esqu r Attorney I.D. No. 61904 P.O. Box 5300 Harrisburq, PA 17110-0300 (717) 238-8187 Date: Attorneys tor Defendant - 6 - bWIlit A .......... r". () . vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - 5593 CHRISTINE H. CAMPBELL, Plaintiff . , GILBERT L. CAMPBELL, JR., Defendant . . : IN DIVORCE THE MASTER: Today is Tuesday, April 2, 1996. Present for a Master's hearing are the Plaintiff, Christine H. Campbell and her counsel Austin F. Grogan, and the Defendant Gilbert L. Campbell, Jr., and his counsel Richard B. Druby. A divorce complaint was filed on September 20, 1994, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The Master has been informed that counsel and the parties will conclude the divorce under Section 3301(c) of the Domestic Relations Code and that affidavits of consent and any appropriate waivers will be filed within a week of today's date with the Prothonotary of Cumberland county. The divorce complaint also raised the economic issues of equitable distribution, alimony, alimony pendante lite, and counsel fees and expenses. The Defendant, in response to the complaint and by way of counterclaim on his own behalf, raised the economic issues of equitable distribution and counsel fees and costs. The parties were married on April 24, 1982, and separated on September 6, 1994. They are the natural parents of two children, Andy and otha. Both children currently reside with the Plaintiff. The Master has been informed that after negotiations the parties and counsel have reached an agreement with respect to the economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be the substantive agreement of the parties and not subject to any modification or changes except for correction of typographical errors made during the transcription. Therefore, that means that the agreement that you are going to state on the record here today will not be subject to any changes and we are going to ask you to return later this morning to review the agreement for typographical errors and if there are ~ny typographical errors we will make those corrections and then we will ask you to sign the agreement by way of affirmation of the terms that have been reached here this morning in this conference. After the agreement has been reviewed for typographical errors and has been signed, then I will prepare an order vacating my appointment as Master, and then counsel can prepare a praecipe transmitting the record to the Court with the affidavits of consent and the appropriate documents requesting that the Court enter a final decree in divorce. Mr. Druby. MR. ORUBY: 1. With respect to the claims of alimony, alimony pendente lite, and counsel fees, both parties waive and forego tho.. claim. as part of this ..ttlement. z. Additionally, with r..pect to the marital home, the partie. ~gree that it will be li.ted for .ale or returned to the Veteran'. Administration, the option which will be choosen will be that option which i. in the financial be.t interest of both partie.. J. Turning to the vehicles. The 1994 Escort which is currently in the possession of Mrs. Campbell will remain in her possession. She will assume whatever oblig~tion there is to the extent that it is encumbered to make those payments. 4. with respect to the 1990 Ford Ranger which is currently in the possession of Mr. Campbell, that will remain in his possession and he will deal with that encumberance and that will be Mr. Campbell's obligation. 5. With respect to Mr. Campbell's pension, the parties have agreed first off that the survivor's benefit which are currently being deducted from the pension will be cancelled. In exchange, Mr. Campbell has agreed to give to Mrs. Campbell a set dollar amount of $250.00 per month to terminate in the event of either parties' death. Mr. Grogan will prepare a Qualified Domestic Relations Order with those terms. 6. with respect to the marital debts, the Federal Credit Union loan which was taken out to consolidate bills, that payment is currently being made on that loan through the pension and will continue to be deducted from the pension until that loan is paid off. Mrs. Campbell agrees to go into the New Cumberland Federal Credit Union and sign whatever documents are necessary to release her from that Obligation. Mr. Campbell agrees that he will be solely obligated on the New Cumberland Federal Credit Union loan and that that debt will continue to be deducted from his military pension as it has been, and he will make whatever arrangements are necessary with the credit union to assume the obligation totally. 7. With respect to the personal property, it is agreed that whatever is currently in Mr. Campbell's possession, as is evidenced from th& appraisal which was completed by Mr. Brumbach, will remain in Mr. Campbell's possession and will be his sole property. with respect to the items currently at the marital home, aqain thoBe items being appraised by Mr. Brumbach, they will remain Mrs. campbell's sole possession with the exception of the Camelback trunk which contains Mr. Campbell's military items including photographs and family photographs which will be returned to Mr. Campbell. Additionally, if it still exists, either at the marital home or at Mrs. Campbell's mother's residence, a 1907 wooden California brewery sign will be returned to Mr. campbell and that will become his sole possession. The parties will make arrangements for the pickup of the two items stated within the next thirty (30) days at a mutually convenient time. 8. With respect to Mrs. Campbell's pension at the Dauphin County Home, the parties believe that that pension was generated post-separation but in the event that that may not be the case, Mr. Campbell relinquishes any and all rights he has to an interest in that pension. 9. With respect to the parties' checking and savings accounts, the parties agree that the issue regarding disbursement of those funds has been resolved and each party waives request for further disbursement by either party. 10. The parties agree that should either party breach the agreement that has been set forth today, the breaching party will bear the costs and attorney fees of the other party in any action that may be necessary to enforce the agreement. 