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Home My WebLink About95-00540 t , . , .:+:.' .:.:.'.:.:. -.:.:..:.:. .:.:. .:+:..:.:.. .:<<." .:+:. .:+:. -,:.:. .:+:. .:+:' .:.:..:.:' .:.:. ':+:. .:+:. .:.:,":.".:+:.' '.:+:.::.:+:.::.:+:.;,.:+:,. .:+:-.:+;.- ,.:.>::':.>~~-;4 ~'t -------..- ---- I ~ ~ ~ ~ ~,.~. ... :) ~ IN THE COURT OF COMMON PLEAS : ~ ~.' ~ ~ ..~ ,', ~ ~ ~ OF CUMBERLAND COUNTY STATE OF i~~~ .\''''I'i!'i--,'r PENNA, ,~ ~ ..~ ~ .., ..... :1 iI ,_ARLENE A, GALLA, .. ... PLAINTIFF, N (). ..95~5~O.. CIVIL_,TERM... ..:; ~ w ~.~ ~ ~.' ..,.,.... ,. 'I V('I';';lIS .. WALTER D; -GALLA, . DEFENDANT ;i 'I I ;! Ii! ~.~ .', ~ ,oj W '.' .'~ ~ DEe R EEl N -Ir -2. ' 2. ft IJ JA D I V 0 R C E dJ.. ..I' ,;u r"" . ..... .k.~. 19q.~., it is ordered and ~ ~~ ~ ~ ~ ~\ ~ ,', ~ s " ~ ~ ~ ... AND NOW, , decreed that. ... . .......... .ARLENE .A.. ,GALLA.................., plaintiff, and. . ... . . '" . .. . . ... ... WALTER' D:' GALLA' .... ... . . . . . . . .... ... defendant, are divorced from the bonds of matrimony, ~ ~ ~.~ ~ ,.' The court retains lurlsdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ,', ~ TilE. PARTIES!. HARRJ:AGE, SEITLEMEN:r. AGREEMENT. OF. NOVEMBER. 6-,. ,1996 .IS. .INCORPORATED IIEREIN' AS' AN' ORDER' OF' COURT',' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ M I'. ~ ~ p M .,~ A .i': . . . 1/ .~. /..;1.~~ ~- .i: ,c>< 'l:J-1I/-I<<!!..iI C . , ~(dj7' 't4~ffi ~~~, k ~j. ... . ... .. tl t7 Prothonotnry M ,', ~ ~ ? ~ -:-:--.-:--.;--; . .~.. ...... .:t:.' .:,t., . " - ...._~---_.., -., ~.".-. ..'~, ~.. -, -'"- j~ --~*~~~**'~******~***ro** .-:", .. . , ,. .,..,.- - . ._.40 . ~.~ ~ ,', ~ ~ ~.~ ~ ,', ~ i '.' i ~,~ ~ ~ ~ ~ .', ~ ~ (, 'J ,~ ~ ~ ... " ,', . ~ ~ 1ii ',' !"; i ~~ ~ " ~ ~:; w :'~ ~ .~ ~ ~.~ ~. ~.' ~ .,~ w '.' ,', ~ ~ '.' ~ '.' ~ ~ '.' ~ '.' .. ~ * /~..)).~ &vt. ~77f'(('J;/E~ - /; ';;)).9(, ;r4 /~M4/;? 4 ~'~~ .\ gall. .ogll3.95/ro.12 .21,95/Io.12.24.95/ro.2.7 .96 SEPARATION AGREEMENT THIS IS AN Agreement made this (I) day of !J7J)((f1m)){lft , 199~, by and between Walter D. Galla, of , , (hereinafter referred to as Husband) and Arlene A. Galla, of One Partridge Court, Carlisle, Cumberland County, Pennsylvania, (hereinafter referred to as Wife). WHEREAS, Husband and Wife were married on August 30, 1986, in Carlisle, Cumberland County, Pennsylvania; and WHEREAS, various differences have arisen between Husband and Wife; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlemsnt of all of those rights and obligations under said Divorce Code; and NOW, THEREFOP~, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other righta under the said Divorce Code not provided for herein and agree as follows: . I 1. SEPARATION. The parties agree that it shall be lawful for each party, at any time hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart, from the other. 2. REAL ESTATE. Husband and wife jointly owned the marital residence located at 120 Linn Drive, Carlisle, cumberland County, Pennsylvania. The net settlement proceeds from the sale are to be equally divided between the parties. J. AUTOMOBILES. Wife shall have as her sole and exclusive property, title to and possession of the 1988 Honda Civic and 1994 Toyota. Husband shall have has as his sole and exclusive property, title to and possession of the 1992 Honda Accord. Said 1992 Honda automobile is currently titled in the names of both parties and Wife shall transfer title to said automobile to Husband at such time as Husband requests said transfer to be made. Until title is transferred to Husband, Husband shall insure said automobile and agrees to indemnify and hold Wife harmless from any liability associated with the operation of said automobile until title is transferred. Each party agrees to indemnify and hold the other harmless from any liability on any loan encumbering the vehicle in their respective possession, for the cost of repairs, maintenance, registration, insurance and/or inspection of the vehicle which each is taking as his/her sole and exclusive property. 4. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their personal property which includes bank accounts, mutual funds, jewelry, clothing, furniture and other personal items. Any and all property in the possession of Husband shall be his sole and separate property and any and all property in the possession of Wife shall be her sole and separate property. Each party forever renounces whatever claims he/she may have with respect to the property which the other is taking. Each party understands that he/she has no right or claim to any property acquired. by the other after the signing of this Agreement. 5. PENSION/RETIREMENT PLANS. Wife hereby releases any and all claims or demands she may have on Husband's pension or retirement plans. Husband hereby releases any and all claims or demands he may have on Wife's pension or retirement plans. 6. DEBTS. The parties represent and warrant to each other that neither has incurred any other debts nor made any other contracts for which the other or his/her estate may be liable, from the date of this Agreement forward. Neither party shall contract nor incur any debt or liability for which the other or his/her property or estate might be responsible and agrees to indemnify the other from any claims made against the other because of debts/obligations not incurred by the other. Wife shall retain the following credit card accounts, which are in her name alone: Harris Savings Bank (MasterCard), Discover, and AT&T Universal VISA and, further indemnify Husband from any claims made against him on Wife's failure to pay on said accounts. 7 . ALIMONY . ALIMONY PENDENTE LITE. SUPPORT OF SPOUSE. The parties waive any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or spousal support from the date of this agreement. Wife does not, however, waive any rights or claims she has for spousal support due Wife prior to the date of this agreement in the proceedings at 1195 Support 1992, in the Court of Common Pleas of Cumberland County, Pennsylvania. B. TAXES. Each party shall file separately for 1995 and subsequent tax years and be entitled to share equally in any deductions until the divorce is final. All tax liabilities due and owing by each of the parties for 1995 and subsequent tax years shall be their sole and separate responsibility. 9. EFFECTIVE DATE. The effective date of this Agreement shall be the date of execution by the parties if they had each executed the Agreement on the same. date. Otherwise, the execution date of this Agreement ehall be defined as the date of execution by the party last executing this Agreement. . 10. DIVORCE. The parties agree that should either party file a Complaint in Divorce, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code, then both parties agree to execute any and all affidavits or other documents necessary for " the parties to obtain an absolute divorce pursuant to Section 3301 (c) of the Divorce Code including waiver of all rights to request Court ordered counseling. It is agreed and understood between the parties that in the event a divorce proceeding is filed by either party in any other jurisdiction, that the parties shall not contest, but instead consent to such proceedings and shall execute any and all documents necessary so as to proceed with and obtain an absolute and final divorce. 11. INCORPORATION INTO DECREE. Should a decree, judgment or order of separation or divorce be obtafned by either of the parties in this or any other state, country, or juriSdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the partes hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or its decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. . , . 12. MUTUAL RELEASE. Husband and Wife do hereby mutually remise, release, quit claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or againet the estate of such other, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate lawsl or the right to take against the spouse's willl or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the curviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the united states, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise" except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 13. COUNSEL FEES. Each party individually covenants and agrees that he or she will individually assume the full and sole responsibility for legal expenses for his or her attorney and court costs in connection with any divorce action which may be brought by either party and shall make no claim against the other for such costs or fees. 14. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 15. MODIFICATION OR WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 16. ~NTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 17. . SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. lB. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her direction, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. I 'I i I I I I 19. CONTROLLING LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 20. INVALIDITY OF PROVISIONS. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only' that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. 21. BINDING NATURE. Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above ritten.~_1. ~p~ .1::T . WITNESS ~-'"' qj-, W TER D. GALLA ,.. . I J \ " . COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On this, the //5 day of IfIbl1lmluh , 199} before me, the undersigned officer, personally appeared Arlene A. Galla, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereun SHAt,. MY COMMISSION EXPIRES: ., ! Nala.ial 50al Jonniio' 5, Calaman. Notary Public Carllskl Bera. Cumborland CounlY My Commission Expl,es Nov_ 29. 1999 Mf\fllllpr f'jinno;yb311/it Association 01 Notilrles STATE OF tJ-.1C\. V\ .....,. ss COUNTY OF .:s::. ~~ : Lo \ C\G\4' On this, the day of \:J()\,}..Q..,\fV\....~u... , 1':!J9:5-, before me, the undersigned officer, personally appeared Walter D. Galla, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. . . ~ IN WITNESS WHEREOF, I have hereunto notarial seal. ~ '5"~ \0 I.l I('{\..CA. ( '" MY COMMISSION EXPIRES:'l Q Vt '2 'S . ,........-...-- , - ;:;cii',IRY I'unll<: ,\I !N! ,-^URIlN S 7 Nonh MJln ,"..I" l111r UT 114720 r()"'~I15,ION FXI'IRES - l\N- H. 1999 STAlE or UTAH ,((crt{ . , ( , ! I.'')', " I .,,\ " I ,:"1 .~~ ,. .. r ,,"j . :'1?1 I :~-,L8 , . .. ... \ )(1..., . , , ,::i-j . .. : ~~ ) ,- , ,.l ~Kn ~. , ',) 1:\ ~'-! .... . , '" , . , " '. .'1 .. ._..._--.~.".,._._~.,..- _. -_._' ..~,,,. -,.-. '," ,-.~,., LAW OFFICES OF . KNUPP &.KODAKP.C. 407 ~A~~~io~R~j~~ET .'. AUG1519S5"it:< ., P.O. DOX 11848 HARRISB!1RO. PA 17108.1848 . ",' . , r ~'.' . , -'.. ~ -. . '... . " ,-.' ,'t~...'. .~..~ ,~~~IfVll. ,::.'.-,..'..:::~ '."--. _..):"'~;"'~ '-., \ '--- ~ '~~-c> ARLENE A. GALLA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 95 . 540 CIVIL ACTION. LAW DOMESTIC RELATIONS SECTION v. WALTER D. GALLA, Dafendant ~M And now, to wit, this ~ day of . , 1995, upon consideration of a Petition for Special Relief flied by I'ntlonette J. M. Galla, It Is hereby ORDERED AND DECREED that Arlene A. Galla and Walter D. Galla are hereby prohibited from transferlng any of the assets of Walter D. Galla or Arlene and Walter Galla to each other or to any third parties. A hearing shall be held on this matter on the c1 () 1IV day of ~.J;u , 1995, at b o'clock t1.m., In Court Room #~3 , Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: J. ~'l ':"1 t.l).';; ~i N J '! UhOJO CN';l'iTi,IO~ A'J.tl~IIO" l'" ..; ~ F' ;OllJO .1 " 56. HV tE 01 LI ~nv v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 95 - 540 ARLENE A. GALLA, Plaintiff WALTER D. GALLA, Defendant CIVIL ACTION - LAW DOMESTIC RELATIONS SECTION PETITION FOR SPECIAL RELIEF Q'JT/ AND NOW, this day of ItJ:2''U '5 T ,1995, comes the Antlonette J. M. Galla (hereinafter referred to as "Petitioner") by and through her attorneys, Knupp & Kodak, P.C. and respectfully requests: 1. Petitioner has flied a Petition to Intervene In the above-captioned matter. The contents of said Petition are incorporated herein as if set forth at ~Iength and ,;., =:::..; :;::.: verbatim. --'j 7 ~ t, I' I I I I I I 1 ; ; , " 2. Petitioner believes and hereby avers that special relief is nec'essary In;the form of prohibiting the transfer of any assets of the Defendant and/~>PlalntIJiand Defendant to each other or to third parties. Petitioner believes that such transfers may be imminent since Plaintiff and Defendant have listed their house for sale. 3. Petitioner believes that Plaintiff and Defendant might conspire to transfer assets In an attempt to shield those assets from execution by Petitioner thereby precluding Petitioner from collecting past due and current alimony to which she is entitled. I 1 I 1 I ,I ! I j J I I I I i , WHEREFORE, Petitioner requests that this Honorable Court Issue an Order prohibiting the transfer of any assets of Defendant or Plaintiff and Defendant to each other or to third parties pending further hearing by this Court. Respectfully submitted, KNUPP & KODAK, P.C. Attorneys for Petitioner Antlonette J.M. Galla '0'<) Dated: f1' -9 - ') , . ;: VERIFICATION ; ~' t', Ii ,I I i, i, i' I i: GARY J. IMBLUM, ESQUIRE, verifies that he Is the attorney for the Plaintiff herein, that the Plaintiff's verification cannot be obtained within the time allowed for the filing of this pleading, that as attorney for the Plaintiff, he has sufficient knowledge and information concerning the contents of the within document and that I I , the facts set forth In the foregoing are true and correct to the best of his knowledge, Information and belief. He understands that false statements made therein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. ~ Gary J. Imblum Dated: ~-'l{ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-540 CIVIL ACTION - LAW DOMESTIC RELATIONS SECTION " ARLENE A. GALLA , v. WALTER D. GALLA, Defendant CERTIFICATE OF SERVICE I, Gary J. Imblum, Esquire, hereby certify that I have served j t I I I a copy of the PETITION FOR SPECIAL RELIEF on the following person(s) by depoeiting a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Dauphin County, Pennsylvania addressed to: , . , ROBERT L O'BRIEN ESQUIRE 17 WEST SOUTH STREET CARLISLE PA 17013 CHRISTOPHER C HOUSTON ESQUIRE FOUR;~9RTH HANOVER STREET CARLISLE PA 17013 KNUP & KODAK, P. . ary J. Imbl 407 North F PO Box 118 Harrisbur PA 17108-1848 717 238-7 51 Attorney for Plaintiff DATED: S> -/6-'1') , . .' x- c: .., ...1 ~~ ,= ..'t' ., 1'1',1;.1:--. :....o:(fl;ni--' :J.: ~.! -..,.\ (II' ;.}I" . ..: ~. ... J ; ,-J. -.,Q _: r:~' :l: ..,: J....")C.)~l -:;.o:.lX::; ,_I : L',,, '.I.... :J~ -'=- Ul N w ~ . LD c.n ~ r ~, .:t .... ...:l k.,- ,~ :-t,. -i'l" . . l~tll~i~~> i fij"~""~"."'>~'.' . .., .... W,~d'" j',:",; .\ " \f, ~i, ,I}, ~' L , " Itl",-'t1;!;;:Jf\:,t.,,\ ..- ~;~~I;~\t;i>'i '!~j~;';' :~_~;;-',,',7:~~--\'{: t '~m=t/~f!:,':~<: ;;:'{",.;;}r~ ):' -': I-Y~': !r&~.h.f/;JJ~~Ii.' '. " '1t" Al!lJ'lt" :l.,-~,S." IT ~ '~ ',','\.''1: l\;'" 'I" '.', /,', ~,'" . ~~:'.' . I 'illy:,!;';'l;';" 1,'l, .1>' ~ I"~ .~~:~t~:!J\~,~;:;' ,:" ,,' , .. ,~7r-~:~ :>::(,~~,:,W- . '.; i> .' ..,]w~ .' ,'_, " ,,~'/ ~',,' L ~,:'.)~I,~~;,:,~j~;iY;:~~~! , , .~".L, ""(),,coJ;; 19'95~~' :.<:~::i:tt~;\:i"'1i~~0.~"P "',. ,.;,. ~ ~:~,nb),.\~ r.r:.~;l1;'i'~\t ,'~', "",}:,)'!:;'r.~~:1::~:~t~;~i\B~ --,:'i;::,\"x..~-::"7-',~ -,' '/:\~:~.~:~;i'~i It, , " ,~."", ......i '\..;' :. . ,.~-,---~-:--~-...~:....~~" ...,---1 'I LAW OFFICES OF KNUPP & .KODA{{P .C. 'CAMERO!,! M"NSION , <107 NORTH FRONT STREET P.O, DOX 11I48 HARRISBURO, PA 17108.1848 ",Aus.'.1'..5 ._~.-.-....~--.t;,':..uo-P.PL--:'''~'''''--1.';';''.i.;.!~';'';;'.;i,'.:.f;;,:,d,~:,;.;,:'j:..'t'i.i.;f.~~liYc1' it'ilJ.Y-tSiI.'tiU~...."".,4I/'lII . , . .0(' " ~ . " ARLENE A, GALLA, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUN:ry, P~NNA NO. 95 - 540 CIVIL ACTION - LAW, , DOMESTIC RELATIONS SECTION WALTER D. GALLA, Defendant AND NOW, to wit, this day of , 1995, ORDER It Is hereby ORDERED AND DECREED that Antlonette J, M. Galla Is permitted to Intervene In this action as a party, BY THE COURT: J. ARLENE A, GALLA, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO, 95 - 540 WALTER D. GALLA, Defendant CIVIL ACTION - LAW DOMESTIC RELATIONS SECTION B.fh TO SHOW CA~ ~A, j- AND NOW, this (1 day of ~ ' 1995, It is hereby ORDERED AND DECREED that Arlene A. Galla and Walter D, Galla shall show cause, If any there shall be, why Antlonette J. M. Galla shall not Intervene in the above-captioned action. This Rule Is rsturnable within twenty (20) days after the service thereof, BY THE COURT: J, I"~ _,..,",.nJ__-., 'I \'IN~,\ I,\SNNJ<, Al~",JO iJnln!jlin~ ,\~\'I~HOIIl(':j ,'. t JO SOlj 10 .oli1 SS. UJ €t I L I ~nv { ARLENE A, GALLA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO, 95 - 540 CIVIL ACTION - LAW DOMESTIC RELATIONS SECTION v, WALTER D. GALLA, Defendant AND NOW, this PETITION FOR INTERVENTION 'pi 'J- day of ~";~J , 1995, comes Antlonette J. M, Galla (hereinafter referred to as "Petitioner") by and through her attorneys, Knupp & Kodak, P.C" and respectfully represents: 1, Petitioner Is the former wife of Defendant, Walter D, Galla, Co 2, Petitioner seeks to Intervene In the above-captioned aotlqn for kt e following reasons: . . ( , I , I I a. Petitioner Is pursuing Defendant for past due and accr'lJlng all: bny c, [11 pursuant to a marital settlement agreement. The amount owed as of October 20, 1993 was $63,138,00 with said amount Increasing at a rate of $520,00 every two weeks, (Some payments have recently been paid pursuant to a wage attachment,) b, Petitioner has flied a Petition to Intervene to number 11 95-S-1992, Cumberland County Court of Common Pleas which Is a support action flied against Defendant by Plaintiff, Defendant's present wife, In said action, Petitioner alleges that Defendant and Plaintiff are not separated and that Plaintiff's Support Action against Defendant is a fraud intended solely to stop Petitioner from receiving pest due end current alimony, c. Petitioner believes and hereby avers that most, if not all, of the assets of Defendant are In joint name with the Plaintiff. d. Petitioner believes and hereby avers that Defendant may seek, through the above proceedings, to transfer all of the marital assets to Plaintiff's name j I I or to have an unreasonable amount of alimony awarded to Plaintiff in an attempt to defraud Petitioner of her ability to collect past due and current alimony. . 3, A determination in the present ectlon as to equitable distribution and/or .1 j , , 'I alimony may affect the legally enforceable Interest of Petitioner and therefore Petitioner should be permitted to Intervene pursuant to Pa. R.C.P. No. 2327(4). WHEREFORE, Petitioner respectfully requests that this Honorable Court Issue an Order permitting Petitioner to Intervene In the above-captioned action, Respectfully submitted, 'l '/ Attorney I,D, . 42606 ont Street P,O. Box 848 Harrlsbur ,PA 17108-1848 (717) 238-7151 Attorneys for Petitioner Dated: cn- ~'t~\1 VERIFICATION GARY J, IMBLUM, ESQUIRE, verifies that he Is the attorney for the Plaintiff herein, that the Plaintiff's verification cannot be obtalnsd within the time allowed for . the filing of this pleading, that as attorney for the Plaintiff, he has sufficient knowledge and Information concerning the contents of the within document and that the facts set forth in the foregoing are true and correct to the best of his knowledge, Information and belief. He understands that false statements made therein are made subject' to the penalties of 18 Pa, C.S. ~4904, relating to unsworn falsification to authorities, d Dated: 9--"9 -~S' I! CERTIFICATE OF SERVICE r' I, Gary J. Imblum, Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing PETITION FOR INTERVENTION to be served upon the following by depositing same In the United States mall, first cless, postage prapald at Harrisburg, Dauphin County, Pennsylvania addressed as follows: ROBERT L O'BRIEN ESQUIRE 17 WEST SOUTH STREET CARLISLE PA 17013 CHRISTOPHER C HOUSTON ESQUIRE FOUR NORTH HANOVER STREET CARLISLE PA 17013 Respectfully submitted, 1 KNUPP & KODAK, P.C. (1.) ,.... By: G ry' J. Imblum j Attorney I,D. N , 4+i506 407 North Fro!), Stteet P,O. Box 1184'8 Herrlsburg, PA 17108-1848 (717) 238-7151 Attorneys for Petitioner Antionette J, M. Galla Dated: 7}-j o-'6)t\ ~ r ~, ~ ... .J '&,- ,.... "tJ"1 . ' ..-,~ c: 'r. ~ i ~Ul~~ .. Xl'\ " J !?",t'l HI' 1 C' ~... I" . I",r. -.~I .11...... ~;.c:;~ ;""J.r.~J l:~" f," 11\ ~~ -,PO -<1[:( ~ c: L-' .J:- (.0 ~ ~ ~ ~ ~ VS WALTER D, GALLA, Deft, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0540 CIVIL TERM ARLENE A, GALLA, PItt, IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, October 23, 1995, 2:15 p.m.,upon consideration of the Petition for Special Relief filed by Antionette J,M, Golla, and after hearing, it is herebY ordered and decreed that Arlene A. Golla and Wolter D, Golla ore hereby prohibited from transferring any of the assets of Wolter D, Golla or Arlene Golla to each other or to any third parties or from encumbering some in any way. Wolter and Arlene Golla sholl not sell or transfer any of their assets, and specifically their residence, to 0 person other than through on arm's length transaction, Mr, Houston and Mr, O'Brien ore directed to make sure that Mr, Imblum has 0 copy of the soles agreement os soon os it is signed. Antionette J.M. Golla sholl receive 30 days'advanced notice before settlement on sole of the house, including the sole price, buyer, and proposed distribution, Said sole sholl be continued if objections to said sole ore filed by Antionette J,M, Golla within said ten day period and ore not resolved prior to settlement, If said sole occurs. proceeds of some sholl be held in 0 Joint escrow account with attorneys of Antionette J,M, ., 95-0540 CIVIL TERM PAGE 2 Galla. Walter Galla and Arlene Galla as Joint escrow agents. Said escrow may not be distributed except pursuant to an Order of Court or agreement of the parties. Any Joint proceeds received from the house settlement sholl be held'inescrow by Mr, Imblum and either counsel on the other side until further Order of Court, . Christopher C, Houston, Esquire h 4 North Hanover Street ~ Carlisle. Po, 17013 I ' For the Plaint! ff II~\~< Robert L, O'Brien, Esquire \' ..r 17 Wes t South Street y Carlisle, Po, 17013 For the Defendant Gory J, Imblum, Esquire 407 North Front Street Harrisburg, Po, 17101 For Antoinette J.M, Golla :mtf By the Court. ',i"'" ,'1'.1 '.; I, ~i l.d !, ~ ); 'I.')~. IH.,' ',' i' '.: 'j I't 11'.) ,\I.I'1..hlil<..'~<l; ~i1~ JO jOI.JJO.IJ; :1 j 56, Hpo 6 1.\ AON 27. ARLENE A. GALLA . IN THE COURT OF COMMON PLEAS OF . Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V . . WALTER D. GALLA NO. 95-540 CIVIL TERM Defendant IN REI ARGUMENT CONTINUED ORDER OF COURT AND NOW, APRIL 27, 1995, the above case appearing on the Argument List for April 19, 1995, is continued by agreement of counsel. Counsel may relist the case when ready. By the Court, JJ ClAl'-"1( (::' . SA,l.e.e.!o/ Harold E. Sheely, P.J. Zl Christopher C. Houston, Esquire For the Plaintiff Robert L. O'Brien, Esquire For the Defendant Gary J. Imblum, Esquire For Antionette J.M. Galla Court Administrator Isld ~ N~~,L '1-1 cUi I (/ $' , .J.,~ ' <.......'" .:...