HomeMy WebLinkAbout94-06358
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. IN THE COURT OF COMMON PLEAS ·
. .
. OF CUMBERLAND COUNTY .
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. STATE OF , ~\~ ,.;.;. PENNA. .
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.' PAMELA S. WELSH, .
~. 94-6358 CIVIL
. Plaintiff l"o o. ,......,.... .
'Vl'I':;ll,) ,
. LESTER G. WELSH, .
. Defendant .
! !
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. DECREE IN .
· DIVORCE .
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~ ANDNOW.~~,'Z~"". 19q~". it is ordered and !
. decreed that" . ,PAM,f;LA, S,,\.'lF,:L,qll, "'" ,........'..,..'.... plaintiff, .
. and, ., . , , ' " , , , , LESTER ,G., WELSH, , , . ' , ' , . . , , . . , ., . ". defendant, :
. are divorced from the bonds of matrimony. .
. .
. The court retains jurisdiction of the following claims which have .
. been raised of record in this action for which a final order has not yet w
. been entered; ;
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PAMELA S. WELSH, ) IN THE COURT OF COMMON I
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA I
vs, ) I
)
) NO, 94.6358 CIVIL
LESTER G, WELSH, )
Defendant ) IN DIVORCE
)
fJt\ECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Tranllllit tho record, together with the following information, to the Court for entry of a divorce decree:
I. Grounds for Divorce: Irretrievable breakdown,
2, Date and manner of service of the Complaint:
Served on D~fendant, Lester 01 Welsh, by certified mail, return receipt
requested, on 17 Novembet' 1994, Affidavit of Service by certified mail
previously filed on 11 January 1995,
3, Date ofexecution of the Affidavit of Consent and Waiver of Notice ofIntention to Request Entry
I oft Divorce Decree required by Section 3301(c) of the Divorce Code:
II By Plaintiff: 1 August 1996
By Defendant:
9 July 1996
4, Related claims pending: None,
B'&~
Attorney for Plaintiff
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PAMELA S. WELSH, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 94 ~ 6358 CIVIL
LESTER G. WELSH,
Defendant IN DIVORCE
THE MASTER I Today i. rriday, September 20, 1996.
Thi. i. the date set for a Master'. hearing and present are the
Plaintiff, Pamela S. Welsh and her counsel Samuel L. Andes and
the Defendant, Lester G. Welsh, and his counsel Robert L.
O'Brien.
The parties and counsel appeared before the Master
previously on Wednesday, May 29, 1996, at which time an
agreement was placed on the record with respect to numerous
issues leaving other matters for further review, negotiations,
and perhaps litigation. The Master has been advi.ed that all
issues have now been resolved by agreement and an agreement is
going to be placed on the record as to the outstanding issues.
The prior agreement will be reaffirmed and incorporated into the
present agreement with one typographical correctiun which will
be noted by Mr. Andes on the record and a restatement of
Paragraph 6.
The partie. have signed and filed affidavit. of
con.ent and the appropriate waiver of notice of intention to
request entry of a divorce decree, both forms being required
under the Rule. of Civil Procedure, so that the divorce can be
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conclud.d und.r s.ction 3301(c) of the Do...tic Rslation. Cod..
Th. agr....nt that is going to be plac.d on the
r.cord today will b. consid.r.d the substantive agr....nt of the
parti.s and will not be .ubj.ct to any chang.. or .odifications
except for correction of typographical .rrors which .ay be .ade
during the transcription. That .eans the agr....nt as stated
h.r. today in the pre..nce of the part i.. and couns.l and the
Master will be the final agreement r.solving all .cono.ic
claim.. The agreement will be s.nt around to couns.l to review
for typographical errors and if any correction. are necessary,
th.y will be made before the final agr.ement i. sent to counsel
and the parties for .igning. The signing of the document is an
affirmation of the agreement as stated on the record her. today,
After the agr.e..nt has b.en revi.w.d for.
typographical errors and has been affir.ed by the partie. and
couns.l by their signature., the Master will prepare an order
vacating his appointment and counsel will then be in a po.ition
to file a praecipe transmitting the record to the Court
requesting a final decree in divorce. Mr. Andes.
MR. ANDES: Thank you. The parties have agreed to
supple.ent the stipulation they entered on the 29th of May 1996
as follow.:
1, The r.sidence at 11 Hilltop Road in N.wville, Cumberland
County, Pennsylvania, will be conv.y.d to Mrs. W.lsh and
will be her sole and s.parat. prop.rty hereafter.
.;
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In exchange for that conveyance, Mr.. Welsh agre.s to pay
to Mr. Welsh the sum of $16,800.00 without intere.t,
on or before the 30th of June in the year 2002 or 90
day. after any of the following event. occur:
a) The re.idsnce at 11 Hilltop Road cea.ing to be
the primary residence of two or more of the
partie.' three children.
b) Mr.. WeIAh'. remarriage.
c) Mr.. Welsh'. cohabitation with another man at that
residence.
Mrs. Welsh's obligation to make this payment to Mr. Welsh
will be secured by a promissory note to b. prepared by
counsel and a mortgage entered as a second lien on the
property at the time the de.d is conv.yed. The partie.
have also agreed that, in the unlikely event that the
holder on the first mortgage d.ems the conveyance from
Mr. Welsh of his interest in the prop.rty to Mrs. Welsh
to be a default of that first mortgag., the partie. will
cooperate to avoid or cure that default, including, if
necessary, reconveying a 1/2 interest in the property to
Mr. Welsh subject to Mrs, Welsh'S right to acquire it in
exchange for the payment provided in this paragraph when
that paym.nt is made.
2. Th. provi.ion of paragraphs 2, 3, 4, and 5 of the
stipulation reached before this Court on the 29th of May
1996, are incorporated herein .xpres.ly. The
typographical change mentioned by Mr. Elick.r appears in
the 8th line of Paragraph 2 where the word formally
should be changed to formerly.
Paragraphs 2 - 5 are transcribed from prior
agr....nt placed on the record May 29, 1996.
2. The parties have agreed with r.gard to the other assete
that they own, including tho.. ite.s list.d in each
party'. pr.-trial statement and including but not
liaited to a 1988 Mercury Topaz automobile and a 1990
Chevrolet Cavalier or the proc.eds of it. trade; the
houeehold furnishings; a savings account at Far.ers Trust
CompanYi two s.all household account. at Members First
cr.dit Union, formerly DArCUi and husband's interest in a
retire.ent plan with Component Building syste.s; that
,
tho.. i~.ms will b. con.id.r.d dis~ribu~ed by ~h.
p.r~i.s, and .ach party waiv.. any fur~her claim. of the
it.m. now in the po.....ion of the oth.r and w. will
not .nt.rtain te.timony a~ anoth.r h.aring about the
value of thoBe asset. or how they have previou.ly be.n
di.tributed.
Th. only exception to that i. that the Mercury Topaz
is curr.ntly titled in both nam.s and Mr. O'Brien will
prepare .ome document. and have Mr. Welsh ex.cute tho.e
so the title can be tran.ferred to Ms. Wel.h, the wife
3. Th. parties each mad. payment of certain marital debt.
after the .eparation, and again the partie. are .ati.fied
that each of them .hall pay the debt. that th.y have paid
.inc. .eparation, and if there i. any balanc. remaining
on tho.e account., the party who has b~en paying them up
to now will continue to pay those. Specifically, wife
ha. paid the balance owed on a Sear. account and hu.band
either has paid or has been paying the balanc. owed on a
Core.tates Visa and a Choice Visa account and he will
con~inue to pay those and she will be re.ponsible for the
Sear. account and we will not have any further testimony
about those or ask the Master to con.ider them further in
equitable distribution.
4. The parties have agreed that they will maintain insurance
on their lives for ~he benefit of the children and in
that regard they have specifically agreed as follows:
a) Husband's life is insured by a policy i.sued by
Monumental Life Insurance Company. He will
maintain that policy and maintain the ~hree
children as the .01. and exclu.ive beneficiaries
until the younge.t child at~ain. ~he age of 23
y.ar. and he will not borrow again.t the policy or
otherwise reduce it. death benefit.
b) Wife'S life is insured by a group plan available
through her employer. She will maintain that
in.urance until the youngest child i. 23 year.,
mailltain the children as the .ole and exclulllive
beneficiaries, and do nothing to reduc~ the
death benefit of that policy a. long a. it i.
available to her through her employment.
5. Th. partie. expect that their children or some of their
childr.n will want to attend COllege or some other form
of higher education after high school. They have agreed
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that after the children have made every reasonable effort
to obtain financial aid in the form of grants, loans,
and other resources, and after the children have applied
their own resources in the form of any savings or
earnings that the children have to assist in paying
for their own education, that the parents will make a
reasonable contribution, whatever they can reasonably
afford to make based upon their earnings, income, and
expens.s at that time.
Resumption of terms added to agre.ment this date,
september 20, 1996
3. The parties replace Paragraph 6 of the prior stipulation
with the following:
Wife waives her claim for alimony.
claim for alimony, alimony pendente
and exp.nses.
4. 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, 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 waiv~r and relinquishment of all such
interasts, rights, and claim..
Each party waiv.s any
lite, counsel fe.s
MR. ANDES: Mrs. Welsh, did you hear what I just
dictated?
MRS. WELSH: Y.s.
MR. ANDES: Do you remember and have you had a
chance to review what we did May 29th, 1996?
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MRS. WELSH: Y.s.
MR. ANDES: What w. are doinCJ toc1ay 18 takinCJ care
of the houae and wrappinCJ up all of the loose ends so we are
don.?
MRS. WELSH: Y.a.
MI. ANDES: Do you und.rstand what we did toc1ay?
MRS, WELSH: Y.s.
MR. ANDES: DO you have any qu.stions about it?
MRS. WELSH: No.
MR. ANDES: And ia that the agr...ent w. reach.d
throuCJh neCJotiationa with your husband and his attorney?
MRS, WELSH: Yes.
MR. ANDES: Is that acc.ptable to you and is that
what you are willinCJ to do?
MRS. WELSH: Y.s.
MR. O'BRIEN: Do you und.ratand what Mr. And.a put
on the r.cord, teater?
MR. WELSH: Yes.
MR. O'BRIEN: Do you agree to it?
MR. WELSH: Y.a.
I acknowl.dCJ. that I have r.ad the above
stipulation and aCJr...ent, that I und.ratand the t.rms of
.ettle..nt aa s.t forth her.in, and that by signing below I
ratify and affirm the agr....nt previously made and int.nd to
bind mya.lf to the ..ttl...nt as a contract obligating myself to
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tha tara. of settle.ent and sUbjectinq .yself to the .ethod. and
procedure. of enforce.ent which may be imposed by law and in
particular Saction 3105 of the Do.estic Relations Code.
WITNESS:
DATE:
~'t:.~
Attorney for plaintiff
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J.?'!':,.. ilL
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Ro ar . O'BrIan
Attorney for Defendant
~~(~
a er G. Wa ah
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PA"IILA S. WIILSH
Plaintiff
IN TNII COURT Of COKKON PLIIAS
OF CUMBII1LAHD COUNTY.