11. Except as herein otherwise provided, each party may dispose of his o~ her property in any way and each party hereby waives and relinquishes any and all right. he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result ot the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instrumen which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. MR. ORUBY: . Mr. Campbell, a tew questions tor you. Were you pre.ent during the entire time that we put the agreement on the record? MR. CAMPBELL: Oh, absolutely. MR. ORUBY: Did you understand all the terms of the agreement as I set them forth? MR. CAMPBELL: Yes, sir, I did. MR. DRUBY: 00 you agree with the terms that we reached and put on the record today? MR. CAMPBELL: Yeah, I do. MR. ORUBY: You understood everything that was said? MR. CAMPBELL: Yes, I did. MR. ORUBY: 00 you have any questions regarding any particular points of the agreement before we close the record? MR. CAMPBELL: The only thing I have a question about is, is it okay for me to go in and look and see what kind of damage they have to be able to see if I can fix them before we even sell the house? MR. GROGAN: You will let Gilbert in the house to look to see if he can repair some of the damage? MR. CAMPBELL: I am a carpenter and I do do my own work. MRS. CAMPBELL: Well, if he brings somebody with him and I am present and he has somebody else with him. MR. CAMPBELL: Would Marty be okay, my neighbor -- our neighbor? MRS. CAMPBELL: No. I would like to have a police officer or 80mebody in that way. I would feel more comfortable. MR. GROGAN: Would 80mebody other than a police officer be all right, like, may be your father or MRS. CAMPBELL: Somebody that I feel comfortable with. MR. CAMPBELL: How about Cindy -- MRS. CAMPBELL: No. THE MASTER: Can you suggest someone that you would feel comfortable with having there? MRS. CAMPBELL: I can bring my neighbor over, the one I socialize with a lot and I'm friends with. THE MASTER: What is the neighbor's name? MRS. CAMPBELL: Her name is -- now my tongue is tied. THE MASTER: Take your time. MRS. CAMPBELL: Karen. I don't know her last naae. She lives right next door to me. THE MASTER: Mr. Campbell, would Karen, her next door neighbor, be all right to have there when you come in? '~'~';t<L" MR. CAMPBELL: Not to have any arguments, beca.",i;; ~,,~'~:::1 ~'T that's not why I'm here. I'm here to get evet'ything ironed ~t.. '.-:_;'-::':~1 I don't trust it and I'll tell you why. The last time I wentw. pick up the trunk there was a big fiasco. She had told me -- THE MASTER: You don't want Karen there? MR. CAMPBELL: No, absolutely not. THE MASTER: Let's find somebody else then, Off the record. (A discussion held off the record.) THE MASTER: We had a discussion off the record and Mr. Grogan is willing to go to the house when Mr. Campbell wants to make an inspection. Mr. Campbell needs to contact Mr. Grogan directly and make arrangements for the time that he is going to have access to the property. Is that all right, Mr. Campbell. MR. CAMPBELL: Yes. (A discussion was held off the record.) THE MASTER: Now, Mr. Campbell, have your inquires been properly addressed? MR. CAMPBELL: I think so. MR. GROGAN: Christine, you were here during this conference today; is that correct? MRS. CAMPBELL: Yes. MR. GROGAN: Did you hear everything -- or is there anything that you are unsure of that you didn't hear correctly about how you're not going to receive any alimony payments but you are going to receive $250.00 a month of his pension, do understand that? MRS. CAMPBELL: Yes. MR. GROGAN: That he is going to cancel the survivor's benefits that would come to you in cas. he died before you, h. is going to cancel that? MRS. CAMPBELL: Yes. MR. GROGAN: That you're going to keep your car; he is going to keep his truck, and that the marital home is going to be put up for sale or it's going to be returned to the VA, whichever is in your financial best interest and your husband's financial best interest? MRS. CAMPBELL: Yes. MR. GROGAN: And that the personal property that you have in your possession, you keep but for the trunk, the military and personal pictures in the trunk, and this California wooden sign that he describes as a 1907 brewery sign. If you have that, YOU'll give it back to him? MRS. CAMPBELL: If I have it. There's a couple of items that were destroyed, you know, my son has a lot of anger and he just picks up stuff and breaks it. MR. GROGAN: And you believe that California sign has been destroyed? MRS. CAMPBELL: Yes. MR. GROGAN: But you do have the trunk at home? MRS. CAMPBELL: Yes. MR. GROGAN: And your husband can come and get the trunk? MRS. CAMPBELL: Yes. And I'll go through the pioture. and give him his piotures that are his. MR. GROGAN: Okay. Did you understand everything else r.egarding your pension at the nursing home and the faot that whatever savings and checking accounts you had have been separated and you are equally happy with the separation there? MRS. CAMPBELL: Yes. THE MASTER: Mrs. Campbell, you're hearing impaired? MRS. CAMPBELL: Yes. THE MASTER: And your attorney has made an effort here to go over individually the terms of this agreement, and have you understood and been able to hear to understand what we have done here today? MRS. CAMPBELL: Yes. If I didn't I would have asked. THE MASTER: You would have asked if you did not? MRS. CAMPBELL: Yes, I would. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures ot enforcement which may be imposed by law and in partioular Seotion 3105 ot the Domestic Relations Code. WITNESS: DATE: 1r<---- </j/f~ Ji) YAIr? , ~~:/t~ff:/~ .' lJlllllit B r., ~ " IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH FRONT STREET . P.O. Box 5300 . HARRISBURG. PeNNSYLVANIA 17110-0300 (717)238-8187 . FAX(717)234-9478 lUHe. ,... MBTZGER WlOORSHAM CHIJSTIAH S. BII.JI. 10llBlT II. YlTTBl JAWBS P. CAU 10lSlT P. IIBO BOWAR!) I. INAUSS. IV' JEUO L. HOCI (AU I. HILOAJRANO' IJCHAAO I. olun STBVIN p. IIINBl 8, 1996 CLAlIO.VIU 1AlI0NA C. CATALDI . JO.\ID CD2'IND IN ova. 1'IJAI. LAW If THlIW'1DIIAL mt.aD Of 1I1AL NNOCJCf April @ VIA rAK AND rIRST CLASS HAIL Austin F. Grogan, Esquire ~4 North 32nd street Camp Hill, PA 17011 Re: Campbell v. Campbell Dear Austin: This will confirm the substance of our telephone conversation ot Friday, April 5, 1996. During that telephone conversation, we discussed the fact that the agreement entered on the record on April 2, 1996, was missing the agreed-upon term regarding the distribution of any prof}.t or loss on the marital home. You agreed with me during that telephone conversation that it was the parties' agreement that any profit or loss on the property would be split on a 50/50 basis. As you will recall, that agreement was stated betore the Master in the presence of the parties and counsel, but apparently that agreement was not placed on the record. Additionally, my notes from the conference reflect the above-stated term. I am assuming that Mr. Elicker's notes also reflect the same unde!'standing. (OJ L0 w Therefore, in order to protect both parties, our clients should sign an addendum to the agreement, memorializing the agreement with respect to the distribution of profit or loss on the marital home. I have enclosed a proposed addendum for your review and Mrs. Campbell's signature. Should you have any problems with the language or with the Addendum in general, please call me immediately to discuss your concerns. Otherwise, please have your client sign the addendum and return it to me for my client's signature. Once again, thank you for your cooperation. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB RBD/pdm Enclosure Richard B. Druby cc: Gilbert Campbell (w/encI.) u't'UOttfO IU:J4 '{Jf/lI lJt Y41~ lIWl"li HBG. PA 141001 ........................... ... ACTIVITY REPORT ... ........................... TRANSIlISSION OK TI/RX NO, 1381 CONNECTION TEL 1815319 CONNECTION ID START TIllE 04108 10:33 USAGE TIllE 01'35 PAGES 3 RESULT OK " ~ Exhibit C ~ 'i IVW METZGER . WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NOUH FRONT STlUT . P.O. Box 5300. HAllRISaURG, PBNNSYLVANIA 1711 0-0300 (717) 238-8181 . FAX (717) 234-9478 "NCII I'" METZGBR WlCll!RSHAM CHlllTlAH S. BII.JI. aOIBJ:r I. YlTTaB JIUt8SP. CAAL aOlur.. UIO IOWA&/) I. INAUlS. rr JIUO L HOCI BAAL I. HILOAlBAHO' llCHAAD t. DRURY STaVIN P. IIIN1a C1.ABJt O.VID LWONAC. CATALDI . -.o~ 110ft. 1IW. L.