- ~ Lr> en ~ -' ,-j ,0, ARLENE A. GALLA, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v . NO. 95-540 . WALTER D. GALLA, . CIVIL ACTION - LAW . Defendant . . . DOMESTIC RELATIONS SECTION . AND NOW, ORD~ S r day of ;Ii f[l}/(h,!fv agreement of all counsel, it is hereby ordered and directed that a this , 1995, upon hearing previously scheduled upon a Petition for Special Relief filed by Antoinette J. M. Galla for September 20, 1995, for 9130 o'clock A.M., is rescheduled to October 23, 1995, at 1130 o'clock P.M., in Courtroom No.3, Cumberland County Courthouse, Carlisle, pennsylvania. J. . HOffer,/Judge / Gary J. Imblum, Esquire Robert L. O'Brien, Esquire Christopher C. Houston, Eequire , _ Ctf-"'<J,., 'lHfld.".L 7/S/'15' ..1, 00, ,,,:,, lJ) !:;1 ,',' U1 , , - - , .... '1-. ,-'; 0 ' ,,"'~' 01 '. '-I '-"i"l s= ...~ :~ c.C c.n ARLENE A. GALLA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW WALTER D. GALLA, Defendant NO. 95-540 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: U.S. First Class Mail, Certified, Return Receipt Requested on February 3, 1995. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 201(c) of the Divorce Code: by Plaintiff on /p1;1~7;1~r- ; and Defendant on November 6, 1996. B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d) (1) (i) of the Divorce Code: None served as the parties signed the Waiver of Notice. N/A. Respectfully submitted, r ~oi Db.-:- Robert L. O'Brien, Esquire \, (") ( .,-," (]:. \~ (~, =; ,~ :'1 . ~) I ',i:) () 'ij ~.! 1." f~;i .;::( :'" ~ . ';..' , ", ::~ 1 i:TJ "'~ ~rn ., '0 ,-22) ,:::!} '-",.'. ....c) d'n '_-:,,1 ; ~:i -< ,'-> '- " , ARLENE A. GALLA, I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW 9i- f)/.f 0 CIVIL TERM IN DIVORCE Plaintiff v WALTER D. GALLA, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claime set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in theee papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request Inarriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR ., TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717 - 240-6200 . ,. . . " ARLENE A. GALLA, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v . CIVIL DIVISION - LAW . WALTER D. GALLA, . 94- <51../- 0 CIVIL TERM . Defendant . IN DIVORCE . COMPLAINT Plaintiff, Arlene A. Galla, by her attorneys, Broujos, Gilroy & Houston, P.C., sets forth the following: 1 Plaintiff, Arlene A. Galla, is an adult individual residing at 120 Linn Drive, Carlisle, Cumberland County, pennsylvania. " 2 ,\ Defendant, Walter D. Galla, is an adult individual reeiding at 120 Linn Drive, Carlisle, Cumberland County, Pennsylvania. 3 The partiee were married on August 30, 1986, in Carlisle, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that couneeling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. B~~fOS'"~ BO TON, P.C. Y hr~stopher C. Hou ton, Esqu re Attorney for Plaintiff 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 . .. , \ .' .. ARL~~LA (~ qc~,- I verify that the etatements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 paCS 4904 relating to uneworn falsification to authorities. ~;:~; ;'!\':' ~,'~ -',,; :1 :--,' : l'~;;;,.(' \. c<,F,O':_". ~}2Y~ }" "'. ::'i;~'_ ' ","-.' .:"',Li," ~'i:-{<} ~~<r\; -- M?c"; if' ::\~\l ~:'\;:( " ~}~~1:1~'!.._ &';fI:'r" :-. '\ i.7:~ ii:tL\' _ :.~-\' ~~t,'l' tt!r" , t~~ii(_~ ',,,;' ~i~~t:i' ~if'J:,f;-;'-- ~~}.j\:;...,{ !:'!~Y ~'/ ~,,!~r 'ft_::f" :,:c:o__,_, '~j"::"i< ~.lhL-.' ,tel "~ .. ~l;" -. (~)Y;;;"'::-<- ~:,~'-r" .'.'''.',', iHI)/' 'I"::' ,;~>~3:;-' - -;'~Y' '-:>:.< " .? [~ . !; ': ',' :) .,., .~ rEU 1153 MI'95 l. ~ "; I ~. (~1I ~; I.... " rl(il-. l " :;,.1::- rtJ.Y lj:1 : ',,; i r , . " j'l L' .fi 175, 50 tda..~ s. DD ..$0..+' - .~ I~D. 50 pcJa~ "qi -;.:.:p ".I.\i; if "'C..~. C,ke! I'J~" R~ ~lllPL{ ","'" '..". ,."-' ,_ -.. ", -;,"',\\t-fj~ ," r"'~) t';f~ f ::'--1;";" \ .. , ' \J' ["'; (: I i \ " "'-~-"':'~"~-'!1"'"_::~"'-"'-:'.,"-~~~~";,,,~~~,!:-_.t~~; . '""-~-""-'._'..'-"'-' . ,. , , , . .! , . , ARLENE A. GALLA, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v . CIVIL DIVISION - LAW . : WALTER D. GALLA, 95-540 CIVIL TERM Defendant . . . IN DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 1, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 90 days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. I understand that I may request marriage counseling and I hereby waive any right to marriage counseling which ie afforded me under the law. 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 authoritiee. DATE: I.+-/~ '7 J qs 1:~ {} 1aJ21",,- E E A. GALLA \ .. , , n \Jl ~ l- (Jl .". c::'I :i!~ 'ui,; Pl OJ!:,:I ,J If! .- ,,) 1'.') ~3 ~~l.'" (/J~; CO ~ti ~ :i~33 '- n ?;n -~ ."f? :;..tG:! r.:? (51 ....c ~ .? Q 0 ~ N . I I , , I I . ARLENE A. GALLA, IN THE COURT OF, COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v 95-540 CIVIL TERM WALTER D. GALLA, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c} OF THE DIVORCE CODE l. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rightA concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be' sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. Date: ~/91 C(l, ()k~, a~ffiL~ ARLENE A. GALLA, P aintiff ., Gq() ~?l~~\~~<L /1 ~_'ls.-\\", \Clc, \''<- -;;;'<' ~ ~. 'I . '" . . '. () ,.0 0 ~ '-" -Il "'r~i ." '-J ,-rt r:lf'Y (~JL! ,:;:) ~'~' - ""'l? .~ ~ :q (J.~ . ~~ Op 8.~ ::! ~:j 'J -'.....r !'~F.1 q:~~~ r- 1:3 '" .. ~ .:J 0::> ~ -. N -- I, v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW 95-540 CIVIL TERM IN DIVORCE ARLENE A. GALLA, Plaintiff WALTER D. GALLA, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on February 1, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 90 days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. DATE: ~ I fc Ji)~QJ~~ W ER D. GALLA # ,- ...'C .." .~,....... ._..'. ._..~ .., _ .t-, _ . .. . . o. . u'1 u., ~? o '11 '.'J "",'I:T!~ " 'J ') ';I-i] -~ "I] I.~l~ ~)rt'1 ,-, ,~ :'.u ...; () (o' '-'1: [!Jt' \ r:::;. . err ...::" ~-:I . ',: ~ :'l'! ..~~ t -,~ ;-.'.; ,,' "', ~ ::": :":' en '- - .. . I .. . I t ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE l. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date :-ill. b I q t ' l ~ ~ A ~- & D. GAL~Defendant , .. ," . " , \ n \(.1 (1 r" C,.J"' "I' ..- :.J ~i "3 .:n en. " "r,- ". ""'l~ ::-.;i f'>,) (/~ .- ) , '-~I- ~ ...~. ~.:\. ;...~ ,-., ~;l- '."1~~ ~I '? ~5rn .I'~ ~ .:. :;~ -::' :J~t ~: ()1 ". ft.~~/;:",~) ,,:,r';1 ;i_:..,:' ,.' , l'li' R '" [>I~~Com.,"tI~~~:~~ot'i'or~don.t..fY~'~.;.;:.-;:~-,~ '. ,,_ H'1110 wli"h,to 'ec.I~I(fthi,. _,-I '~i ;7:!e~~t: ~~~::.~ ~'i~!~""r;. al lid. 10m, ~alhii woe." ::~~~I~g ..IVlc.., !rDI.~ .~'lr. ,~: I;: r,:~'~~'~'I~~~J~~;~: i;~n,al t~';'~;ipl;~~, a; an I~ b'~kli ~P'C' i, b .~. Add;.,.~ ':. ~: 1:':.s\-,t~';:'l_~::;,"~~i~tA'~~~~~;';;;t~'~~PioU'~~w t~'~Um~' ._"~, ~#<~. ,i' ;:.i;ThlIR'tufn"tc.lptwm.ho.-tow~_tht,'rUdtw..dt_livtttd.nchhed'l' ;~_J~_"" " ," <-/:.:--:,~,~!, ~~ g\.d'.VI'td;'.~,:"~-~;;':::";' ",;-,' "'.': :.,', :,'" :: '-, !J1P, -.,: > Consult oltmaster for re.:,";"_':-;' ; ':....':'3.. Anlcl.Addr....dID: ,', ",' ',', ,,' :" 4.,'Anlcl.Numb., :,'"':.....,, ",,', " : ,':1',:,":'''::'''''),''''',,:'''''',':'':' '," '''",' ',' '28 '12i3'l"'i:':"';:;':""'~"!.':j: .:I)/,~I1U~ALTER.D,'~ALLA.' ""," P 8 3,' 7.. ""':", , 'E,,",.120':LINN'.DR'/"<'d,: ,.", ,4b,Servlc.Typ., ,,',,,',,>,,,,,,,,,,,;," \'8,:;~:dARLISLE:PA','liO'13' ,,';,' 0 Regl.t~'.d:):D,'n.ur~~ ;\;:;,;:',:" ~i )~i/.t,1(,;:';~/'ln,::\;~t'i~> " >';:)~~:~~~:M~iiEg ~~~;~;R~~~I'~~;O;~;'{: t' 0'::'1::);';-:'\';::' :-"":~,:",,.: ',. "..' ;." ,', ," I.' ""'15' ,0'"''''\'''.''''' ,,,,,> ,I,,'.,'.., "",.,1':/..'0."010...." ",,'.. """ ....' L!i ;;;fi!~;,:(.F:'~{.fjS;~;f;';:;:;:;.'~Z::...:, I. ' ,/:i":I;':';.:,,.:ttff:~;' ~"".,: :{,;<:',i~ ;i, I. ~~ddnl.' a.."Addr....... Addr...IOnly qU..I.d!: ~.; &,' SI ~~:r.(Aginl'" , , ;'; i.n~f~,~,trl~'.: ,)/<~:t~:;,;',i~~~h=: 1~!I""-'''''''''''''''''' .=' "",'';',',!.. ;",,'" '.',1":" """"',,\\ ~~l:-:t'1.;.,":.\":i<":i;':';i~"'/t:Hjf~.{..) ,l "!i.-: _ ..';-' -. ~':~,.:~L,","-\-./~:Jlt:.~.~Jl-l{~~Y\:\;.~ \i..!'!lto'l'! , /. J pr"i'\u., ,1~9.', 1t,~ 'r~ ,3':H!4 , ; DO,ME8~C RE!~R~ ~ECEI~}'. ......~lIdtJlu".....oI,j Itll,"J...!.iI ." "....' , ","'",", ,', .'.. ..\-, ".:.!f.\,. ~ I....... .. ,j ... ARLENE A. GALLA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA. Vs. CIVIL ACTION - LAW WALTER D. GALLA, Defendant NO. 95-540 CIVIL TERM CERTIFICATE OF SERVICE I, Christopher C. Houston, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. BRO~J9S! GILROY & HOUSTON . /714 BY / '~, ~ '1'([ L--. tChristopher C, Houston, Esquire DATE: /,;J/rp/9f.. . f " . . , , ~;c.",...v ~-~,_.,~'..,"-.. ... t, " I i i ( l."J I f, ! , I ,- ',"', :..1\ 1 " '") I I ~'J " .. j : I,".'] , ;2.1 " .L '10 "..1 ',.., '1,") ,-\It1 ~::l :::5 ~~ "-:1 ~!; ! !~'! r~; ,-.! ~. -: j :~:. . I '.' r.:J / , glll...00 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-540 ARLENE A. GALLA, Plaintiff WALTER D. GALLA, Defendant CIVIL ACTION - LAW ARLENE A. GALLA'S ANSWER TO THE PETITION FOR INTERVENTION AND NOW, comes the Plaintiff, Arlene A. Galla, by and through her attorney, Christopher C. Houston, Eequire, and answers as follows: 1 Admitted. 2 Admitted in part and denied in part. It is admitted that the Petitioner is pureuing the Defendant for past due and accruing alimony and that the Petitioner has filed a Petition to Intervene to 1195-S-1992 in the Court of Common pleas of Cumberland County. It is specifically denied that the Petitioner has any legal basie upon which to seek intervention in the proceedinge at l195-S-1992 or in these proceedings, that the Plaintiff and Defendant are not separated, or that Plaintiff's eupport action is a fraud. By way of further answer, the Plaintiff is not seeking to transfer all of the marital assets to her or seeking to have an unreasonable amount of alimony awarded to her. ~ . , \ ' 3 The averments of Paragraph 3 of the Petition eet forth a legal conclusion to which no response is necessary. To the extent that a response is deemed to be necessary, the averments of Paragraph 3 are denied. WHEREFORE, the Plaintiff reepectfully requests this Honorable Court deny the Petitioner's intervention in the above-captioned proceedings. ~"' Chr stopher e. Houston, Esqu re Attorney for Plaintiff Broujos, Gilroy & Houston, p.e. 4 North Hanover street Carlisle, PA 17013 717 - 243-4574 . - I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made eubject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Q\.Lo~ 0 .qCi~ ARLENE A. GALLA '. r ! ': ARLENE A. GALLA, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-540 v WALTER D. GALLA, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I 1 I, I I I I I, Christopher C. Houston, Esquire, certify that on this date I served the foregoing document by first class mail, postage prepaid, on the following: Robert L. O'Brien, Esquire O'Brien, Baric & Scherer 17 West South Street Carlie'le, PA 17013 Gary J. Imblum, Esquire Knupp & Kodak, P.C. Cameron Mansion 407 North Front Street P. O. Box 11848 Harrisburg, PA 17108-1848 Date: r.r/(j1 \- hr etophe C. Houston, Eequ re Attorney for Plaintiff Broujos, Gilroy & Houeton, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 ,,' ~"""'-~- ..~-_... --'.-""". t::- " '. I' '~J .') ,... " f;f' "" ;.'i,:::::1'4' ;.":.,,1"0'- , ., 1'__;1 . "I -:'C f ''< " , , c...> to N ,',." ,:.'. ..':: ~"'1 I>. :'UI .....1 ~... ~.. .< ;.rt ~..: " .::.:: <.0 t.I;. .,.' ,.... PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and sumitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next: o Pre-Trial Argument Court . Argument Court ',', i CAPTION OF CASE (entire caption must be stated In full) vs, (:) =r.: " , . , '" .. ....-' . " -.J I ,', r , " " . " C.u - " .. '" ..~ , ~. ,~, , W I, '~':f~ -0 = .., I' ..; - -' c..n <.r' ARLENE A, GALLA Plaintiff WALTER D, GALLA Defendant 9t - SilO No, +t95 Civil S 19 Jl2....; 1. State matter to be argued (I.e" plaintiff's motion for new trial, defendant's demurrer to complaint, etc,): Petition of Antionette J,M, Galla for Intervention Motion of Antlonette J.M, Galla for Consolidation 2, Identify counsel who will argue case: (a) for plaintiff: Christopher C. Houston address: 4 N, Hanover St., Carlisle, PA 17013 (b) for defendant: Robert L. O'Brien address: 17 W, South Street, Carlisle, PA 17013 for petitioner: Gary J, Imblum address: P,O, Box 11848, Harrisburg, PA17108 3, I will notify all parties In writing within two days that this case has been listed for argument. 4. Argument Court Date: April 19, 1995 ~~/ A; (Attorney for pelllOrr) Dated:~/0i h')~ ! j '.; '''" MLM OIA::03/24195 AEV,03/24195 -1 . j j, i I J I CERTIFICATE OF SERVICE I, Gary J, Imblum, Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing PRAECIPE FOR LISTING CASE FOR ARGUMENT to be '.'.' ; served upon the following by depositing same In the United States mal/, first class, postage prepaid at Harrisburg, Dauphin County, Pennsylvania addressed as follows: ROBERT L O'BRIEN ESQUIRE 17 WEST SOUTH STREET CARLISLE PA 17013 CHRISTOPHER C HOUSTON ESQUIRE FOUR NORTH HANOVER STREET CARLISLE PA 17013 " Respectfully submitted, KNUPP & KODAK, P.C. By: Gary J, Imblu Attorney I,D, 0, 1 606 407 North ront $freet P,O, Box 1 848 Harrisburg, PA 17108.1848 (717) 238.7151 Dated: 3-?~ -qtj Attorneys for Petitioner Antlonelte J,M, Galla -..:" " .\ ORIGINAL i: ; , ,...., 1 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2 3 ARLENE A. GALLA, PLAINTIFF :1 VS. CIS - S~O NO. H!l5 S 1932 4 5 WALTER D. GALLA, 6 DEFENDANT 7 8 9 10 DEPOSITION OF: WALTER D. GALLA 11 TAKEN BY: INTERVENOR 12 BEFORE: ELLEN SWAYZE REISSER REPORTER, NOTARY PUBLIC ,:; 13 DATE: MAY 19, 1995, 9:25 A.M. 14 PLACE: KNUPP & KODAK, P.C. 407 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 15 16 17 f,) \~,,', ,-: , , \= '" 18 = 19 ,J" , ~.; I~~,., '_rl '~~Jl .c- ;~~. :-; '~ ~~ \..- '-~ ,,,, ~, ~r< :.... :.~ "" QI -0 ::>: 20 21 - u:> c.T1 22 23 24 J 25 GEIGER 6 LORIA REPORTING SERVICE, 2"08 PARK DR, SUITE 0, HOG, PA 17110 7l7'~"H~08 OR 1.000.2Z2..e77 2 f') 1 APPEARANCES: 2 CHRISTOPHER C. HOUSTON, ESQUIRE FOR - PLAINTIFF ROBERT L. O'BRIEN, ESQUIRE 3 4 5 FOR - DEFENDANT 6 KNUPP & KODAK, P.C. BY: GARY J. IMBLUM, ESQUIRE 7 FOR - INTERVENOR 8 9 10 11. 12 ~.., 13 ::...J 14 15 16 17 18 19 20 21 22 23 24 25 v GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE B. HOG" PA 17110 717'!5"'HIOQ OR I'BOO'2:22'4877 3 Ii 1 TABLE OF CONTENTS 2 WITNESSES 3 4 FOR THE INTERVENOR DIRECT CROSS REDIRECT RECROSS 5 Walter D. Galla By Mr. Imblum By Mr. O'Brien By Mr. Houston 5 72 54 77 67 6 7 8 9 10 11 EXHIBITS 12 () 13 ANTIONETTE GALLA EXHIBIT NO. MARKED AND PRODUCED 14 1 - Separation Agreement 6 15 2 - Spousal Support Agreement 20 16 3 - Motion to Void separation Agreement 23 17 18 4 - Amended Order of Attachment of Income 44 19 20 21 22 23 24 25 \.,....1 GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE D, HOG, PA 17110 717".1>1'08 OR 1'800'222'41577 ~ 10 11 12 o 13 14 15 16 17 18 19 20 21 22 23 24 25 ~ 4 1 EXHIBITS 2 WALTER GALLA EXHIBIT NO. MARKED AND PRODUCED 3 1 - Earnings Report 54 4 5 2 - Letter dated 11/21/94 from Arthur L. Rhoads to Walter and Arlene Galla 54 6 7 3 - Letter dated December 1, 1993, from Richard H. Neff to Walter Galla 54 8 4 - Photocopies of wage stubs 56 9 5 - Photocopies of wage stubs 56 6 - 1994 Income Tax Return 56 7 - Purchase arrangement 57 8 - W. Galla to T. Galla payments revised 6/25/92 58 9 - Income and Expense Statement of Walter Galla 77 GEIGER a LORIA REPORTING SERVICE. 2408 PARK DR, SUITE D, HOG. PA 11110 711""H!lOU OR 1'800'22Z'4en ~ 1 WALTER D. GALLA, called as a witness, being 2 sworn, testified as follows: 3 4 DIRECT EXAMINATION 5 6 BY MR. IMBLUM: 7 Q walter, my name is Gary Imblum. I'm the 8 attorney for Antionette Galla. We're here this morning to 9 take your deposition in the matter of Arlene Galla v. Walter 10 Galla with respect to a petition for intervention into that 11 proceeding filed by me on behalf of Antionette. 12 You're here today represented by your attorney C) -'." 13 Robert O'Brien. I'll be asking you some questions. If you 14 don't understand the question, you're free certainly to ask 15 me to repeat it or to clarify it for you. 16 If at anytime you need to talk to Bob, Robert 17 O'Brien, you can do so. And we can take a break and you can 18 talk to him about anything you need to talk to him about. 19 Do you understand the instructions? 20 A I do. 21 Are you under the influence of alcohol or Q 22 drugs right now? 23 A No. 24 Q All right. You were previously married to 25 Antionette Galla, is that right? v GEIGER A LORIA REPORTING SERVICE. 2..00 pARK DR., SUITE D, ItOG. PA 17110 717.~.H'08 OR 1.000'222'''577 5 1"""\ 1 A 2 Q 6 Yes. And at some point you became divorced, you and 3 Antionette were divorced? 4 A 5 Q 6 August of 1980? 7 A 8 Q Yes. And you entered into a separation agreement in That's true. And pursuant to that separation agreement -- 9 well, let me show you what we'll mark -- 10 A That separation agreement was contested in 11 Virginia court prior to coming up here. 12 Q "~") (t!~' 13 Yes, and we'll get to that. MR. IMBLUM: If we can mark that as Antionette 14 Galla Exhibit No.1. 15 (Separation Agreement marked Antionette Galla 16 Exhibit No.1.) 17 BY MR. IMBLUM: 18 Q I'll show you Antionette Galla Exhibit 1 and 19 ask if you can identify that? 20 A Yeah. This is it. The attorney of record on 21 this thing is deceased, also. 22 Q But this is the separation agreement between 23 you and Antionette? 24 A 25 v True. GEIGER 6 LORIA REPORTING SERVICE, 2408 PARt< DR., SUITE 8, HOG. PA 11110 717-!14H50Q OR 1'800'2Z2.~577 Q And pursuant to that agreement, were you to o 7 1 pay, after your children reach majority, Antionette $520 2 every two weeKS for alimony? That's correct. I paid her a total so far of 3 A And I'm aware Including all the child support and monies Including the child support? Yeah. And at the point of the claim I was 10 overpaid with -- I had overpaid the amount of money due at 11 the time in May -- whenever that came up here -- 1993. 12 c) 13 14 15 ....J 4 over $225,000. 5 Q 6 A 7 beyond that. 8 Q 9 A I can verify. We have some other records that " we can get into later, if you wish. Q Well, one question I have, you later in Virginia challenged the separation agreement; did you not? 16 A I was told thet I should not come to the state :- , j..... 17 of Virginia. I was represented by counsel down there, but ','i.i .,::q~ 18 for fear of being put in jail. -<i ';'& 19 20 A Virginia. 21 22 '\1; Q But your counsel filed to -- ; ,"','. :-'\;1 yeah. I did not make an appearance in .,-;; ':.Il ....,\ ".if!;' Q And a court order was entered -- there was a _~'ti 23 decision by the court down there that included an evaluation ..,.,',f,; ': "', ,U:.l ~,.;?~1. 24 of what you owed on your past due spousal support? A There was a judgment entered against me for -:.:;,j-'~ 25 \\~ ",;.;;.; .;1';"'" ;-;-,:\{~' '. GtlaER I!II LORIA REPORTING sERVICE, 2400 PARK DR. SUITE B. HOG., PA 17110 717'l5"l'l!SOO OR 1-800'222.A5'17 '''~.i "C-'--' /'t :I .":,., '""l '''') [ '~.'''"'! B 1 $63,000. My question is, if yOU said that yoU paid as g .uch'. yCU .,y yOU h'V' to Antion.tt., whY would tho couct . h.v. .nt.c.d .n ocd.c lik. th.t .nd why wouldn't yOU h'V' 2 Q 5 been represented at the time? 6 A MY attorney had recommended at that point 7 there waS several other claims of fraud committed by , Antionntt. .nd .y .ttocn.y tog.th'C th.t wnc' put up fcont 9 and that was never resolved. 10 I ...n, It w.n ca.olv.d hy tho i..uanc' of · 11 judgment. I could not appear down there. " Q couldn't yoU h.vn givnn anY pcoof th.t yOU h.d 13 of payments to your attorney to present? 14 A My attorney died. MY attorney was an addict 15 and he died. wasn't he at the proceeding that resulted in 16 Q 17 this order? NO. The original attorney 1 had reported that 19 h' h.d committ.d tho fc.ud w.. d.c....d. And tho .ttocn.y 18 A ,0 th.t c.pc.,nntnd .. down th.c' ,.id h. ,hould puc,u. th.t " c.th'c than tho ,0 oc $gO,OOO ov.cp.yo.nt th.t I h.d mad. 22 based on the records that yoU have. MR. IMBLUM: For some simplicity, this is a ,. copY of tho ocd.c of octohac '0, ",g, th.t" pcaviou,'y 23 25 attached. DO YOU want me to mar~ each of these or -- .J GEIGER. LORIA REPORTING SERVICE, a40B p~R' DR, SUITE Bo HBO, p~ 17110 1I7,..",50B OR "BOo,,a"4571 9 I, I' I"l 1 MR. O'BRIEN: Whatever. It's already a part of the record in the sense that it initiated this whole , " i.\ 3 process of the -- Ii I' i 2 4 MR. IMBLUM: This was filed here. 5 MR. O'BRIEN: Yes, it was filed. 6 BY MR. IMBLUM: 7 Q I'll show you a copy of the order of Fluvanna 8 Circuit in virginia entered October 20, 1993. Now, on the 9 last page it indicates that you're represented by counsel. 10 A That's correct. 11 Q Is that the counsel that you referred to that 12 passed away? l::J 13 A No. The one that was part of the original 14 agreement. We had a claim against Antionette that my 15 attorney -- we used one attorney and that one attorney 16 represented both of us. He was my attorney, 'but he 17 represented both of us. 18 And we charged Antionette with fraud for 19 conspiring to rig this agreement in this way. 20 Q But at this proceeding -- At this proceeding here this is the result of 21 A 22 that action down there. And we did not at that point bring 23 up the overpayment. 24 But I'd like to give you this and this in 25 relation to that. That is a spread sheet that shows the J '-' GEIGER &; LORIA REPORTING SERVICE, 2400 PARK DR. SUITE D, HOG. PA 17110 717.541'1!500 OR 1-800'222'."77 10 I"j 1 summary of the overpayment at the time which has since 2 been expired. In other words, by not paying that may be 3 moot; but that is the amount of money that was given to her. 4 5 6 in error. 7 8 through 1987? 9 A 10 Q 11 summary to me. 12 A Q So you're alleging that these -- That the figures -- that $63,000 judgement is A Q Now, the dates on these checks range from 1983 Yes. What do you -- now this summary. Explain this The summary shows that basically -- I need to o 13 refresh my memory here. That basically I would of had a 14 positive $12,000 in '87 and subsequently dropped. 15 But the judgment -- if we looked at the 16 numbers -- the amount of money that was available when this 17 judgement was made, it shows that I had overpaid -- I think 18 it was credited. 19 Q 20 A You were credited with 17 -- From June of '87 through May of '93, okay. 21 And in June of '87 sometime in here I was $22,000 ahead of 22 the game by the records of these checks. 23 Q 24 1980. 25 A . j '-' This agreement was signed in 1980, August of That's right. GEIGER A LORIA REPORTING SERVICE, 2400 PARK oR_. SUITE 8. HOG. pA 11110 717"'41-1'00 OR 1'800'222''''77 I"""') 1 Do you have any record of payment from August Q 2 of 1980 through 1983? 3 A Yes. I have all the checks. I didn't bring 4 those with me. Since this applied to only this time period 5 I brought these records. And here's a summary of what had 6 happened all the way,along, from 1980. 7 Q Will you produce the -- 8 A I've got another stack of checks like this 9 (indicating). I didn't bring those because I had entered 10 this as -- this is a summary of it here (indicating). 11 MR. O'BRIEN: Off the record a second. 12 (Discussion was held off the record.) ..."..\ V 13 BY MR. IMBLUM: 14 Q What other proof do you have of payments made to Antionette? 