PIINNSYLVANIA
VI,
LIISTER G, WIILSH
Defendant
CIVIL ACTION - LAW
NO, 94- f.. 3)" CIVIL TlIlK
IN DIVORCE
NOTICII TO DIlP1lND AND CLAI" lIGHT!!.
You have been sued in court. If you wish to defend against the claiMs set forth in
the foregoing pages. you lUSt take proMpt action. You are warned that if you fail to do
80, the case May proceed without you and a decree in divorce or annul.ent May be
entered against you by the court. A judgMent lay also be entered against you for any
other claiM or relief requested in these papers by the plaintiff. You may 10le ~ney or
property or other rights important to you. including custody or visitation of your
children.
1 When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
Carlisle, Pennsylvania l70l3
IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYER'S PliES OR
IIXPBNSES BEPORE 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 FINO 01JT WHERII YOU
CAN GET LEGAL HELP.
Court Administrator, Fourth Floor
CUMberland County Court House
Carlisle. Pennsylvania 17013
Telephone: (717) ~40-6~00
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I VHBlBlOlB. Plaintiff requests
I the Divorce Code of Pennsylvania.
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this Court to enter a decree in divorce pursuant to
COUNT II - BOUITABLB DISTRIBUTIQN
9, During the course of the Marriage, the parties have acquired nUlerous iteMs of
property, both real and personal, which are held in joint naaes and in the indIvidual
naMes of each of the parties hereto.
VRBIBfOlB, Plaintiff prays this Honorable Court, after requiring full disclosure
by the Defendant, to equitably divide the property, both real and personal, owned by
the parties hereto as marital property.
COUNT III - ALIIlONY
10. The Plaintiff did not pursue a career outside of the hOMe during the larriage
but instead devoted herself to rearing the children of the parties and laking a good
hOMe for the Defendant and the faMily.
ll. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the Marriage.
I 13. Plaintiff is unable to support herself in accordance with the standard of
!lliVing of the parties established during the Marriage through appropriate eMploYMent.
I 13. The Defendant is eMployed and enjoys a subRtantial inCOMe frOM which he is
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i able to contribute to the support and laintenance of Plaintiff and to pay her aliMOny
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in accordance with the Divorce Code of Pennsylvania.
IHIIBrOlB, Plaintiff prays this Honorable Court to enter an Ord~r awarding PlaiD-
Itiff frOM Defendant perlanent aliMOny in such SUIS as are reasonable aD~ adequate to
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,Iupport and laintain Plaintiff in the station of life to which she has beCOMe
" accustOMed during the Marriage.
coutl'I' IV - ALIlIONY PBNDllN'I'B LI'l'B AND COUN8BL fBBS AND BPala
14. Plaintiff is without sufficient funds to retain counsel to represent her in
tbis Matter,
15. Without competent counsel, Plaintiff cannot adequately prosecute ber claiMs
against Defendant and cannot adequately litigate her rights in this Matter.
16, Plaintiff is without sufficient incoMe to support and Maintain berself during
the pendency of this action.
l7. Defendant enjoys a substantial incoMe and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action and to bear the
expense of Plaintiff's attorney and the expenses of tbis litigation.
VHBlBPOlB, Plaintiff prays this Honorable Court to order Defendant to pay ber
reasonable alimony pendente lite during the pendency of this action and to order
I Defendant to pay the legal fees and expenses incurred by Plaintiff in the litigation of
I this action.
I
I verify that tbe statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of
18 Pa. C.S. 4904 (unsworn falsification to authorities).
l~;t:~~
PAI'IE(A S. WELSH
/ M;v~~ J<1~4
Date
ANDES;.. VAUGHN , BANGS
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Attorney for Plaintiff
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t~1 tHE r.OURT or COMMON Pt,EAS or
Ct.'MtIERLAND COUNTY, PENNSYLVANIA
PAMELA s. WELSH. '---
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~IO , 94-6358 CIVIL TERM
Defendant.
:'!OnON FOR .U'?'H~It:-!E~I! OF ~!AS!ER
(il:~lU:fc) (:lefendant), :noves the court to appo1nt
following claims:
TTO'c::rr1:"l) t'! WTO'TC:~
a ~ster with respect to the
()(J Divorce
( ) Annulment
( ) Ali=lony
( ) Ali=lony ?endente
( X)
( )
( )
( )
Distribution or ?ropert:,
Support
Counsel Fe..
Costs and Expenses
Lice
50
and in support or the ~otion statas:
(1) :li!o,:o'ler? is complete as :0 the daims(s) for '.hieh the
appointment or a ~ast8r is requested.
(2) 'the defendant (has) (K~~X) appeared in
(by his aetorn.y, Robert L. O'Brien
(3) the staturory ground(s) for divorce (is)
Irret.rievable Breakdown
(4) :lelacs :he inapplicable ?aragraph(s):
(a) 'the action is not contested,
(b) _~ agreement has been reached with respect to the
rlOll\4l.
(c) Th~ltCtiOn is contested with respect to the following
(5) The action ("~"-'-'H) (does not involve) complex issues or lav
:he action (personally)
,Esquire) ,
,an)
following claims:
claims:
or fact.
(6) The hearing is expected to take i (~.<.~u) (days).
(i) Additional information, if any, relevant to the motion:
~A"'-L. ~
Attorney for "it~~t)
(Defendant)
\ (.L. d ORDER APPot~T!~G :1AS't'ER
AND NOW ~c. '.,(\ / T ,19ll, r J--':'( 1-:',( L( ((Ie (,/(--.,
is appointad aster ...Jth respect to the following daims:J':;Q C~(LL~__
Daoce:
!lquire ,
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PAMELA S. WELSH,
Plaintiff
)
)
)
)
)
)
)
IN THE COURT or COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-6358 CIVIL TERM
IN DIVORCE
vs
LESTER G. WELSH,
Defendant
ORDER OF COURT
AND NOW, this }J,Odday of ) I'{'-<J ' 1995, upon motion of
the Plaintiff, a hearing is scheduled in this matter for
) nL 3:00 p,m.)
, ) J(.lj(~ ' the...iitt day of . 'pii.y , 1995,.....In Court
Room NO: ~, Cumberland county co6rt House, Carlisle,
Pennsylvania.
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PNtELA S. WELSH, 1 IN THE COURT or COMMON
plaintiff 1 PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs 1
1 CIVIL ACTION - LAW
LESTER G. WELSH, ) NO. 94-6358 CIVIL TERM
Defendant 1 IN DIVORCE
1IOTl0ll FOR _allING 0If REQUEST
FOR ALIIIOIfY PIDIDBN'l'B LITE
AND NOW comes the above-named Plaintiff, by her attorneys,
Andes, Vaughn & Bangs, and moves the Court to schedule a hearing
on her claim for alimony pendente lite, counsel fees, and
expenses, all as raised in Count IV of her complaint in this
matter.
:gUGHN , .AN"
u;;r~.Q;,
Attorney for Plaintiff
I.D. 1117225
..
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PAMELA S. WELSH, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
VI. )
)
LESTER G. WELSH, ) NO. 94 -6358 CIVIL
Defendant )
) IN DIVORCE
fMmfi
, .~ .
Sir:
,-
Please withdraw all economic claims previously filed on behalf of the Plaintiff In the
above-ceptioned matter including the unlimited to claims for equitable distribution, alimony,
alimony pendente lite, counsel fees, and expenses,
&~~
Attorney for Plaintiff
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PAMELA S. WELSH/
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY/ PENNSYLVANIA
NO. 6358 CIVIL 1994
LESTER G, WELSH,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
WAIV.R 0' .OTIC. 0' I.T..TIO. TO RaOU..T ..TRY 0' A
DIVORC. D.CRE. U.D.R 13301(C) 0' TB. DIva.C. COD.
1. I consent to the entry of a final decree in 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 inunediately after i.t 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 subject
to the penalties of 18 Pa,C,S,A. 54904 relating to unsworn
falsification to authorities,
Date: ~~/ /,96 ~~/ --! LA...
~ ~ ~~r'-LESTER G, WELSH
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PAMELA S. WELSH,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6358 CIVIL 1994
CIVIL ACTION-LAW
IN DIVORCE
v.
LESTER G. WELSH,
Defendant
UPIDAVIT OP CO...IIT
1. A complaint in divorce was filed under Section 330l(C) of
the Divorce Code and wae filed on November 9, 1994,
2. The marriage of the plaintiff and defendant h
irretrievably broken and ninety days have elapsed from the date of
the filing the Complaint,
3. I consent to the entry of a final decree in divorce after
service of the notice of intention to request entry of a decree.
Date:
~/// /96'
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LESTER G. WELSH
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PAMELA S. WELSH, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs )
) CIVIL ACTION. LAW
LESTER Q, WELSH )
Defendant ) NO. 94.63S8 CIVIL TERM
) IN DIVORCE
^FFlDA VlT 9F CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 9
November 1994 and was served upon the Defendant on or about 17 November 1994,
2, The marriage ofl'laintitT and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint on
the Defendant.
3, I con$entto the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention
to Request Entry of the Decree,
4, I have been advised of the availability of marriage counseling and understand that the
Court maintains a li"t of marriage counselors llnd that I may requ~stthe Court to require my
spoU$e and I to participate in counseling and, being so advised, do not request that the Court
require that my spouse and I participate in counseling prior to the divorce becoming final,
I verify that the statc:ments made in this Affidavit are true and correct and I understand
that fal$e statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating
to unsworn falsification to authorities,
7, 3>1 () 6
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PAMELA S, WELSH
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PAMEI.A S. WELSH, ) , IN THE COURT OF COMMON
Plaintift' ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
va )
) CIVIL ACTION. LAW
LESTER G. WELSH )
Defendant ) NO, 94-63S8 CIVIL TERM
) IN DIVORCE
W AIYEI\ OF NOTICE OF JNTEJIITIQN TO REQUEST ENTR~
QF A OlVQRCE DECREE UNDER SECTION 330ltcl Q~ THE DIVORCE c;OOE
I, I consent to the entry of a final decree in divorce without notice,
2, I understand that I may lose rights concerning alimony, division of property, lawyer's
feea. or expenses ifl do not claim them before a divorce is granted,
3, I undentand 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,
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PAMELA S, WELSH
Dated:
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SAMUEL 1.. ANDES
ATTORNI!Y AT LAW
5li11a NORTH TWaLPTH IIT..IiT
P. O. BOX 168
LBNOYNK, PENNSYLVANIA 17043
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('1') NI.1IMl
9 October 1996
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E. Robett Elicker II, Master
Office of the Divorce master
9 North 1-1l1llover Street
Carlisle, PA 17013
RE: Welsh
Dear Mr. Elicker:
The transcript of the agreement is satisfactory with my client, Please circulate it
for signature by all parties.
I am sending a copy of this letter to Rob O'Brien, to remind him that he is to
prepare a deed, note, and mortgage so that we can execute those contemporaneously with
the settlement agreement and other documents necessary to conclude the divorce.