\W n 1IIIIWDW.JDrMD 0I1'aIAI. AfNOtC1CY April 25, 1996 lrn Austin F. Grogan, Esquire 24 North 32nd street Camp Hill, PA 17011 Re: Campbell v. Campbell Dear Austin: This will confirm our telephone conversation of April 22, 1996, during which you informed me that the addendum to the agreement I forwarded to you on April 8, 1996, has been sent to Mrs. Campbell for her signature. You indicated that you would be calling her on the evening of April 22 to remind her to sign it and forward it on to you. Once you receive it, please forward it to me so that I may have Mr. Campbell sign it. Additionally, although I forwarded Mr. Campbell's affidavit of consent and waiver of notice to you on April 5, 1996, apparently you did not receive it. Therefore, I havo enclosed another executed set of those documents. @ L0 w Finally, Mr. Campbell will be calling you to set up a time during which both of you can go to the marital residence for. an inspection. Should you not hear from him within the next seven (7) days, please call me. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB Richard B. Druby RBD:cl Enclosures cc: Gilbert Campbell (no enclosures) ~ ,. EII.lbIt 0 r"\ . UNCO .... METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH PaoNT SnlBT . P.O. Box 5300 . HARRISBURG. PBNNSYLVANIA 17110-0300 (717) 238-8187 . PAX (717) 234.9478 IVW METZGBll W1CXUSHAM CHIJSTIAJlS. 1l1.]B. 101lr. I. YlTTBI JANIS P. CAAL BOllar P. UBO IDWAIlD I. UAUJS,IV' jlUDLHOCZ BABL.. HILOABlAHO' llCHAaD I. OIUBY lTBVBN P. IIIN" CtAU O.vall BAKONAC. CATALDI . &IUD CDIWIm II C'4 'fIlAI.1AW IV' 1111 JW'DIAL IDAID Of TIW. MNOCJC'I June 27, 1996 VIA FAX ~ustin F. Grogan, Esquire 24 North 32nd street Camp Hill, PA 17011 Re: Campbell v. Campbell Dear Austin: Despite my repeated requests to you, your client has not returned the executed stipulation amending the Marriage Settlement Agreement. As the parties, and you yourself, have acknowledged, the agreement at the time of the Master's hearing was that the parties would bear equally any loss incurred on disposing of the home. Should your client decide not to return the executed document to me, I will have no alternative but to proceed with litigation on the issue. That avenue will be both costly and unnecessary. Accordingly, I ask that you have that document returned to me as soon as possible. Additionally, please be advised that Mr. Campbell has decided not to take sole ownership of the marital home. Instead, he has chosen to notify the mortgage company that the home should be returned to the Veterans Administration. Consequently, I would ask that you call me as soon as possible to discuss these developments. cc: Mr. Gilbert Campbell KNAUSS & ERB Very RBD:cl /J.2'17'J1 IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NoaTH PaoNT STUBT . P.O. Box 5300 . HARRISBUIlG, PeNNSYLVANIA 17110-0300 (717) 238-8187 . PAX (717) 234-9478 UHC. .... MBTZGER WlCXllll.SHAM CH1l5T1AN 5.111,11. 10lBlT I. YBTTBI JAMU P. CAllL 10tBRtP. UIO IOWARD I. INAUU.IV' ]BUD L. HOCI ILUl. I. HIIJlAIRANO' llCHAAO I. OIUIV SlIVlN P. WIHBR CLAU O.VlII IAlIONA C. CATALDI . IllUD CDr1ND If C3'VI. TIIAL LAW rr THlIW1CHN.IOAID OIl1lALMNOCJCY TELEPHONE (717) 238-8187 TELECOPIER (717) 234-9478 TO: NAME: COMPANY/FIRM: ADDRESS: Austin F. Gro~an, Esquire FAX NO.: 761-5319 FROM: Richard B. Druby, Esquire RE: Campbell v. Campbell (91-56) DATE: June 27, 1996 NO. OF PAGES (INCLUDING THIS PAGE): two SENDER COMMENTS: TIME: 3 \00 p.lV--. CONFIDENTIALITY NOTE: This messaqe is intended onlv for the use 01: the individual or entitv to which it is addressed and mav contain information that is Drivlleqed. confidential and exemDt from disclosure under aODlicable law. If the reader of this message i. not the intended recipient, you are hereby notified that any diss~mination, distribution or copying of this communication i. strictly prohibited. If you have received this communication in error, please notify us immediately by telephone at (717) 238-8187, and return the original message to us at the above address via the u.s. Postal Service. Thank you. 08/Z7/~8 is: 02 t:717 2H 9418 MWK&E HaG. PA 141001 ...t....t.t....~....*...... .., ACTIVITY REPORT ... ........................... TRA,~SIlISSION OK Tl/RI NO. CONNECTION TEL CONNEl.'T I ON I D START TillE USAGE TIllE PAGES RESULT 2974 78153111 08/27 15:01 01'07 2 OK 'J ., ~ .. ," . I". lJlllbit E . . . IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH PIONT SnuT . P.O. Box 5300 . HARRISIURG. PeNNSYLvANIA 17110..0300 (717)238-8181' PAX(717)234.9478 lolNC. ,... METZGBR WlClERSHAM CHlJSTIAH S. III. JL 10lUT I. TITTU JAKU P. CAAL 101lIT. UIO ID\l/AlDI.BNAUSS,nr JIUD L. HOCB KAl1... HILDAlItAHO' IlOLUD I. OIUIY ITlYBN, MIHIR CLAUIltVIU IAUONA C. CATALDI III 1llMD~.aw. ra&AlLAW rr M......JDIID at 1IW.NNOCN:r July 2, 1996 .. VIA FAX Austin F. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 - ,-,.,,.f. "'1',-- ~ Re: Campbell v. Campbell Dear Austin: (OJ Please be advised that X have not received a response from you to my fax letter of June 27, 1996, and my telephone call to you of Friday, June 28. I would appreciate your calling me regarding your client's failure to return the Addendum to the Marriage Settlement Agreement which I forwarded to you on April 8, 1996. I cannot understand why the obtaining of her signature should take nearly three months since there is no dispute as to what the agreement was at the time of the Master's hearing. I would appreciate your calling me as soon as possible to let me kno~ the sta~us of that Addendum. L0 w Additionally, with respect to the Retired Pay Order, I would request that two minor changes be made. At the end of paragraph #8 entitled "Benefit Commencement Date" I would appreciate your putting in the words "whichever occurs first." That language would assure that there is no option to be chosen by the parties and that the benefits stop as soon as the first party dies. Furthermore, I would like paragraph #9 to read as tollows: The Alternate Payee shall not receive any share, pro rata or otherwise, of any cost-of-living adjustments or other economic impr~vements made to the Participant's benefits on or after the date of his retirement. Finally, please note the change in our address. Please forward all further correspondence to the address listed above. Very truly YOurs, METZGER, WICKERSHAM, KNAUSS & ERB Richard B, D.uby RBD:cl CC: Mr. Gilbert Campbell (regular mail) .:;r'/':> ':i I I . . , IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH fRONTSTRBBT I P.O. Box 5300 . HAARlSBURG, PeNNSYLVANIA 17110-0300 (717) 238-8187 . fAX (717) 234-9478 lUol'C. ,... METZGBR WlOORSHAM CHIJSTIAN S. BlI.JR. 10llar I. urn. JAMIH CAAL ROllIn UIO 10WAAO I. BNAUSS,IV' JIUO L HOCI XAAL I. HILDABJlANO' IJCHABD I. ORUBY sraVlN P. NINBI CLAU OtVlU LUIIONA C. CATALDI .1DMD~.CJVI,11W.LlW'W na NA1DIAL DID Of JIW. MM'Jt.JI:f TELEPHONE (717) 238-8187 TELECOPIER (717) 234-9478 TO: Austin F. Grogan, Esquire NAME: COMPANY/FIRM: ADDRESS: FAX NO.: 761-5319 FROM: Richard B. Druby, Esquire RE: Campbell v. Campbell (91-56) DATE: June 27, 1996 TIME: i/:.,1? /'t" NO. OF PAGES (INCLUDING THIS PAGE): two SENDER COMMENTS: CONFIDENTIALITY NOTE: This messaqe is intended on Iv for the use of the individual or entitv to which it is addressed and mav contain information that is privileqed, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone at (717) 238-81B7, and return the original message to us at the above address via the U.s. Postal Service. Thank you. 07/0l/96 16:28 U1l7 214 9418 lIWIf6E HaG P\ 141001 ...