15 16 A I have the actual checks with her signatures 17 on the back. For all those checks. 18 Q For all the checks that you've given me a copy 19 of today? 20 A Yes. 21 Do you have copies of any checks or proof of Q 22 any payment since December of '87? 23 I have made payments -- yeah. I made A 24 payments. I made a couple of payments, but I don't remember ....J 25 when they were exactly. GEIGER 6: LORIA REPORTING SERVICE. 240B PAnK DR., SUITE D. HaG. PA 17110 111.e.H!:lQB OR l'OOQ'222.A!:l77 11 f I 1 2 3 4 5 6 7 8 9 10 11 12 <) 13 14 15 16 17 18 19 20 21 22 23 24 25 J -~--"~ , 12 Q W", yoU throu.h coun..l prov'd' o' w,th proof of anY payment made since December of '817 A y..h. It w...'t . .,..'f'c.nt amPunt. Wh.n .h. d.c'd.d to fll' .n't ...'n.t .. 1 .topp.d p.yo.nt. I had maintained -- as this record shows, I had ..int.i..d p.yo.nt. th.t w.r. rou.hlY $4,000 · y..r for several years. And it was my understanding at that time that tho $4,000 w.. .d..n.t. -- w.. .o'n. to r.l"V' .. of this r..pan.'h,"ty. It w.. not wr,tt.n. ..YD' lt w.., '0 f.ct, . un".t.r.' ..r....nt. Bnt D.cau,' th.r. w'. no pur.uit ,. this, this waS -- Q The order is approximatelY -- A yeah. I mean, I had pursued -- Q __ 13,000 14,000 a year, isn't it7 A ya.h. 1 h.d .ctu."Y -- ,n th" ca.. 1 had go.' out with" lif. th'nkin. that th" i. what 1 w.. .oin. to p'y, And for th.t p.r,od of t'o' 1 thou.ht th.t w.. -- yon ,"ow, wh.n 1 .ot this .uit ...,n,t .. 1 ju.t ..,d tho hell with it. I didn't pay her anymore. Q I'd appreciate it if YOU would produce any other evidence yOU have of payment. NOW, when yoU got divorced from Antionette, what .,..t. did yoU ..d up w,th uut of tho .arri..., A $1500 and a '14 peugot and relocated up here. ,,,,.. . '0'" ....."" """,. ".. "" ... ~'" '. .". .. "," ,,,.,,.,.... ,...."'..." 13 (1 1 At that point she was receiving 50 percent of my income. 2 3 4 5 Q A Is that pursuant to the alimony order? That was what was given her. Or pursuant to the separation agreement? Yeah. That agreement was based on potential Q A 6 reconciliation. And there were some clauses that were left 8 disbarred. 7 out. My attorney down there, the deceased one, was 9 I tried to get evidence against, you know, 10 against that, but they couldn't open the Virginia records 11 up, so. 12 Q (""" ,#!pI 13 your name whenever you separated? 14 A 15 Q 16 A Did you have any bank or checking accounts in No. We ,had a joint account, that was it. Who ended up with the joint account? She did. I ended up with liabilities of owing 17 her mother, I guess, 4,000 or $5,000. It's all in the 18 agreement as to what I got. 19 I mean, the agreement is totally one sided and 20 was made that way based on reconciliation within a year or 21 two. 22 Q There's nothing in the agreement that refers 23 to reconciliation? 24 A 25 No. There's a number of things that out of that agreement. I trusted my attorney. At that -..) GEIGER a LORIA REPORTING SERVICE. 2400 PARK DR., SUITE S, HaG. PA 17110 717'~"H!50D OR l'OOO'Z:ZZ"U577 14 .'1 1 point in time I was an active alcoholic and had a lot of 2 sympathy, you know. 3 Q Now, let's move over to your marriage to 4 Arlene. When did you and Arlene get married? 5 A August 30, 1986. 6 Q Now, after you got married, how did you two 7 divide up the paying of the bills in the household? 8 A She took care of most of the bills. I'm a 9 very active person in my job and maybe tend toward a little 10 workaholism and she takes care of the bills and I 11 participated whenever I could. 12 Q She took care of physically paying the bills, i::) 13 but whose money went towards which bills? 14 A I gave her a check and we put our checks 15 together and we paid bills, as normal married people would 16 do. 17 Q Did you give her your entire check? Yeah. 18 A 19 Q Was there any allocation that your check went I i ! , 20 to pay bills X, Y and Z and her check went to pay bills A, B 21 and C? 22 A No. It was what I would consider a normal I, ;,'1 23 marriage relationship. I don't know how you do it, but 24 that's how I did it. And I did that with Antionetts, too. v 25 Q What assets have you and Arlene acquired GEIGER 6 LORIA REPORTING SERVICE, 2408 PARK DR., SUITE D. HOG., PA 17110 717'S41'lSDO OR 1'000'222',4517 15 I ! ! , : ! ! '1 1 since YOU've been married? A few thousand dollars in mutual funds. j! 2 A 3 Q 4 A Can you be more precise than a few thousand? ',j 1 I don't know. probably as far as jointly 5 owned funds go maybe about $36,000 worth. 6 Q 7 A 8 Q 9 A 10 Q 11 A Whose name are those mutual funds in? They would be joint. Have they always been a joint thing? Yeah. Who are those mutual funds with? They're in the record here. I don't know what 12 they are. They're located in the income tax statement. (""" ,,~ 13 I don't know what the current status is. A 14 good portion of the funds were reduced to cash status on the 15 basis of the volatility of the stock market and expected 16 down turn, so we just put it into other things. I guess 17 they're in CDs or something. I don't know. 18 19 Q How long ago did you reduce them to cash? Within the last couple weeks probably. And A 20 looking at the stock market, it was very difficult to 21 project what's going to happen. 22 23 were they in? 24 , '--J 25 GEIGER a LORIA REPORTINO SERVICE, 2400 PARK DR.. SUITE D, HOG., PA 17110 717'SCH!lOB OR l'BOO'2U'4~77 Q Is that money now in bank accounts? Q The ones that were reduced to cash, whose name A Joint. 'I 1 A 2 Q 3 A 4 Q 5 have a house? 6 A 16 I think so, yeah. In whose bank accounts? Joint. What other assets have you acquired? Do you We have a house having a mortgage on it. 7 Approximately about an $80,000 mortgage. 8 Q 9 A 10 Q 11 A 12 Q "", (",.,; 13 A 14 Q 15 A What do you estimate that house is worth? Maybe a hundred. Is that house up for sale? No, not as of yet. Do you plan on selling it? We do. When do you plan on marketing the house? When it's ready for sale. I'm still doing 16 work around the house to try to get it cleaned up and stuff. 17 I would quite frankly like to be rid of all of 18 this as soon as possible. 19 Q 20 A 21 22 A Now, do you have a pension fund? I have a 401K. Q What's the approximate value of that? 22,000, ballpark. I had a break-in two weeks 23 ago Tuesday and a lot of my financial records in my computer 24 were taken. The computer was taken. 25 v I had two computers taken. One from the GEIGER 6: LORIA REPORTING SERVICE. 2409 PARK DR., SUITE B. HOG., PA 17110 717'!S4HSOB OR I'BOQ'222'''S77 17 ,') 1 company and mine. My file cabinets have been gone through. 2 They took Arlene'S credit cards. They took a whole bunch of 3 stuff. 4 My file is in disarray so I don't know what 5 else was taken. I just mention that as a fact that when you 6 gave me this statement to bring this stuff in, I was out of 7 town. We had just been broken into before I left on the 8 trip, that's why we postponed it until today, if you recall. 9 And I didn't have time to get all of the 401K records. 10 Q These two computers, were they at your home? 11 A Yeah. 12 Q what else was taken? (", "'f'~ 13 A Possibly some stuff in the files. My wife's 14 credit cards were taken. A camera was taken. Sixty dollars 15 in cash was taken. A number of other things. We have a 16 police report. I have a police report number, if you'd like 17 that. 18 Q Yes, please. What police? 19 A Carlisle. The police report is 9506299. I 20 had a lot of records that I carried with me that pertained 21 to some of the matters we're discussing here were in my 22 traveling computer case so I don't have all the things I 23 would have liked to bring. 24 But they didn't take the checks or any of the 25 other stuff that was there. ....J GEIGER a LORIA REPORTING SERVICE. 20408 PARK DR., SUITE B. HOG., PA 17110 7I7.e"HeaD OR 1.BOQ'222..en rJ 1 Q So the assets that you and Arlene own, you 2 have the mutual funds, the house, the pension. What other 3 major assets do you have? 4 A I have a car that I use as part of joint 5 property. It's a 1992 Honda Accord. 6 Q Whose name is that in? 7 A That's in joint. There's a 1988 Honda Civic 8 I believe is joint. I'm not sure. It could be Arlene'S. I 9 don't remember. 10 And she has a paseo and I believe that's 11 in her name. 12 Q Any other major assets? 13 A No. 14 Q Have you transferred any of your assets since 15 you've been married? Transferred any major assets since 16 you've been married to Arlene? Sold, given away? 17 A No. 18 Q Was there anything in your name personally 19 when you got married that you transferred into Arlene's 20 name? 21 A probably me with my liabilities. 22 Q Okay. But how about was the house purchased 23 after you were married? 24 A Yeah. I wasn't really credit worthy at the 25 point of entering the marriage. c:::> v GEIGER a LORIA REPORTING SERVICE. 240B PARK DR., SUITE B. HOG., PA nllo 117-!54H!50B OR 1'80Q'222'4!177 18 I) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 C) v 19 Q Did you own any major assets when you were married? A Previously? Q When you got married to Arlene. A No. I had a 1982 Horizon. Q Did you have a house? A I did not have a house when I married Arlene. I lived in apartments. Like I said, I could not afford a house. Q Did you have mutual funds then? A No. I didn't have any mutual funds. I didn't have anything. I was not able to on that income. Giving her $13,520 every year, I couldn't do anything with that. Plus I covered my kids' costs for schooling, which is not counted in that $225,000. Q At what rate are you contributing to your pension plan now, do you know? A Nine percent. Q How long have you contributed at a rate of nine percent? A I believe since I got started at that company. Q How long ago was that? A Oh, golly. I don't know. The last part of 1990. I am concerned about, you know, about the fact that I am -- you know, this is going to take some time because I GEIGER a LORIA REPORTING SERVICE. 2408 PARK OR. SUITE D, HOG, pA 11110 717,54",508 OR 1-000'222'4577 (') 1 don't want to place myself at too much jeopardy at the job. 2 It's been a lot of stress lately, you know, with all this 3 stuff. 4 But we have to get through these things this Q 5 morning. 6 Now, in November of 1992 you and Arlene 7 entered into a support agreement. 8 A We were having problems together. A part of 20 9 it was related to my recovery from alcoholism. And part of 10 it was what you're handling now, this thing. This fiasco. 11 MR. IMBLUM: This will be Antionette Galla 12 Exhibit 2. r:.:> 13 (Spousal Support Agreement marked Antionette 14 Galla Exhibit No.2.) 15 BY MR. IMBLUM: 16 Q Mr. Galla, I show you Antionette Galla Exhibit 17 2 and aak if you can identify that? 18 19 A yeah, that's ours. Q And that's the support agreement between you 20 and Arlene? 21 22 A That's true. 23 sentence -- the last sentence says, "In addition all jointly Q Now, in this agreement it refers in the last 24 held property will remain in control of Arlene Galla during 25 \ ' . -.....) I ! this period." GEIGER 1Ii LORIA REPORTING SERVICE, 2408 PARK DR. SUITE D, HUG. PA 17110 717"41.1508 OR "000'222'4577 21 ,'") 1 A I did that just to give her in good faith that 2 I wanted to reconcile. I wanted to remove any feeling of 3 loss from her, so I made that agreement on that basis. 4 Q Now, you said you were having problems at this 5 point, that's why -- 6 A Yeah.. Yeah, that's right. This is what -- 7 as I indicated, I'm a recovering alcoholic and I'm changing. B My whole way of relating is changing, so I have problems and 9 that's the result of it. 10 Q Now, how did you and Arlene arrive at the 11 value of $1800? 12 A My analysis of what we were spending was o 13 basically that she needed $900. Right now with the $400 " 14 , that you managed to get out of the judge for her every two 15 weeks we're in financial difficulty. 16 Q Back at this time though we weren't getting 17 $400 in wages. 18 A No, that's true. No. What I did is I filled 19 this out. And besides, I had already set a precedence with 20 my previous wife. I gave her 50 percent, too. I didn't 21 think there was anything wrong with that at all. 22 Q So this was calculated based on 50 percent of 23 your net? 24 A Yeah. Basically on that fact that I had 25 looked at the analysis. I did an analysis of what we v GEIGER a LORIA REPORTING SERVICE. 2""08 PARK DR. SUITE 0, HOG. PA l71l0 717-!541'1&00 OR "800'ZU',U77 22 r) 1 were spending and it looked like she could make it with $900 2 and maintain all of our jointly held property. 3 You remember I had mentioned, I had given 4 Antionette 50 percent of my income when I came up here, too. 5 I thought there was nothing wrong with that. Are you saying 6 that there is something wrong with that? 7 Q I'm just asking you why you did what you did. 8 A That's why I did it. 9 Q Did you ask anyone how much you would be 10 paying if the court ordered you to pay support, how much 11 you would pay? 12 A No. () 13 Q Are you aware that if the court ordered you to 14 pay support under your net income and her net income it 15 would be closer to $880 a month instead of $1800? 16 A Well, .you told me you could take 65 percent of 17 my income. 18 Q My question is, are you aware that based upon 19 your net income and Arlene's net income at the time this 20 agreement was entered into the total amount that you would 21 have been ordered to pay her in support, if she had pursued 22 it to the court, was approximately $880 a month? 23 A Why did the domestic relations office permit . i i 24 it to happen? 25 Q Because you agreed to it. -......) GEIGER A LORIA REPORTING SERVICE, iZ40B PARK DR., SUITE B. HOG. PA 17110 717'5.1-1500 OR 1'800'222'4577 ..:: ":"'\ " 1 A 23 I had no reason not to. I wasn't given any 2 guidelines at all. I didn't know I was overstepping the 3 bounds of whatever table that you pointed out in the paper. 4 I didn't know a table existed. 5 I was worried about her and reconciliation. I 6 could a damn about a table. 7 Q Now, this agreement was entered into in 8 November of 1992? 9 A 10 Q Tliat's right. Isn't it true that in December of 1992 that'S 11 when you filed to void the separation agreement with Arlene 12 in Virginia? (;, 13 A 14 Q 15 A 16 Q 17 look at it. 18 19 Exhibit 3. To void the separation agreement with Arlene? with Antionette, excuse me. Filed to void? Well, I'll mark an exhibit and you can take a MR. IMBLUM: That would be Antionette Galla 20 (Motion to Void Separation Agreement marked 21 Antionette Galla Exhibit No.3.) 22 BY MR. IMBLUM: 23 Q I show you Antionette Galla Exhibit 3 and ask 24 if you can identify that document? 25 ...J This is totally true, yeah. Yeah, this is it. A GEIGER a LORIA. REPORTING SERVICE. 2400 PARK DR., SUITE e. HBG., PA 17110 7I1-!!i,U'1508 OR I'BOO'2Z2'.~77 " t) 1 It basically states that the separation agreement that I had 2 made with Antionette is unconscionable. I mean, it's just 3 basically it, yeah. 4 Q Is this entitled Motion to Void separation 5 Agreement, is that right? 6 A That's what it says, yeah. 7 Q And this is a motion to void the separation 8 agreement with Antionette? 9 A Yeah, that's true. 10 Q And at the end of it it has a certificate as 11 to whsn it was mailed to Debra Gardner, Antionette's 12 attorney, and it says the 4th of December 1992. 13 A Yes. 14 Q This was filed by your attorney, David 15 Heilberg? 16 A Yeah. 17 Q So wasn't this around the same time that you 18 and Arlene entered into the support agreement up here in 19 Cumberland County? 20 A It could have been. I don't remember the 21 timing. A lot of things were happening here. I was told by 22 Arlene that she wanted a divorce. I didn't want a divorce. 23 Q Well, the support agreement, isn't it dated 24 November 21, 1992? 25 A Yeah. () '-J GEIGER 6 LORIA REPORTING SERVICE, 2400 PARK DR., SUITE B, HOG., PA 17110 717'~.H'li508 OR 1.800'222'.577 24 ~) 1 Q 25 And then this motion shows that it was sorved 2 December 4, 1992? 3 A 4 Q Yes. These two are very close in time, maybe within 5 15 days or so of each other? 6 A Yeah. Do you have any other records? Is 7 there anything else leading up to this? 8 Q 9 point. 10 A Well, this is what I think is relevant at this I mean, there's been a paper trail since 1980 11 between Antionette and different att?rneys and now. 12 .\ if one is the I don't know if these are two ,""'" t~,,:1 13 result of the other or not. I can't answer that. 14 Q That's the question I have for you. Was your 15 decision to enter into the eupport agreement with Arlene 16 motiyated at all by the fact that Antionette was trying to 17 collect alimony from you and that you filod this motion to 18 void the separation agreement? 19 A 20 Q 21 A Well, this came after this. But they were close in time, right? Well, I had problems with Arlene in terms of 22 the relationship and this is what came out of that. 23 Q 24 A 25 Q J The spousal support agreemont? Yes. Was the spousal support agreement motivated -- GEIGER a LORIA REPORTING SERVICE:. HOft PARK OR. IUITI b, uno. pA 11110 .IlH~41'lftOIl 0" l'OOO'ilU'."17 /1 , ] " , i -''''i'" ....,., :~. \ "" '. .' I ~'"..~ . . .. >>-. -'''' ' . . . '\, " \ ',' . . . ' -- --"," -~ ~ " . . 26 ''1 1 A I blamed Antionette for the marriage break up. 2 Q Was your entering into the spousal support 3 agreement motivated at all by Antionette trying to collect 4 alimony from you or was it connected in any way 5 A Well, this doesn't show anything about 6 Antionette collecting money from me. This basically says 7 that I'm pissed and I don't want this agreement. That's all 8 it says. And it's the result of this. 9 Q But are the two related in any way in your -- ' 10 A Yeah, I was mad. I was mad. I reacted back. 11 I mean, I didn't want this agreement. I didn't want to pay 12 her anything. ,'~ ("..) 13 Q Did you know that if a wage attachment was 14 entered for one-half of your income, it would be very hard 15 for Antionette to attach your wages? 16 A I didn't know anything about that. That had no bearing on you entering into a 17 Q 18 support agreement with Arlene that she could have one-half 19 of your net income every month? 20 A I gave her the half net based on need. Based 21 on a spread sheet analysis of what we had. 22 Q And not based on the fact that you knew 23 Antionette would have a tough time attaching your wages? 24 A I didn't know anything about it. I could care 25 less about what Antionette did at that point. I wanted to v GEIGER a LORIA REPORTING SERVICE, jl:406 PARK DR., SUITE O. HOG., PA 11110 717'S41'U~OO OR I'BOO'222'.U577 27 ~ 1 get rid of the agreement and that's why I took a legal 2 response to this thing. 3 This agreement, the separation agreement, is a 4 major cause of this problem that we're having together in 5 our relationship. 6 7 8 9 10 the answers. 11 A 12 BY MR. IMBLUM: ~...... \.'t<v:!) 13 Q Q And your wage -- A I mean, how would you put it together? I ask the questions. Q MR. O'BRIEN: He asks the questions, you give Sorry. Now, your wages were attached pursuant 14 to this spousal s1lpport agreement, were they not? 15 A 16 Q 17 A 18 Q Yes. In the amount of $1800 a month? 900 every two weeks. After you began paying Arlene the spousal 19 support you were still living at the house, is that correct? 20 A I lived there until, I think, May of '93. And 21 then I leased an apartment at I guess 226 or 229 Bedford 22 Street in Carlisle. 23 And I maintained that residence until sometime 24 in December of '93. I found at that point I could not live 25 on 50 percent of my income and I came back. We had made an v - GEIGER a LORIA REPORTING SERVICE, 2400 PARK DR, SUITE D, HUG, PA 17110 717'~41'''DB OR 1-800'22:1:0041577 ,0 1 agreement. 28 II I: /' i I' 2 Somewhere in there you killed my checking 3 account. You attached my checking account or put a judgment 4 or whatever you did to me. You blasted my checking account. C) 5 Q this case. A Q A Q I don't believe I was retained until 1994 in No, you did it. I don't hold any resentment. Yeah. " Would you produce those. (Witness complies.) There's a letter -- I 15 believe we have a letter also that basically states that I 16 stayed there until December of '93 I think it was. I don't 6 7 12 A 17 remember exactly. 18 13 Q 19 till December of '93? And you resided at this apartment from May 20 14 A 21 that period of time, as well. Yes, I did. Yeah. Well, I traveled extensively during 22 Q A Q 23 the house during any of this time, the marital residence? You traveled extensively. Did you reside at 24 A I might have spent a little bit of time there v 25 to pick up some of my clothes. It was a very small ~.. GEIGER a LOIIIA REPORTING SERVICE. 2400 PARK DR. SUITE D. tl8G. PA 17110 117'!i41'1t10B OR 1'800'222'4~77 'I 1 apartment. 2 And like I said, I wanted to make sure that 3 our jointly-held properties were held intact, so that was 4 Q So did you pay any of the expenses at the 29 5 marital residence after you began paying the spousal support 6 to Arlene? 7 A I don't know if I did or not. I don't have 8 I thought sure I did. I'm sure I did, because we did not 9 have a hostile relationship. But I did try to live on my 50 10 percent of my income. 11 Q 12 point? 13 A (') .~ Did you pay any of the mortgage after that I didn't pay the mortgage, no. No. As I had 14 indicated before, Arlene paid most of the bills. 15 Q When you entered into the spousal support 16 agreement were you represented by counsel? 17 A 18 Q 19 A I made the spousal agreement up myself. Were you represented by counsel? When the original order was entered, is that 20 what you're asking? 21 Q Yes. When you entered into the spousal 22 support agreement with Arlene were you represented by 23 counsel? 24 A 25 Q .J No. Was Arlene represented by counsel? - QEIGER a LORIA REPORTING SERVICE:, 2408 PARK OR. SUITE U. HOG., PA 17110 717-'."1508 OR 1'800'222'.577 30 -1 1 A No. We made this up together ourselves. This I , 1 I I, 2 was our agreement between us. B A Where this was made a court order? Bob 3 Q And neither of you was represented by counsel 4 at that time? 5 A No. 6 Q Nor in any of the proceedings in December of 7 '92 where this was made a court order? 9 entered the court order for me. 14 Q He represented you? A well, he put the court order in, yes. Q Did anybody represent Arlene at the time? A Bob entered the court order. Q To your knowledge, Arlene didn't consult any other counsel in this matter? 10 11 12 ::J 13 15 16 A To my knowledge, no. We had sat down and 17 agreed that this was the best course to allow some time and 18 to give her some feeling that our properties were going to 19 maintain, you know, in cheCK, while we tried to reconcile. 20 Q Now, do you have a record of actually making 21 the payments to Arlene of the $1800 a month? 22 A The $1800 a month was being taken from my 23 check and the stubs reflect that. 24 Q All right. And do you have pay stubs that 25 show that? '-....J GEIGER A LORIA REPORTING SERVICE. 2400 PARK DR.. SUITE D, HOG., PA 17110 711'S4HSDB OR "BOQ'aZZ'.UI17 A I have pay stubs here that -- yeah. There's I ,I some here and I can show you all the pay stubs for record. " L " There's a statement that basically shows that I'm sure. ') 1 2 3 4 Q 31 The wage attachment has been consistent since 5 this was made a court order and the money has been taken out 6 of your wages consistently since that time? 7 A 8 Q That's correct. During this period of November of '92 till 9 now, did Arlene gave you any money for any reason? 