Thank you for your cooperation,
Sincerely,
2JL-
Samuel L. Andes
amr
Enclosure
cc: Rob O'Brim, Esquire
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SAMUEL L. ANDJ,;S
ATTOUNKV AT LAW
.,,,., HUNTH TwaLrrll .TN._"
V,O, BOX 18U
LBNOYNB, PBNNHVLVANJA 1104:'
CC(Q)rPY
TlLI,IIQNI
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31 July 1996
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Lawrence E. Welker, Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle. PA 17013
RE: Pamela Welsh vs. Lester Welsh
No. 94-6358 Civil Term
Dear Sir:
Enclosed for filing in the above case are the Plaintiff's Affidavit of Consent
and Waiver of Notice. Thank you.
Sincerely,
Samuel L. Andes
Ie
Enclosure
cc: E. Robert Elicker, II, Esquire /
Robert L. O'Brien, Esquire
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PAMELA S. WELSH,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
LESTER G. WELSH,
DEFENDANT
PAMELA S. WELSH,
PLAINTIFF
442 SUPPORT 1995
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
LESTER G. WELSH,
DEFENDANT
94-6358 CIVIL TERM
O"DER OF COURI
AND NOW, thIs U day of June, 1995, following a combined hearing on
the Il8ues of child support and alimony pendente lite on the above-captJoned cas.,
IT IS ORDERED:
(1) Lester G. Welsh shall pay alimony pendente lite to Pamela S. Welsh In the
amount of $46 per week.
(2) Lester G. Welsh shall pay child support to Pamela S. Welsh tor the support
of their children, April, bom August 15, 1981, Joshua, born July 3, 1984, and David,
bom June 2, 1988, In the amount of $104 per week.
(3) Both orders shall be effective April 25, 1995,
(4) Lester G. Welsh shall receive credit on his child support obligation In the
amount of $100 per week tor his private payments to Pamela S, Welsh between April
25, 1llG5 and May 24, 1995. He shall receive a credit tor his $104 per week private
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paymentlelnee May 24 on hie child eupport obligation, and a credit of $19 per week
for hie private paymenw elnee May 24 on hie alimony pendente lite obligation.
Edgar B. Bayley,
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Samuel L, And.., Eaqulre
For Plaintiff _ e.I..... ('N; ~1. 4./:18/9.5'.
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Robert L. O'Brien, Esquire
For Defendant
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O'BRIEN, BARIC" SCHERER
17 Welt South Strut
Car/ille. Penmylvania 170 I J
Steven J. F/,"",an
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Rob,,, L. O'Brien
David A. Baric
Michael A. Sch""
(717) 149.687 J
FAX (717) 149.$7$$
November 1~, 1995
Samuel L. Andes, Esquire
S2S North 12th street
Lemoyne, Pennsylvania 1704~
RE: Welsh v. Welsh
Dear Sam:
Enclosed please find a copy of the Interroqatorie.
which Mr. Welsh has completed and siqned.
Very truly yours,
O'BRIEN, BARIC & SCHERER
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Robert L, O'Brien, Esquire
RLO/au
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cc: E. Robert Elicker, Divorce Master ~
(w/copy of Interrogatories)
File
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SAMlJEL L, ANDES
ATTOHNtlY AT LAW
"''''''' HUNTH 'tWlll.nll MTH"KT
P,O. nox lOll
LIlMOYNI!:, PIlNNSYLVANJA 17043
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to November 1995
E. Robert Eli~ker, 11, Esquire
Divor~e Master
9 North Hanover Street
Carlisle, PA 17013
RE: Welsh vs Welsh
Dear Mr. Elicker:
The above matter is scheduled for a pre-hearing conferen~e in your om~e Monday
morning. When you scheduled that conference, back in September, you directed Mr.
Welsh to file Answers to my Interrogatories at least ten days before the conference and
you told counsel, at that time, that the conference would not be held until the
Interrogatory Answers were filed,
I have not received any Answers to those Interrogatories and must, therefore,
request that you cancel the pre-trial conference until the Answers are provided to me.
Those Interrogatories were sen"d in late March and Mr. Welsh and his attorney have had
seven months to answer them, . rtainly feel that is adequate time,
Unless I hear from you to the contrary, I will assume the pre-trial conference is
canceled and will not appear Monday morning, Thank you for your consideration.
Sincerely,
fJ C3. nluJ_
Samuel L. Andes
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cc: Robert L, O'Brien, Esquire
Law OllletJ
O'BRIEN, BARIC. SCHERER
17 W,SI Soulh 5',,,,
Ca,lIsi,. P,nnsylvanla 17013
SlfvI" J. Flsllma"
01 CowuII
Rob", I.. O'B,II"
David A. Ba,le
Mlellad A. Sell""
(717) 149.6873
FAX (717) 149.575$
August 9, 1995
Robert Elicker, Esquire
Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
RE: Wel~h v. Welsh
Dear Mr. Elicker:
Enclosed find the pre-hearing statement relative to the above.captioned matter.
Very truly yours,
O'BRIEN. BARIC & SCHERER
l{(f)/J..udJ;: Mr?iUrJ / ~
Robert L. O'Brien, Esquire
RLO/jc
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cc: Samuel Andes, Esq. w/Enc.
File
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on June 26, 1995. At the time of the hearing, Mr, Welsh had been
forced to leave the job he had been employed at for the past
employer.
Shortly after he left his prior job with Component
;, Building Systems, Inc., the company filed a bankruptcy,
I I . ASSETS
The parties allsets cons 1st of the equity in the marital home,
the homes furnishings, the husband's pension which had slightly
i over $1,000.00 as well as small amounts in the parties bank
accounts and equity in their respective automobiles, Attached is
a copy of the deed to the parties property as well as an inventory I
of the furnishings at the parties home. Husband claims as a non-
I marital asset a Jeep motor vehicle which he purchased after the
parties separation and which is curr~ntly financed,
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III, LIABILITIES
The parties primary liability is the mortgage against the I
home, In addition there were credit card accounts that were paid
by the respective parties subsequent to the separation which are
still being paid off.
IV, EXPERTS
Defendant does not intend to call an expert in the event the
parties can agree on a value for the home,
V. WITNESSES
The defendant does not intend to call any witnesses.
Household Child Houllhold Child
W..k Week Month Month
EXPENSES
Home
Mortgage/Rsnt ........................................ $ $ $ $
Malntenanc. ........................................... $ $ $ $
UtlllUes (hllsphons, heating
.Iectrlc, etc.) ........................................ $ $ $ $
Employment (trsnsportstlon,
lunches) .....................,......................... $ $ $ $
Taxes
Resl Estste .............................................. $ $ $ $
P.rsonal Property................."..........."... $.--.-. L $ /3',0 $
Income ..................................................... $ , $ $
Insurance
Homeowners ...............,........................... $__ $ $ $
Automobile .....................................,........ $ $ $ ~c".... $
Llfe/Acclden: 'Health '..,..........""............ $ $ , //6 4~ $
Other ,....................................................... $ $ $ $
Automobile (payments, fuel, 3,....?c7 I!)O
repairs) '.......... ...........,..... ......,....... ....... $ $ $ ,.
M.dlcal
Ooctor, Oentlst, Orthodontist ................ $ $ $ $
Hospital................................................... $ $ $ $
Special (glasses, braces. etc.) ............... $ $ $ $
Education
Prlvat., Parochial School...................... $ $ $ $
COlleg. ..................................................... $ $ $ ,
P.rsonal
Clothing ,.................................................. $ ~-,(..,...~ $ , ,.<r.O~ ,
Food ......................................................... $ .Jl".' ..... , -jCJ OC-' , h)(l..~o $ ,.,:)<?6, c;CI
Oth.r (hou"hold supplies, , ..$1:?' .%'
bsrber, etc.) ................"........................ $ $ $ J..t1 00
Cr.dlt payments and loans .................... , , ,dt1O ,;0 $
Miscellaneous
Houlehold help/child care ..................... $ , , $
Entertainment (Inc. pspers,
bOOkS. vacation. pay TV, etc.) ............ $ , S $
Giftl/Charltable contributions .........,.... , S , $
Lega' Fees ............................................... S S , ,
Other child lupport/sllmony
payments ............................................. , , , $ y;l? c~
Oth.r (Ip.clfy) ............................................... , , , $
Total Expenses ............................................. , 30, 00 , S C;:1 cO $ 87i'O 0..< $ .d'~c. CO
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OAAY L. HlNTZER and VICKIE A. HENTZER. hi. wif., of R.R.'4.
N.wvill., C~b.rland County. F.nn.yly.nia
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WITHISSlTH. thotl. co.dd...llo. 01 Forty-nin. ThouOlnd Nino lIundnd ond no/100
($49 ,900.00) ---------------------------------------..---------------- Dollen,
1ft h.,u' ,old, th. rlcel,t wh.re.' II hereby acknowl.dg.d, the lold g,onlo,. 40 he,."" .,.". 0,,11
...voy 10 th. ..Id I".'''. . thoir hoir. and aOliln..
ALL THAT CERTAIN tra.t of land .ituat. in W.ot Fonn.boro Townohip. Cumb.rland
Couoty. F.nnoyly.nh, bouu....d and du.ribtd u followl!
BECINNING at a point at the w.otorn right-of-way lino of Town.hip
Rout. T-436 at tho point of intor...tion b.twoon Lot. No. 6 and 7
on the h.r.inaft.r montion.d plan of lot.; thoneo .lona .aid diyid-
ina Un. North fifty-four ('4) d'art.. thirty (30) minutu ...0-(0)
.ocond. t..t two hundr.d forty-.ix and forty-fiya hundradth. (246,4')
flit to . point; than.. alona other lando now or fonaorly of 'r.... G, ,
Chlltnut. .t ux., South thirty-two (32) d'anOl fHtun (15) minutu
fifty-thr.. ('3) a..ond. I..t on. hundr.d .i~lty and tw.nty-nina
hundr.dtha (180.29) foot to a point; thon.a alon8 the diuidina line
botw..n Lot. no. , .nd 6 on tho hareinaft.. montiun.d plln. South
fifty-four ('4) d.,ro.. thirty (30) minut.. ..ro (0) ...on.... Waat
two hundred thirty-.ix .nd tw.nty-.i,ht hundr.dthl (236,28) f..t to
. point in ..id Town.hip Road T-436; th.n.. within the riaht-of-wlY
of ..id T-436. North thirty-five (3') dlar... thirty (30) minut.. ..ro
(0) a..onda w..c onl hundr.d oiahty (180,00) f..c Co a poinc, tho pll..
of BEGINNINO.
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CONTAININO .894 a.ro.
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BEINO LOT NO, 6 of the lubdivition plln for Fred O. Chutnut 01.-
r..ordod in Cumborllnd County Flan look 38 Faao 36.
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BEINO tho .amo tra.t of land arant.d and .ony.y.d by Fr.d O. Ch..tnut
and Ruth L. Ch..cnut, hia wif., by do.d dac.d July 18, 1980 r.cordad
in ~UIIlb.r1and ~ounty Dud 800k "A", Volume 29, Paao 498, unto Cary
L: Honu.r, one of tho Granton h.nin namod. _ A... L' __
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1006 29 IA~( 506
MELA I, WELIH. ) IN THE COURT or COtlHON
Plaintiff ) PLEAI OP CUMBERLAND
) COUNTY, PENNSYLVANIA
v.. )
) CIVIL ACTION - LAW
)
EITEl G. WBLIH, ) NO, 94-6358 CIVIL TBIM
Defendant )
PLAIftIPP'1 PU-ftIAL B'A'rI!IOIIft'
AND MOl cosea the above-naaed Plalntif!, by her attorney, Sa.uel L, Andes, and
u~lt. the fOllowing Pre-Trial Stateaent pursuant to Pa. I,C.P. 1930,33(b):
1. ABB!!B. Attached hereto and aarked as Schedule A and Schedule B are charts
listing the .arltal and non-aarltal assets of the parties as they are presently known
o the Plainti ff.