*.........~..,.......... ... ACTIVITY REPOR'r ... .....................a..... TRANSlIlSSION OK TX/RX NO. CONNBcrION TEL CONNECTION ID START TIlE USAGE TIIIB PAGBS RESULT 3051 7815318 01/02 18:27 01'13 2 OK ,j (OJ ~ w . .. . IVW METZGER · WICKERSHAM · KNAUSS & ERB AITORNEYS AT LAW 3211 NOlrH fRONT SU.BBT . P.O. Box 5300 . HAIIUSBURG. PSNNSYLVANIA 17110-0300 (717)238-8187 . PAX(7t7)234.9478 UNC;;. .... MBTZGl!R WlCXERSHAM CHIJJTWI J.IU.JI. IOtUT t. YlTTU jAMBJ P. CAAL tOtlBT .. aslO IDWAID I.IHAUBJ. IV" )lUll L HOCK CLAU DIVIU IAllOHAC. CATALDI . IOMDC8nIIm II ow. TIIAL lAW IY nil NAJDM..... Of DIAL /IlNOCJCt LUL t. NILOAlBAl/O' BICIIA&D.. OIUIY JTBYBN Po IIINIR July 13, 1996 VIA FAX AND REGULAR MAIL Austin F. Grogan, Esquire 24 North 32nd street Camp Hill, PA 17011 @ Re: Campbell v. Campbell Dear Austin: This will confirm our telephone conversation of today regarding the Addendum to the Settlement Agreement reached on April 2. Once again, although you stated that the parties did agree at the Master's hearing that any profit or loss on the disposition of the marital home would be split on a 50/50 basis, your client will not sign the Addendum which clarified the meaning of paragraph 2 of that Agreement. Consequently, you may instruct your client that, given her unreasonable position, I have no alternative but to file a Petition with the Court in order to have that agreed upon term made part of the Settlement Agreement. Additionally, since there is no justification for your client's refusal to sign the Addendum, I will also seek attorney's fees and costs as part of the relief requested in that Petition. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB Richard B. Druby RBD:cl cc: Mr. Gilbert Campbell (regular mail) . I ;S ~~ ~>' "'''' ~~~ ~"'E o . u~~ ....z> O::>H OU E-<U Od '" CQO\w O~lI'\U U lI'\Od 10 '" ....> ::r:WO\I-i E-<e;j '" zSOZ I-Ic.JZH ~- " J ( , ",-'T '. .e " ; ( , i ;'. , .' , ~j (:-; r '.i" ') , .' , '. , fl. , J ... ... ... ... .. c ... Cd ... '" .. ~ 'tl C .. ... .. .", III a: w '" III III .. i J ~ ::;::J'\;O! . ~ ... 0 z i c Z r1 .( 1/'1 0 III ~ ,.. II J( )- III W ... ~ ~ It I ~ . z IIJ 0 lie 0 III ~ ~ ~ ll: ~ ~ '" It iij , PI ~ it It . J: o o PI o Q E . ~ ~ '" '" ~ U Od .., '" U ei:i ~i Od OZ ....H ~ i:: 1-<; H H 1-<::> HU I-<H::J [teu ",<< UI eij~ ",U'" a: Id CI N ti ~ . > :J '" '" ~ U . :c '" z H .... '" H Od :c U . . ~ .... CO '" '" ~ H U '~' j ~ IE ;0 .. . .. .. . . ..... . . JUL 2 2 1OO6tY - . ~ -' ;;. .' . CHRISTINE H, CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-5593 CIVIL v, GILBERT L. CAMPBELL, JR" Defendant IN DIVORCE ANSWER TO DEFENDANT'S PETITION FOR ORDER CLARIFYING AMBIGUfTY IN MARRIAGE SmLEMENT AGREEMENT AND NOW comes the Plaintiff, Christine H. Campbell, by and through h~r attorney, Austin F. Grogan, Esquire and files this Answer: 1, Admitted, 2. Admitted, 3. Admitted, 4. Admitted. 5. Denied, strict proof demanded, 6. Admitted, 7. Denied, strict proof demanded. 8. Admitted in part with clarification. Further explanation, Plaintiff's counsel agreed the parties discussed that any profit or loss would be split on a 50/50 basis. Furthermore, Plain1iff's counsel confirmed that that was the discussion before 1he Master and denies that 1he term was inadvertently admitted from the record. Regarding Exhibit "B", denied as to the intent of the letter, 9. Admitted in part that1he Defense counsel forwarded an Addendum to Plaintiff's counsel. Plain1iff's counsel agreed that he would advise his client to sign it to avoid further litigation, 10. Admitted in part, denied in part. Admilled thatlhe Plaintiff's counsel advised Defense counsellhat he would advise his client to sign it in order to avoid further litiga1ion. 11. Denied as 10 the agreement set forth in 1he Addendum. Plaintiff's counsel once again agreed 1hat he would advise his client to sign it to avoid further 1i1igation, 12. Denied, 13. Denied, Ihe parties never agreed to 1he Addendum, Plaintiff's counsel did advise the Plaintiff to sign it in order 10 avoid further litigation, 14, Denied, 15. No response necessary. 16. No response necessary. 17. Denied, strict proof is demanded. 18. Denied, strict proof is demanded. 19. Denied, slrict proof is demanded. WHEREFORE, 1he Plaintiff, Christine H, Campbell, respectfully request this Court to dismiss the Defendant's Pelition as meritless. 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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-5593 CIVIL TERM CHRISTINE H. CAMPBELL, Plaintlft . . GILBERT L. CAMPBELL, JR., Oefendant IN DIVORCE ORDER Vi ",<, AND NOW, this L day of Y/!<) /1// ... ~r 1997, upon consideration of the within Emergency Petition to Enforce Marriage Settlement Agreement, it is hereby Ordered that a hearing be held on that Petition and the pending petition filed on July 18, 1996 on the 1'8(J,dayof /1.~.ttUa.''U.L , 1997. The hearing will be held at tI :\: 30 o'clock -fL.m. in Courtroom No. _L, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: . /J;L J. I ~ (5) Plaintiff is hereby directed to execute all documents necessary to ettectuate the terms ot this Order. ; f~ i>." BY THE COURT: J. .. ..., . CHRISTINE H. CAMPBELL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-5593 CIVIL TERM GILBERT L. CAMPBELL, JR., Defendant . . IN DIVORCE --GIDley P.-rITIOIf TO BJlJ'ORCII MARRIAGII SIITTLIIHIlIfT AGRII_W1l'l' Petitioner, Gilbert L. Campbell, Jr., brings this Emergency Petition to Enforce Marriage Settlement Agreement and, in support thereof, avers as follows: 1. Petitioner Gilbert L. Campbell, Jr., who was the Defendant in a divorce action between the parties. 2. Respondent is Christine H. Campbell, who was the Plaintiff in that action. 3. On April 2, 1996, Petitioner and Respondent entered into a Marriage Settlement Agreement. A true and correct copy of the Marriage Settlement Agreement is attached hereto as Exhibit "A" and incorporated herein by reference. 4. On May 14, 1996, a final Decree in Divorce was entered by the Court of Common Pleas of Cumberland county, No. 94-5593 and said Marriage Settlement Agreement was incorporated into, but not merged with, the final Decree. 5. Paragraph 2 of the Marriage Settlement Agreement provide. as follows: Additionally, with respect to the marital home, the parties agree that it will be listed for sale or returned to the Veterans Administration, the option which will be chosen will be that option which is in the financial best interest of both parties. ~ .... . currently, there is a Petition pending betore this Court to clarity an ambiguity in that paragraph. That Petition seeks to include agreed upon but inadvertently omitted language setting torth an equal distribution ot profit or loss on the disposition of the lIarital hOlle. 