10 A Well, you know, because I didn't have a 11 checking account or any other way she paid the bills as she 12 did before. o 13 Q 14 A 15 Q She paid the household bills? Yeah. Did she give you any money above and beyond 16 paying the household bills? 17 A Just enough to basically to live on I guess. 18 I've been trying to maintain my 50 percent, but the bills 19 were paid by her. 20 Q Did she give you any money above and beyond 21 paying the household bills? 22 A Well, yeah. Yeah, she did. consistent with, 23 you know, 50 percent of what, you know basically 24 consistent with this (indicating). 25 Q .....; This agreement says that your wages are GEIGER II LOAIA REPORTING SERVICE, 2400 PARK DR. SUITE 0, uao, PA 17110 711"4101'08 QR ,.800.222'.US17 32 I I I , , ;i I ."') 1 attached for $900 every two weeks. A Yeah. 2 3 Q From December of '92 till now. 4 A Yes. 5 Q She used that money to pay the household 6 bills? 7 A Yes. 8 Q During this time did she give you any money? 9 A 50 to a hundred bucks a week. On the average 10 maybe 50 bucks a week. I have very little expenses, if I 11 don't have an apartment and other bills. 12 Q Did she give you more when you had your () 13 apartment? 14 MR. O'BRIEN: I'd like to speak with him in 15 response to that question. I don't think he's understanding 16 something. 17 (Brief pause.) 18 A I misunderstood you I think. Could you 19 rephrase that question again one more time to make sure I 20 understand it? 21 BY MR. IMBLUM: 22 Q Yes. From approximately December of 1992 i i. 23 until now there's been a wage attachment where $900 of your 24 net pay went to Arlene every two weeks. 25 A Yes. v GEIGER A LORIA REPORTING SERVIce. 2400 PARK DR. SUITE n. uoo" PA 17110 7IHt41'1&OO OR l,oOO'2U-lIen o o v 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q During that period of time did Arlene give you any money for any reason? A No. The paycheck went -- my paycheck went to Arlene and Arlene gave me money back from the paycheck. Q Now, wait. The wage attachment A The wage attachment was a separate check. I had nothing to do with that. That was a court order. Q But you also gave her your paycheck? A I gave her my paycheck because there was still some bills that needed to be paid and then I took back some money, $50 or so or a hundred dollars a week. We don't have a hostile relationship here. We're trying to reconcile, okay. Q I understand. NoW, when you had an apartment A Yeah. Q __ and she only gave you 50 to a hundred dollars A Oh, no. I had more money when I was living in the apartment because I needed it. I had bills in the apartment. Q How much did you -- A I don't remember. Q Did you have the same arrangement where you gave her your check when you lived in the apartment? GEIGER a LORIA REPORTING SERVICE, 2408 PAnK DR. SUITE D, HBO., PA 11110 117'~.H~08 OR l'BOQ'222'U77 .'1 1 A 2 Q 3 A 34 Yeah. How much back did she give you? Enough to cover my expenses. I don't remember 4 what that was. I had the rent. I had $325 or whatever it 5 was for rent and I had light bills and electric bills, a 6 phone bill. No, an electric bill. I don't knoW, clothes, 7 expenses. I don't know what those numbers were. 8 Q How would it work? Would you just ask her for 9 whatever money you needed? 10 A Yeah. If I needed money, I tried to keep it . 11 consistent within what I had agreed to. I couldn't make 12 it on 50 percent and that's why I came back. () 13 14 Q 15 A 16 Q You look puzzled. I'm just thinking of my next question. Oh, okay. I look puzzled a lot. When did you and Arlene 17 separate, if at all? Were you separated in November of 18 19927 19 A No. No. I didn't leave the residence until 20 May of '93 I think it was. I wanted to assure Arlene 21 basically that we were going to try to work this stuff out. 22 I didn't want to just leave her without having anything. 23 Q So, the status of your marriage in November 24 of '92, you were having problems, but you weren't separated; '>..,,) 25 is that the correct way? GEIGER a lORIA REPORTING SERVICE, 2408 PARK DR. SUITE 0, HOG. PA 17110 117"41>1500 OR "800.222'.571 35 () 1 A That's the correct way of putting it. 2 Q And then you were separated from May of 1993 3 until December of 1993. Since December of 1993, have you 4 and Arlene been separated? 5 A No. We have lived in separate bedrooms. I 6 mean, I have my bedroom and I had my work station downstairs 7 where I did my work at. And she had her bedroom and we kind 8 of divided the house up into hers and mine basically. 9 Q What period of time did you have separate 10 bedrooms? When did you start to have separate bedrooms? 11 A Oh, it's been at least -- it would have been 12 in '93, I mean, when I came back. You know, late '93. 13 December. Since December of '93 at least I think. 14 Q Did you have separate bedrooms in November of 15 ' 92? 16 A We had separate bedrooms after -- in May for 17 sure, because I wasn't there. And I think when I came back 18 we had separate bedrooms. 19 Q Did the two of you socialize with your friends, 20 go places together, et cetera, from November of '92 through 21 May of '93? 22 A Let me put into the record both of us -- this 23 is our third marriage. We're both probably warriors of the 24 matrimony trail, if that's a good way to put it. 25 Q I never heard that term, but I like that. ~1 ;", -..) O[IGER & LORIA REPORTING stRVlct, 2<408 PARK DR, SUITE B. HBG. PA 17110 117.e.&HSOB OR 1'800-222'.577 '1 :) ...) 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A So we basically -- I mean, we both have grown from each of our marriages to the point that we're adults. We don't have a problem from that standpoint. We tried to maintain as good a relationship as we could during the period of the reconciliation. Which means that we didn't necessarily go out. I don't drink anymore. I don't do any of that stuff. I have my own things that I do. She has her own things. Our marriage was probably null and void a lot earlier than it is now, but we attempted to reconcile. I did. Q I'm trying to pinpoint. Now, you said you were in separate bedrooms at least since May of '93? A Yeah, right. Somewhere in that area, yeah. Q The status of your marriage in November of '92, you were still in the same bedroom? A Yeah, I think so. Q Still have sexual relations? A No. We haven't had sex in seven years. Q When did sexual relations end? A Seven years before that. I mean, about one year after we got married. o What year would that be? A '87, '88. Somewhere in that area. '87. Q So none since '87 or '88? GEIGER a LORIA REPORTING SERVICE, 2400 PARI( OR. SUITE g. HOG., PA 17110 717'S4H~OD OR I'SDO'222.4S77 '1 ~.:> -...) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 37 A Yeah. Q So from '87 or '88 until -- A I can't remember the exact I didn't mark down in my book the last day I had sex. Q I understand. So approximately May of '93 you were in the same bedroom, didn't have sexual relations? A Yeah. Q Now, was there any point in time when you did not socialize together? A We weren't very social together. Q From what point on? From '87 or '88? A All points. Well, I would say probably, you know, within a couple, three years, after we got married we weren't very social. I don't remember the exact and I don't even want to drudge a lot of that stuff up. I realize you need to pinpoint things, but I can't be more clear than that. Q I understand. December of '93 you came back? A Yes. Q Were you in separate bedrooms after December i: of '93? A Yeah. Yeah. I'm pretty sure we were. Q No sexual relations after that point? A No. Q Did you socialize from December of '93 till QEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE D. HOG., PA 11110 717'154H!lOB OR "BQo'2:z2'4l577 38 !"'"') 1 now? 2 A I said good morning and good evening. See 3 you in the morning. 4 Q All right. I 5 A I wanted to have a better relationship. Under 6 the circumstances it was difficult to do so. With all this 7 other stress we had, it was difficult. Q Now, in April of '94 Arlene purchased a Toyota ! : , , 8 9 Paseo. Just explain to me your involvement in that. 10 A That's a complicated issue. It kind of sounds like I did something wrong here. I really didn't. , ; ! i 11 12 Back in 1988 Arlene was using her car. I was .'~."\ .~ 13 using mine. And I have a stepdaughter Sand~. She bought an 14 '83 civic. The Civic ran out of gas. I mean, it basically 15 was defunct. 16 So she was given the '88 Accord to use. She 17 couldn't be given it because she was a minor, so she was 19 In 1992 I took her '83 Accord and traded that , I I I I I 18 given it to use. 20 in. I took her '83 civic and traded that in on a '92 21 Accord. The one we mentioned earlier. 22 Q On a '92 Accord? 23 A Yeah. Then in 1992 Sandy got the '88 Honda. 24 I think I mentioned that. Then Arlene traded theC:~~)Accord 25 in on the Paseo in 1994. v GEIGER a LORIA REPORTING SERVICE. 2400 PARK DR, SUITE D. HOG, PA 17110 111-541-1"08 OR "800'222'4517 j.- " '1 I~) ....) 39 1 Q Now, at that point whose name was the ' 88 -- 2 she traded the '88 Accord? 3 A The '88 Accord was a jointly-owned car, if I 4 remember correctly. I don't remember. I think it was. I 5 don't know. 6 Q This you when you bought the paseo? 7 A Yeah. The '88 Accord was a jointly-owned 8 piece of property. 9 Q Okay. 10 A Okay. 11 Q And you traded it in on the Paseo? 12 A Yeah. That was Sandy's car that she was 13 using. 14 Q Your daughter? 15 A My stepdaughter. 16 Q Okay. 17 A Then when the '88 Accord was traded in, Sandy 18 got the '88 Honda Civic. 19 Q Okay. 20 A That' B how that happened. It sounded like 21 musical cars. It's actually four cars involved here. 22 Q Are you liable for the note on the '94 paseo? 23 A That needs to be cleared up. There'S 24 basically the bank loan -- a bank loan would have cost 11 25 percent interest. And getting the loan at the auto dealer GEIGER a LORIA REPORTING SERVICE. 24Q8 PARK OR., SUITE D, HOG., PA 17110 7INS41'I~OB OR l.eOO'2Z2..U577 ~..) ;,') ....; 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40 it was a five-and-a-half or six percent loan. So in reducing cash flow I co signed for the thing, but I do not own the car. Q So you co-signed for the Paseo, but the Paseo's in A Arlene's name. Q __ Arlene's name? The summer of 1994, tell me about the trip to the Grand Canyon. A As I indicated, I traveled I think in 1994 I might have traveled 80,000 air miles. Q You traveled for your business? A I did during that period of time, yes. And I went to Arizona on a business trip and Arlene came along with me in the summer of '94. It was June of '94 or whatever. I could get you an expense report to back that up. And she accompanied me. Her purpose in accompanying me was to look at Arizo~a as a potential site of relocation for herself. And she traveled extensively over the state during that period of time I was down. I guess it was like a four day trip or something. If during that trip she traveled to the Grand Canyon or not, I don't know. Q Were you at the Grand Canyon? A No. OEIGER a LORIA REPORTING SERVICE, 2408 PARK DR., SUITE D. HOG., PA 17110 717.,4H,OB OR "800'222'4577 ~ () 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 Q You were in Arizona? A I was on a business trip. Q What city? A The Phoenix area. Q And what area did she look at for relocation, Phoenix? --.) GEIGER a LORIA REPORTING SERVICE, ~40B PARK OR_. SUITE D, UOG_. PA 17110 711.541'1!SOB OR 1'800'222'4'77 "'l C) \..J 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 Q I don't know the geography out there. But the rest of the nights she spent with you in the hotel room? A Like I said, I'm not sure how many days it was. It was probably four days and three nights. Something like that. So at least one of the nights, as I seem to recall, she might not have been there. I don't remember if she was there or not. Q Was any of this trip motivated by your wanting to reconcile with her? A Reconciliation has always been in my mind with Arlene, even though we're having these problems. Q So would it be fair to say that you've always wanted to reconcile and it's been up to Arlene whether or not you reconciled or not? A Arlene has been a primary -- she doesn't like the residual of my addictive behaviour. So that's about as succinct as I can be. Q Are you still attempting to reconcile? A Yeah. I mean, you know, I would like to see a difference. I don't know if there's any hope for that though. I think I've practically given up on that. I'm sure Arlene has. Q Did you give up on that based upon her filing the divorce complaint? GEIGER 1\ LORIA REPORTING SERVICE, 2408 PARK OR. SUITE D, HOG, PA 11110 717'~4H!50o OR t'800'nZ'.~77 n 1::) , ....) 43 1 A Well, I gave up on it after -- I mean, we're 2 still together. I mean, we're not divorced yet. 3 Q Correct. 4 A What do you mean? I'm not sure I understand 5 that question. I haven't divorced -- she has filed for 6 divorce in February of this year. 7 Q Maybe I misunderstood. Have you given up on 8 reconciliation at this point? 9 A That's part of my addictive behaviour. 10 I don't know if you ever give up on anything. I've been 11 married three times. I really don't want to have another 12 one. 13 Q I understand. But have you given up on 14 reconciliation? 15 A I may be close to that. 16 Q Okay, that's fine. Now, you increased your 17 withholding near the end of 1994. 18 A That's correct. 19 Q Can you explain to me why you increased your 20 WithhOlding, your federal withholding? 21 A Yeah. What happened was, it was probably 22 pretty ignorant of me in not recognizing what was going to 23 happen. 24 In October of '94 I realized that we no longer 25 had two dependents. Sandy, my stepdaughter, had become GEIGER a LORIA REPO'n1NG SERVICE, 2408 PARK DR. SUITE e, HOG., PA 17110 717''''H~OO OR "800'222'041577 " 44 f) 1 independent. She basically was going to file her own 2 return. 3 And my stepson, Bill, we had expected him to 4 come back. He's living somewhere else within Carlisle. So 5 we had two less dependents. 6 So in consultation with Mr. Art Rhoads, our 7 CPA, he indicated that it would be wise to increase the 8 withholding to the amount specified by that form Mr. o'Brien 9 gave you to avoid a large lump sum payment. 10 That was insufficient. We still owe $273 11 for 1994 taxes. That was done on the basis of two checks 12 that I had given him in October. Those two. c> ,~ 13 Q You gave him the checks to analyze? 14 A ' Yeah. And the letter that he gave me is the 15 result of that. So in the end I had to pay $273 for taxes. 16 (Amended Order of Attachment of Income marked 17 Antionette Galla Exhibit No.4.) 18 BY MR. IMBLUM: 19 Q I have before you Antionette Galla Exhibit 4. 20 That's entitled Amended Order of Attachment of Income, is 21 that correct? 22 A This is not the original. No, this is not 23 right, I don't thinlc. Is this the one -- there were two of 24 them. There was one that was listing it for 1400. See, 25 this is on two different docket numbers. This was the .J GEIGER A LORIA REPORTING SERVICE, 2408 PARK DR, SUITE B, HOG., PA 11110 717'54101508 OR 1'800'222'4577 'I 1 original? 2 MR. O'BRIEN: I don't know. 3 A I don't know. 4 BY MR. IMBLUM: 5 Q Let me ask you a simple question based upon 6 this. Was the amount that was taken out'of your check for 7 support increased? Was more taken out as of October of o 1994? Was the amount of the attachment increased? 9 A I don't know. You'd know that. I don't know. 10 Q Didn't you know how much money you ended 11 up with at the end of the month? 12 A Well, I wasn't paying $873 in. I was only (".... ly~~J 13 paying $073 in according to my check stub. I wasn't paying 14 900. 15 I don't know. If you look at those stubs I 16 think they were saying it was like $873, if I remember 17 correctly, and change. I don't know all that happened in 18 there. I don't remember. 19 Q Let me look at something here. According to 20 this record this is your earnings report dated November 18th 21 of '94. 22 A Okay. 23 Q Is it true that your federal withholding went 24 up at your payroll ending period October 31, 1994? -..) 25 Yeah. This is that increase that was brought A GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR" SUITE O. HOG., PA 17110 717".4!'ISOB OR 1'800-222'077 .r"\ ~:) ......) 46 1 on by me making that change with that withholding. Sure, 2 yeah. It went up by 200 bucks or so, right. 3 Q So it went up from 484.68 to 684.68? 4 A Yeah, that's approximately correct. That's 5 what they're doing, yeah. 6 Q This is an order, Antionette Galla Exhibit 4. 7 Doesn't this indicate that the Cumberland County domestic 8 relations office is increasing the attachment on your 9 income? 10 A No. No. I don't know if they did or not. 11 The fact is that has nothing to do with this increase. 12 Q The order speaks for itself. 13 A But so does the fact that I owed the taxes. I 14 mean, I just did a little bit of planning a little bit late 15 in the year. I should have done that earlier. 16 Q Were you aware in October of 1994 that the 17 attachment of your income might go up -- 18 A No. 19 Q because Antionette was pursuing you for 20 spousal support? 21 A No. No. No. No. I had no, you know -- 22 I have no reason what was happening. I mean, she wasn't 23 talking to me obviously. Antionette wasn't. I didn't know 24 what she was doing. 25 I mean, I knew that you had grabbed a hold of GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR., SUITE 0, HOG. PA 11110 117'S4H!50B OR 1'800'222'4'77 47 r) 1 my checking account. I knew that. But I don't know what 2 happens to these things and I didn't know that this was 3 going to happen. Ii 4 I did know that I was going to have to pay 5 probably 2,000 bucks or more in 1995 because of those two 6 withholding exemptions that were no longer there. 7 Q Just to reiterate. At the time that you 8 increased your federal withholding, you were aware that I 9 had attempted to attach your bank account; is that correct? 10 A I don't believe I was aware of that at the 11 time. I mean, the timing might be coincidental. I 12 certainly did not under any circumstances do what I did to ..oIlio) ( . """'.'''' 13 avoid your -- whatever you were doing, because I'm not even 14 sure that the times were the sarne. 15 I do know that I was going to have to pay 16 taxes. So in order to avoid paying all that in one lump 17 sum, I opted probably properly to do what I did. I didn't 18 check with you though. 19 Q No. 20 A No. 21 Q And your accountant is advising you that you 22 still owe taxes for 1994? 23 A I paid taxes, $273 taxes worth, yes. 24 Q 273? 25 A Yeah. You have a copy of that, I believe. o GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE D, HOG, PA 17110 111"4101508 OR "800'222''''77 ') 1 48 MR. IMBLUM: off the record. 2 (Discussion was held off the record.) 3 BY MR. IMBLUM: 4 Q What was the reason that you could no longer 5 claim Sandy and Bill as dependents? 6 A 7 with us. 8 Q 9 A Sandy was working and Bill no longer lived How old was Bill in 1994? Bill opted to live with some friends at the 10 age of 16 or thereabouts. Arlene could fill you in on that. 11 I'm not clear on the details. 12 Q ':"') 1~ 13 A 14 Q 15 A So he was 16 in 1994? 16 or 17, I forget which. Sandy was how old in 1994? Sandy's 20 now, so she was 18 at least. 19. 16 That was a year ago. 17 Q 18 time? 19 A 20 Q Well, was Sandy attending college at this Sandy has attended college, yes. 1994 was the first year that you and Arlene 21 did not claim Sandy and Bill as dependents? 22 A That's true. 1993 I believe reflects that. 23 I'm not sure. You'll have to check that and eee. 24 Q In 1993 was Bill living with friends? 25 A I believe so. '-.J GEIGER a lORI" REPaRTING SERVICE. HOD PARK OR. SUITE D, HOG, PA nllo 117-"'1-1&00 OR 1'800'222'41577 .' I :-,..t.,,'-.'~l' 'i;'-~1"~ "".~, ... " ~ :...""""...~,, ,~:~:.. -r~-'- -, ~j . 49 o 1 Q Well, why did you determine that you couldn't 2 claim Bill in 1994 but you could in 19937 3 A Only because of the fact that -- you have to 4 check the records. I don't remember if we claimed him or 5 not. I'm pretty sure that we did. 6 And we figured that we were okay in doing that 7 because we had supplied more than half his support because 8 he had left in 1993, I believe. 9 I don't remember what the details were. 10 Arlene could probably fill you in better on that. 11 Q Were you and Arlene supporting Bill in 19947 12 A I don't believe so. 13 Q Were you and Arlene supporting Sandy in 1994? 14 A Sandy had a job and was going to school. 15 Q Were you providing any of her support7 16 A She was paying rent or whatever for future 17 college or whatever. We helped her save, I guess. Arlene 18 could tell you more about that. 19 Q Did you help her pay for college or -- 20 A I didn't. 21 Q You don't know if Arlene did? 22 A I cannot answer the questions. 23 Q Okay. How was the amount of the extra federal 24 withholding arrived at? 25 A Well, I recognized the fact that I was going L:J v GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE 8. HOG., PA 17110 717'!l4H~OO OR "800'222-4577 J () v 50 1 to have less dependents, so I called Art Rhoads and said, 2 Art, here's the numbers. Tell me what kinds of problems I'm 3 going to have to in 1995 when I go to pay my taxes for 1994. 4 He told me. 5 The assumptions were 'that we would continue 6 with the same approximate number of line items, you know, 7 the same value as the line items and carry it into 1994 as 8 we had in 1993. And just project what the actual taxes were 9 basad on the IRS schedules. 10 He came back with those numbers and I acted 11 accordingly. 12 Q Was it any part of your analysis in increasing 13 your withholding -- that you would increase your withholding 14 to a level so that the amount of support you were paying to 15 Arlene would still be 50 percent of your net? 16 A I never judged that at all. I was simply 17 working on the basis of what Mr. Rhoads had told me and you 18 have the documentation there in front of you. 19 Q Do you get paid bonuses or anything other than 20 your regular paycheck? 21 A No. As a matter of fact, I just recently got 22 a two percent or three percent raise which is reflected on 23 the checks or whatever it was and that's the first raise 24 I've had I think since I came there. Since I began 25 employment. GEIGER A LORIA REPORTING SERVICE, 2..06 PARK DR_. SUITE D. HOG. PA 17110 717.tI"Htl08 OR 1'600'222'4'17 51 ....."') 1 Q Do you receive bonuses or any other 2 remuneration from your work other than your weekly paycheck? 3 A I get recovery of my expenses through the 4 valid -- you know, through an acceptable system. If I spend 5 a hundred dollars on the road, they give me a hundred 6 dollars back. 7 I get no extra funds, no bonuses, no nothlng. 8 Q Nothing beyond your regular paycheck and being 9 reimbursed for expenses that you submit receipts for? 10 A That's all. 11 Q Did Arlene file a divorce complaint against 12 you in December of 1994? 13 A She filed it in February, I think. I don't 14 think she filed it in December. It was February, wasn't it? 15 MR. IMBLUM: Was it February? 16 MR. O'BRIEN: February. 