3, IIPII' WITNBBBBB. Unless the parties can agree upon either the value or the
I.posltlon of the .arltal residence, Plaintiff will have a real estate appraiser
estify to it. value,
I Unless the parties can agree upon the value or disposition of the household
ifurniShlngS and other tangible personal property, Plaintiff will have an expert testify
~. to the value of those ltels.
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I 3. 1m llIftlIIBBB8. At the present tiae, Plaintiff intends to call only heraeIf
I !to teatify. !f Defendant, however, clal.s that his earning capacity is only that of
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Ibis pre.ent e.ploy.ent, she reserves the right to call Defendant's present e.ployer,
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~i. for..r e~loyer. and such other witnesses as say be necessary to establish his
~ctud earning capacity.
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Ii 4. DRIII'f8. Other tban Incose tax returns. title docu.ents, and bank stat...nts
,
'laid the like, Plaintiff anticipates no exhibits at the hearing. She re.erves the
I
I'
I',
I,
ight. howpver, to offer such exhibits as .ay be required to rebut any evidence offered
y the Defendant,
~. INCOKB, Attached hereto is an earnings report fr~ Plaintiff's e.ployer
her gross earnings and all deductions through late June, 199~.
6. BlPBNSBB. Attached hereto is a listing of Plaintitf's current living
7, lBrIIBMBNr 88NIPITS. Plaintitt believes that Detendant has liquidated his
etire.ent plan with his tor.er e.ployer. C~ponent Building Systels, Inc., and expects
o receive intorlation about that trol Detendant or his attorney. If that inforlation
s not adequate to value Husband's interest in that plan, additional intorsation will
e necessary. through discovery, and an expert witness IdY be necessary to establish
he benetit's value. Plaintitt believes, however, that the intor_ation will be
8. COUNSEL 'kBS. Plaintitt has incurred counsel tees at the present tile ot
pproxi.ately $2,070.00 and expects that counsel tees, through the laster's
roceedings, will be another $1,~00.00. Those tees are cbarged at the rate ot $1~0.00
9.
'BlllCllAL PlO'Bln.
To Plaintitf's knowledge, there will not be a dispute
bout the division or valuation of larital property. If tbere is. she proposes that
be parties bave the itels appraised so that tbe laster can assist thel in diViding
10, NlIltAL @IIIl. At the tile ot separation, the debts owed by the parties. in
to the car loan and IOrtgage were the following:
Sears credit card
$1.000.00
$60.00
II
II
II
Bon-Ton credit card
2
Wardl credit card
$2,000.00
$400.00
$800.00
Coreltates Vila
Cboice Visa
Bunoco credit card
Unknown
Dr, Conner (for
cbildren's braces)
$100,00
Various bospital and
doctor billa
$400.00
11, .IDIOIID IIIOLU!IQN. Plaintiff proposes tbat the residence be transferred to
er 10 tbat Ibe .ay .aintain it aa a b~e for the parties' cbildren and that Defendant
ay ali.ony to Plaintiff in accordance with bis earning capacity,
B~~Q~
uel 1,. Andes
Attorney for Plaintiff
3
mIIP.!!l!I A = LIB' or IlAaI'AL A8811'l'l1
Date of Non-Kad tal
t Value Valuation Portion Lien.
esi4ence at $7!i,OOO.00 8/9!i None Kortgage to
1 Hilltop Lane, (e.t.) Keri4ian Bank
ewville, West ('U,OOO.OO
enn.boro TOWDShip. balance approx.)
uaberlan4 County
f
Ii u.ban4's interest Unknown NIA None None bOWD
I, in a retire.ent plan
,
i- r .i.Uar asset
" i th COIIponent
I
uil4inC] Syste.s, tnc.
aVings Account at $900.00 !i/93 None None bOWD
u.en Truat Co.
o a.all account a at Unknown NIA None None bOWD
e~ers first Cre4it
uion. for.erly DArcu
988 Mercury Topaz Unknown NIA None None bom
utOllObUe
990 Chevrolet Cavalier $6.000.00 !i/93 None $2.300,00 owa4
utOllObUe (est. ) to DAPCU
beellaneoua ite.. $2,000,00 8/9!i None None IoOWD
f houlehold (est. )
urnhhinga and
aogible per.onal
roperty
II
ICIIIlDULII I = llU Qf. JIQIHIu"AL PlOpa"
~
Date of
Valuation
Itiw.
.1, .avin9s bond. held by the
arti.. for their .inor children
$2.000.00
8/95
None known
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co. mE IllPJ, CLoCK lIelln NO,
HTV 001629 002 ??oo9100.6
MEMBERS 1ST FEDERAl. CREDIT UNION
5:/75 E, TRINOtE ROAD
MECHANICSBURG, PENNSYLVANIA '7055
Social S.C:Uflly Numb., I 9!HS4 - 14"6
TtlMftbl. Mlllllnt Slnlul Slnole
E Ilc"lIpllona IAlto'h nnee,
F.d.,,\! 3
6ttll.
Ll)cnl :\
E.rnlnao f.l. hour.
R'gulat 7 3558 77 ,00
Aelro
Vae 7, 3558 3,00
OVfllIme
SIck
OlducUono
-,
Ih.!..~
566 40
~5 62
22,07
Ora.. Pl1V
,,.,14 .no
51.tutorv
Federal IncolTl/l TSM
Soclsl Securlly Ta)(
Medlcar. TalC
PA Slale Income Tax
Mechenlcabur Income T B>t
PA SUI/SO, Tax
.2344
,lJ 77
.7 90
"7,19
,6,14
.068
Volunt.rv
8el8.
Saving
NI' PlY
.69,36-
,455 61
'0.00
V'" 10 d.11
6,978,40
26,62
207,57
2' ,01
127,75
7 1t-n 111j
316,34
443,87
103,81
206,08
73,61
8,10
201,12
Excluded r,om f,der.I' ....blt wig..
Your lec1ersl taxable wage! Ihls period are $544.73
MEMBERS I sr _EOERAL CREOlr UN'ON
5275 E, TRINDl.E BOACI
MECHANIGSRUnO, PENNSYLVANIA 17055
!l!22.ll1'~ 1.lnl ....unl of ,.
PAMI!UIS, WelSH "..!',\\
1 ~) i{
V'::; '",\ I!",
~ \\\5:' " 'J
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Earnings Statement
/,(1J)
o
Period Ending:
paV Dale,
00/16/95
0ll1231'l5
PAMELA S, WELSH
11 HILLTOP LANE
NEWVILLE PA 17241
Othor B.n.lllo ond
In'ormellon
Sick
Vae
'hi. p.rlod totll 10 dl'l
79,50
69,60
Import."t Not..
YulJR HUUHL'" ~All: HAS ElEI~N C~I"'~(.E[) 'ROM 7.0000 TO
7.3MB
Advlc. numb.r:
.\"iC \"
c::,~~CCq~.I.~m~
134997000
000002~OO 15
06123/95
"e.oll'IIBII
2313 8224
.mount
$<55 61
NON-NEGOTIABLE
EXPENSES
~'.. .~
Household
Week
~ l.. ..: ;.;...1 " ..' :~.
Home
Mortgage/Rent ..........................,............. $
Malntena",ce ............................................ . $
UlIlltJee (telephone, heating ..' '1 . ~ ' " ,>' , .
electric, etc.).........................:.~:.l....:.:;.~ .1$ " ,.'.r. " , $
Employment (transportation:""" ,\]" II, ".""';0 .::'~;'
': I "'h' "')"~'1"'-1 .' to' '; '~l' <f' ;1,' $'1"-\'"1'
unc .. ...............................................
Taxes
Resl Eetate .............................................. $
Personal Property................................... $
Income ..................................................... S
InSUi."ce" -~_... ,- -, ..
Homeowner.' :...:....:.....::.::..;'..:................ - $' ,
Auiomoblle ..~.............:..:.:.~:~...-.~:.:~....~......' s
Llfe/Acc:id'enIlHealth '..::::.:.....:................ $
Other ........................................................ $
Automobile (payment'. fuel,
rspalrs) ..........I:i~~...f!.1-&!.~F.... $
Medical
DOctor, Dentist, Orthodontist................ $
Hospital................................................... $ _
Special (glasses, braces, etc.) ............... $
Education
Private, Parochial School....................... $
College .:................................................... $
Pereonal,,"
Clothing ...................................................
Food .........................................................
Other (household eupplles.
barber, etc.) ...:.......................:..............
Credit paymentssnd loans ....................
Miscellaneous
Household help/child care .....................
Entertainment (Inc. papers,
books, vacation, pay TV. etc.) ............
Gifts/Charitable contributions ..............
Legal Fees ...............................................
Other child support/alimony
payments .....,.......................................
Other (apeclfy) u.;.~J""~.~..tll'lbl..*'..
e...+> .J.,~"" r'
Total Expenses ...........,.,...............................
.. $
$
$
$,
$
$
.,. $
$
$
'" $
, '
$ $
$_'--:" " $
..,; - 0"
$ $
$ $
$ $
$ - $
$' S
$ S
$ S
, $
, $
Child
Week
s
s
"l.
," ;"
,
,
,
Household
Month
Child
Month
s ~.'7 S. IX)
s "'0. OV
$ 35'-
, 4S
,
S 2~S:Ol) , l{per
! ,
s
-",
,
...;,', ,1,. :
$ IV' :\\ ~ $
S $
$ - $
.
.~.
: '~~: .d.,
$ 12;00'" ,.-
$ , , '
/zioo, ,C(2.
$
, ,'.
.';'" . , _'1:- , "-
$ "
$ $
$ $
S 3..Bo. IX> , 3 oz>. DD
s 4t1~.oi) , 30D.1>>
l6'o~ OIJ f
S $ /20
$ BO.oD, $ ,-
, -- $
S -LOt'). DO $~
, roD. DO ,_!'D
$ ,
S ,
,~ , / 4-0.00
s 2-'1 2f.00 $ '21'72
r
IJl S ~
~ ~ e ;
~~i~~
...l lo ~ III
"" ~. ~
[I.l III ~ r.I bol
~ 0 100 ~ Co.
J:S~ ~
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,
, PAMELA S. WELSH.
, Plaintiff
IN THE COURT Of COMMON
PLEAS Of CUMBERLAND
COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-6358 CIVIL TERM
IN DIVORCE
vs.
: LESTIIR G. WELSH.