6. In any event, the parties previously agreed that the sale of the home is not feasible since it would yield less than the current mortgage balance. 7. Accordingly, on June 21, 1996, Petitioner forwarded a letter to GE Capital requesting that the property be returned to the Veterans Administration's control and ownership. A copy of that letter is attached hereto as Exhibit "B". 8. On September 13, 1996, undersigned counsel spoke with the loan representative from GE Capital Mortgage. The loan representative indicated that the loan was being processed for foreclosure but that those foreclosure proceedings could be halted if the VA was willing to take the home. See copy of undersigned counsel's letter dated September 13, 1996, to GE Capital, attached hereto as Exhibit "C". 9. On September 17, 1996, undersigned counsel spoke to the loan representative trom the Department of Veterans Affairs. The representative indicated that she needed a letter from Plaintiff/Respondent prior to any foreclosure proceedings being halted. A copy of undersigned counsel's confirming letter dated September 19, 1996, is attached hereto as Exhibit "D". -2- .. ~ . \ . '. 10. On September 19, 1996, undersigned counsel forwarded a letter to Plaintiff/Respondent's counsel advising him of the necessity of having his client execute a letter expressing her desire to have the Veterans Administration take over the home. Undersigned counsel also advised that it was improper for Plaintiff/Respondent to be living in the residence without making mortgage payments and that any losses resulting from her residing in the home without making payments on the mortgage would be her responsibil i ty. See undersigned counsel's letter dated September 19, 1996, attached hereto as Exhibit "E". 11. On December 30, 1996, after not receiving a copy of Plaintiff/Respondent's letter to the Veterans Administration and GE Capital, undersigned counsel again wrote to opposing counsel requesting the letter and putting Plaintiff/REspondent on notice that her failure to forward such a letter constituted a breach of the Marriage Settlement Agreement. Undersigned counsel put Plaintitt/Respondent on notice that, should a letter not be forthcoming within seven (7) days, a Petition would be filed with the Court addressing the breach of the Agreement and seeking costs and attorney's fees for compelling her compliance. Plaintiff/Respondent was also on notice that the petition would seek to hold her liable for 100 percent of any charges, costs, and expenses associated with the breach which lead to the foreclosure proceedings. See letter of December 30, 1996, attached hereto as Exhibit "F". -3- - 12. To date, Plaintitt /Respondent has not forwarded a request to the VA and GE Capital and is therefore in breach ot the Marriage Settlement Agreement. 13. Respondent hag the ability to comply with the relevant provisions of the property settlement agreement. However, she has chosen to breach the provisions in order to live in the home rent free. 14. This Court has the authority pursuant to Sections 3105 (a) and 3502(e) of the Divorce Code of 1980, as amended, to enter an Order directing Respondent to notify the Department of Veterans Affairs and GE Capital of her intention and desire to have the Department of Veterans Affairs assume ownership of the marital home under a deed in lieu of foreclosure. 15. Furthermore, this Honorable Court has the authority, pursuant to the above-referenced sections and paragraph 10 of the Marriage Settlement Agreement, to award costs and attorney's fees against Respondent for requiring Defendant/Petitioner to bring this Petition to enforce the Agreement. 16. Moreover, Defendant/Petitioner respectfully requests this Honorable Court to issue an Order making Plaintiff/Respondent responsible for any outstanding mortgage payments, late charges, attorney's fees, and any other sums incurred as a result of the foreclosure proceedings. 17. Further, Defendant/Petitioner believes and therefore avers that Plaintiff/Respondent has been receiving information trom the mortgage company but has not been forwarding it to -4- A A Defendant/Petitioner. Therefore, Detendant/Petitioner is not fully aware of the action. taken by the mortgage company to date. 18. Accordingly, Defendant/petitioner respectfully requests that this Honorable Court schedule an emergency hearing in order for Plaintitf/Respondent to establish cause, if any she has, why she has failed to comply with the Marriage settlement Agreement. Furthermore, in order to preserve judicial economy, Defendant/Petitioner respectfully requests that the hearing also address the Petition for Order Clarifying Ambiguity in Marriage Settlement Agreement filed on or about July 18, 1996. WHEREFORE, Defendant Gilbert L. Campbell, Jr., respectfully requests that this Court schedule an emergency hearing addressing Plaintiff's failure to comply with the terms of the Marriage Settlement Agreement and ~equests that Plaintiff be ordered to pay Defendant's costs and attorney's fees incurred in compelling her compliance with the Agreement. Finally, Defendant requests that this Court order that Plaintiff is responsible for all charges, costs, and expenses related to the foreclosure proceedings. & ERB, P.C. By ~ R chard B. Dr , Esqu1.re Attorney I.D. No. 61904 P.O. Box 93 HarriSburg, PA 17108-0093 (717) 238-8187 Attorneys for Defendant Date: FebrUary~, 1997 -5- ullilMt A "'"" ,-., . ~ " CHRISTINE H. CAMPBELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 94 - 5593 GILBERT L. CAMPBELL, JR., Oetendant IN DIVORCE THE MASTER: Today is Tuesday, April 2, 1996. Present tor a Master's hearing are the Plaintiff, Christine H. Campbell and her counsel Austin F. Grogan, and the Defendant Gilbert L. Campbell, Jr., and his counsel Richard B. Druby. A divorce complaint was filad on September 20, 1994, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The Master has been informed that counsel and the parties will conclude the divorce under section 3301(c) of the Domestic Relations Code and that affidavits of consent and any appropriate waivers will be filed within a week of today's date with the Prothonotary of Cumberland County. The divorce complaint also raised the economic issues of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Defendant, in response to the complaint and by way of counterclaim on his own behalf, raised the economic issues of equitable distribution and counsel fees and costs. The parties were married on April 24, 1982, and separated on September 6, 1994. They are the natural parents two children, Andy and Otha. Both children currently reside . ~ , with the Plaintiff. The Master has been informed that attar negotiations the parties and counsel have reached an agreement with respect to the economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be the substantive agreement of the parties and not subject to any modification or changes except for correction ot typographical errors made during the transcription. Therefore, that means th~t the agreement that you are going to state on the record here today will not be subject to any changes and we are goirlg to ask you to return later this morning to review the agreement for typographical errors and if there are any typographical errors we will make those corrections and then we will ask you to sign the agreement by way of affirmation of the terms that have been reached here this morning in this conference. After the agreement has been reviewed for typographical errors and has been signed, then I will prepare an order vacating my appointment as Master, and then counsel can prepare a praecipe transmitting the record to the Court with the affidavits of consent and the appropriate documents requesting that the Court enter a final decree in divorce. Mr. Druby. MR. DRUBY: 1. With respect to the claims of alimony, alimony pendente lite, and'counsel fees, both parties waive and forego . 