17 BY MR. IMBLUM: 18 Q Have you been served with a copy of that? 19 A I have one, yeah. Would you like to see it? 20 Q Yeah, I would, if you have a copy. Did you 21 discuss with Arlene why she was filing for divorce now? 22 A I think finally the fact that -- I don't know 23 what her thoughts were. I think the best answer to that 24 question is have her answer that question, because I'm not 25 totally sure. () v GEIGER 6 lORIA REPORTING SERVICE. 24108 PARK DR. SUITE D, HOG.. PA 17110 7INI"H~08 OR "800'222'''&71 52 ,., 1 Q Did she discuss with you while she was filing 2 now? 3 A Not really, but I think I could make some 4 judgments. I never asked the questions. 5 Q I not asking you to infer. I'm asking you if 6 she discussed with you or told you or discussed with you in 7 any way while she was filing for divorce now? 8 A No. But it would probably be something like 9 I've had it. 10 Q That's your inference? 11 A Would be my opinion. And I don't blame her. At this point now are you still residing 12 Q 4"""'-';1, \::.;,> 13 together in the marital residence? 14 A No. We're residing apart in the marital 15 residence. 16 Q You are both residing in the marital 17 residence. Separate bedrooms? 18 A Yes, that's correct. 19 Q This is sort of out of order. But did you and 20 Arlene have a prenuptial agreement? 21 A To honor and carry forward? No, I did not 22 have any prenuptial agreement with her at all. 23 Q No written agreement between the two of you 24 before you were married about what would happen if you ever 25 split up? ..J GEIGER a LORIA REPORTING SERVice, ;UOO PARK DR. SUITE D, una. PA 17110 717.ft4H~OQ OR 1'000-i122-.,77 1'") 1 2 53 A No. Q Do you have any agreement now as to a 3 post-nuptial agreement or a marital settlement agreement or 4 anything? 5 A 6 Q 7 A 8 agreement yet. 9 Q It is not complete. Are you negotiating that presently? I have not seen the first draft of the Is any of your property or Arlene'S property 10 being sold or transferred presently or within the last six 11 months? 12 A There have been no transfers of anything or () 13 sale of anything. 14 Q 15 A Any gifts? No gifts. All the property that we have 16 remains in joint right now. 17 Q Could you tell me what you are requesting as 18 part of your divorce settlement? 19 A We haven't really totally worked it out yet. 20 I'm not at liberty to discuss it right now. I just don't 21 know what that'~ going to be yet. 22 Q You can't even tell me what you've requested 23 or what you're looking for? I'm not sure, J 717.'.1-1500 OR 1-000'222'.577 24 A I haven't seen a first draft. 25 what Arlene wants. v GEIGER a LORIA REPORTING SERVICE, 2400 PARK OR-, SUITE D, HDG, PA 17110 r) 1 Oh, the first draft would be based totally on Q 2 what Arlene wants without any input from you? 3 I have been very good to all my wives, as is A 4 obvious from what happened to Antionette. 5 MR. IMBLUM: I have no further questions. 6 7 CROSS-EXAMINATION 8 9 BY MR. O'BRIEN: 10 Mr. Galla, I'm going to ask you to identify Q 11 some matters to be entered in the record here that you've 12 been referring to in your testimony. o 13 (Earnings Report marked Walter Galla Exhibit 14 No. 1.) 15 (Letter dated 11/21/94 from Arthur L. Rhoads to Walter and Arlene Galla marked Walter Galla Exhibit No. 16 17 2. ) 18 I (Letter dated December 1, 1993, from Richard 19 H. Neff to Walter Galla marked Walter Galla Exhibit No.3.) 20 BY 11R. O'BRIEN: 21 Mr. Galla, marked Exhibit 1 of Walter Galla is Q 22 the photocopy of the form that was filled out for your 23 domestic relations hearing, is that correct? 24 A Yes. \.J 25 And you had indicated I believe when Mr. Q GEIGER a LORIA REPORTING SERVICE, 2"08 PARK DR. SUITE B. HOG. PA 17110 711'541'HiOB OR I'DOO'222'4!S77 54 .'j c:> o 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Imblum was questioning you that you had a pay increase two or three percent since the time this has been filled out? A Yes. I guess it might have been a month ago or somewhere in that area. Q Mr. Rhoads? A Now, you testified that your accountant was That's correct. Q And did you request in writing from him documentation as to the tax liability? A I requested a statement from him. I like to reduce it to paper work and this is it. Q And that's been marked Walter Galla Exhibit No.2? 55 A It's No.2. Q You've testified also that you had a lease of an apartment for a period of time in 1993. And did you again request that your landlord provide you a written statement as to the term of that lease? A Q A this, yeah. Q correct? That's correct, yes. And is that Walter Galla Exhibit 3? Yeah. There's also a lease that goes with Right. And that's Walter Galla Exhibit 3, is that A That's 3. OEIOtR a LORIA REPORTING SERVICE. 2400 PARK DR.. SUITE 8, HOG.. P... 17110 717'!5,U'1!508 OR 1>800-222'''577 .''1 1 56 (Copies of wage stubs marked Walter Galla 2 Exhibit No.4 and Walter Galla Exhibit No.5.) 3 BY MR. O'BRIEN: 4 Q Exhibits 4 and 5 are photocopies of your wage 5 stubs that you retain after the check is turned over to you? 6 A 7 Q 8 A 9 ones, yes. 10 Q Yes. Would you look at those for a moment. (Witness complies.) Yes. And these are the And that shows the withholding in that period 11 of time going for your federal tax withholding going from 12 $484 to $684? t"j '<tw 13 A 14 Q Yes. And your testimony was that that was in 15 response from Mr. Rhoads's advice? 16 A 17 Q 18 "A 19 Q That's correct. His letter is dated November -- 21st. -- 21st of '94. When did you speak with him 20 in regard to making that change? 21 A It would have been in October sometime I would 22 imagine. I just told him to verify in writing what he had 23 told me. 24 (1994 U.S. Individual Income Tax Return marked ....) 25 Walter Galla Exhibit No.6.) GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE 0, HOG. PA 17110 717-'4"'1500 OR l'QOQ':UZ'4877 57 2 Q Mr. Galla, what's been marked Walter Galla I !' i: " .-, 1 BY MR. O'BRIEN: i; 3 Exhibit No.6, is that a photocopy of the tax return that 4 you and Arlene filed for the year 1994? 5 A This is it. 6 Q And that reflects that despite the amounts 7 withheld from your respective pays, you still had a tax 8 liability of $273? 10 (Copy of purchase arrangement marked Walter \ fj 1j 9 A That's correct. 11 Galla Exhibit No.7.) 12 BY MR. O'BRIEN: , ;") . "'-"';rl'- 13 Q Walter Galla Exhibit No.7, is that a 14 photocopy of the purchase arrangement for the paseo 15 automobile? 16 A That's correct. 17 Q And that car is used by your wife Arlene? 18 A Yes. 23 Q So if Mr. Imblum goes through the original 19 Q Who makes the payments for that car? 20 A It comes out of the joint funds that we have 21 together. Arlene specifically makes the payments, but she 22 pays all the bills. Has been. 24 checks that were provided, he'll see payments made from that 25 joint account? J GEIGER a LORIA RE',PORTING SERVICE. 2.408 PARK DR., SUITE P. HOG. PA 17110 111'5"1-11508 OR 1'800-222'''1577 ~ 1 A 58 Yes. I try to share in it a little bit, but I 2 don't always do that. Share the pa~nents of it. I don't 3 always sign some of the checks. 4 Q But the vast majority of those checks would be 5 signed by Arlene? 6 A 7 Q 8 own? 9 A By Arlene, that's correct. Do you have a separate bank account of your I had a separate bank account, but I no longer 10 have a separate bank account. It was closed by Mr. Imblum 11 or he attached it or whatever you do with it. 12 Q -.) I" "J"", 13 A 14 Q 15 A Someone did it? Yeah, it was terminated. The attorney down in virginia? Right, precisely. 16 (W. Galla to T. Galla payments Revised 6/25/92 17 marked Walter Galla Exhibit No.8.) 18 BY MR. O'BRIEN: 19 Q Mr. Galla, Walter Galla Exhibit No. 8 are 20 photocopies of checks that you sent to Antionette from late 21 1983 through 1987? 22 A 23 Q That's correct. And then prepared on the top of those pages is 24 a summary of the total payments during that time frame? 25 A GEIGER a LORIA REPORTING SERVICE, 2"08 PARK DR., SUITE 0, HDO, PA I?IID 717'1541011508 OR 1'800'222'''1577 .-...,) This is a total amount of money given to (J 1 Antionette Galla, yes, 1980 through 1993. 2 Q And the checks just represent a certain 3 portion of that? 4 A A certain portion from the period roughly 5 1983, 12/21/83, through the last check is December 6, 1987. 6 Q YOU've indicated that you do still have copies 7 of-- B A I believe I have copies of those checks, yes, 9 and I will make sure I give them to you. I thought I 10 brought them with me, but I didn't. 11 Q To the extent that you have those available, 12 you will provide those? 13 A Yes, I will. 14 Q You stated that you never appeared in the 15 state of virginia in reference to 16 MR. IMBLUM: off the record. 17 (Discussion was held off the record.) 18 BY MR. O'BRIEN: 19 Q Now, Mr. Galla, you indicated that you never 20 appeared in Virginia after Mr. Heilberg, your attorney, 21 filed a petition to void the separation agreement. 22 A No, sir. 23 Q And why didn't you appear in that proceeding? 24 A I was told that if I were to appear that I 25 would be most likely held in contempt of court. And by () J GEIGER a LORIA REPORTINO SERVICE, 2400 PARK DR" SUITE D. HOG.. PA 17110 717'UH!lQB OR 1'800'222,,,577 60 ."J 1 advice of Mr. Heilberg I stayed away from the state of 2 virginia. I still stay away from the state of Virginia. 3 And in order to reopen that again, to continue 4 that thing, it would have required that I come up with 5 $63,000 they told me to go ahead and reopen it basically and 6 I could not reopen it under those circumstances at that time 7 and I could not appear there, so -- B Q So you stayed in Pennsylvania? 9 A Stayed in Pennsylvania and I was represented 10 by counsel only. 11 Q YOU've indicated that you travel extensively 12 in your job. Do you avoid the state of virginia in your , ("') ',,+-,,- 13 traveling? 14 A Yes. I attempt to get into Dulles only when I 15 have to. 16 Q Now, you've indicated that in addition to 17 paying 18 A I might add that I have children in virginia 19 that I'm being sort of forced to stay if I take a chance, 20 I know they'll pick me up down there, if I get picked up for 21 anything at all. I feel that, anyway. 22 Q In addition to paying Antionette the amount of 23 money that is documented in the exhibits, as well as what 24 we'll show later, you stated that you've assisted your 25 children also in their college educations? '-J GEIGER & LORIA REPORTING SERVICE:, 2408 PARK DR., SUITE D. HaG. PA 11110 1I7'!54H!5CB OR 1-800'222'4577 '1 (:J --.J 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 A That's correct. Q Which children did you help with college? A My oldest son and my youngest son. Q Your oldest son, what school did he attend? A He attended virginia Tech. Q And could you give us an approximate amount of money that you assisted him during his A Roughly $4,000, $5,000 a year. Q For how many years? A Probably four to five. There was one time where he had to take a loan out himself. I just didn't have it. But I believe I maintained a residence for him, as well. I have checks to cover that, as well. Q What time frame are you talking about that you were helping him? A That would have been in the 'B7, 'B8 time frame I think. I think he just finished up here recently. , BB time frame. Q Would that have been when he started roughly? A No. That would have been well toward his end. I also contributed to my other son, Brian; and that would have been in the '87 to '89 time frame. Q And what school did Brian attend? A Brian went to several schools. Brian is my problem student. He's probably going to become a GEIGER III LORIA REPORTING SERVICE, 2"00 PARK DR, SUITE 8, HOG., PA 17110 117'541-\508 OR I.BOQ'Z22'.U571 'J 1 professional student. 2 He's still going to school. He's probably at 3 James Madison now. He went to Virginia Tech also. This is 4 a check to the Virginia Tech office of student accounts for 5 $1500. That was one semester, I think, and it was December 6 '89. 7 Q And how old is Brian now? . 8 A This is bad. I think Wally'S probably 28 and 9 Brian is two or three years younger than that. I can't 10 remember. 11 Q And how many other children I have two other daughters. My oldest 12 A '....\ (~""f;J 13 daughter is 33, 34 and my youngest is 30ish. 14 Q So the four children that you and Antionette 15 Galla had are all adults and the youngest is approximately 16 25 years of age? 17 A Yes. Right. 18 Now, in addition to the payments that you've Q 19 made to Antionette Galla over the time, the separation 20 agreement outlines that she received certain other items of 21 property; is that correct? 22 She received a farm. That was probably valued A 23 at least 80, 85, 90,000 in Virginia. She received a 24 building lot at a resort area there. She received all of ....J 25 our farm equipment and tractors and things like that. All GEIGER a LORIA REPORTING SERVICE. 2406 PARK OR, SUITE B. HOG. PA 17110 117'~""I~OB OR 1'800'222'.571 62 63 .-, 1 farm implementation, everything. 2 Q 3 A 4 Q All the furnishings in the home? Yes. Do you know how long she continued to reside 5 at the farm in Virginia? 6 A 7 Q 8 the time that she received it? 9 A Two or three years. Was there a mortgage against that property at Yeah. probably would have been in the area of 10 maybe about 45,000. Somewhere in that area. 11 Q 12 mortgage? ,~ l, ,.) '..~~- 13 A 14 Q She accepted the responsibility of paying that Yes. Did she take any of the other debts that 15 existed during your marriage? 16 A I took all the debts. I have canceled checks 17 for the loan made to her mother. I mean, the pay back of a 18 loan to her mother. I have various other documentation that 19 covers that. 20 Q Now, at the time that you and Antionette 21 separated, you said that you were actively an alcoholic 22 and you also indicated that you were hoping for the 23 prospects of a reconciliation with her. 24 A 25 Q ~ That's correct, yes. Were attempts ever made at a reconciliation? GEIOER 1II LORIA REPORTING SERVICE, 2408 P~RK DR, SUITE p, HOG. PA 17110 111'~.U'I~08 OR 1.800-222..577 1\ no\lse to1: s~e 'io\l aa'l ane 1.t. '<Iaa 'lean' ~ i.n t.ne ~ 'lean' o 1\ 4 S 'lean. 0 6 t.nat. t.i.\\\e1 1 d '<Ie 1.i.~ed t.i.\\\e at\ \ltl ne1:e one 1.i.a1.e. i.n ca1: a \\\Ont.n sne c~e O')l.i.\\\at.e1.'l a'l?'l?1: \l<> ne1:e1 c~e ,~ i.n '\.91)~ 01: co1:1:eCt.. ..",at.'a . 1)4 i ..... & t.ne ni.d an'l 0" 1: at. ...' t.n ne " e \).tI ",'" cniJd1:en co~ e at. 1:eai.denc d '<Ie nad a 1\n d t.nat a \\\ontn an 1.1. c~e \).tI. 'tne'l a ded to1: ane 1:esi. 1\ t. ~i.1.1.o'<l '<Ine1:e '\.'\.4 t,as di.dn't. '<I01:)\.' o tnat t.i.\\\e1 d1:i.n)\.i.n<! at. l!>\).t. t.ne .... '00 .c,,, c"c c,~.. · c", ..,.~,.. .c "..... 1" 1. '<Iaa a d tne\\\ \)." 1. \\\o~e 1. \l\ean. I) 9 1.0 '\.'\. ,f'') ~...,,'.( ". 0". o?' 1 ""0'. t"" ...tt. '0' .... ... .. . .,.. .._ c.,,,,,. - \Fe 1.oade ...at.i.ona1. a ... .",,0' ,. ".- ~ .. .'0..... ,. · .... 1\'1\ 1. '<Iaa -" 1.ate1: I 1:eco~e"J a1:o\).nd' 1.1. t.ne '!la'l d ne1: a 'cono1. an t.O a'" addi.cti.on ad\).1.t. ,t .,.. '" .."0.....' \"I'l6e a1.cono1.i.C e t. "~to ,. .. .,c. C.. . .. ..'" ?o.'.~. , ".,.. ,. , ..... .0" 1 .,.." ... a1.cono1. c, 0 ",,,c~ 1.ate1:' C",,'d ot an d 6 ,.... ........ d 1. 1.ea1:n6 I'>n n )\. 0\lt1 ni.nq t.ne . di.dn It. '!lo1: na'l?'l?e i.1.i.ati.on 'tnat. 1:econc 1.'2. '\.~ '\.4 '\.S '\.6 '\.1 '\.1) '\.9 \'.) t.ne t.'<Io ot t.i.\I\e t.nat t.ne 1.a6t ,\,...,.\.06 oil 1.6 t.nat G f~ ",,0 o .Il"~ e, lie . 6 f~II" 011, G !t~"~\Ct., 1,,0 ~ "t.,O'f\'\~ o't.\Gt." a ,"of'\ 1\ t1:o\\\ \\\'1 1:e1.at.i.onsni.tI to\).nd O\).t. .. i.ona1. d'l6t\lnc'" '2.0 '2.'\. '!lnat '!la6 Q '2.'2. \\0' '2.~ '2.4 'l.S I'> 65 ,., 1 attempted to reconcile? 2 A 3 Q Yes. In reference to your work, you relocated and 4 you've been employed in the Carlisle area? 5 A 6 Q 7 A B Q 9 A 10 Q 11 A 12 Q Yeah. Since what year would you say? Since 1980. And that was when you left Virginia? Yeah. And separated from Antionette? Yes. That's true. Do you know what Antionette's work history has ;--. '~J 13 been since you separated? 14 A Yes. Before I left she had received an RN, 15 registered nurse, degree from a Virginia college down there. 16 She had gone to college while we were married 17 and when she received her degree, I left. 18 Q Did you support her during the time that she 19 was attending college? 20 A 21 Q 22 A 23 Q 24 subsequent? 25 A ~ Yes. Did you support her and -- I supported the whole household, yes. Do you know whether she worked as an RN Oh, yes. She worked as an RN in ICU units for aEIGER 6 LORIA REPORTING SERVICE. 2408 PARK OR. SUITE 0, HDG., PA 17110 717'154""00 OR 1-800'222'''&77 tl several years. I don't know if she -- we have not had a very good communication trail, so I don't really know all 1 2 3 that's happened. 4 Through various sources, mostly the children, 5 I found out that she was injured on the job and she's 6 collecting disability at least from one source and perhaps 7 another source, as well. 8 I know that. I don't know anything else. 9 That's all supposition on my part. I've been told that, but 10 it's all secondhand type stuff. 11 Q To your knowledge, she lives in the Richmond 12 area? <) 13 A She has a home -- resides in a home in 14 Richmond, yes. She has her own home down there. 15 So I understand. 16 Q Now, you reduced the payments to Antionette -- 17 A That's correct. 18 Q -- after the children had left home? 19 That's correct. I could not afford to put A 20 them through college and maintain the payments to her. I 21 just couldn't do it. 22 Q How much did you reduce the payments to? To $4,000 a year. 23 A 24 Did she accept those payments for a period of Q v 25 time? GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR_. SUITE B. HOG. PA 17110 717'~4H!50D OR "000'222,.4577 66 I I! r "1 1 A 2 five years. 3 4 Q A 5 Q 67 She accepted them for a minimum of four to And then she filed this action? That's correct. Did you have any discussions with her prior to 6 reducing that or subsequent to that? 7 A I had many discussions with her. My period of 8 recovery began in 1986, so that's six months before I got 9 married. And in working through it, I decided that it would 10 be healthy for me to reduce it, so I did it. 11 Q This situation with Antionette is extremely 12 stressful to you, isn't it? t:') ~" . 13 14 A Yes. Q Do you feel that YOU've taken care of 15 Antionette and the four children that you and she have had 16 with one another? 17 18 19 correct? 20 21 22 A Totally. And you want to be done with it, is that Q A Yes. MR. O'BRIEN: That's all I have. 23 BY MR. HOUSTON: 24 Mr. Galla, back in Mayor April, that time Q 25 frame, of '93 when you moved into the apartment, did Arlene -..J QEIGER a LORIA REPORTING SERVICE. ZAOS PARK DR, SUIlE D, HOG. PA 17110 111.D4HDOB OR l.ooo.au.un 68 .'l 1 ask you to leave at that point? 2 A No, I did that myself. I felt that it was 3 best for me to be away, so I did. 4 5 point? 6 Q But you two weren't getting along at that A No. No. I mean, with all of this 7 going on and just trying to balance recovery plans together, 8 you know, it just wasn't working. 9 Q Now, since you moved back in in December of 10 '93 or thereabouts, I know that your testimony is that 11 you've tried to or your hope has always been until most 12 recently that you would want to try to reconcile, is that ,:) 13 A That's correct. 14 Q On the other hand, isn't it not true that 15 Arlene has not had that same interest? 16 A Yeah, I think that's probably a fair 17 statement. But she has tried, also; so I have no resentment 1B to her. 19 Q \ You haven't pursued marriage counseling? We had gone to counseling, yes. 20 A 21 Q When was that? 22 A I know I had go no through an EEAP I had gone 23 to three or four or five sessions myself. And then we !lad 24 gone to Mr. Wilms, a counselor in Mechanicsburg, prior to 25 that. v GEIGER a LORIA REPORTING SERVICE, ;Z40B PARK DR., SUITE B. HOG. PA 17110 717.54101500 OR "800'222'4577 69 ') 1 I don't remember the time frame. I don't 2 remember if that was before the separation agreement or 3 after, but sometime we did. I don't remember. 4 BY MR. IMBLUM: Can I ask for a spelling on that? What's that I \ 5 Q 6 name? 7 A Wilms, W-i-l-m-s. Peter. B BY MR. HOUSTON: 9 Q When you say before or after the separation, 10 YOU're talking about when you left the household in May of 11 '93 or after you got back? A Yeah. Before we came to the making of a 12 separation agreement. I think it was pre that date. pre 13 o 14 1992. Oh, you're talking noW about the support 15 Q 16 document? That'S true. I don't remember. A 17 But since that time you've not pursued any 1B Q 19 marriage counseling? 20 A No. I participated in a 12 step program and I 21 am working in a 12 step program. 22 Q What's that? A AA. 23 you're still working with AA? I'll never be cured with AA, it's just that 24 Q A 25 GEIGER' LORIA REPORT'NG SERYICE, 240. PARK OR, SU'TE B, HBG, PA 17110 7''''4''150. OR ".00'222'4&77 ....) 1 ~, 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 -...,) I'm still going to meetings. Q You're still involved in the meetings? A yes. Q Arlene doesn't participate in that? A Arlene is not an alcoholic. She may be an adult child of an alcoholic and is an adult child of an aloobolio aod ia purauing bar oun rnooverY tbrougb enotber means, but it'S not a 12 step program. Q She'S not working with yoU in your recovery efforts? A No, definitely not. Q She has taken trips to Arizona without you, is that correct? A I don't know. I know that she went on that trip with me. Q Didn't she go some place this spring without you? Oh, yean~ She went back to Arizona, yeah, I forgot. She took her daughter, I guess. DO you knoW whY she went there? continuing looking for a site for relocation A that'S right. Q A perhapS. Q 'A Q Didn't ask for yoU to go along? I was not asked to go along. DO YOU know when that was approximatelY? GEIGER' LOR" REPGRTlNG SERVICE, 2AG. P~R~ DR. SUITE ., ~OG, P~ 17I1D 117'54\'100' OR "800'222,"11 '1 1 A 2 Q 3 thereabouts? 4 A 71 ~ jl I l, February, March time frame, I guess. About the time that the divorce was filed, It might have been just around there, yeah. 5 I don't know the exact date. I can't remember. 6 Q She has indicated to you not only through the 7 filing of the divorce, but verbally that she wants to get a 8 divorce; is that correct? 9 A 10 Q Yes. And I know your testimony was that you haven't 11 actually worked on, from your end, a separation agreement. 12 But you are aware, are you not, that your wife and I have /.." ~~PI 13 been working on a proposal, is that correct? You're aware 14 of that? 15 A 16 that. 17 Q 18 A 19 Q Yeah. I'm aware that you guys are working on You're aware of that through YOJr attorney? Yes. And I believe you said that the house hasn't 20 been listed yet because you're working on it to get it to 21 the point where it's ready to be listed? 22 23 now. 24 A That's correct. I'm doing some painting on it Q I don't know if it was you or Arlene, have 25 touched base with a realtor in regards to listing it though, ,..) GEIGER a lORIA REPORTING stRV/CE, 2400 PARK DR, SUITE D. HOG, PA 17110 717'S4HSQO OR l.eOO'a2Z'4!177 -) c:> --...J 72 1 correct? 2 A Oh, yeah. 3 Q And that was the advice of the realtor to get 4 the house to the point where it was ready to be shown? 5 A Definitely. She came out and looked at the 6 property and said we should do this, this and this and I'm 7 doing that, that and that. 8 MR. HOUSTON: I don't have anything else. 9 Thank you. 10 11 REDIRECT EXAMINATION 12 13 BY MR. IMDLUM: 14 Q Who's the realtor? 