Defendant
II
,
PLAINTIff'S IN'l'BUOGATORIIl8 TO DllfllNDAlft'
TO:
Robert L. 0' Brlen. Esquir~
17 West South 3treet
Carlisle. PA 17013
Counsel for Detendant
PLEASE 'rAKE NOTICE that you ue required. pursuant to Pa. R.C.P. 4005 and 4006, to
tile the original with the Court and serve a copy on the undersigned, of your Answers
to the wlthin Int~rrogatorle8 within thirty (30) days after service of same. Each
Interrogatory shall be answer.ed fully and completely. in writing and under oath. If
there lfi Insutticlent space to answer an interrogatory. the remainder of the answer
shall tollow on a supplemental sheet.
Th~s" Interrogatories shall be continuing in nature. It. at any time subsequent
to the liling of your orlginal answers, you or anyone actlng on your behalf should
learn or be made aware ot additional information requested but not contained in your
original answers, then you shall promptly file a Supplemental Answer containing the
same.
DATE: J7 March 1995
ANDES. VAUGHN & BANGS
~.~ A:de~
Attorney for Plaintiff
ANDES. VAUGHN & BANGS
Post Office Box 1~8
Lemoyne. PA 17043
(717) 761-5361
I .-r . ..,. . .
i,1 ,
, I .
IP I
II
11
I:
,
,
INSTRUCTIONS AND DEFINITIONS
The following Instructions and Definitions form an integral part of these
I Interrogatories. and the Interrogatories are to be read and answered in accordance with
these Instructions and Definitions.
1. DOCUKBNT The term "document." means any written. printed, typed. or other
il
graphic matter of any kind or nature, however produced or reproduced. whether sent or
received or neither. including drafts and copies bearing notations or marks not found
on the original. and Includes. but. is not limited to:
(a) All cont racts. ilgreements. representaUons. wilrrantles. certificates.
opinions;
(b) All letters or other forms of correspondence or communication. including
envelopes. notes. telegrams, cilbles. telex messages, messages (inCluding reports,
notes. notations. and memorilnda of or relatlnq to telephone conversations or
conferences);
(cl All memoranda. reports. financial stiltements or reports. notes. transcripts.
tabulations. studies, analyses, evaluations, projections. work papers, corporate
records or copies thereof. lists. comparisons, questionnaires. surveys. charts. graphs,
'summaries. extracts. statistical records, compilations;
(d) All desk calendars, appointment books. diaries;
(e) All books. articles, press releases. magazines. newspapers. booklets,
: circulars. bulletins, notices, instruct.ions. manuals;
(f) All minutes or. transcripts of all meetings; and
(g) All photographs, Inicrofilms. phonographs. tapes or other records, punch
cards. magnetic tapes, disks, oatilceLls. flrums. printouts, and other data compilations
from which information can be obtained,
II. COfOOlMICATION
The term "commllnicat Ion" means not only oral cOlnmunications,
representations. or warranties, but also any documents (as slIch term is defined in
,Section I above), whether or not stich document or the information contained tberein vas
"
transmitted by its author to any other person.
.,., .
..,..
..
..
I:
"
III. IDBNTIFY: IDBNTITY: IDENTIFICATION When used in reference to a natural
person. the terms "identify", "identity", or "identification", mean provide the
following:
(a) Full name;
(b) Present or last known business and residence addresses;
(c) Present or last known business affiliation: and
(d) Present or last known business position (including Job functions. duties. and
responsibilities) .
Wh~n used with reference to any entity other than a natural person state:
(a) Its full name;
(b) The address ot its principal place of business;
(c) The Identity of all individuals who acted and/or who authorized another to
act on its behalt 1n connection with the matters referred to;
(dl In the case of a corporation. the names ot Its directors and principal
oft Icers; and
(e) In the case of an entity other than a corporation. the identlties of its
partners or princlpals or all individuals who acted or who authorized another to act on
its behalf in connection with the matters referred to.
'When used In reference to a document, the terms "Identify", "identity". or "identifica-
'I tion" mean prov ide the fo llow ing:
(al The nature ot the document (e.q. letter, contract, memorandum) and any other
, information (i.e. its title, index. or tile number) which would facilitate in the
, identification thereof;
(b) Its date of preparation;
(c) Ita present. location ,Inll the identity (as defined previOUSly herein) of its
! present custodian or. it its present location and custodian are not known. a descrip-
tion of Its last known disposition;
I (d) Its subject matter and substance or, in lieu thereof. annex a legible copy of
the document to the answers ot these Interrogatories:
,I
::
" .
....
.'
~
,
,
"
;1
(e) The identity (as definl"! previously herein) of each person who perforllled any
,! function or had any rol~ in connection thereof (i.e. author, contributor of infor..-
: tion, recipient, etc.) or who haM any knowLedge, thereof together with a description of
leach such person's function, roLe, or knowledge; and
,
(f) If the document has been destroyed or is otherwise no longer in existence or
, cannot be found, the reason why such document no longer exists, the identity (as
'I' defined previously hereIn) of the people responsibLe tor the document no longer being
in existence and of its Last custodian.
I'When used in connection with an oral communication, the terms .identify-, -identity. or
-identification- mean provide the tollowing intormation:
(a) GeneraL nature (i.e. conterence, telephonic communication, etc,);
(b) The time and pLace of its occurrence;
(c) Its subject matter and substance;
(d)
" funct ion
together
The identity (as defined previousLy herein) of each person who performed any
or had any roLe in connection therewith or who has any knowLedge thereot
with a descriptIon of each such person's function, role, or knowLedge;
(e) The ident i t Y (as def ined prev iOlls I y here in) of each document which refers
thereto or w~ich was IIsed, referenced to, or prepared in the cOllrse or as a result
thereot; and
IV. DI!SCl.lBE; DESCRIPTION When IIsed wi th respect. to any act, action,
',accounting, activity, audit, practice. process, occurrence, occasion. course of con-
'duct, happening, ne~otiation. reLationship, scheme, transaction, instance, incident or
1
'event. the terms -describe- or -description- mean provide the tOllowing information:
(al Its qeneral nature;
(b) The time and place thereof;
(c) A chronoLcgicaL account setting forth each element thereot, what su~h ele.ent
: consisted of, and what transpired as part thereOf;
(d)
function
together
The identity (as defined previOUSly herein) of each person who performed
or had any role in connection therewith or who has any knowledge thereof
with a description of each such person's function. roLe, or knowledge;
any
(e) The identity (as defined previousLy herein) ot each document which refers
: thereto or which was used, referenced to, or prepared in the course or as a result
thereot; and
J#It
....
. .
.
i
,
(f) The identity (as liefined prllviously herein) of each oral comunication which
,Iwas a part thereof or referenc~d thereto.
"
"
"When used in connectlon with dny calculation or computation. the terms "describe" or
:i
'I "description" mean provide t.he fo11owin'1 intormation:
(a) An explanation of its meaning;
(b) An explanation of the manner i~ which it was derived:
(e) The identity (as defined previously herein) of each person who performed any
: function with respect thereto and d description of his function;
(d) The identity of each rlocument (as defined previously herein) which refers
, thereto or which was used, referenced to. or prepared in the course or as a result
thereof: and
(e) The ident.\ty (as defined prevlously herein) of each oral communication which
occurred in the course of the preparation thereof or which referred thereto.
V. PACTUAL BASIS Thll term "factual basis" means:
(al Set forth each item of information upon which the allegation, contention.
,claim, or demand to which it pertains is based; and
(b)
knowledge
thereof.
With respect to each such ltem at information, identify each person having
thereof and identity and lies(:ribe (as defined previously herein) each source
VI. RELATES TO: THBRETO The terms "relates to", "relating to", or "thereto"
when used in connection with any act, action, activity, account, practice. process,
occurrence, occaSlon, course of conduct, contractual provision or document, happening.
relationship, scheme, conference, discussion, development, service, instance, incident.
event, means used or occurring or referred to in the preparation therefor, or in the
course thereof, or as a consequence thereot. or refer[ing thereto.
VB. PElSON The term "person" means all natural persons, corporations,
partnerships, or other business associations, public authorities, municipal
corporations, state qovllrnments, local governments. all governmental bodies, and all
'other legal entities.
"
,
50 Please state whether there have been any prior legal
proceedings between yen and your spouse of any nature or between
you and any other person involving y01r spouse or any members
of yaur household ar yenr spouse's h01sehold. If there were any
prior legal proceedings, please utate, for each such proceeding',
the following'l
,
Iii
1
"
r
.
:11,
h
"
<,
,
"
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~,
-~'I
f'"
~
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.
'4'
A.
C01rt or
term and
,'I'he date the action was cc:mmenced, the
c01rts in which it' was caMIenced, and the
doc~et number of such action:
B. 'I'he names and addresses of attorneys for
eac!'1 party:
c. 'I'he result of each proceeding and the
present status of each proceeding.
Not Applicable.
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6. If you have been married previously, please state, as
to each marriage, the following:
A. The date and place of the marriage.
B. The name of your former spouse.
c. The names, dates of birth, and present
addresses of any children born of that marriage.
D. The name and address of any person having
custody of any dependent chi~ren of r~at prior
marriage.
f
E. How that marriage ended and the date,
place, or reason for its dissolution or termination.
F. The terms of any agreement or order of
court requiring you to provide financial assistance
of any kind toyour former spouse or any other
person as a result of the marriage. If there is
an order of court or a property settlement agree-
ment or any other writing which specifies duties
and obligations, or outlines the marital property
gettlement, as a result of that marriage and
its termination, please attach a copy.
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Not Applicable,
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b. If you are self-employed or conduct a business or
profession as a sole proprietor, partner, or corporation; plea..
provide the following:
A. A description of the type of business and
a description of the nature of the services performed,
the goods sold, or the business conducted.
B. The name, address, and telephone number of
all business offices and locations for such business.
C. If it is,. partnership, please list the names
and home residence addresses of all partners or owners
of any interest in the business and the extent of
their ownership and the extent of their voting control
of the partnership. please identi~y whether any of
the persons so listed are related to you, by blood
or by marriage, and, if so, how they are so related.
O. If the business is . corporation, please
identify all the officers, directox's, and stoCKholders
of the corporation, including any person or persons
who own any option to acquire stocK, and identify
the extent of their stock holdings in the corporation
and, if any of those persons are related to you by
blood or by marriage, please identify the persons
related and state how they are so related.
E. Please state the length of time the business
has been in effect and please identify the date or
dates in which you acquired any interest in the
business and please state the nature and extent of
the interest you acquired on each such date.
F. Please identify the person or entity who
is the custodian of the records of the business,
giving their business name, address, and telephone
number and identify how long such person or entity
has perfo~ed services as custodian of the records.
G. Please state whether or not the business's
current records are now in possession of the person
or entity identified in your answer to sub-paragraph
F hereof.
H. please identify the person or entity who
has prepared federal income tax return! for the
business for each of the preceding five years.
.
I. Please furnish copies ol the federal income
tax returns for the business lor the precedinq five
years and attach them hereto.
J. ,Please state whether or not any financial
statements, balance sheets, income statements, or
the like have been prepared by at for the business
at any time durinq the preceding three years and,
if they have, please attach copies hereto. If there
are no copies in your possessic:n or which you can
readily obtain, please state who has copies of such
records currently in their possession.