4 tho.. claims as part of this settlement. 2. Additionally, with respect to the marital home, the partie. agree that it will ~e listed tor sale or returned to the Veteran's Administration, the option which will be chaosen will be that option which is in the tinancial best interest or both parties. 3. Turning to the vehicles. The 1994 Escort which is currently in the possession or Mrs. Campbell will remain in her posseesion. She will assume whatever obligation there is to the extent that it is encumbered to make those payments. 4. With respect to the 1990 Ford Ranger which is currently in the possession of Mr. Campbell, that will remain in his possession and he will deal with that encumberdnce and that will be Mr. Campbell's obligation. 5. With respect to Mr. Campbell's pension, the parties have agreed first off that the survivor's benerit which are currently being deducted from the pension will be cancelled. In exchange, Mr. Campbell has agreed to give t~ Mrs. Campbell a set dollar amount of $250.00 per month to terminate in the event of either parties' death. Mr. Grogan will prepare a Qualified Domestic Relations Order with those terms. 6. With respect to the marital debts, the Federal Credit Union loan which was taken out to consolidate bills, that payment is currently being made on that loan through the pension and will continue to be deducted from the pension until that loan is paid off. Mrs. Campbell agrees to go into the New Cumberland Federal Credit Union and sign whatever documents are necessary to release her from that obligation. Mr. Campbell agrees that he will be solely obligated on the New Cumberland Federal Credit Union loan and that that debt will continue to be deducted from his military pension as it has been, and he will make whatever arrangements are necessary with the credit union to assume the obligation totally. 7. With respect to the personal property, it is agreed that whatever is currently in Mr. Campbell's possession, as is evidenced from the appraisal which was completed by Mr. Brumbach, will remain in Mr. Campbell's possession and will be his sole property. Witb respect to the items currently. at the marital home, again those items being appraised by Mr. Brumbach, they vill remain Mrs. Campbell's sole possession with the exoeption of the Camelback trunk wbich contains Mr. C..pbell's military items including photographs and t.mily photographs which will be returned to Mr. Campbell. Additionally, if it still exists, either at the marital home or at Mrs. Campbell's mother's residence, a 1907 wooden California brewery sign will be returned to Mr. Campbell and that will become his sole possession. The parties will make arrangements for the pickup of the two items stated within the next thirty (JO) days at a mutually convenient time. 8. 'With respect to Mrs. Campbell's pension at the Dauphin County Home, the parties believe that that pension was generated post-separation but in the event that that may not be the case, Mr. Campbell relinquishes any and all rights he has to an interest in that pension. 9. With respect to the parties' checking and savings accounts, the parties agree that the issue regarding disbursement of those fu~ds has been resolved and each party waives request for further disbursement by either party. 10. The parties agree that should either party breach the agreement that has been set forth today, the breaching party will bear the costs and attorney fees of the other party in any action that may be necessary to enforce the agreement. 11. Except as herein otherwise provided, each party may dispose ot his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect' this mutual waiver and relinquishment of all such interests, rights, and claims. MR. DRU9Y;. .M=. Campbell, a few questions for you. Were you present during the entire time that we put the agreement on the record? MR. CAMPDELL: Oh, absolutely. MR. DRUBY: Did you understand all the terms ot the agreement as I set them forth? MR. CAMPBELL; Yes, sir, I did. MR. DRUBY: Do you agree with the terms that we reached and put on the record today? MR. CAMPBELL: Yeah, I do. MR. DRUBY: You understood everything that was said? MR. CAMPBELL: Yes, I did. MR. DRUBY: Do you have any questions regarding any particular points of the agreement before we close the record? MR. CAMPBELL: The only thing I have a question about is, is it okay for me to go in and look and see what kind of damage they have to be able to see if I can fix them before we even sell the house? MR. GROGAN: You will let Gilbert in the house to look to see if he can repair some of the damage? MR. CAMPBELL: I am a carpenter and I do do my own work. MRS. CAMPBELL: Well, if he brings somebody with him and I am present and he has somebody else with him. MR. CAMPBELL: Would Marty be okay, my neignbor __ our neighbor? MRS. CAMPBELL: No. I would like to have a pOlice officer or somebody in that way. I would feel more comfortable. MR. GROGAN: Would somebody other than a police officer be all right, like, may be your father or MRS. CAMPBELL: Somebody that I feel comfortable with. MR. CAMPBELL: How about Cindy -- MRS. CAMPBELL: No. THE MASTER: Can you suggest someone that you would feel comfortable with having there? MRS. CAMPBELL: I can bring my neighbor over, the one I socialize with a lot and I'm friends with. THE MASTER: What is the neighbor's name? MRS. CAMPBELL: Her name is -- now my tongue is tied. THE MASTER: Take your time. MRS. CAMPBELL: Karen. I don't know her last name. She lives right next door to me. THE MASTER: Mr. Campbell, would Karen, her next door neighbor, be all right to have there when you come in? MR. CAMPBELL: Not to have any arguments, becau.. that's not why I'm here. I'm here to get everything ironed out. I don't trust it and I'll tell you why. The last time I went to . pick up the trunk there was a big fiasco. She had told me __ THE MASTER: You don't want Karen there? MR. CAMPBELL: No, absolutely not. THE MASTER: Let's find somebody else then. Off the record. (A discussion held off the record.) THE MASTER: We had a discussion off the record and Mr. Grogan is willing to go to the house when Mr. Campbell wants to make an inspection. Mr. Campbell needs to contact Mr. Grogan directly and make arrangements for the time that he is going to have access to the property. Is that all right, Mr. Campbell. MR. CAMPBELL: Yes. CA discussion was held off the record.) THE MASTER: Now, Mr. Campbell, have your inquires been properly addressed? MR. CAMPBELL: I think so. MR. GROGAN: Christine, you were here during this conference today; is