15 A I don't know. It's a friend of Arlene's. 16 She knows that we're probably going to get one or two more 17 realtors out to see what they think and we'll give it to the 18 one that we think we're most comfortable with. 19 Q Do you think there would be a likelihood of 20 you and Arlene reconciling if you were able to resolve this 21 matter of support with Antionette? 22 A I don't know. 23 Q Have you ever discussed that with Arlene? 24 A No. I think that I'm recovering in my way. 25 She's recovering in hers. Unless we got together on those OEIOtR 6 LORIA REPOATlNG SERVICE, HOB PARK DR, SUITE 8, HOG, PA 17110 717'e.H~OB OR 1-000':222'.577 ~ ....) j'~j . 73 1 iteme, ee weii ee eome re,olution with thi', 1 don't think 2 tb,re" e'Y ohenoe. .ut 1 don't knoW thnt to be -- yoU 3 knOW, th,t'e o",'ng for nn opinion. 1 don't h,ve anY good 4 feelings right noW' 5 o you stated that when yoU and Antionette got 6 divoroed you took ,11 the debt' and that yoU made the 1 payments on the debts? A would that be other than the mortgage on the yes. 8 9 Q 10 house? yeah. yeah. yeah. DO YOU have proof that yoU paid thOse debtS? 11 A 12 Q I happen to have some of those with me. I'm " not a verY good bOOkkuepet. I keep jU,t thoee thin,e tbat I 15 thought it was necessary to keep. 16 Q What would thOse debts be? A 13 " . well, it wa' at leaet I think $6,000 lowed " her mother. .od I peid tbat off in the rate of 50 buoke e 19 month with six percent interest. 20 .ere are eome of tho,e obeok' right here 21 ,indio'tin,)' .nd I think thete" more tban that. <hi' wae 22 still going on in 'B6. 23 Q Can I take a look? Q Montecki, that'S Antionette's mother? 24 A yeS. 25 ,,,... . ",.. ..~","' ..~, ... .... ... ""' . ,.,. .. "'" ",..,.""" ,.-......", ....J -~ , 1 A 2 o 74 That'S Antionette's maiden name, yes. What other debts are you testifying that you 3 paid that were marital debts? 4 A All the ones in the separation agreement. AS 5 listed in the separation agreement. 6 Q 7 A 8 specified. 9 Q So you paid all of those? Yeah. Yeah. As charged, yeah. Or as Referring to the separation agreement, it 10 refers to a debt to Albemarle Bank and Trust? 24 against the Fluvanna county school board for harassment and 11 A 12 Q 13 A (..., ..... Q 14 15 A 16 17 18 19 20 21 22 23 That's correct, yes. And the Montecki debt? Yes. Sears? Yeah. Q Carlton Brooks? A Correct. Q Dr. Lipard? Yep. Rivas? A Q Yep. That was for a musical instrument, yes. A Q And Dwosking and peaslee? That was an ACLU attorney when we filed suit A 25 a couple of other things and we took the school board to GEIGER' LORIA REPORTING SERVICE, ,.00 PAR~ OR _ SUITE B, HBO _ PA \7110 7\7""-"OS OR l'OOO-222-'S71 , \ ! v :i:'!: 75 .~ 1 court and I got that bill, too. 2 These are some checks that are from Peter 3 Wilms for Arlene and myself and I don't know who was which 4 and which is which on this; but we both went and we found 5 that-- 6 Q 7 A Mr. Wilms, oh, he's the counselor? Yes. Here's more Montecki checks 8 (indicating). You know, I paid her up to '89 it looks like. 9 Up to '90. 10 Q Were you owed money when you and Arlene 11 entered into the separation agreement, approximately $5,000 12 from your boss? {."J. .'"'~' 13 A 14 Q I'm sorry. Say that again. Were you owed $5,000 from your boss for a loan 15 that you had made to him whenever you separated? 16 A 17 Q 18 A 19 Q What? Were you owed money -- From who? I don't have the name. It would have been one 20 of your business associates. 21 A 22 Q 23 A Never. Never. Never. Or a boss? Never. Never. Never. I have no knowledge of 24 that at all. Absolutely none. I don't know where you got 25 that from, but I don't know anything about that. That's a v GEIGER 6 LORIA REPORTING SERVICE. 2408 PARI< OR. SUITE D, HOG. PA 17110 717,!UHSOB OR 1.000'222'4577 ,,,,",, () .....J 76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I wish I did. The home that you testified was worth about 85 new one on me. Q or 90,000 A Q A Q Yeah. -- what was the purchase price of that home? 50,000 maybe. Was that maybe four or five years before you separated that you paid that amount? A I think we bought that home out in the country there was bought probably in '73 or '74. Possibly. I don't remember, but it should be on that separation agreement. It might help me there, I don't remember. Q I don't see any reference where it indicates when it was purchased. Do you know whether your children, your stepchildren Sandy and Bill, received a tax refund for 1994? A I don't know that. Arlene could tell you that. These are checks that cover the cost of sending them to school at least partially. I don't have all of those unfortunately, but those are what I was able to afford. And what I retained here, I guess. There's probably more of them here, but -- MR. IMBLUM: I have no other questions except I guess just to clean up the record I would have to move GEIGER a LORIA REPORTING SERVICE. 2408 PARK DR.. SUITE D, HOG. PA 17110 717-1541'1"08 OR "800'222',U77 77 ') 1 for admission of my exhibits. MR. O'BRIEN: I have no problem with that. MR. HOUSTON: No objection. 2 3 4 (Income and Expense Statement of Walter Galla 5 marked Walter Galla Exhibit No.9.) 6 7 RECROSS-EXAMINATION 8 9 BY MR. O'BRIEN: 10 Q Mr. Galla, what's been marked as Exhibit 11 9 is the expense statement that you prepared in reference to 12 your expenses as of the hearing scheduled for December? ,~... i~Aj' 13 A Yeah, that's true. 14 Q That just shows your separate expenses, it 15 doesn't show any of the expenses that Arlene would have? 16 A Yeah. I don't know. There should be one for 17 hers, but I don't know where that is. Maybe she has it 18 here, I don't know. This is mine, yes. 19 Q You stated that your wife, Arlene, takes care 20 of the budget and the payment of the bills and the 21 household. 22 A She's very good at that and she takes care of 23 that, yes. 24 Q So specifically, what you've shown as your ....j 25 expenses are what you anticipate? GEIGER a LORIA REPORTING SERVICE, 2"00 PARK DR., SUITE D, HOG,. PA 17110 711'!lUI~08 OR 1-800.:n2-.517 78 ...-..,' 1 A. Estimates, yeah. Yeah. MR. O'BRIEN: That's all I have. I move for 2 3 the admission of Walter Galla Exhibits 1 through 9. 4 MR. HOUSTON: No objection. off the record 5 for a second. 6 (Discussion was held off the record.) 7 MR. IMBLUM: I have no objection to the 8 exhibits. 9 (The deposition was concluded at 11:45 a.m.) 10 11 12 ,r,,\ '....# 13 14 15 16 17 18 19 20 21 22 23 24 u 25 GEIGER a LORIA REPORTING SERVICE, l40D PARt( OR. SUITE a, HUG., PA 17110 711.S4"'SOB OR 1'800'22ih'~77 79 tj 1 STATE OF. PENNSYLVANIA SS. 2 COUNTY OF DAUPHIN 3 4 I, Ellen Swayze Reisser, a Reporter 5 Notary-Public, authorized to administer oaths within and for 6 the Commonwealth of Pennsylvania and take depositions in the 7 trial of causes, do hereby certify that the foregoing is the 8 testimony of WALTER D. GALLA. 9 I further certify that before the taking of 10 said deposition, the witness was duly sworn; that the 11 questions and answers were taken down stenographically by 12 the said reporter Ellen Swayze Reisser, a Reporter '.....) ((~.. 13 Notary-Public, approved and agreed to, and afterwards 14 reduced to typewriting under the direction of the said 15 Reporter. 16 I further certify that the proceedings and 17 evidence contained fully and accurately in the notes by me 18 on the within deposition, and that this copy is a correct 19 transcript of the same. 20 ELL REPORTER 21 subscribed my hand 22 23 24 My commission expires: ....) 25 June 26, 1995 GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR., SUITE D. HOG., PA 17110 717,UHSOB OR 1'000-222'4577 t "'.' i ',.\ ',' II ,(J' 'S J-O ",~lfttt1 :J. l(}~ .JJ.lrI. ~ s;9. 0 ~ 1i,.5"D1:O I IUlola'1/ h\~, '. SIlPARATIOlI AGRnmHlNT Vi~~ r'~ (~'r.J,N}3.JJm... 1.1!.Q..'\l!L c(-ctrb~ UJ) THIS AGRllEMUNT is m!$lo thir. 29t.h ony of'OAugust, 1980, by .'-... I .. ........... - ......... . ,. , , . ~ .,,,1-", ; \ ,I I ' I -f. II';' !','': , I'., , t.,. . ~, ' .', ., .. ,', j" ',.~ ji:X:."..,'"., KP,~;~'i;,}.,v;';':'" . '4,J.o,-.l.\I,\:"'I~$,f,~~ ,....... " .' v''''''\',I' '[1."'" .',., '; ~:; ',~, .<. . I' ,......, l' ,'" r;..:: ..:,1....., "d ~', ," I,\l,,~.:l .,. " I."" ........ ,..' . ".:,.' nu butl~oon NAI.TBR DELPIliS GALLA, of C!\Il1'lottusv:l.lll!, Vb'g:l.lIin, (horo:l.p "HusbRnd") and ANTIONliT'rn JIlANm"!'D 1.:ONTliCKI GALLA; Fluvanna.. , . ' County, Virgin:l.a (heroin "l~:l.fo"), I~ITNBSSBTII: '".".t thl' pllrtl<:s \lore 1U11'l'~'iod on tho 215 t day of ( Broadviow, IllinoIs, and I ! ' \Hllil\EAS, January, 1961 in " .' l'IHDRllAS, there were four (4) children born o€ this mnrria~o, to-wit: Debra Dee Gall~ Johnuon, born tho 11th dny of, l7ebrllury, 1961, now omnndpa teu, S}uu'on Denis c Ga 11a \'ace, born the 25th dn)' of July, 1963, now omanc1.pa.ttlll, Waltc~' J. GaUa, born the 20th day of October, 1966 and Brian Keith Galla, born tho 10th day of September, 1969, antI. l'/lWRllMl ,certain d1f:fp.renc,):l have arisen hetw\~l)n the p:.\Tties as (1 .flllult of whi.ch tho parties are now living separate and apart, and have been so r.opantcd :;inca the OSth day of JUlle, 1960, Droit . 1'I1113RnA~" th~ parties intond to .:cntilluo l.i.ving separate and apurt and th(',y desire to reduce to ,rdtinj; their agroemont concernill!,: tho divl:;lc.n or their joint prorcrt)', mntters of spousal support allll chillI !'.\lIlPort, mDttcT~, of c!lild custody, and all othm' chili!!., rillht!'. and dcmr:md~ orizing out of their .' .. . marital rcl;lti,ollsJd.ll, NOH, '1':mRIJPORH, ill con:i:l.dcrRtlol\ of: tho premiseG and the lnl~tllal [l:-::mi:l\u or the ll;lrtie::; cout.::.\lI(:c\ hC1'ein, it :l.s '.l \ AMATO, AMATO Go ASSOCIATES, LTD. \ AnORU;VS AT LA... 30. EAST JEFFEASOII ST. CIlAAIOnESVIUE, VA. . 22901 aareed ns folloWll: 1. PARiIll5 TO LlVn STIJlARAill Ar:~ APART: From \:he date hereof: an'l u!t(:r, the, partior. \~1l1 continue to live :lepnratu 1l1ld np~rt from one "nothor, und anch pnrty w111 bo ontitlod to live -1- '. EXHIBIT A to t.ho blllr.nc:a in hill or hOT z,op:;'l'nto hIm". chocldng /J.ccounts from thlu date !orwr.rd but thi:l right o!: ~u.ch p:1.1.t)' to the ownership of his 01' her 5opa1'l1to bank chocking account llhnll not limit other obligation of the pat ticS itS containcrl htll',:-1.n. Thl: joint savings, account ::.';. .\lo~:r.;:...lc B:mk Ec 'fru3t in \:II':: amount of $6,400.00 shall bo uivi.leo.:\:'O r\~lH\\'/!;: $l.:iOo.no t.o !I\I~h(1nd for r010cl;\tion oxpenso:., ,lor1 the bal(ll1CO of ~.\ ,9ll0.1)(l :;1.a1\ go 1;0 tho Wifc. . ",' . , t '0' , I ,'t' \ \ I I , frec (rom mol.,sta don, authority, anll control, direct or in- direct, from the otllur, in tho same manner nS if unmarried, and el;\ch party horato shall have nll tho riHhtn and privilogos that each 1o:ol.ll.d otherwise have if not mnrrLcd to the otller, 1ncludinIJ I . thc light to roside at any p1aco, enRage in any occup(1tion, employmont ur busineSS, and to contrnct or be cont.ractc,l with, without the consent of tho other, in (111 respocts as if unml;\rricd. 2. lU1SrON5ItlILlTY FOlt DBBTS: Tho puties shall not 111CU1' any l\ebt in tht! hur,lo of tho otller OT 011 the credit of the other, noither sh(\ll pledllO thlJ other l!l crl1tlit in (lny mllnnor, aftar tho cl'ecut1.on ofthl:s AgrccUlont. The parties have fully, disclosed to Q('.",h ot\lor \:he (.llligo.tio\\C thttY huve inCUl'l'ed prior, to this datu in the n!unu of 01' on tho crodit of the other and ollch shall h~l'Cllfttl1.' u" l..tlllpo\\sib1u fol.' his o'r her respoct.lve obliga- tions whuthul' lncurrou uufore 01' o.ftor tho datu of t1l1s Agr eement. Husband ag~ce~ to pay ~u11y and slltisfy tho follo~lnR obligl;\tions I;\nd to 1Io1u \~irc harmlellS theroon: (II) ,\1bOI,1l1rlo Unl'!; & Trust ,. I1pproxllilatolY ~l,900.00, (b) Jeanette Montecki . $3,000.00, plus interest, (c) S(;llT5 . $r,R.OO, (d) Carlton r:rooks - $116.00, (tI) Dr. Lipurl! _ ll.\l!lToxill\ll.telY ~SO.OQ, DIO';lliUn !\ l'O:H.lee '- $1,500.00, (() ltivus - $lG4.00. 3. nANK ACCOUNTS: 1110 plll.t iUll 1l0'~ h:WCl their funds in -CT\llCl:il111 . sepurate b&llk/ acCo\\nts anti there are no j 0 ill t chocUn~ accounts in thll no.mc of the pllTt lou . \i;lch pa,'l.y ~hall he fully entitled AMATO, AMATO &0 ASSOCIATES, LiD. ~TTORHIi'tS ~T lAW 30_ WT J'FF'RSOH ST. CHARlOTT'SVll~" V~, 22'101 -~.. " , . , f ~~ .CJ'!" . ~l" ..~i .' :~~'...~ .,,<, . ~.~ 6; (JO ',!>. \. ',... ~ , ~. ..,1: ". AUTOMODnm; AND MOTOR VnfnCl.nS: !lusband and Wife agroe to soll tho following v(lhic1011 jointly olfflod hy tho partias and tho procoeds th~rofrom shall go to tho Wlf~: .,. (n) 1976 !londa, (b) 1969 ChrYlll"l', (.:: ) 1969 Poru Van, (t1) John ! I Husband shall hovo solo ownership of 11 Deero ~odol n. Tractor. :."....: ,':;\\ll'~' 1971 Pougot now pol01y in his name. Wife shlll1 have 5010 ownol':lhip of ,1 1970 lIonlla "nil 1965 Dudge Truck now solely in I I i ! !' ; ! i ,j har name. The 1971 Toyota Corona Jointly owned by the parties, is now being seld to Dobra Doe Galla Johnson; all futuro paymonts being mudo on said automobile slwll go to tho Wife, 5. TANG!BLP._~~ONAL PROpnR1'Y: All tangible personal property locat.ed at Rt. 2, Box 205, Scottsvillc, Virginia, shall honcoforth DO the property of the l':ifr., save nnd except Husband' 5 personal items. 6. Rr..u. f:5TATn PROPERTY: TIll) portieG (nn! 05 tonants by tho entirctj' tho l'(l:lidence and 26 acro~ wi th shed and barn locatod'. at Rt. 2, nox 205, Scott:;viJ.10, Vlreinin, encumhered by two (2) deeds of tl'Ur.t Hhich totnl approxir.lOtol)' .~:'!G, 000.1)(1. Hu:;bnnd agreos to forthwith t.ransfer to II'Hc nn,' nnd 011 right, titlo and interest \..hlch ho mny have in and to so id ren1 property 1n considerntion rOl' ,,'hi.ell Wife al:rClc:; to Ul::;umc rosponsibility for further payment of t:he mOl'tcano obligation the'l"eon and save lIusbunJ harmlcn:: therofor. l'lift' o!l'l"OOS tel he rC:lponsible for pnyment of :ll J. :'(:1I:lir:;, maintenance,: tnxor.;'ctc. on said pr?porty, 'fhu purtJ.an UIIlI ail tOntlnt:l by tho until'ety Lot 141, Phus", 6, I.l\ko ;.lolltlc,'llll, I'lllvannu Cllllllt)l, Vlr::lnla, :laid property to bo Gold by the partios and tho p1'ocl1l1l1:\ 1:0 (to to the Wife. 7. C/lTl.D CIIST01W AlID fj(JPPCln'J': - - . TO, AMATO Go , OCIATES, LTO. . ORNm ^TLAW T JrFFUSOIl sr. RlonUVlLLr, VA. 22901 (L\) l'IiL'o :311u11 hove tho ClI.,tIHly nnd control of the porties' minor children, W~ltcr J. GalIn nnd D1'lnn Keith Galln; pro\'J.ded, h():~l'vcr, that llur.bllnd ;:lwl1 h:l\'e rO:l!lonablo rights of vhitntl,on upon Oi.l'1nl: l'/lfu roallonnblo notice of "3" \ . "., ',',' ':!' . ; 1 ;1 I I .\ , I I I f . ':.f' -.r':-, , ,~."~.' (d) Husband Shllll pay to Wife tho SUll1 of $ 520.00 very t\,/o uc"ks commencing on tho 05t.h_ dRY of SeTltomber ,1980 or tho support and maintenance ot said minor children of tho artiea until such children reach the age of eightoen (18) years, arrios, or otherwiso becomes solt-sufficiont, whichever shall 1rst occur. Husband agreoS to pay lncrollsos in support baned on he need;\ ot said childrol\ and/or tho incomo of the HII,bl\m1. In he event Wife does 1\01: recoive n\lTt\ing cOTtification, Husbc.nd agrees that said support shall be increased. In the ovent wife is incapllcitutad Ilnd cannot ~Iork Ilnd recoive income. Husband agrees that !laid :;UpjlOl.t slldl be adjustO\\. B. SPOUSAL SUPPORT (^LI~~NY): At such time as each of the above minor children llhall roach the Ilgo of eighteen (lB) y"T', .'TT1.., .T .th.T"" h.e.... ,."..u,,'e'.nt, that ehl1'" portion of suppOTt and. l'Jllintenanco shn.ll condnuO to be paid to' the ~IHo 11:1 spou5l\.1 suppOTt. in tho S(lmo amount Husband is contributin~ at \luch tlme, and cOl\tinuing until \'Iife's death or l' olilCltl' 13.go, :Itntu'tOTY 01' common 1.11'4. whic.h~VOT fiTst oc.curs. \). !.!~cmm TAlC DBPllNDRNTS: Tho pllTties Ilgreo thl1t the Huabl1nd ~hllll claim one (1) UlinoT chilli (15 n dependent fOl' purpoSo , ,I . . . ~ . ...". . . Imo or times ~t which ho intends to exercise such right'. (b) Tho partios ,hnll confer w1.th oaeh other on 11 import lint matters pertllining to such minOT children'S health, olfaro, edUCAtion, and upbringing with a view to I1rrive nt a aTmonLb~ policy c~lculated to promote the children'S bost nteTst. Husband shllll bo responsiblefoT payment of colloge oduca- ion of said minor children. (c) Bile h 1"11 rty sl11\11 promptly notify tho othoT of ho childron's SOTious injul~ or illness whilo in his or her ustody. 01{ ~",-t,) .'t ..,,\J~ %11) 'Y AMf\TO, AMATO (, ASSOCIAT!:S, LTO. ATToRN,n AT LAW 301 ","ST J'FF'RSON Sf, CHARLOTT'SVILL'. VA. 22901 of filing llcdel'Oll and Stllte Income 'l'IlY. RoturnS. nnd the wifo shall clailll onll (1) minor chlll\ Il!l a dopondent for purpose of filing' Pedoul nnd $tl1tc Incomu 'Lal(. R,rtUrl\s. -4- ",", . <':~ "0 .+~:: . 0/1;~'; . ';'j,~tt~ , ,,011:.' .' ":~~' . ".\}~i' .~~ .".,<;\~;~ . . . -'1'" . I' .1 10. HBDICAL INSURANCn: Husband agrees to maintain B1uo Cross/B1uo Shie1d,or comparable hospital and medical insurance for each of tho parties' children until such child graduates from collego or reaches the age of 22, whichever ~' . ,I occurll first, und to maintain such coverago on Wife so long as Wife is eligible for coverage under Husband's pOlicy. 11. LIFE INSURANCD: Husband shull from tho date of this Agreement maintain in force and effect a $SO,OOO.OO life insurance pollcy naming IHfo as priluary beneficiary and the aforesaid two (2) minor children as contingent beneficiaries. At such timo as said minor chi1dron roach the age of eighteen (18) years, marries, or otherwise become seU-sufficient, sllid policy shall namo Wife as primary beneficiary and all four (4) children born of the parties ao contingent beneficiaries. 12. OTHER: Husband agrees to be responsible for payment of all medical and dentul bi1ts not cov~red by the aforesaid ~edical insurance of said minor children. AMATO, AMATO &- ASSOCIATES, LTD. ATTOAH;VS AT LAW 304 ;AST J;FF;ASOH ST. CHAALOTTUVILL;, VA. 22901 13. RELBASn FROM FURTHBR OBLIGATIONS: Bxcept as heroin otherwise provided, each party hereby releases the other from any and all further liabilities or obligations, whether of support or otherwise, and each hereby releases all property, ren1 or persona I Which each may own or hereafter acquire, from nny and all claims, debts, 1iuns, or other obligations which might otherwise attach '0 accrue by reason of tho parties' marriago, inCluding tho rights of dower, curtesy, inheritance, and any right to ronounce or take against wills. l1ach party will, nt tho requost of the othor, j 01 in and execute such deeds, cortificates of title, or other In- struments as may bo nppropriata to give full force nnd effect to the terms of this Agreemont', and in pllrticulnr will join in any convoyanco of, deed of trllst on, mortgage on, or other encumbran -5- , . \ . on roal ostate, in order to rOl,aso his or her claim of curtesy or dower therein. Notwithstcnding the foregoing mutual releases, such rolol\5es , . clllim or shall not be doomed te be ro10ases or waivers of any ! clailas or causo or causClS of action, which either party m~r h~Ye against the other arising nIter the date of this Agree- ment, but not arising out of the marital relationship of the partios. Further, such mutual reloases and waivers I1S set forth . above shall not constitute waiver or roloa5e of the right of eithl.lr part)' to obtain judgmont in ln~l 01' in equity and obtain execution and collection thereon against the property of the other for bi'each of thi:; Agreement, nor waivci' or rolease of any other right or rights, or cause or causes of action arising from the broach of this Agreement. 14. llIVOnCB: Tho parties hereto agree tlult this Agree- ment shall Mt bar or affect any oi tho riChts of either party hero to to institute 01' prosecute against the other in any Court of co~potent jurisdiction, proceedinns for divorce, and they further agreo that in the ovent such P1'ocoedings are insti tutod by either of thCIiI, each of them will ask the Court to affirm, ratify, and incorpol'ato tho provls ions of this Agreement into any.. Decree rnndorod pursuant to Bny divorce proceedings. l5. ATTORNBY'S FBnS: Husband agrees to pay atto1'ney's' feos and cost of both ptlrt1es in connection with any aspect of the preparation of this Agreement, and in connoction with any divorco procc~diuUs by oithor of the partlos against tho other. Husband fu~thor tlllroell to bo responsible for payment of deed AMATO,AMATO& and title transfer containod ill this Agreemont as the neod ASSOCIATES, LTD, i ATTORNIiYS AT LAW a r SOil. 30_ EAST JEFFERSON ST. CHARLomSVILLE. VA. 16. EURTHliR !!Y.l!CUTJ ON OF DOCUmiNTS MD/OR INSTRU~IBNTS: 22901 Each of tbe pnrtius ngruc to execute such other and further aSSllrllllCCJS, documonts, and/or instruments as may bo nocessary to carry out the intent of this Agreement. -6- . ., .... .. .1' 17. fQ1;I'l'ROI.I,UlG LAI'/: It 13 a;;rocd that the terms hero- of, inlloJ:ar tL!i they 'roqu ir., COl\ll t ruc tlon or anforcomont, I1re to bo construo\l in accordance I:ith tl111 1UliS nf tho :Jtate of Virl~inin. 13. C:IMlGJ! or. AODnr.S5: !illch (l f thu partios hereto --- agroes to keep the other informod or his or her wheroabouts, I' . ) and shall within ~O days of any ch~nU\l of addross so notify the other in writing. 19. MODIFIC.\TION ONl.I IN ~:RrTH!9.: llach of the parties agrees that this ^~roomont contains the" !lntire undorstanding and agreement of the partios and shall not bo modifl~d oxcopt by an agreement in writing ~xacuted with thn ~n~r formBllty ns this Ag\"cemcr. t. ZOo COHTINUItlG npPI!CT: Tld,:: AUTCMlont shall be of continuing Callr;t and ...ulldlt~. Iwt1\'ith::.tamUnt; the posnib1e rcconcilia tlol\ uf.fol't:: h..-t.\/C,C11 tlip. I'ill"t Los. It i:. undllrstood tlnu .1t:,r\';l.hl b(:t.\H.::'.... ~..hn l,~\':t.t':::\ thrd f,l,J.~. r":fl.\ratit~n ''\i'i'':"ccmcnt llh:lll be 0;: coutinlllnp, rd',r:ur.l; nn~l v~.l \11 nnrl hincUnc upon the parties lUlU ;;hall Ill1t 'tcn'ln.tnn~.r. 'mlr:','l ;L\H\ 'lIltll tho p:lrties OXocutll .:. tCl':n,tulI'.;lml :1l;\'::',IOI(:ut III ,I.'I'l.ting of equal di;lnity 1101'oto, or IUlless all:l llllt-il tho ~HlrtiM l'll:mrno n common marital abodo fo\' a continuous per locI 'J E II t le,lst !l0 days. ~~. 11AIVl!R: No wuiver DE nR~ branch or dofnult under . this Agroement shall bo clr.cme:l to be n Haive'!' of any :mbsoquont broach of default of thn sn~n O~ olmllnr nature. AMATO, AMATO Go ASSOCIATES, LTD. ATTORH'YS AT LA'" 30\ ,",ST J'FF'RSOH ST. CHARLon'SVILL'. VA. 22901 I\'l'l'~msr. t.lle l.ollo',dng sl3ml,1;u\"e~ ,In.l. 5~,;ll:l. \ ( ; ",.~.,iJr\..'" '(, ',", .,,~ ) 'Q rL '; \ \\I~,'\.,. ',\'/; l~' \X.J..1J<.lb _(SDAL) -\~ol wrlTCIIinTsGnlla' ' -'. ,r;,'J .~.,., , " (..0,: ?;!:r./,,; l-cL~ . (l"l-L.IJ.t:Z;!S_kb.t-.2.C.l.lu. r..{"u:~tt?.B^L) , 'nt onettc cone t tc :.Ionteclc:i Gallo. -7- I i! II \ \ f-. .' , . , , " I \... . STA1B Of VIRGINIA COUNTY OF ALBF.MA\\LB, to.~,it: Th' fo,.,.l., ,.."...., w.. .c...wl"'" b.f'" m. by .' , .."," ~,'.hl. G.ll' o. ,h. ",h d.y of AOGo'" ,"0. My commission Clxpi1'OS ~1 Jnnut11'Y. 19l1~. L9 H /.~ ..!f{ ~ dr' ~Ub"1.ic STA1B O~ VIRGINI^ COUNTY OF ALBB~RLB. to-witl Th' f.,.,ol" ","0"" w.. ,c.,oWl.d,.d b.fo'. .. by A.,lon.'" ,...."0 .on'"'' G.ll. on ".. ,,,h d.y of Ao,O'" 1980. t1.y comml.s:lion OXpi1'05 31 Jnnuo.;:y, 1983. , ~.