K. Please list all assets, includinq real
estate and inventory belonging to the business,
accounts receivable, and other tangible and :l.ntan-
qible assets of the business, giving their date
of acquisition, the value or 'cost at acquisition,
their present market value, and their present
location, for all assets owned by the business.
L. Please state your weekly gross income
or draw fran the business, including all compen-
sation in the fatm of wages, salory, earnings,
interest payments, and the like, and all other
sums of money paid to you by the said business,
including a description of the feder.al, state,
local. or any other taxes or other amounts withheld
or deducted from such paycheck, if any such amounts
are withheld or deducted.
Not Applicable,
.,
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lO. Please state and desc~ibe any other benefits, compen-
sations, services, or the like which you receive from, as' a
result of, or, incident to your employment, including but not
limited to, contributions to any pension, profit-sharing, or
other employee or employment benefit plan, the provision to
you of an automobile or the payment of travel expenses or allow-
ances, by your employer or anyone else, free meals or reimbursement
for meals, re~ursement of entertainment expenses or payment
of same, re~u~sement for lodgin~ or payment of same, medical,
dental or hospital insurance or insurances, life inourance,
,
disability insurance or disability or sick pay, vacation pay,
paid holidays, legal services benefits, or the like. For each,
state the particular details of such benefits and state the
value of such benefits to you, in cash value, if known.
Lump sum payment of $1,253,00 for retirement from
Compnent Building Systems,
.
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13' Please provide the name, business address, and ~elephone
number, and a description of any relationship they have to you,
for each of the following which you have retained, hired, or
used th~services of at any time during the five years preceding
these Interrogabories:
A. Attorney.
B. Accountant.
C. Stockbroker.
D. Investment counselor~
E. A brief description of the services which
each of the persons listed in your answers to the
preceding sub-paragraphs provided for you and the
date or dates during which the provided those services
to you.
A. Robert L, O'Brien, Esquire
Attorney representing me in divorce proceeding
from May, 1993 to present.
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14. please state Whether you are owed any money by any
person, firm, business, corporation, or entity Which has 'not
already been disclosed in your answers to the preceding Inter-
rogatories. This question specifically and expressly includes
any "bearer bonds" or other debts owed to the holder or bearer
of the document evidencing the indebtedness of which you are
now the owner or possessor or in Which you have any right
or claim to ownership or control. Also please state whether
you have been owed any money or funds or have been the owner
or controller or holder of any such debts or items Clot any
time during the three years preceding this date. For each
such debt or item, please state the following:
A. A description of the debt or item and
the llII\ount currently awed to you.
B. The person or entity owing the debt to
you.
c. The current market value of any such
debt. if there is a regular market for such items.
D. The date you first were owed any money
by such person or entity or first acquired any
interest in or control over any indebtedness or
cbligation by them or it, the person fran Whan you
obtained it and the consideration you paid for
it or the asset or money you transferred for it
and the basis for this person or entity owing you.
t. Whether or not you have ever transferren,
given, sold, or otherwise disposed of any of the
items listed in your answers hereto and, if so
the name and address of the person or persons,
or entity to Whan you made llUch transfer, the
date you made such transfer, and the consideration
or price for Which you made such transfer.
Not Applicable.
. .
1~. Identify any automobile, motor vehicle, trailer,
camper, mobile home, motorcycle, boat, aircraft, or vehicle
of any nature that you a.m now, have an interest in, ar have
owned or had an interest in at any time during the past three
years. For each. please state:
A. The manufacturer's name, the model
number or identification, and the year of manu-
facturer.
B. The date acquired and the price or
consideration paid or promised to be paid there-
fore and the reasonable value at acquisition.
C. If such item has been transferred by
you, the date of such transfer and the name,
address, and relationship, if any, to you,
the price or consideration paid or received
therefore, and the reasonable market value of
such it (It\ at the date of such trans fer.
O. The present location of such item.
F. The present market value of such item.
F. The name, address, and relationship
to you, if any, of a co-owner. encumbrance
holder. or interest holder in such item, and
the extent of their cwnership interest or encum-
brance interest.
Sold-1990 Chevrolet Cavoleve
1989 Mercury Topaz. 11 Hilltop Lane, Newville, $2,000.00
1987 Jeep Cherokee, 260 Mt, Rock Road, Newville, $4,000.00
lij. If you have transferred any real estate, or any interest
in or claim to any real est~te, at any time during the pendency
of this action or at any time during the three years immediately
preceding the filing of this action, please state:
A. The location and identity of the property,
including the recording reference for any document
or documents whiah ;created or describe your interest
therein.
B. The date you first acquired any interest
in such real estate.
C. T~e date you transferred any interest in
such real estate.
D, A copy of the document 0= documents by which
you transferred your interest therein,
E, The identity of the person or persons you
transferred such interest, including their name,
address, and any relationship to you.
r, The consideration you received or were
promised for such transfer and the disposition you
made of such consideration,
Not ~pplicable.
19. Please list all items of: household furnishings and
appliances and other tangible personal property assets owned
or claimed by you which have a reasonable value in excess of
$1,000.00. For each such item for which the information has
not been previously provided by you in your answers to these
Interrogatories, please provide the following:
A. A description of the asset.
8. The date acquired.
C. The price or consideration you paid
for such item. '
c. The reasonable market value of such item
at the date of acquisition.
E. The present market value.
F. The present location,
G. The name and address and relationship,
if any, of any person which owns an interest in
such property with you,
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22. Identify any and all debts, liabilities, or obli-
gations, of. any nature that you may now have, or which you
now owe, including all debts secured by a writing or not,
and including any and all credit card obligations and open
charge account obligations, which you have not already previously
described in your answers to these Interrogatories. For each,
please provide:
A. The nature of the debt, liability. or
obligation.
B. The date acquired"
C. The identity of the creditor or obligee,
including their name, address, and relationship
to you, if any.
D. The outstanding balance now, if any,
E. The outstanding balance at the date this
divorce action was filed, if any.
F. The account number or other identifying
number or symbol.
G.
payments
years.
The dates. frequen~y, and amounts of any
thereon made during the preceding three
H. The nature and identity of any collateral
or security pledged.
I. The term of the obligation and the date
on which final payment is anticipated.
J. Any and all judgments relating thereto.
K. Whether such debt, obliqation, or liability
is secured by or reduced to any writinq. If it is.
please attach a copy of that writing to your answers.
L. What you received in exchange for the
debt, liability, or obligation and what disposition
you made with the funds or assets so received,
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23. Please state whether you are the beneficiary of
any trust. If you are, please provid" the name of the'trust.
the name, address, and relationship to you, if any, of the
settlor of such trust, and the name, address, and relationship
to you, if any, of the trustee of such trust. If so, please
provide a description of the assets and their approximate
current market value. Please state whether you have be.,n the
beneficiary of any such trust at any time durinq the past four
years.
Not Applicable.
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24. please state whether you hold any assets in tr~st
for yourself Qr any other person, or have so held assets in
trust for another person or persons at any time during the pre-
ceding four years. It so, please identify, by name, ft~dress,
and relatiGnship to you, if any, the settlor and the beneficiary
or beneficiaries of such trust, and please describe the assets
and their approximate market value, which you so hold or held.'
Not Applicable.
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26. Please state whether you have placed any assets of
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any nature or type whatsoever into the possession, ownership,
care, control, name, title, or custody of any other person,
company or entity at any time during the preceding thrflle years.
If you have, for each such asset, please state:
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A. The date of such transfer.
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B. The identity, including name, address,
and relationship to you, if any, of the person
orentity now in possession of such item.
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C. The present location of such asset or
item.
D. The present market value of such item
and the market value for such item on the date
this divorce action was commenced.
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E. Please attach a copy of any document or
or other writing relating to these assets and
their possession by or control of such other
person or entity.
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~8. If you now a. party to any lawsuit, excepting this
divorce action, or if you have been a party to any lawsuit any
time during the preceding four years, please provide:
A. The nature of the suit.
B. The identification of all parties, including
names, addresses and relationship, if any, to you.
C. The caption of the lawsuit and the names
and addresses of all attorneys representing any
parties in the lawsuit.
O. The amount in contro~ersy.
E. If it has been settled, dismissed, or
j otherwise terminated, the date of such termination
and the amount or amounts of any payments or
transfers as a result of or causing such termi-
nation and the names and addresses of the parties
making and the parties receiving such payments or
transfers.
Not Applicable.
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29. If you have acted as a co-maker, guarantor, or
endorser of any loan, or if you have guaranteed or promised
to pay the debt of any other person, within the past three
years, please provide:
,A. The amount of the loan.
B. The date the loan was first made or
taken.
C. The terms of the loan.
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o. The present amount owed or the present
outstanding balance.
E. .The identity of the obligee.
F. The identity of the .obligor, including
their name, address and relationship, if any,
to you.
G. Please attach copies of any and all
documents relating thereto.
Not Appli cable.
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30. Please state whether you contribute to the support,
maintenance, or welfare of any person other than yourself
or if you have done so at any time during the preceding three
years. You may, for purposes of this Interrogatory, exclude
your present spouse. Please provide:
A. The name and address, and a statement
of their relationship, if any, to you, of each
such person you support or to whose support
you contribute.
B. The amount and frequency of such
payments or contributions and whether they are
made in many or in kind.
C. Whether the contributions are voluntary,
by written agreement or by order of court and,
if they are by agreement, please attach a copy
or, if they are by order of court, please identify
the court action by caption and please provide
the names and addresses of all parties to that
action and the attorneys who represent or repre-
sented them at the time the order was entered.
April Welsh. Daughter. 11 Hilltop Lane, Newville
Joshua Welsh, Son, 11 Hilltop Lane, Newville
David Walsh, Son, 11 Hilltop Lane. Newville
$100.00 per week from May, 1993 until present
VOluntary
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31. Please state what counsel fees and costs you ,have
paid or havq promised to pay for services rendered in this
matrimonial or divorce action or in any prior action of
divorce or annulment between you and your pre.ent spouse.
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32. Please identify, by name, addresa, and relat~onship,
if any, to you, all persons who were witnesses to or have
knowledge or information of any relevant facts relating to
this action or who possess proof or evidence of the incidents
or acts involved. Please indicate which were eyewitnes.es
and which have documents in their possession or under their
control which relate to this action.
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33. State or i.dentify, by name, address, and rela~ionship
to you, all persons you propose to call as witnesses in this
action. Please identify all such persons you propose to call
as expert witnesses and identify their area of expertise.
Please attach true copies of all written reports rendered to
you by any such proposed expert witness or any written state-
ments provided:.to you by any of the witnesses listed in your
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answ&r hereto. If you have received a report from such witness
which is not written, please supply a summary of any oral
.
report rendered to you.
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34. Please describe your education and training, including
a list of all professional or educational degrees, certificates,
license" or statuseo you now hold or have held at any time during
theprec~ding four years.
Not Applicable.
.
. .
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35. Please list all educational institutions which you
have attended during your lifetime, including the date of lour
attendance, the highest grade of schooling completed, any
degrees, certificates, or awards you receive as a result of such
schooling, And the nAme and address of each such educational
institution.
Letort Elementary School, 1966
St. Patricks, 1967-1975
Carlisle High School, 1975-1979
12th grade highest grade completed
.