that correct? MRS. CAMPBELL: Yes. MR. GROGAN: Did you hear everything -- or is there anything that you are unsure of that you didn't hear correctly about how you're not going to receIve any alimony payments but you are going to receive $250.00 a month of his pension, do you understand that? o . MRS. CAMPBELL: Yes. MR. GROGAN: That he is going to cancel the survivor's benetits that would come to you in case he died befo~e you, he is going to cancel that? MRS. CAMPBELL: Yes. MR. GROGAN: That you're going to keep your car; he is going to keep his truck, and that the marital home is going to be put up for sale or it's going to be returned to the VA, whichever is in your financial best interest and your husband's financial best interest? MRS. CAMPBELL: Yes. MR. GROGAN: And that the personal property that you have in your possession, you keep but for the trunk, the military and personal pictures in the trunk, and this California wooden sign that he describes as a 1907 brewery sign. If you hav~ that, YOU'll give it back to him? MRS. CAMPBELL: If I have it. There's a couple of items that were destroyed, you know, my son has a lot ot anger and he just picks up stuff and breaks it. MR. GROGAN: And you believe that California sign has been destroyed? MRS. CAMPBELL: Yes. MR. GROGAN: But you do have the trunk at home? MRS. CAMPBELL: Yes. MR. GROGAN: And your husband can come and get the trunk? MRS. CAMPBELL: Yes. And I'll go through the pictures and give him his pictures that are his. MR. GROGAN: Okay. Did you understand everything else reqarding your pension at the nursing home and the fact that whatever savings and checking accounts you had have been separated and you are equally happy with the separation there? MRS. CAMPBELL: Yes. THE MASTER: Mrs. Campbell, you're hearing impaired? MRS. CAMPBELL: Yes. THE MASTER: And your attorney has made an effort here to go over individually the terms of this agreement, and have you understood and been able to hear to understand what we have done here today? MRS. CAMPBELL: Yes. If I didn't I would have asked. THE MASTER: You would have asked if you did not? MRS. CAMPBELL: Yes, I would. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratity and affirm the agreement previously made and intend to bind myself to the settlement as a contract Obligating myself to the terms ot settlement and SUbjecting myself to the methOds and . procedure. of .nt~rcement which may be impo.ed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: 4rkn .1 1r<---- Aust n ~~~ Attor~~~ intiff pW"" . Attorney for Dete:la'nt .' </ ft/f~ , &t1ffi. @/9? bllMI ,-., .-.. . June 21, 1996 Re: Gilbert L, Campbell Jr" 166-46-3904, 27 W, Main Street, ~lainfield, PA 17081, US Army Retired Subject: Return Property to VA Control and Resale GE Capital Mortgage 901 Roosevelt ~arkway Chesterfield, MO 63017 To Whom It May Concern: Effective May 1996 I became legally divorced and I am living at 27 W. Main Street, PO Box 28, Plainfield, PA 17081, Tel: (717) 258-1085 separate from my ex-wife, Currently my ex-wife Christine H. Campbell, 180-56-5525 is living at 806 Hummel Avenue,.L8moyne, PA 17043, Tel: (717) 730-3784 and is co-mortgage owner of this residence. She is responsibJ.e for the mortgage while living there through (GE Capital Mortgage, PO Box 7999, Philadelphia, PA 19101- 7999, Loanft 10299014 Tel: 1-800-222-0238), She has not made payment for the month of May, and June. I would like to give the house to the VA, PO Box 8079, Philadelphia, PA 19101, VA Loan # LH 454239 Tel: 1-800-827-1000, Mr, Brindisi, I am responsible for my debts in the future and I am trying to save my credit, but do uot have enough money to make payment for my ex-wife and reside at my rented residence of $500,00 a month, Sincerely, ha.t/6:..dltf k-. Gilbert ~ c~mpbell Jr, Staff Sergeant, US Army Retired cc: Metzger, Wickersham, Knauss & Erb Richard Druby, Attorney 3211 N, Front Street PO Box 5300 Harrisburg, ~A 17110-300 Tel: 238-8187 ~ , -""'. lJ~C ~ r--.., Exhibit D "'"" . IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH FRONT STRUT . P.O. Box 5300 . HAUISBUlG. PeNNSYLVANIA 17110-0300 (717) 238-8187 . FAX (117) 234-9478 'IIHCa .... METZGI!R WlCKERSHAM CHlJlTlAN S. IU.Jl. InnlT I. YBTTBl )AllIS P. CAlL 10lnT P.I\IBO 10WARD 1.IlNAUSS.IV' JIUO L Hoa XABL I. HILDAlRANO' l!CHAIO I. OIUIY STlVIN IIIINBI eLAIlI DIVIU lAMONA C. CATALDI . IDUD CD:r'IIm III ~ TIlA&.I.AW 1Y .,. twXIIM.lDM>> OItIW. MNOCN:'t September 19, 1996 @ Ms. Maryanne Leahy Department of Veterans Affairs P.O. Box 8079 Philadelphia, PA 19101 Re: Loan No. LH 454~39 (OJ Dear Ms. Leahy: This will confirm our telephone conversation ot September 17, 1996, during which we discussed the Campbells' desire to have the Oepartment of Veterans Affairs obtain possession of the home by deed in lieu of foreclosure. currently, Mr. and Mrs. Campbell are divorced and are unable to maintain the payments on the mortgage. As your records indicate, payments are due for the month of May forward. As you indicated to me, you needed a letter from the Campbells indicating that they desire the VA to take possession of the home. I have enclosed a letter which was forwarded to GE Capital Mortgage on June 21, 1996, by Mr. campbell expressing those sentiments. Apparently, this letter was sent to the improper address and, I have forwarded it to the proper individual at GE Capital Mortgage. For your information, this claim is being handled at GE Capital Mortgage by Ms. Tina Richardson, 4680 Hallmark Parkway, San Bernardino, CA, 92407. I will be contacting counsel for Mrs. campbell so that he may have his client forward a letter expressing her desire to have the Veterans Administration obtain the home, It is my understanding that once both letters are received by you and GE Capital, you will be contacting GE capital to inform them of the possibility of acquiring a deed in lieu of foreclosure. At that juncture, any foreclosure proceedings which have begun will be halted until the VA makes its determination of whether to follow through on the deed. L0 w If my understanding regarding our conversation is incorrect, please advise. otherwise, if there is anything further that I ,'"\ t""'\ EJhibit E . . w IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH FRONT SUUT . PO. Box 5300 . HARRISBURG. PENNSYLVANIA 17110-0300 (717) 238-8187 . FAX (717) 234-9478 "J"'~. I'" METZGBR WlCURSHAM eHaJSTlAN s. UI.)I. 10lUT I. YBTTBR JAMBS P. CARL 10tllT P. UIO 10WAAD I. INAUSS,IV' )IUO L. HOex lAAL.. HILDAlJAHO' lJeHoUO I. OIUtY $lIVlN .. IIINII eLoUI OIVIU lAMON... C. CATALDI . IOAID ~ II CML 1IW. LAW II' M IW'DIM.IDMD Of fIIAL IDIOCN:'f September 19, 1996 @ Austin F. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 Re: Campbell v. Campbell Dear Austin: (ffi As y~u can see from the enclosed letter, the VA and GZ Capital need a letter from Mrs. Campbell expressing her desire to have the Veterans Administration take over the home. I would ask that you have your client execute such a letter and forward a copy to Ms. Richardson and Ms. Leahy. If that poses a problem for you or your client, please advise immediately. Obviously, it is in both our clients' interests to resolve this matter as soon as possible and without foreclosure proceedings. Additionally, please advise as to whether your client is still in the marital home. I believe it .is improper for her to be liv'ing in the residence without making any mortgage payments. Therefore, any damages or losses resulting from her residing in the home without making payments on the mortgage will be her responsibili ty. L0 Along the same lines, please advise as to whether your client has had a change of heart regarding signing the Addendum to the Marriage Settlement Agreement. At this juncture, since you have denied certain facts which were contained in my confirming letters to you (to which you did not note errors in or lodge any objections to at the time you received them), your client has created the necessity for the taking of depositions or a formal hearing. Obviously, your client's position has now necessitated additional unnecessary litigation which is not in either party's best interest. Therefore, before I schedule depositions and a formal hearing, I will attempt again to see if your client is willing to avoid those expenses and sign the - . . . ~, . Austin F. Grogan, Esquire September 19, 1996 Page 2 Addendum. Naturally, it she has another alternative, I would be interested in hearing it. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB Richard B. Druby RBD:cl co: Mr. Gilbert Campbell .-, ,~ . ' . , , - " " ..' .. ~. . tllIiIlltF '. . IVW METZGER · WICKERSHAM · KNAUSS & ERB ATTORNEYS AT LAW 3211 NORTH FRONT STRUT . PO. Box 5300 . HAUISBURG. PBNNSYLVANIA 17110-0300 (717)238-8187 . FAX(717)234-9478 \1""'.11 IS.. METZGER WlCJ(E!lSHAM CHllSTIAH S. BII.JI. IOtUT B. YBTTBl JAlIlS P. CAll 10tBAT .. IBID IDWAJ.D B. INAUSS.IV' Jil.BD L. NOCI RAIL I. H/LOAlRANO' B1CHAAO I. OIUIV sraV.N I W/Nn CLAAIC OIVBII IAWONA C. CATALDI . ~ CIIIIWIm If ow. 1'IW.l.AW ft' lie *"'*M. aID Of 1IW. AD'oOUCV December 30, 1996 VIA FAX AND REGULAR MAIL @ Austin F. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 Re: Campbell v. Campbell Dear Austin: (ill As of this writing, I have not received a return phone call from you in response to thn message I left on your answering machine on December 20, 1996. As my message indicated, I have not heard from you as to whether your client forwarded a letter to the VA and GE Capital expressing her wish to have the Veterans Administration take over the home. L0 w Back on September 19, 1996, I provided you with the names and addresses of the contact people at the VA and GE Capital along with my letter to the VA and Mr. Campbell's letter to GE Capital. I requested that you have Mrs. Campbell forward a similar letter so that the house could be turned over to the VA. As we previously discussed, a sale of the home would not be feasible since it would yield less than the current mortgage balance. On October 1 you wrote to me indicating you had trouble contacting Mrs. Campbell regarding my letter and that you would get in touch with her as soon as possible. I acknowledged your letter on October 8 and again urged you to have her forward the letter as soon as possible. To date, I have not heard from you as to whether such a letter has been forwarded. Since Mrs. Campbell signed a verification to her responses to the Request for Admissions, I am assuming that you were able to meet with her subsequent to your October 1 letter. Therefore, if she has forwarded a letter to the VA and GE Capital, please provide a copy to me. . , . ". . - . . Austin F. Grogan, Esquire De~e.ber 30, 1996 paCJe :l If she has not torwarded a letter to the VA and GE Capital requesting that the VA take over the home, it is our position that she is in violation ot the Marriage Settlement Agreement, paragraph 2. While we are currently in dispute over how the protits or losses on the disposition of the home are to be divided, the Agreement clearly states that the home will either be sold or returned to the Veterans Administration. Since we have agreed that the only viable alternative is to return it to the Veterans Administration, your client's failure to assist in that endeavor breaches the agreement reached. As provided in paragraph 10 of the Agreement, "... should either party breach the agreement ..., the breaching party will bear the costs and attorney feas of the other party in any aotion that may be necftssary to enforce the aCJreement." Therefore, please be advised that if your client does not forward a letter within seven (71 days of the date of this letter to GE capital and the Veterans Administration requesting that the Veterans Administration take possession of the home under a deed in lieu of foreclosure, I will file a Petition with the Court addressing your client's breach of the Agreement. That Petition will request that your client comply with the Agreement and will also request costs and attorney's fees for compelling her compliance. Furthermore, since your client's actions are the sole cause of this mortgage going to foreclosure, I will request that she be 100 percent liable for any charges, costs and expenses associated with the default. At the same time, I will have the Court address the current Petitioll pending before it. Once again, due to your client's unreasonable position, additional litigation is necessary and expenses are being incurred. Hopefully, your client will realize that it is in her best interest to have this matter resolved at this juncture without the need for Court intervention. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB Richard B. Druby RBD:cl cc: Mr. Gilbert Campbell . .' . I .0 . . 0, .. VDIrICA'I'IOR I, Gilbert L. Campbell, Jr., do hereby acknowledge that I have read the toregoing and that the tacts stated therein are true and correct to the best of my knowledge, information, and beliet. I understand that any talse statements therein are made subject to penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: ,4jV7/ .-- G~~4~ . . . -. .. .. . C"~IrICA~. O. ."VIe. AND HOW, on this !/J! day of February, 1997, I, Richard B. Druby, Esquire, of Metzger, Wickersham, Xnauss & Erb, P.C., at~orneys for Defendant, Gilbert L. Campbell, Jr., hereby certify that I served the within P.tition to .ntare. K&rriaq. ..ttl_eDt Aqre_eDt this day by depositing the same in the United Statem mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Austin F. Grogan, Esquire ~4 North 32nd street Camp Hill, PA 17011 ~~ , rll ... 1 .1 1 , , " 1 . , .' . -<~P~ry"1 // ,;?,) ,.. ..... ~~ - c- - ... 1 ~ r: 1II ~ 0 .., 0 ... VI 0 ! s Q E ~!~8 ~ . i ; a ~ ~ ~ . VI w .. ~ " II · · . · . d . ~n.. w .. .; jC OJ . . , ... . II: " ... ii " . N ~ t; :E ~ .. it .... .." . .. .. .. . CHRISTINE H. CAMPBELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY, PENNSYLVANIA 94-5593 CIVIL TERM VS, GILBERT L CAMPBELL, JR.. Defendant IN DIVORCE IN RE: EMERGENCY PETITION TO ENFORCTi MARRIAGE SETILEMENT GREEMENT ORDER AND NOW. this Ii' day of February. 1997. further hearing hereon is continued in light of Ihe agreement of the parties as reached in open court and announced in their presence, The parties arc ordered and directed to comply with 'he agreement as announced. BY THE COURT. / /lri Austin F, Grogan. Esquire For the Plaintiff e.~~ (7'l....:.A..l ~/~c Jif'1. -, "A.t'. Richard B, Druby. Esquire For the Defendant :rlm