~~ o I\1'Y uolic \ W\TO, "I'I"TO rr ~ SOCIA1'lOS, L10. \ . ~TToalllO'lS ~tlJ,'" , . oHMt J;FF;asoll st, . cw.a~oTT;SVI~~;' V~, 22901 ~ ~ \ ~ .8- " " Spousal Support Agreement This Agreement made this day, November 21. 1992 between Walter and Arlene Galla is meant to protect the property and Interests of Arlene Galla in addition to providing sufficient funds to maintain the household In a manner in which she is accustomed. The agreement will remain in effect as long as the couple attempts to reconcile their marriage and will be voided by mutual consent. I. Walter D Galla will pay to Arlene A. Galla the sum of $ 1800.00 monthly. This payment will be made in two installments of $ 900.00 each on the 10111 and 25111 day of each month. In addition all jointly held property will remain in control of Arlene A. Galla during this period. Signed-W~A1~ ~ Walte"r D. Gall Date~ Signed QL Arlene A. Galla Date I //~3 ICfL I . af~,- , ......1 .- ill ""!1io'<IIl\Vt""'..,.rA~"'''''''.' )' ""'1"', . I . .':." . , I , ".-.~ ,., .' VIRGINIA: IN THE CIRCUIT COURT FOR FLUVANNA COUNTY WALTER D. GALLA complainant v. Case 110. 1242 ANTOINETTE J. M. GALLA Respondent I. i MOTION TO VOID SEPARATION AGREEMENT COMES NOW your Complainant, WALTER D. GALLA, by counsel, and, based on the legal authority recited bel?w, requests the following relief: That this Honorable Court void the Separation Agreement of the parties, dated August 29, 1980, previously affirmed, ratified and incorporated by reference in this Court's December 11, 1981 Final Decree of Divorce and in support of this request states as follows: 1. The above described agreement between the parties is unconscionable because it was procured by the Respondent's undue influence. 2. The above described agreement between the parties is also unconscionable because (a) it is grounded upon inadequate consideration to your complainant; (b) its inadequacy of consideration is such as to shock the conscience of a court of equity; and (c) its procumerment. resulted from the constructive fraud of the Respondent and the now deceased attorney then purporting to represent both :.~ ~ signatory parties'despite his obvious conflict of interest: Stephen Amato, Esquire. 1 / , - , . . " , , . , , / 1", .' 3. A Court of equity is required to conduct a hearing to determine the merits of your Complainant's allegations as to the validity of the above described agreement and, if your Complainant prevails, the Court must rescin~, cancel and reform their agreement. See, Jackson v. Sevrnour, 193 VA 735 (1952); Seaboard Ice Co. v. Lee, 199 VA 243 (1957); Derbv v. Derbv, 8 Va. App. 19 (1989); Hale v. Hale, 20 Va. cir..230 (Henrico Co. 1990). FOR THE ABOVE STATED REASONS, your Complainant requests the relief specified in this Motion. WALTER D. GALLA /B OU~SEL (~ Dav d VSB # 18750 300 Second Street, N.E. ' P.O. BOlC 2056 Charlottesville, VA 22902 804-293-4874 .. CERTIFICATE I hereby certify that a true copy of this document was mailed on this ~ day of December, 1992 to: Debra S. Gardner, Esq. P.O. BOlC K-101 Richmond, VA? , Hellberg 2 ARLENE GALLA ANTOINETTE J. M, GAI.I.A , PLMI'lI'lFI' DR 20,781 DR 23,139 IN 'lllE axJR'I' OF C(M>ION PI~,AS 01' CUMBERLAND COUN'I'Y, PENNSYINANIA VS OCMES'I'IC IlELA'l'IONS SEC'l'ION WAI.TER D. GALLA ,DEF'END/lN1' CIVIl, ACI'!ON - SUP POR'I' NO. 1195 A~IENDED NO. 956 ORDER OF A'!'1'ACllMEI'll' OF INW1E OF OF l<l<l? 199/, ~I Reeves-Iloffman. 400 W, North Street, Carlisle, PA 17013 AND N:M, this 7th day of October , 19~, pursuant to the laws of the Commonwealth of Pennsylvania, the income of Walter D. Galla defendant/obligor, social security nU11ber, 345-30-3562 , of 226 N, Bedford P.O. Box 1155. Carlisle. PA 17013 ,is hereby attached to the following extent. , St .. You are directed to pay to the Domestic Relati~s Section of the Court of Canron pleas of Curberland County, the sUm of $ 1463.34 t fi!'! month out of the inccm:l due the defendant/obligor, within ten days after the date of the defendant/obligor is paid. '" 0'Tl ' Co Xo "'X'Tl "'",- "'1II'- .-...'" ",_0 :>:00 ",,,,",, nm"" I\) 0"'0 Q C:)Jorn :- Imn'IFY TIIIS Pl\YMENr BY PLIIC!NG .NH3ER DR 20,781 00 YOOR ~/PA-mPm'. DR 23,139 -c;:; ~ the Domestic Relations Office will = .., -. HI\KE Ou;x:KS PAYABLE' W: ro.,) romsTIC RELT\TICUi SECl'IOO P.O. BOX 320 ClIRLISLE, PA. 17013 Q:l Upon receipt of the support payrrent, distribute the payrrent as follows: twice per mont' It l\M:XlI'll' UflED $ 900.00 SUPPOm' $ per twice $ 563.34 per month $ per $ per ARREI\RJ\GE OOE DPA $ ARREI\RJ\GE OOE PLI\IN'I'IFF $ 63 , 138. 00 BLOOD TESTS/OJS'l'S $ SERVICE FEES/OJS'l'S $ nlis order of attachment for support is binding upon you until further notice and shall have priority over any attachm:mt, execution, garnishment or wage attachrrent under state or local law except one relating to a prior support order. You nlUst com- rrcnce the attachrrcnt of the defendant/obligor '5 inccrrc as soon as possible but no later than fourteen (14) days fran the date of the issuance of this Ordcr of Attachncnt. You arc notified further that pursuant to lawl 1. 'rho dofendant/obligOl: has been notified that iln Order of Attachrrcnt for Support would be issued. 2. Wilful rililul"lJ to cc:Alqlly wi th thiB nnlct. nny reBlIlt in (I) YOUl. being ildjlldged in contenpl. of Coun ilnd cellini ttecl to jail or fined by the COUl't; (11) YOUL. being held liilble 101: i1ny ilnmll1t not withheld or withheld but not fOl'Wilrded to the IXxl'cr.tic Reliltionr. Section; ilnd (III) attilclm:mt of your funds or property. J. '111e attachment of incaoo or the possibility thereof ilS a basis, in whole or in part, for the discharge of an employee or any disciplinary action against or derrotion of an crrployee is prohibited. Violation nay result in (I) your being adjudged in contClll1t and carrnitted to jail or fined by the Court; and (II) an action against you by the employee for damages. 4. If there arc in your employroont, one or rrore additional crrployees whose incares are subject to Order of the Court of Ccmron Pleas of Cumberland County for attachoont for support; you nay c:arbine the attacl-aront pay- ments into a single payroont to the Domestic Relations section and separately identify the portion attributable to each obligor. 5. You llUst notify the Domestic Relations Section when the defendant/obligor terrrdnates employroont and provide the Domestic Relations Section with the employee I s !as t known address and the ncure and address of the new employer, if known. I 6. The maximum am:Juot of the attacl-aront shall not exceed 50 % of the defendant's disposable earnings. 7. The telln "income" as defined by law includes canpensation for services, including but not limited to, wages. salaries, fees, cCXTtJCnsation in kind, commissions, and similar items, income derived from business, gains derived from dealings in property, interest, rents, royalties, dividends, annuities, incare from life insurance and endO'nlllCnt contracts, all foJ:11lS of retirement, pensions, income from discharge of indebtedness, distributive share of partnership of gross income, income in respect of decendent, income from an interest in an estate or trust, military retirement benefits, railroad crrployroont retirement benefits, social security benefits, temporary and pernanent disability benefits, workrren's canpensation and uoemployroont COlpCnsation. YOO MAY DElXJC'f Ani 'I11E IWJ\NCE DUE 'I11B 0EFENIlIINl' 1IN J\KXJN1' muM. '10 'lID PERCENl' (2%) OF 'I11E J\KXJN1' PAID FOR CLERICAL \'tORI< lIND ~ INVOLVED IN <Dfi>LYING WI'I1l 'I11E ORDER. (SEE PI*lSYLV1INIl\ UIW 1985-66, SECTlOO 4348.) BY '11 IE <XlURT, ORa: Lucinda E. Sheaffer cc: Defendant" .' . . 06..___~,..._...... , - , "" <II >-... co .. "'<II ::l ,....'" o <II .... .. 'J " " 0 "'.. ... ... <'II ... a :3 .... <'II 0 ........ " !j" - ... .. llll' .. eo c a ~ C... I-l bJ ... C 0 <'l .... '" :c ::l <'II ::> '0 <II '" :z: I ]jl:' :j 't'4 j,J .., g ~ OIl ~ ~ "''' u ~ ... <II '" >-".. ..... "'..... ~I" ~ ~! . ... ~ .. '0 <II GI .3 3 ~ ~~' ~ ~ ~ >- a o ~ <II if; ~ 0 <II a ;:....:: == lU l.W j,J en "0 0 l.W Ul ~>-o ..",>. " 0 '" u 0 <II 0 U :> ... 00.. .a.c .. l>o.c u ' JJ"~ ... .c... "\ \ oJ < \!J .. .. 0'" ........ .. :J <= 0 o "... & 'j~.8 II .. ... II- .J~:;:e1' c- o.co g I ~....... ~ .... "'0 cu .~ <II.c C .. .. ... OIl.. " <II <II ....... .. <= <II ::l .. .. I to a.. . 4) 1-4 .. CD . - <n Q.I j,J c . . ..:: "1'1 > C:..-t . .. <II ~ "'" .. llll .. 0-a;:~ ~ tii :: oS ~ )< l:1 ~ '" .:\ .. ~;: ~ :- ,'~... 0. -g .: ~ ~ 3 /aJ~~~ 1::.....: ~ U <IJ es '.noe OJ liS In":i ~ ~ ... ......... '" '" >- <=.. :. "'IW4lw:30 IOO~r-4 taJ...-lGJO ~lMc..'Pi ra.... ::l ><0 ~ c..> cU ..... 0 co j,J . ... ns "'0-1 ~oGlcog'Ogu ~ ~ ~ E ~ ~ J ~ Ul S . 0: ::> <oJ ~ ::> 1;; o '" t<l 0: Ul <:> /' is ~ r ._, ~ ~ i' .... ~ ~ .:::t ::j 5:1 tl i1 ~ q gj E ~ ~j ~ & ~ ~ ~ ~I ~I c1 \1""1 ~ ~ '!I !QI - - ut crl ~I i1 ~I~I 001 1>01 ~~ ~ ~ i:>'ll ~I ~ ~ ~ ~ \I r1 ~ ~ ~ ~ rj rl ~I ~ ~I bil ..j .)1 ~ ~~~~~ ~ ,~~ H ~ ~ ~ ~ ij ij ~~~~l ~ ~~~~~ ~ ~ ~ ~ ~ ~ ~ l ~ ~ ~ i 1 ~~~~~ 1 ~~~~~ 1 ~~~~~ :4' : >< -' . e2.Q: - 1,' .. ~ -./' -g o ... 0 u <= lQ .5 ~ co Gl co <II .. <= ... ... ... ra u > ,l:l ~ .:l ~~ij ~~~ U~ ~ ~ ~ & ~ ~ ~ ~ i U~ ~ ~ ~ .~~ t ~ ~~ ~1 : :: q : ~ : cu -11: J,~ - u ""..... . ..:...t - cu c ~ U - - 6 ~ ~ ~~ : -a .. .. III GlJ' ~ C :2 C a.. - .... = en ~ tlJ" 0 ... .s .c ....'0 ~ ~ 'Pi ..... 1-4. p.. CD ] ~ ~ Jf U ~ " l;l :J ~ ~~.:'i. :8" ~. ~ .j:l ... ? .. r L I I )~ .... l{. '\'5l .. >. .. '" <= o 'tI .. Gl ... <= ... llll .. ... 0 Ul '" oJ [AJ to IrzJJ Tax Services, Inc. 321 SECOND STREET, NEW CUMBERLAND. PENNSYLVANIA 17070 Wc.ITC-r C?\J J\rlc:~" Gontl /;;'0 L;i1n Of. c.arliJIG- f/+ 170 J3 RE: /qq~ F~"b.",1 III,""'/] T"')l.C:-s' f6~.s,-J 0" I...f~n..~ru'" Y04 s,,//Jir:,). .j:'Clt' q~ SA/Cl'/~S a"/Iui,,,} Q31.s ref"'AJ tv, I..rC."C:11, o"v,.d~h, t1.) c-Ilfiroli{ G,,"'AJJ, '(OIJt' 94 F6dc..",,/ Tr.~ will be. ilJl,J ;1.,'1. Oil) yt1t1t' Fc.Jt7'<{ wit~ ~I1IJINJ 6ve-" kI;t~ n,. ]"1c.(tf'Jc:d P~r Oc.T. -AJ()II.- {Jec.. yO/l viII .rrill he .s~ltr by A""Y., '/;100.0, flit-II b(.,~; slid' hy T~jJ a",ow.;r loIe: q;,(: fo Qv~/J "pC"Nt;lty, 'I~ YOLe wi.s~ loIe T'~ P'Y"'f:loIt Ly 1-15,95. flt:<J<.' dtJlIt"t I'tC. if Q"lr~iAJJ /,Ill ,,;!'...I h'!f~I.I.s, ~j) 10'00 <!.UJ 4vo/d II Pc:""Il"y, sriJ/ w/iii~ r4(, !Jl4liM/A/C"J C.D~/J r, .ka QAJ e-J"';" ,t,,) $; Nee-fe; I Y J (),;If1 1- fL~t . " ,,~ .' ~,...... , . - .' .... --- , " ' . t 19 Surrey Lane Mechanlcsburg, Pennsylvania 17055 Oecember 1, 1993 Wal ter Galla P.O. Box 1155 Carlisle, PA 17013 Dear Walter: This is to acknowledge receipt of your letter of November 25, 1993 Indicating that you will be terminating your lease at 226 North Bedford Street as of December 31, 1993. I may be showing the apartment to perspective tenants dUI'lng December. I will however, attempt to give you notice before coming. According to my records, you have two set of keys to the apartment. When you vacate the property, please place the keys on the kitchen table and lock the door by the knob lock. Since I would like to have the apartment secured when vacated, If you move out before December 31, I would appreciate a phone call at 697-2064. Another thing that you could do that would help me In preparing the apartment for a new tenant would be to jot down a list of any problems that you know about In the apartment. You did indeed pay rent for the apartment from May 1,1993 until December 31, 1993 thus fulfilling the six month lease plus two additional months. As per our lease, I will forward the deposit minus any charges, to you within 30 days. Thanks for your prompt rental payments. Sincerely, _ , ~'./~" , I'~ 1-..: I ' / . , ..,~, / " i. // / .. . / ~.. ." ..... \' /7 /,'/ Richard H. Neff /' REEVES.HOFFMAN DIVISION .:00 '.'I, ~ICRTH ST ';.\RLIZLE:. .'''' . ..~1J EMPLOYEE NO, , EMPLOYEE NAME, ' I!mi3 SOc. SEe. NO. CHECK DATE ,CHECK NO, 021337 \):~..' ~ :/94, I j I I )dJ \J~LrER ~ ~~L~A il Q'I::4S-30-:!E'lia ;,IL ,1(. 'i7 ...;; ~ " ,~ ,) 0 -. - ':'::0:::: : ! -. .,toO -. '; \.j'~ 'j.; 7 : I:W~ "7C ',',&1,1: r~~~;:::~: .11; 10') .\CI:~U~: 1/:\,,; 1--- ".) 0 ...:.". . - ':URPEr~T ": ~.... p- ~ .')-!oj;'-:-:: !NSIJR i'1ED: , ~ -:~ :}': ~ . ~=: . ~ i' 1~AGLIl BAse: . - I - GR\JTH BAse: " f,' , 'I -. 11,~I;LN .sUPL: -- . ':'. - , - . - ...,34 ;.: :~ ,-. ~, ... GiHlTH SIJPL: .. .,:.: -, - , -- 1).1 1 , I'J !1AGLN 'IOL' ;:'. , - - J I - ." 1;~UTH VOL: J ~ - - -. '. -- , J I .- , u.'.;E ,;r;CH: ~,,) .: "", - . " ':',' NF-7 Ff\~: ~ ?~ : t 1___,____~:::-.-:_--::_ .~ ( 1.:.10". :!..lC'" :JP::~: :p.~~.. !i(j:..~:. r- -, - - ...---- ,. ._~ . ---'r---.."-----". ==VES.HOFFMAN DIVISION .:,,:: ",'I ~:c::;-- Si. CARL1SI.s'. :" . ":'-1 : EIIPlOYEE NAIIE '. I!mi3 : 5Ot:.sec NO. ~HeCKI10 021383 ( 7100345-30-3562 08/31/94 CURRENT YEAR-TO-DATE INSUR MEO: 2,750,00 44,000.QOMAGLN BAse: GR\.lTH BAse: 3,366,000 MAGLN SUPL: 6,922,S8hGR\.lTH SUPL: 1 ,232.0011 MAGLN VOL: 66. OOh GRIJTH VOL: 440,OO'llJAGE ATTCH: 210.37 4S4 . GS 77 ,00 4.12 27.50 17.50 ( 27.50 27,50 C 55,00 55,00 S2.50 ( 82,50 900,00 ( NE,TEA:fe ~r"t... i!EF':nF. '-:epSI?'~ t~l AEEVES-HOFFMAN DIVISION .lCC'.'I"'OATHsr. ~"RLISLE. ::1.\. ,.~t'J EMPlOYEENa. EIIPLOYEE IUIIE - see. SEe. NO. CHECK DATE :~eCKNO, 021615 16J WALTER 0 ;AL~A s qOO~4=-30-~SGa' , I. : :/':1.& $AL: 'Z6 3i Hq~ C:, 7S? 0') r:URPE:.'Ir '(E,;\" - ~c -0,0\ 'i"! :n9:IJR MEO: ~ -e . '.\1) <:- -0:>" '"A, ~.l\";t..:1 BASC: - . . ..., _ , , - . I;~ 'JTU BASe, ." -, .;, .; . r1.~I;I..:1 SUPL, .. , . ~ - , . , I~;'~ ~ ~H SUPL: :.: u ". . , - :11) : - . r1.'GLN VOL: , .; , , : i,i=tJTH VOL: . ::") . ~ WAI;~ ,1TiCH: '';?iJS:; . -... . ,. ~ '. M .':'1';:- =\17 : 'v- '.'~ I .:U7 rTO v~c T~M!N 3.; ~oa ,o\CCRUEO 'JAC LE.=-1' :31', ,),) - -----, NET :=~:J~ 4 .. h:!=;' .~~. ~.....t:.~ \""..-~.':"~ '00..,4':." .... :_.:-:~- , -:-:-T:-=-=::-:-:-::-~' ._-~-:~---------- AEEVES-HOFFMAN DIVISION ~.': 'l ';CF=TH Si :~P!.::h.::. '. . ~" j .::a='':,;J''~==1D m:m : sac. sa::. NO.. :~e':KNO, 021568 6900345-30-3562 10/31/94 CURRENT YEAR-TO-DATE INSUR MED: 17,5 2,750.00 55,000,00 MAGLN BASC: 27.5 GR\lTH BASC: 27,5 210,37 4,207.50 MAGLN SUPL: 55,0 684,68 9,061.60 GRUTH SUPt.: 55.0 77,00 1 ,540. 00 MAGLN 'lot.: 82,S 4.12 82.50 GRUTH VOL: 82.5 27,50 550.00 UAGE ATTCH: 873.1 163 UALTER D GALLA SAL: 62,67 HRS 'lAC: 24,00 HRS 1 . 988.46 761.54 GROSS: YTD VAC TAKEN 64.000 ACCRUED 'lAC LEFT 76.000 FICA: FIJT: SIJT: OST: CIJT: NET PAY: 525.67 ~'.e,"'5i! ::e.1C.. H',~i::Ic :P'~SI:'.'IO ';l-eCl( ------ -.--..... __'.r_'_.. - -_..- -r-- -.__ _ ..._ . .... ----. .--------..---__1--- t- I . ~ .:.' ~ i -.::': I :; 5. ~ ...~ .. .."_. - .;.:. ;:: 3;:: 1 AEEVES-HOFFMAN DIVISION ..._------...-~- J~OW ~jOATHST. C~RLISi.; :., ':""1:3 EMPUlYEENO, EMPr.oYEENAUE ' ma , . soc: sa:. NO. CHECK DATE CHeCK NO. 021521 163 WALTER D GALLA 690Q345-30-3%2' 10/1-1.'''5 ~,'L: .96,6. HR," ~,7='),OO CURRENT YEAR-TC-OAT~ Z,iSO,OO S2,aSO.00 r NSIJR MED: MAGL:! BASC: GRUTIi BASC: MAGUI SUPL: Gl<UTH SUPL: MAGLN Val.' C;PUTH VOL: \lilGE ATTCH: GROSS: YTO VAC 'AKEN .;Q aOQ ACCRUED VAC LEFT ~5,~00 FICA: FU r; SUT' OST; CUT, 5"~~ ~u Z l'J. 33 ..1.34. r;.P. 3,99; t1 S,37'j,9i! 77.00 1. "6J, .) " I ."T ~ '- -~ -r.' t '.. , _'J ':'7. =,) N€T PAY: 698.31 ;lUAU ::Ie:r...r". H If F.4<1jlniO ':"+!';,( 17, S 27.S ~- - c:;, . OJ 55.0 55 tJ 3a. Sl 82 :1 900.J ] 1040 Label (5ft InSlIUClions on p.g. 12.1 u.. th. IRS lab.I, Olharwl.., pl.... ponl o,typ., Presldlnl/II Ellctlon Campaign ~ 5.. a e 12,) ,. 1 2 3 4 Filing Status (See p.ge 12.) Cht<:k only one box. Exempllons (5.. p.ge 13,) II mo,e Ih.n .i. dependenl.. ... p.ge 14. Income Attach Copy B 0' your Form. W.2, W.2G, end 1 D99.R h.". II you did nol gel e W,2, s.e p.g. 15, Enclo... bul do net attach, any p.ym.nl wllh your relurn. Adjustments to Income Caution,S.. Instructions . . ... Ail]iiiIiif""" Gross Income Cepartm.nt of Ihe rr...ury-lnt.rn.1 A.venue Service ( .5. tlldlvlduallncGme Tax Return ~@94 III . . IAS Un C)rWy-OO nol ","I. Of lI.pI. In &hi. ,pace For Ihl VIII Jan. 1~. 31, 1994. or other ,... ve.r blOlnninQ Your h'll nama and Inlual Lasl "1m. . 10S", Indlng . 1.0MB No, 15<15,0074 Your 10cl.1 IIcurtty numlMr .345 :30:35(,,;1 SPOUI'" locl.lltcurtty number ~~7170IH80 For PrlvBcy Act and Pap.rwork ReducUon Act NoUca, aae paga 4, Ve. No NOI.: CIl.dJng -Ye,. will nor ,"'nge )'OUr tv or rtduce )'OUr refund. .13, J (SINo. cllllttllns h~ItI)'M IIomtIII IS9-1 Slngl. Marrl.d filing Joint ralum (oven II only one had Income) Married filing separale relum, Enl.r .pou..'. soclal.ecunty no, lbove end lull nam. here, ~ Heed 01 hou.ehold (with qualifying person), (See page 13,) II tho quelifylng person I. a child but nol you, depandent. anter this child's name h.re. ~ 5 Ouall In wldow(e with de ndenl child ( eer spouse died ~ 19 . See p. 6. ~ Vou...II, II your parenl (or .omeone el.e) can claim you.. . d.p.ndenl on hi. or he, tax relum. do not check box 6a. Bul be .ure 10 check tI1e box on line 33b on page 2 b Sou....".",.,.,." .,'. c Dopondents: 121 ne,k 131 II 'Of 1 or olde,. (4J Ot~endenl's 111 Name Ili,SI. IMi.1. Ind Int namel II unde' ttependenl'S socl.1 mutlty rel:honShip to J " number ou No.olbolll chlCkld on II ., I,d II ~ N.. .1 your .hlldn, ..1. WhO: . liVId wlllly.u . d1d,'1 IIV1 willi you dUI to dlvorCl at up.ratlon (III pl,"14) Dlplndlnl. on Ie nollnl'rd.bon _ Addnumbll"l .nt'rld on IInlllboy, ~ .9 10 11 12 13 14' 16b 16b 17 16 19 20b 21 22 7 L A D E L Lost name 31 D 9 9 FOtIll 1040 (1894) III toinl felum, spou,o', h'st name and millal a 'N Home addrlss (numbe, and lUte", II you have a P.O, bOI, see page 12, Api, no. H I R E City. town or post offiCe, 11111. and ZIP Codl. II you hlv' . 100.~n addtell, IN p.OI 12. c..ar IJk A 110.3 Do you went S3 10 go 10 Ihl. 'und? . , , . , , . II a olnl relum. doe. ou, .pou.e want S3 10 go 10 Ihls lund? . d II your child didn'lliv. wilh you bulls cl.imed as your dependenl under a pll'l985 .oreemenl. check hers ~ 0 . Total number ot exam tlcns claImed . . . . . . . . . .' ? Wages. .aleries. lips, etc. Anech Form(.) W.2 . , . , , . Sa Taxabl. Inlere'llncome (see pege 15), Attach Schedule B II over $400 b Te.....mpt Inlere.1 (.ee page 16), DON'T Includ. on line 8. 6b 9 Dividend Income. Attach Schedule B II over $400 , , ,. .", 10 Taxable relunds. credlls. or oll.el. 0' "ale and local Income 'axes (see page 16) 11 Alimony received . . . . . . . . . . . . . . . . . . . 12 Bu.lnesslncome 01(10'.), Anech Schedule C or C,EZ . , . , . LO~J. 13 Cepltel gain or (Io,s). II ,equlred. allech Schedule 0 (... pag. 16) , , . . 14 Olher gains or (Io.ses), AIIach Form 4797. . . , , , . , , , , , . . 16. TolallRA dlslribution. . ~ U b Tax.ble atI1O\Jnl (... page 17) 16. TOlal pensions and annuities l.!!!.1 U b Taxabl. amounl (see page 17) 17 Renlal ,eal e.lale. royaltie., pa~nership., 5 corporation., Irusls, elc. Attach Schedule E 18 Farm Income or (loss). Anach Schedulo F . , . . . , . , , 19 Unemploymenl compen.ation (.ee peg. 181 , I ' I' , . , . . , , , . 20. Social .t<:urily benems 120. I L-J b Taxable amounl (s.. page 18) 21 Olher Income, U'I type end amounl-5e. pag.18 ..............'..,......,......,.... 22 Add Ihe amounlsln Ihe farrl hi column for lines 7throu h21. ThI.ls our lotallncome ~ 23a Vour IRA deducllon (.ee page 19) , , . , 230 b Spou.e'. IRA deduction (.ee page 19). . , 23b 24 Moving ..pen.e., AIIach Form 3903 cr 3903,F 24 26 One'helf 0' .ell,employment lax, . , , . 26 26 S.If,employ.d health In.uranc. deduclion I'.' page 21) 26 27 Keogh r.tiremenl plan and s.If,.mployed SEP d.ducllon 27 26 Penalty on early Wllhdrawal 01 .avlng., . . . 28 26 ""many pa'd. Rec'p'.nl" SSN ~ 29 30 Add IIn.. 23a Ihrou h 29, The.e .re our lotal ad u"m.nt., . . , . . ,~ 30 31 Sublraclllne 30 from line 22, This Is your adjuslad aronlnc.ml. 111m Ih.n $25,2961nd 1 child lived Wllh ou less Ih.n $&,000 If . child dldn'l live .,Ih ou, scs ohmed Incom. Cled,I' on p. . 27 ~ elt. No 113100 SCHEDULES A&B (Form 1040) Schedule A-Itemized Deductions (Schedule B Is on bock) ~r ot.la No, 10.0,007. ~@94 OtpAl"lment olltlt ',.UIIl'Y 131 Inl.'"a1 A....."",. StlV'C. Name(11 .hown on Form 1040 r Medical Caution: Do nol Include expenses reimbu,sed or paid by a/hers. and 1 Medical and denIal expenses (sea page A-l) , . . , Dental 2 Enter amounllrom FOlm 1040, line 32. 2 Expenses 3 Multiply line 2 above by 7.5% (,075). , . . . " 3 4 Sublract line 3 Irom line 1. II line 3 Is more Ihan line 1. enler .0. Taxes You 6 Slale and local Income laxes . . 6 Paid 6 Real eSlale laxes (see page A.2) , , . . , . " 6 (See 7 Personal property taxes. . . . , , . . , " 7 pageA-l.) 8 Other taxes, Llsl type and amount ~""...O,t.r.",,,, ~ """. "'''''''''''''''' ",,,,,. ",e,I;!).!.'!I.!... ".q .r,.~ ,,,., 8 9 Add lines 5 Ihrou h 8 . . . . . , , . . , , . Interest 10 Home mOllgage Inleresl and pomts repolled to you on Form 1098 t. You Paid 11 Home mortgage Intelest not reported to you on Form 109B.1I paid (See to the person from whom you bought the home. see page A'3 pege A'2,) and show thaI person's name. Idenllfy'ng no,. and adaress .. At1lchment SeQuence No. 07 Your locl.'ltcurtty numb.r . . A"och 10 Form 1040. . Soo In.llUctlon. for Schodul.. A and B IFo,m 10401, ................................................................ ................................................................ Nole: Personal Intere.ll. not deductlbla. ................................................................ 12 Points not reported to you on Form 109B, See page A.3 for special rules. . . . , . . , . . . . , . Investmentlnloresl. II required. attach Fo,m 4952, (See page A-3,) , . . . . . . . . . . . . . I' Add lines 10 throu h 13. . , . , , . . , . . Gi~s by cash or check, If any gl~ of $250 or more, see page A,3. . . . . , . . . . , . . . . . Other than by cash or check, If any gilt of $250 or more, see page A.3, II ove, $500, you MUST attach Form 82B3 Carryover from prior year , , , Add lines 15 throu h 17, . , . . , . . . . . 12 13 14 16 13 Gifts to Charity II you maau 16 giN and got a bena'" for II, 17 aee page A'3. 18 Casually and Theft Losses 19 Job Expenses 20 and Mosl Olhef Miscellaneous Deductions 3/0 Casually or Ihe~ loss(es). Attach Fo,m 4684. (See page A.4.) Unteimbursed employee expenses-job travel, union dues, jab educatron. etc, If required, you MUST attach Form 2106 or 2106.EZ, (See page A.5,) ~ ..,........... ..,....'...... ....".... .....".. J."O,b,., fill f.~.'1IL:.. .H..,. ,...... '......,......... ".... ...y':D.b", EA't:v.JC....,. ,~",. Tax preparation fees . . , . , . . , , . . , Other ~xpenses-Investment, safe deposlI box, etc, Llsl type and amount ~..,........,SD.a,...., ..,........".. '~ ....",..,..,..............,.....,.."..........",....",..".. 22 Add lines 20 through 22, , , . , , . . , .. 23 Enter amounl from Form 1040, Ime 32. 24 ~~ Mulllply hne 24 above by 2% (.02) . , , , , " 25 Subtracl hna 25 from line 23. If line 25 Is more Ihan line 23, enter .0- Moving expenses Incurred before 1994, Attach Form 3903 or 3903,F, (See page A,5,) . . Other-from list on page A.5, Usttype and amounl ~ .......,......,......,....,... , 21 22 (See page A'5 for expenses to deduct he'e.) 23 24 25 26 Olhef 27 Miscellaneous 28 Deductions Totsl Itemized Deductions -0- 29 Is Form 1040, I,"e 32, over $lll,BOO (over $55,900 II married filing separately)? NO. Vour deduction is nOI limite. d, Add the amounts In the lor rrghl column } for I,nes 4 through 2B, Also. enter on Form 1040, line 34, the larger of .. this amount or your etandard deduction, . YES. Vour deduction ma be hmlted, See po e A,5 for lhe amount to ente" For Paperwork Reducllon Act Nollce, 100 Form 1040 In.lrucllon.. C.'