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40. Please state whether you have been named as the
beneficiary. legatee or heir in any estate of any decedent at
any time during the past four years. please state whether you have
any expectancy to receive an inheritance or any other assets
from any estate at this time. For each such expectancy, or for
any estate in which you have been named as a benef ic iary, legatee,
or heir, please identify the estate and provide t~e following:
A. The name and date of death of the decedent.
B. The county and state in which letters of
I administration or letters testamentary have been
issued or will be issued.
C. The name, addre ss, and rela tion to you, if
any, of the personal representative of the estate.
O. The amount of the expectancy or inheritance
you expect to receive.
Not Applicable.
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41. Please state the names and addresses of your parents
and state whether they are now living or deceased. If deceased,
please state when they died and whether you received any
inheritance from them.
Mary Welsh, 579 F Street, Carlisle, Pennsylvania
Lester Welsh, deceased, September 16; 1966
No inheritance received.
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: i COHHONWEALTH OF PE:-INSYLVANIA
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Personally appeared before me, the undersigned. a Notary Public in and for,the
I COMmonwealth and County aforesaid. deponent, who being duly sworn according to law.
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deposes and says that the answers contained in the foregoing Interrogatories are t.rue
land correct to the best of his knowledge, information and belief.
/~
~ter G. Welsh
Sworn and subscribed to
before me this" day
of ..' , 1995.
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PAMELA S. WELSH,
Plaintiff
IN THE COURT OF COMMON PLEAS Or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 94 - 6358
LESTER G. WELSH,
Defondant
IN DIVORCE
ORDEIl AND NOTICE SETTI~HEARING
To:
Pamela S. Welsh
Samuel L. Andes
Lester G. Welsh
Robert L. O'Brien
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania, on the 7th day
of M..y , 1996, at 9:00 a.m., at whiCh plact!
and time you will be given toe uppo~tunity to present witnesses
and exhibit~ in support of your case.
By the Court,
~ a~ 0 ..n::::
Harold E. Sheely,
.Judq('
Date of Order and
Notice: 2/20/96
By:
DIVorce Master
If YOU 00 NOT HAVE A
TELEPHONE THE OFFICE
CAN GET LEGAL HELP.
LAWYER OR CANNOT AFFORD ONE, GO TO OR
SET FORTH BELOW TO FINO OUT WHERE YOU
Court Administrator
Fourth Floor. East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
PAMELA S. WELSH,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
6358
CIVI L
1994
LESTER G. WELSH,
Defendant
IN DIVORCE
ORDER AND NOTICE SBTTING HBAR.!!'!Q
TOI
Pamela S. .Welsh
Samuel L. l.ndes
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
Lester G. Welsh
Robert L. O'Brien
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street Carlisle, Pennsylvania, on the ~
day of ~.2..':!.!.!.-_, 1 'J.l-E.. , at 9:00 a .m, at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court,
~~\~
Harold E. Sheely,
Judge
Date of Order and
Notice: 5/29/96
By:
'Divorce Mas ter
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
PAMELA S. WELSH,
Plaintiff
'~ IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO.
CIVIL
1994
6356
.'1
LESTER G. WELSH,
Defendant
IN DIVORCE
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RESCHEDULED HEARING
ORDER AND NOTICE SBTTING HEAI!!!!Q
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To:
Pamela S. Welsh
Samuel L. Andes
Lester G. Welsh
Robert L. O'Brien
Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
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You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street Carlisle, Pennsylvania, on the 20th
day of September , 199~, at 9: 00 a.m, at which place and
time you will be given the opportunity to pr~sent witnesses and
exhibits in support of your case.
By the Court,
~a~~~ J \:::
Harold E. Sheely,
,Judge
Date of Order and
Notice: 8/2/96
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
PAMELA S. WELSH, IN THE COURT OF COMMON PLEAS or
plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 94 - 6358
LESTER G. WELSH,
Def.ndant IN DIVORCE
THE MASTER: Today is Wednesday, May 29, 1996, the
date s.t for a Master'. hearing. Present are the Plaintiff,
pam.la S. Welsh, and her counsel Samuel L. Andes and the
D.fendant, Lester G. Welsh and his counsel Robert L. O'Bri.n.
The Master has been advised that the parties and
counsel wish to place on the record certain stipulations
r.garding the identification and valuation of assets and to
identify any remaining issues which will be sUbsqquently
discussed and negotiated and ultimatly heard by the Master if
the parties cannot reached an agreement.
This action was commenced by a divorce complaint
filed by the plaintiff on November 5, 1994, raising grounds for
divorce of irretrievable breakdown of the marriage.
The Master
has been advised that the parties will sign and file affidavits
of consent within the next two weeks so that the divorce can be
concluded under Section 330l(c) of the Domestic Relations Code.
The complaint also raised the economic issues of equitable
distribution, alimony, alimony pendente lite, and counsel f.e.
and .xp.n....
Th. partie. were married on March 14, 1981, and
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separated May 16, 1993. They are the natural parents of three
minor children, all of whom reside with wife in the marital
residence at 11 Hilltop Lane, Newville, Pennsylvania.
Mr. Andes is going to state on the record the
stipulations that the parties and counsel have agreed to in the
presence of the parties.
It is also noted for the record that present in the
hearing room is Timothy Wilmott, Master from Franklin and Fulton
counties who is an observer today. Mr. Andes.
MR. ANDES: The parties have agreed as follows and
this will be a stipulation by which they will both be bound and
we will have them express that on the record. The agreement
they have reached is as follows:
1. The residence at 11 Hilltop Lane, Newville, Pennsylvania,
is the only marital asset about which the parties will
continua this litigation. The home has been appraised by
an appraiser selected by wife. Husband will make
arrangements to have an appraiser of his selection
appraise it and the parties will then try to meet and
agree upon the amount of equity and some terms for
disposition of the house.
It is our hope that we can agree that the house in some
fashion will be transferred to wife and that she will be
obligated to make some type of payment to husband.
The date, the terms, the amount of the payment is all
subject to further negotiation. In the event those
negotiations are not successful, we will ask that a
hearing be scheduled, at which the Master will have to
make equitable distribution of the house and resolve all
claims related to the house.
2. The parties have agreed with regard to the other assets
that they own, inclUding those items listed in each
party's pre..trial statement and including but not
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limited to a 1988 Mercury Topaz automobile and a 1990
Chevrolet Cavalier or the proceeds of its trade; the
household furnishings; a savings account at Farmers Trust
Company; two small household accounts at Members First
Credit Union, formally OAFCU; and husband's interest in a
retirement plan with Component Building systems; that
those items will be considered distributed by the
parties, and each party waives any further claims of the
items now in the possession of the other and we will
not entertain testimony at another hearing about the
value of those assets or how they have previously been
distributed.
The only exception to that is that the Mercury Topaz
is currently titled in both names and Mr. O'Brien will
prepare some documents and have Mr. Welsh execute those
so the title can be transferred to Ms. Welsh, the wif..
3. The parties each made payment of certain marital debts
after the separation, and again the parties are satisfied
that each of them shall pay the debts that they have paid
since separation, and if there is any balance remaining
on those accounts, the party who has been paying them up
to now will continue to pay those. specifically, wife
has paid the balance owed on a Sears account and husband
either has paid or has been paying the balance owed on a
Corestates Visa and a Choice Visa account and he will
continue to pay those and she will be responsible for the
Sear. account and we will not have any further testimony
about those or ask the Master to consider them further in
equitable distribution.
4. The parties have agreed that they will maintain insurance
on their lives for the benefit of the children and in
that regard they have specifically agreed as follows:
a) Husband'. life is insurftd by a policy issued by
Monumental Life Insurance company. He will
maintain that policy and maintain the three
childrftn as the sole and exclusive beneficiaries
until the youngest child attains the age of 23
years and he will not borrow against the policy or
otherwise reduce its death benefit.
b) Wife's life is insured by a group plan available
through her employer. She will maintain that
insurance until the youngest child is 23 years,
maintain the children as the sole and exclusive
beneficiaries, and do nothing to reduce the
.
death benefit of that policy as long as it is
available to her through her employment.
5. The parties expect that their children or some of their
children will want to attend college or some other tora
of higher education after high school. They have agreed
that after the children have made every reasonable ettort
to obtain financial aid in the form ot grants, loans,
and other resources, and after the children have applied
their own resources in the form of any savings or
earnings that the children have to assist in paying
for their own education, that the parents will make a
reasonable contribution, whatever they can reasonably
atford to make based upon their earnings, income, and
expenses at that time.
6. Wite waives her claim for alimony. Each party waives any
claim for counsel fees but reserves their right to seek a
contribution toward costs. This waiver will not prohibit
the Court in making equitable distribution from
considering all the factors listed in the Divorce Code
under equitable distribution.
MR. ANDES: I would llke the record to show that
the parties spent about an hour and a half this morning with
their counsel and, in fact, with one of the witnesses, my
client's mother; and that they have had an opportunity to
discuss all of this with their attorneys and I'm going to ask my
client -- I'm going to tell you first of all that even though
this is not in writing and you are not signing it, when you
agree to what we just discussed today and what she took down,
you're bound by it. Do you understand that?
MS. WELSH: Yes.
MR. ANDES: And next week or tomorrow or next
month, you can't change your mind and decide, Gee, I raally do
want to reinstate this claim or that claim. Do you understand
.
~
that?
MS. WELSH: Yes.
MR. ANDES: And what we are doing today take. away
all of the issues and resolve. all of the i..ue. except the one.
that we've talked about -- re.erving, which are di.tribution ot
the house and perhaps a portion of costs which would be
appraisal tees and the like between the parties. Do you
understand that?
MS. WELSH: Yes.
MR. ANDES: And knowing that, are you willing to be
bound by this?
MS. WELSH: Yes.
MR. O'BRIEN: Mr. Weleh, you've heard what Mr.
Ande. ju.t expressed to Ms. Welsh, are you in agreement also
with what has been discussed here and the terms that we have
reached?
MR. WELSH: Yes
(A discussion was held off the record.)
THE MASTER: A hearing is scheduled for Friday,
August 2, 1996, at 9:00 a.m. Notices will be sent to the
parties and counsel.
cc: Samuel L. Andes, Attorney for Plaintiff
Pamela S. Welsh, plaintiff
Robert L. O'Brien, Attorney for Defendant
Le.ter G. Welsh, Defendant
O"ICI 0' DIVOIICI MAITIII
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanov.r Street
Carlisi., PA 17013
(717) 240-6535
.. ........ ..okor, II
Divorce Multi
Tr_1 ole CoIror
D1f1ol M"'lIller/Aeporler
Wo.. IIIOro
897-0371 Ext, 6535
Sept.mber 20, 1996
Samuel L. Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
Robert L. O'Brien, Esquire
O'BRIEN, BARIC' SCHaRER
17 West South street
Carlisle, PA 17013
Re: Pamela S. Welsh va. Leat.r G. Welsh
No. 94 - 6358
In Divorce
Dear Mr. Andes and Mr. O'Brien:
Enclosed is a draft of the agreement which you put on the
record on September 20, 1996. Pl.as. review the draft for any
corrections with the understanding that no substantive changes
can be made.
Wh.n you have reviewed the draft give us a call and let
us know if you want us to send the original to the Plaintiff's
attorney for signature who then can transmit the original to the
Defendant's attorney for signatur.. When I receive a signed
copy of the document I will then obtain a Court order vacating
my appointment.
Thank you for your continuing cooperation in brinqing
this matter to settlement.
V.ry truly yours,
I. Robert Ilicker, II
Divorce Master
PAMELA S. WELSH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS. NO. 6358 CIVIL 19 94
LESTER G. WELSH,
Defendant IN DIVORCE
STATUS SHELT
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OFFICIO' DIVORCI MASTIR
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(711) 240-6535
I. 1Io1le.. Illeller, II
Olvorc. Mallar
Treel .10 Colrer
Offlc. ManlQ.,IR.porta,
Wes' ......
697-0371 Ex\. 6535
July 19, 1995
Robert L. O'Brien, Esquire
O'BRIEN, BARIC' SCHERER
17 We.t South Street
carli.le, PA 17013
Samuel L. Andes, Esquire
ANDES, VAUGHN , BANGS
525 North Twelfth Straet
P.O. Box 168
Lemoyne, PA 17043
RE: Pamela S. Weleh vs. Lester G. Welsh
No. 6358 Civil 1994
In Divorce
Dear Mr. Andes and Mr. O'Brien:
By order of Court of President Judge Harold E. Sh.ely
dated July 14, 1995, the full-time Ma.ter has b.en appointed to
the above referenced divorce proceedings.
A divorce complaint was filed on November 9, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage. I assume that there is no issue with resp.ct to
grounds for divorce and that both parties will sign and file
affidavits of consent. If, however, my assumption is not
correct, please advise immediately.
The complaint raised the economic issues of .quitable
distribution, alimony, and counsel fees and .xpen.es.
Based on the assumption that there is no issue with
regard to grounds for divorce, I am directing each couns.l in
accordance with P.R.C.P. 1920.3J(b) to file a pre-trial
statement on or before Friday, August 11, 1995. Upon r.ceipt of
the pre-trial statements I will immediately schedule a
.
.
Mr. Ande. and Mr. O'Brien, Attorney. at Law
19 July 1995
paqe 2
pre-hearinq conference with counsel to discu.. the i.sue. and,
if nece.sary, schedule a hearinq.
Very truly your.,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statement.
are set forth in .ubdivi.ion (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
PAMELA s. WELSH,
plaintiff
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VB.
NO.
6358
CIVIL
1994
LESTER G. WELSH,
Def.ndant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Samuel L. Andes
, Counsel for Plaintiff
, Counsel for Def.ndant
Robert L. O'Bri.n
A pr.-h.aring conference has b.en scheduled at the
Office of the Divorce Master, 9 North Hanover Street, Carli.le,
penn.ylvania, on the 13th day of November, 1995, at 9:30 a.m.,
at which time we will r.view the pre-trial statements previou.ly
filed by couns.l, define issues, identify witne...., explore the
po..ibility of s.ttlement and, if necessary, schedule a h.aring.
Very truly your.,
Date of Notic.: 8/16/95
E. Robert Elicker, II
Divorce Ma.t.r
I'
An.wers to the Interrogatories should be provided to Mr. Ande.
and the Ma.ter ten (10) day. prior to the pre-hearing
conterence.
,
r .
".
~I
t '
\
PAMELA S. WELSH,
plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: CIVIL ACTION - LAW
NO. 6358 CIVIL 1994
LESTER G. WELSH,
Defendant
: IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
Robert L. O'Brien
, counsel for plaintiff
, counsel for Defendant
TO: Samuel L. Andes
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover street, Carlisle,
pennsylvania, on the 16th d~y of February, 1996, at 1:30 p.m.,
at which time we will review the pre-trial statements previouslY
filed by counsel, define issues, identify witnesses, explore the
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 12/5/95
E. Robert Elicker, II
Divorce Master
PAMELA S. WELSH,
Plaintiff
IN THE COURT OF COMMON PLEAS 01'
CUMBERLAND COUNTY, PENNSYLVANI^
vs.
CIVIL ACTION - LAW
NO. 94 - 6358
LESTER G. WELSH,
Defendant
IN DIVORCE
RESCHEDULED HEARING
ORDER AND NOTICE SETTING HEARING
---
To:
Pamela S. Welsh
Samuel L. Andes
Lester G. Welsh
Robert L. O'Brien
, Plain t iff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania, on the 29th day
of May , !996, at 9:00 a.m., at which plac~
and time you will be given tile uppo:rtuIlity to present ~litnesse'i
anrt exhibit~ in support of your case.
By the Court,
~~ \:::
Harold E. Sheely,
,Iudq':'
Date of Order and
Notice: 3/26/96
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor. East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
PAMELA S. WELSH, . IN THE COURT OF COMMON PLEAS or
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VB. NO. 94 - 6358
LESTER G. WELSH,
Defendant IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Friday, February 16, 1996
Present for the Plaintiff, Pamela S. Welsh, was
attorney Samuel L. Andes, and present for the Defendant, Lester
G. Welsh, was attorney Robert L. O'Brien.
A divorce complaint was filed on November 9, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claims of equitable distribution,
alimony, alimony pendente lite, and counsel fees and expense..
Counsel have indicated that the parties will sign and file
affidavits of consent so that the divorce can be concluded under
Section 330l(c) of the Domestic Relations Code. Counsel for
wife has indicated that perhaps wife will withdraw her claim for
alimony. There may be some testimony, however, if the alimony
claim proceeds, on marital misconduct involving husband's
alleged relationship with a female friend prior to the
separation of the parties. Also raised by the wife and her
counsel is an emotional condition which wife has had to deal
with during the course of the marriage which apparently arises
out of her relationship with husband rather than any other
causes.
The parties were married on March 14, 1981, and
separated May 16, 1993. They are the natural parents of three
children, 1pril, born August 15, 1981; Joshua, born July 3,
1984; and David, born June 2, 1988. The children are currently
in the custody of the mether. Husband pays child support in
the amount $104.00 per week and alimony pendente lite in the
amount of $46.00 per week.
Wife is 34 years of age and resides at 11 Hilltop
Lane, Newville, Pennsylvania, with the children. She is
employed at Blue Shield in a training program. Her income is
unknown and counsel for wife is requested to provide an earning
statement. Wife has not raised any health problems. Wife is a
high school graduate.
Husband is 34 years of age and resides with a
female friend and her children at 260 Mount Rock Road, Newville,
Pennsylvania. Husband is currently employed by Russel Building
as a carpenter. His gross weekly income is $330.00, his net
weekly income is $266.85. Husband has not raised any health
issues. Husband is a high school graduate.
The parties own a home where wife is currently
living with the childt'en at 11 Hilltop, Newville, Pennsylvania.
Husband has indicated he believes the house has a value of
$110,000.00 and wife has indicated on her pre-trial statement
that the house has a value of $75,000.00. Counsel have advised
that they will have to have the property appraised to determine
the market value. The house is subject to a mortgage in favor
of Meridian Bank with a payoff of approximately $44,000.00.
The monthly mortgage payment with escrows is $480.00 which is a
figure that is two years old meaning that the amount wife
currently pays may be slightly higher.
with respect to bank accounts, the parties had a
savings account at Farmers Trust with approximately $900.00 to
$1,000.00. Husband got those funds. There were two accounts
at Members Federal Credit Union and counsel need to determine
the amount of money in those accounts. Husband also received
the sums in those accounts as well.
wife has a 1988 Mercury Topaz which husband has
placed a value on of $2,000.00. wife has not indicated a value
in her pre-trial statement; therefore, the vehicle will probably
have to be appraised. Husband sold the 1990 Chevrolet Cavalier
and we need to know the sale price of that vehicle to help us
arrive at the market value for purposes of equitable
distribution. Husband currently has a 1987 Jeep which he
purchased subsequent to the separation. Apparently he did use
funds received from the sale of the Chevrolet Cavalier to
purchase the Jeep.
When husband was employed at Component Building
Systems, he was involved in a retirement plan. When he left
that company he received a lump sum payment, according to his
answers to interrogatories, in the amount of $1,253.00. Mr.
O'Brien is going to verify that amount for Mr. Andes.
The household tangible personal property remains
with wife and that property will have to be appraised.
According to Mr. O'Brien his client left essentially with his
clothing and other personal items and did not take any of the
tangible personal property.
Wife has listed on her pre-trial statement numerous
,
.
.
marital debts. According to counsel wife has paid off the Sears
credit card leaving the other debts to be paid by husband. We
should have statements showing the amount of the debts at the
time of separation. Husband will receive credit for what he has
paid on account of the debt and will probably be credited with
paying the balance of the debt inasmuch as the debt will be
allocated to him. Wife will receive credit for payment of the
debt on the Sears card.
Counsel for wife has indicated that there are
approximately $2,000.00 worth of savings bonds which were
purchased for the children. Counsel for husband and wife will
probably be able to agree that those bonds can be retained for
the benefit of the children and not be subject to the IIquitable
distribution of the other assets.
The main issue in this case is whether or not wife
should be permitted to stay in the marital home with the
children deferring husband's equity interest for a period of
time or whether the house should be listed for sale and sold so
that husband can immediately realize at the time of sale his
equitable interest in the property. Mr. Andes indicated that he
would suggest that the sale be deferred until the youngest child
has reached 18; Mr. O'Brien would like to have the interest of
husband available as soon as the sale of the house can be
accomplished. The Master has suggested for purposes of
discussion that perhaps we give wife some additional time in the
property until the oldest child reaches 18. We have discussed
the problem with using a child'S birthdate as a guideline based
on the consideration that all of the children are currently
living with wife as we do not want to put the children in a
situation where they become pawns in a situation which would
affect when the house is to be sold depending on where a
partlcular child is living. A resolution of that issue may be
to simply pick a date four years from the date of the final
resolution of this matter when the parties would have to resolve
the house issue and wife would either have to buyout husband's
interest at that time based on the appraisals or the house would
have to be sold.
9:00 a.m.
A hearing is scheduled for Tuesday, May 7, 1996, at
Notices will be sent to counsel and the parties.
E. Robert Elicker, II
oi vorce Master
001 Samuel L. Ande., Attorney for Plaintiff
Robert L. O'Brien, Attorney for Defendant
....u.1. 1o..ND..
.,. MIlT DlLON.
SAMUEl. L. AND1':S
ATTORNIIY AT LAW
eriil\ "O.TH TW.LF1'H liT..."
p, o. BOX 1~8
LIIMOYNII, PIINNIIYLVANJA 17043
'......011.
en') ,.,..lIlN
,
3 December 1996
,..x
(,." '."'4111
E, Robert Elicker, Master
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Welsh vs, Welsh
Deer Mr, Elicker:
Enclosed, at long last, is the fully executed copy of the transcript of the
Agreement reached before you on 20 September 1996 in the above matter, Pie...
vacate your appointment so that we can conclude the divorce by the end of the year,
Thank you for your cooperation,
Sincerely,
~
Samuel L, Andes
amr
Enclosure
cc: Robert O'Brien, Esquire
Pamela Welsh