. No 11330X Schadula A IFo,m lIMO) 1~ FOt'm 1040 (1994) Tax Compu- tation ISee poge 23,) U you WOnl Ihe IRS 10 flgur. your lax, see page 24, Credits (See poge 24,) 45 48 47 48 49 80 51 52 53 Payments ~ 56 Other Taxes (See poge 25,1 Allech Forms W,2, W'20. and 1099,R on thelronl. 57 56 89 80 Refund or 81 Amount 82 You OW8 83 84 Sign Here Ke.p 0 copy of thi, return for your records. Paid Preparer's Use Only Go Iq 4S - 50- .3Sf"J, 32 Pago'"2 34 3~ Amounl from line 31 (odJuSI.d gro.. Incom.1 . , . . , , , , , . , , 33a Check U: 0 You Were 85 0' Older. 0 Blind: 0 Spouse wos 85 0' older. 0 Blind, Add the number or boxes checked abolJe Dnd entor the 10101 hero, " ... 33a b It your parent (or someone else) con cloim you as D dependent, check here ... 3:Jb c It you ore married filing separately and your spouse Itemlzos deductions Or you a,. a dual,.latus ollen. .e. page 23 nod check here, . . . ., ~ 33<l 0 lIemlzed d.ductlon. Irom Schedul. A. IIn. 29, OR Stondo,d d.ductlon .hown b.low lor your filing Slalu., But U you ch.ck.d any box on IIn. 330 0' b. go to pa9a 23 10 Ilnd your ,'andard d.ducllon, U you cheeked box 33c, your ,'andard deduction I. Z.ro. · Slngle-$3,800 . Head 01 hou..hold-$5,800 · Married IllIng lolnlly or Quollfylng wldow(arH6.350 · Marri.d IiIlng ..porolely-$3.175 Sublroct line 34 from line 32 . . , . . . . . . . . , , . . U Iln. 32 I. $83,850 0' I.... multiply $2.450 by Ih. 1010' numb., 01 ex.mptlon. clolmed on IIn. 6.. U line 32 I. OVer $83.850, .e. Ih. work.he.' on pogo 24 fo, Ih. amounl 10 enl.r , Taxabl. Incom.. Subl,acl line 38 from IIn. 35, U IIn. 38 I. more Ihan IIn. 35, .nl.' -0- . Tax. Ch.ck U Irom . 6l:l Tax Tobl., b 0 Tax Ral. Schadul.., c oCapilal Oaln Tax Wor!(. .h..t. 0' dO Form 8815 (.e. page 24). Amounl from Formla) 8814 ~ . I Additlonollox.., Check U "010 a 0 Form 4970 b 0 Form 4972 Add IIn.. 39 and 39 . . . Cradit for child ond dapendanl cora exp.n.... Allaoh Form 2441 Cr.dlt fo' Ih. aldarly or Ih. di.abled. Allach Sch.dul. R, , Foreign tax cr.dit, Allach Form 1116 . . , , , . . Olher credil. (.e. page 251. Ch.ck U from a 0 Form 3600 b 0 Form 8398 c 0 Form 8801 d 0 Form IspecllYI _ 44 Add IIn.. 41 Ihrougn 44 . , . . Subtract line 45 from line 40. If line 45 Is more than line 40, enler .0. . Ent., th. I.rg.r 01 your; 35 38 37 38 38 37 39 40 41 42 43 44 ~ 41 42 43 45 48 47 48 49 80 51 52 53 ~ 85 S.U'.mploym.nl tax. Anach Schedul. SE. . .' , A1lernaliv. minimum lax. Allacn Form 6251 . . . . , . . . . Recaplur.'axe.. Ch.ck II from a 0 Form 4255 bD Form 8611 cO Form 8828 Social .ecurity and Medicare lax on tip Income nol raported 10 employOl, Allach Form 4137 Tax on qualified retirement plan.. Including IRA!, U required. allach Form 5329 . Advance earned Income credit payments 'rom Form W.2 Add line. 46 Ihrou h 52. Thl. I. our tolalla. . . Federal Income tax wllhheld, "any Is Irom Form(511099, cheek ~ 0 1994 eSlimaled tax paymenls and amounlapplied from 1993 relum . Earned Incom. credlL U required, allaoh Schedul. ErC I'.. page 27), Nonlaxabl. .arn.d Incom.: amounl ~ I I I and type ~ .......,............,.............................. Amounl paid Wllh Form 4868 (.xl.n.lon r.qu.." . Exc... social security and RRTA lax wllhh.,d (... page 321 Olh.r paymenl.. Check If Irom a 0 Form 2439 b 0 Form 4136 Add Iin.. 54 Ihrou h 59, The.. ar. our total a m.nta . . , . . ,~ II line 60 I. more Ihan IIn. 53. subl,acI Iln. 53 'rom IIn. 60, This Is Ih. amount you OVERPAID, ~ Amoun! ollina 61 you wanl REFUNDED TO YOU, . " .".., Amounl of line 61 you wanl APPLIED TO YOUR 1995 ESTIMATED TAX ~ 63 II hn. 53 I. more Ihan IIn. 60, .ublract hn. 60 Irom IIn. 53, This Is Ih. AMOUNT YOU OWE. For dalaiis on how 10 pay. Including what to Willa on your paym.nl. a.. page 32 , , . E.tlmaled tax .naU I.e. a a 33), AI.o Includ. on IIn. 64 65 Und., pen,llles 01 perJury, I dICtate tN11 hl\" I"minld lhls reluln and accompanying IChedul11 and .lllem.nll, Ind to lh. be.t of my knowltdoe and btl"t, th'y at. trut. Conecl, al\d compl'le. Otc:laralion 01 p"pa"t (olher Ir..n lupaye'lls based 011 all information 01 which prep'"r hlllltf knowftdg.. ~ Your ligNlfure 0.111 Your OCcupahon ~ Soous.', S'O""lur. If a ,0-"1 'ttlll''', 80TH mUll "gn O..le SPOil"" Occup.II'On Prepare,', ~ ''Qn.lulO , Firm'. nBI"e (Ot yourl ~ II "Il..mplo~eo) and addlell ~~Meom 321-5rnmrl5t I.. ...,1-... P"pare,', 'ocIII .ecu'lly no. :?i 351Q. 9Yo h ..1 .,. SCHEDULE C (Form 1040) l]@94 Profit or Loss From Business (Sol. Proprl.torshlp) ~ Partn.rshlp., 'oint v.ntur.., .tc" mu.t III. Form 1065. AttaChment ~ Attach to Form 1040 or Form 1041. ~ 5.. In.trucllon. lor Sch.dul. C (Form 1040), S.ouence No, 09 Socl.1 .ecurlty numb.r ISSNI J 4 S i J 0 ! 3S(,). B Ent.r p,lnclpal bu.ln... cod. (s.. page C.6) ~ o Emplo)'er ID number IEIN), " .nv OMS No U"5~ Dtpll'lmenl 011'" T....ury Inltf"" R.~I1\I.l' S~IC' 19tH Nam. of plapllllor A a ~r < Prlnclp.1 bu.ln... or prol...lon, Including product or '.rvic. (... page C'I) Se:/c,.J BusIness name. If no separate bus1ness namo, leave blank. c E Business address (including Suite Or room no,l ... " ........... .......... """" I....'... ........, 0.....' ............ .......... ........ ..... City. town or post office. slalo. and ZIP codo Accounllng m.thod: (1) ~ Co.h (210 Accru.1 (310 Oth.r (,p.clly) ~ ........,,,..,,,........,..,,,..............,..... M.thodl.1 u..d to . Low.r 01 co.t Oth.r (att.ch Do.. nol .pply (il voluo clo.lng Inv.ntory: (1) 51l. Co.t (2) 0 or mork.1 (31 0 .,plonBtion) (41 0 ch.ck.d, .kip hn. H) Was there any chango in delermining Quantities. COSIS, or valuations between opening and closing inventory? II "Ves," attach explanation. . . . . . . . . , . . . . , . . . . . . , , . . . . , .. .. Old you IOmaterially participale" in the oporatlon ollhlS business dUring 19941 II "No," seo page C.2 lor limit on losses, II you staned or acquired this busine5s dUring 1994. check here. . . . . . . . . . . . . . F G 1:1: , ,~~ H I J . Income 1 Gro.. r.c.lpt. or .01... Coutlon: 1/ thl. income wa. ,.pOtt.d 10 you on Fo,m \V'2 and 'h. .S'a'ulo'!' 0 (" <./ I .mploy... box on thallorm was ch.ck.d. s.. pag. C,2 and. check h.,. ~ 1 2 Returns and allowances , . 2 3 Subtract lin. 2 I,om lino 1 , 3 (" <I I 4 Cost 01 good. sold Ilrom hna 40 on page 21 4 5 Gro.. profit. Subtract lin. 4 'rom Iln. 3 . . , 5 ~<ll e Olh.r Incomo, Including F.d.rol and sl.to gasolin. or fuel tax cr.dll or r.fund (... pogo C,2) . 5 7 G,o.. Income. Add lino. 5 and 6 ~ 7 t. tj I . !II Expenses. Enler ex enses for business use of \ our home only on line 30. 8 Advanl.1ng . . 8 .3--5 19 Pen~llon and proflt.sharmg plans ~ 9 Bad d.bls Irom salos or 20 Rent or I.... (.e. pogo C,4): ~' .arvic.. (.a. page C.3) 9 D VehICles, macnmery, and equIpment. 20a 10 Ca, and truck expenses ELI b Olher business propeny . 20b , ('.0 page C.3) . 10 21 Repairs and m810lenance . 21 . 11 Commi..ion. and I..., 11 22 Supplies (notlnctuded in Pat1l11) , 22 "180 12 Depl.llon. 12 23 Taxes and licenses, . . . ~ ~61 13 Depreciallon and section 179' 24 Travel, meals, and entenainment: ellpense deduClion (not Included D ltallel. . . . . . . . 24a In Pon III) (.e. p.g. C'3) 13 b Meals and en. 14 Employ.. ben.fit programs lenGinment (olhar than on lin. 19) . , 14 cEnter SOli 01 . 15 tn.uronc. (oth.r Ihan hoolth) . 15 line 24b subjecl 10 limilalions 18 Intar.'1: ~ I..e pag. C.4) . a Mongoga (paid 10 bonk., elc.1 ' 16a d Sl.lbtraclline 24c Irom line 24b 24d b Olh.r. 18b .2(,,7 25 Ullht,es 25 17 Legal Dnd professional 26 Wages (less emplo)menl credits) , 28 servIces. 17 27 Olher ollpensesllroln hno 46 on 16 OHico e)lpense , 16 page 2) 27 26 Total IJlpenses belore expenses lor business USe 01 home. Add hnos B through 27 In COlumns. ~ 26 ItJ/g 29 T.ntatlvo profit (Ioasl, Subtract line 26 I,om line 7 , 29 l "777J 30 Exp.n.o. 'or bu.ln... u.. 01 your home. Atloch Form 6829 . 30 31 Not p,ollt or (10"). Subtract "n. 30 I.om hn. 29, · If n prolil, enler on Form 10401 line 12. and ALSO on Schedule SEI Une 2 (stalulery employees. (777) see poge C.5). Estales and truslS, onlOr on Form '04', hne 3. 31 · If. 10... you MUST go on to lin. 32, 32 If you hove a loss, check the box thai deSCribes your investment In thiS DCllvilV lsell pago C,SI · If you ch.ck.d 320, on I., Iho loss on Form 1040, tin. 12, and ALSO on SCh.dule SE, Iin. 2 (statu lory .mploya.., '00 pag. C.5), E.tal.. and l'u.I., .nl.r on Fo'm 1041. lin. 3 · If you choc,ed 32b, you MUST o"och Form 8196, For Paperwork ReducUon Acl Notice, loa Form 1040 l".tructlons. ITEM US} \94101 } } 32a t&l Alllnv..lm.nt I. at rl.k. a2b 0 Some Investmont Is not at risk, Sch.dul. C (Fo,m 1040) 1994 ~................J"-'t~_. \r ., i'<l. ~ ..:,;:..4.0-'.#-_,.. ... ,,~... '.' " " . - Not.: /I au had ave' $400 in tMable Inle,esl Income. au musl also com lere Pall /II. 1 List name 01 payer, II any Inte,est Is from a selle,.Iinanccd mortgage and the buyer used the property as a personal residence, see page B.1 end list this Inlerest first. Also show Ihat buyer's SOCIal secunty number and eddress ~ ............"... fA 1 JL'< .tl !.....t:'l...(L,. ~.~t!. .lM.: ...~~l, ,..,...... .............. . ,... ,......,...' Hau.i.I....,.$ ~:~I.':'J,J...,......,....,......, ........,... ......,...., ...'",..,...,... ,Q1.li-.1 to y,., 8f1 n J<".,.,...,.,....,..,.,.,....,."......"."..,....",. ...""".....,.. .~( .~, ..$. ~,d ~j).". G.,.'!~.~.,. F..'!!. ~.C!!...T. r.~~ f.,.~!':,.......,." .... OM. No.1S4S'OO74 Plgl 2 Your ,ocl.1 ItcUrlty numb'r 345 ISO i S(. AIt.chment Sequlnel No, 08 Schedule. Ala (Form 10ol0J tOOol NamelS) shown on ;orm 1040. 00 nol enl,t nome Ind 10(101 'teofllr numb" 11 IMv.n 0" att1" Ilde. e; T~" () Co, G Co ~ Schedule B-Interest and Dividend Income (Se. page B'2,) Amount ............................................................................................ ............................................................................................ .................................................................I.......................... 1 Part I Interest Income (5.. pages 15 and B.I.) Not.: II you received a Form 1099,INT, Fo,m 1099,010, Or subsliM. slatem.nt from a brokerage 'irm, list Ihe firm's name 85 (he payer and onter Ih. totat Inler.st shown on that form. Part II Dividend Income (Se. pages 16 and S.I.) Not.: II you received a Form 1099,OlVor substitute statement from a brokerage firm, list tho lirm's name os th. pay.r and enl., tho tOlal divld.nds shown on thot form, Part III Foreign Accounts and' Trusts ........................................................................,................... ............................................................................................ ............................................................................................ ............................................................................................ ............................................................................................ ............................................................................................ ............................................................................................ 2 Add the amounts on "ne 1 . , , . . , , , . . , , . , , , , , 3 Excludable Interest on series EE U.S, sav,ngs bonds Issued after 1989 from Form 8815, line 14. Vou MUST eUach Form 8815 to Form 1040 . . . . , ,. 3 4 Subtract line 3 tram line 2, Enter the result here end on Form 1040 line 8a ~ 4 Note: If au had over $400 In 'ass dividends and/or olha, dlslributions on stock, au musl also com 2 6 List name of payer, Include gross dividends and/or other distributions on stock here, Any capital gain dislributlons and nonlaxable distnbutions Will be deducted on lines 7 and 8 ~ ....,......,......................,..............,....,....,........, ..,....,.,.,....,..H. M ~ h~,1." F..q',~J..,..c., f.'"..,....,.,..,."......".,.."...". ,......",......" J:19.':\p,1, hlt.c... F.,~,~J.(I'''" ,(",q /,p.'.,.".,..,.,......,.".,..,..,..., "....,.",. ....' ,J;.I),vt!:~,~,q.., f....,h... G,,~~, .,....,.,..,.."".,...,..".,.....,." "....,.",..,.,.,:r. ~('.. A!'I~!.'.~f,~" ,f. ~ ~.h,.,....,.,....,..,...,......,."."..,...., ,.. ..... .......... Fi,d,(;.II.ty... .J;,.It."......,.",.,.,...., ,.. '..... ,....... ..,.. ......, ,.,...."",..,... .P.. i.Q uc.,1'..., J\, "~I (.',..,:J.'k :.,..,....,..,."....,..."..,.".,., .. ,......",.".., P. j,Q!<If';cr. ....Af:\~r/h~,.. ,F.~"l..+.~\:."., ..,..,.. ........, ,...... ... ....,....,.... J.o.r.~.. .C.c..\7,~! !/.."..,..,..........,....,. ...... ........ ..,.. ....... 6 ............................................................................................ ............................................................................................ ............................................................................................ ............................................................................................ ...........................................................,................................ 8 Add the amounts on "ne 5. . . , , , . . . , 7 Capital gain distributions, Enler here and on Schedule 0' . 8 Nontaxable dislributions, (See Ihe inst. for Form 1040, line 9,) 9 Add lines 7 and 8 . . , , , , , . . , , . , 10 Subtract line 9 tram line 6, Enter Ihe result here and on Form 1040, line 9 . .. 10 ., , 'If you do not need SchedUle D to repOIl MY other gains or losses, enler your capital gain distributions on Form 1040, line 13. Wrlle "CGD" on the dotted line next to line 13, If you had over $400 of interesl or diVidends OA had a foreign accounl 0' were a granlor of, or a transleror 10, a lore'9n trust, you must complele this part, 11. At any time during 1994, did you have an ,ntereslln or a signature or other authority over e financial account In a foreign country, such as a bank account, secunties account, 0' other financial eccount? See page B.2 tor exceptions and filing requirements for Form TO F 90,22.1 , , , , b It "Ves," enter the name of the foreign country" ......'"'....' "....,..........,...................,.. 12 Were you the gran lor of, or transleror to, a tore'gn trustth.1 eXlsled during 1994, whether or not au have an benefICial inlerestln it? If "Yes," au ma have to f,le Form 3520, 3520,A, or 926 . For Pap.rwo,k A.ducllon Act Notle., se. Fo,m 1040 InslrucUons, Schedul. B (Form 1040) 1994 I I I t .-; 'OMB No, 1545,0074 SCHEDULE D (Form 1040) Capital Gains and Losses ~@94 ~ AII.ch to Form HMO. ~ See In.t,ucllon. for Schedule 0 (Form 10401, ~ U.e IIn.. 20 and 22 fa' more sp.ce 10 lI.t transactions lor line. 1 and 9. O.partm'(lloltn.Tl'''~ (31 UlllttTlal Fl.vll'l\l' Svw<. NlIme(lllt\own on Form 1040 'No T(:;r "..J A,/eJJ~ A, Short-Term Co Ital Gains and Losses Assets Held One Year or Less (I' Description 01 lbl Oale (e) Dale sole ldl Sales price lei Cosl or It) LOSS property leumple; aCQuired I". p,nt 0.31 01"" bUll Ill" is mote tFlaM ldl. '00 Ih. XVZ Co I IMo, day. 't') (MO. doly. yr,) . Isoe po e 0.31 tubUlel (dllrom (el 101 GAIN II (d) Is more Ihan (el, lublfact(elltom{d) 1 2 Enter your short.term tOlals, II any, from hne 21, . , , . . . . , , ., 2 3 Totel short. term seles price amounts. Add column (d) of lines 1 and 2 , ,. 3 4 Short.term gain from Forms 2119 and 6252, and short.term gain or (lOSS) from Forms 4684, 6781, and 8824 . . . , . . . . , . . . , , 5 Net short,term gain or (loss) from partnerships, S corporations, estates, and trusts Irom Schedule!s) K.l . , , . . . , , , . . . . . 8 Short.lerm capital loss carryover. Enter the amount. If any, Irom hne 9 of your 1993 Capital Loss Carryove, Worksheet . . . . . 4 5 6 7 Add hnes 1,2, and 4 Ihrough 6. in columns (0 end (gl. 7 8 Net short.term co Ital gain or loss), Combine columns 10 and ( ) of hne 7 .,.' ~ 8 Lon .Term Co Ital Gains and Losses Assets Held Moro Than One Year 9 10 7 gS' 73'15: 10 Enter your long,term totals, .f any. from line 23, . . . , , . . . . . . Totallong.term sales prlca amounts, Add column (d) of IInas 9 and 10. .. 11 12 Gain from Form 4797; long.term gain Irom Forms 2119, 2439, and 6252; and long.term gain or (loss) from Fo,ms 4684,6781. and 8824 , . , . 13 Nellong.term gain or (loss)lrom panoerships. S corpora lions. eSlales. and trusts Irom 5chedulels) K,\ , 11 14 Capilal gain distrlbulions 15 Long.term capital loss carryover. Enter the amount, if any, Irom line 14 of your \993 Capital Loss Carryover Worksheet . . , , I 4 ole> 15 16 Add hnes 9, 10. and 12 through 15, In columns In and (91 16 , , . . . ~ 17 10 Combine lines 8 and 17. II a loss, go to line 19, II a gain. enler the gain on Form 1040, line 13, Noto: II both lines 17 and 18 a,e gains. see the Capllal Gain Tax Worksheet on page 25 19 II line 18 is a (loss), enter here and as a (loss) on Form 1040, hne 13, the smaller 01 these losses: e The (loss) on hna 16; or b 1$3,000) or, II martlad "llng separalely, ($1.500) , , , , , , , , . , , . Note: See the Caplin. Loss Carryover Worksheet on page 0,3 .I/he loss on Ime IB exceeds the loss on Imo Ig or,l Fo,m 1040, line 35 is a loss. For Paperwork Reduction Act NoUce, see Form 1040 Instructions, CIII No, t1338H 16 19 '~~ ,~ Schedule 0 (Fo,," 1040) llXl4 Schedule C (Form 104011994 Pig. 2 a .34 O-.].5{,,;2, '. IDIIII Cost of Goods Sold (see page C-5) 33 Invenlory el beginning 0' yoer. II difleren1 'rom la.1 yoar'. clo.ing Invenlory, e!loch e.plonallon 33 '34 Purcha.e. Ie.. co.t olllem. wilhdrewn 'or personal use 34 35 Co.t of labor. Do nOllnclude selaIY paid 10 yourself 35 36 Malerlal. end supplle. 36 37 Olher co'l. . , , 37 38 Add line. 33 Ihrough 37 38 39 InvenloIY e1 end of year 39 40 Coat or goods aold. Subtract Ilne 39 'rom line 38. cnler lhe result here and on page 1, lino 4 40 Informal/on on Your Vehicle. Complete this part ONLY If you are claiming car or truck expenses on line 10 and are not required to lIIe Form 4562 for this business, See the Instrucllons for line 13 on page C-3 to find out If ~ou must file. 41 When did you pt3ce your vehIcle in servIce lor bUSiness purposes? (monlh, dnv, year) ... .....t.!..........(l'.~ . 42 Of the lotal number or miles you drove your vehicle during 1994. enler the number 0' mites you used your vehicle tor: e 8u.lness .......l.f:{..;?.........,....,..... b Commuling ....<~.l,$.,Q,................ c Olher ......~.~2Q.!.................. 43 Do you (or your spouse) have another vehicle avallnble lor personal use? . ,~ Yes 0 No ~ Ye. 0 No .Iil Ye. 0 No ,fij Ye. 0 No 44 Was your ...ehlcle available 'or use during OU'duly hours? 4511 00 you have evidence to suppon your deduction? b II "Ye.; I. Ihe evidence Wllllen? . . , , . laD Other Expenses. List below business expenses not Included on lines 8-26 or line 30. ............................................................................... ...................................... ...................................................................................................................... ...................................................................................................................... ...........................................................................................,.......................... ...................................................................................................................... ...................................................................................................................... ................................................,...................................................................... ...................................................................................................................... '. ...............................................................................................................;...... .' 46 Tolal othor expensos. Enter hort,) and on page 1. Ilno 21 . . . . . . . . 46 FO: 8606 Nondeductible IRAs (Contributions, Distributions, and Basis) Dtpattmen, of In, T,usury , .,. Please aee What Records Must I Keep? on page 2. Inltrnal nhtm.!. 5'1'10(:' .... Attach to Form 1040, Form 1040A, or Form 1040NR. Name, II mimed. file a ..parale Form eeoe lor each ,pouII. See inllruCllons -';' O~iB No. 15.5,1007 ~@94 Attachment Sequon", No, 47 Your 10cl.1 IIcurlty numb., .;;lL7!70! Q80 HarTle IOdtess (number and 'treen, 0' P 0 bo..., mall is nol delivered 10 your home) CIIV. lown Ot pOS! oHiC', slale. ana ZIP cod. Enter only those contributions Included on line 1 that were made during 1/1/95-1/17/95, This amount will be the same as line 1 if all of your nondeductible conlllbulions for 1994 were made In 1995 by 4/17/95. See Instructions , . . . , . . . . . . , . , . Subtract line 4 from line 3 , . . , , . . , . , , , , . , Enter the totat valua of ALL your IRAs as of 12/31/94 plus any outstanding rOllovers, See Instructions . . . , . . . , . , , . , , . Enter the total IRA distributions received during 1994. Do not include amounts rolled ovar belore 1/1/95, See instructions. , , . , ,. 7 8 I ~. Add lines 6 and 7. . . . . . , , , ~ Divide line 5 by line 8 and enler the resull as a decimal (to at least two ,~Z; places). Do not ente, more than "1.00'. , . , . I. . , . ., 9 X Multiply IIna 7 by line 9, This is the amount of your nontaxable distributions lor 1994 , Subtract line 10 from line 5. This Is tho basis In your IRA(s) as 01 12/31/94 Add lines 4 and 11. This Is your total IRA basis 'or 1994 and sarller years . . . , 2 3 4 6 8 7 B 9 10 11 12 B . . . . . . Fill In Your Address Only ~ It You Are Filing Thle Form by Itself and Not With Your Tax Return Contributions, Nontaxable Distributions, and easls 1 Enter you, IRA contributions for 1994 that you choose to ba nondeductible, Include Ihose made during 1/1/95-4/17/95 Ihat were 10' 1994. See Instructions, . , . , , Enter your total IRA, basis for 1993 and earlier years, See instruCl,ons . , . . , , . , Add lines 1 and 2. . , , , .. "'" . , . , , , , . . , , Old you receive No It-- Enler the amounllrom line 3 on any IRA line 12, Then, stop and read When dlotrlbutlons and Whore To Fila on pa90 2. (withdrawals) In 19947 Ves ~ Go to line 4. Taxable Distributions lor 1994 13' Subtract line 10 Irom line 7, Enter the result here and on Form 1040, I,ne 15b; Form 1040A.linel0b; or Form 1040NR, line t6b, whichever applies. , , , . . , , . . , . . . , . " 13 Sign Here Only It You Under penallies 01 pefjury, I declare Ihall have e.amlned Ihi, form, Including accompanying allachmenl., and to Ihe bill of my Are Filing ThIs Form knowledge and bebel, Ill' true, corroel, and comptele, by Itaell and Not With Your Tax Return ~ Your I,onalute Paperwork Reduction Act Notice We ask fa, the Information on Ihls form to carry out the Internal Ravenue laws of Ihe United States. Vou ore required to give us the Information, We need It to ensure that you ora complying with those laws and to allow us to IIgure and collect the ,Ight amount of tax, Tho time needed to complete and file this form will vary depending on ind,vldual circumstances. The estimated averaga time Is: Racordke.plng, 26 min.; Learning about tho low or the lorm. 7 min.; Preparing tho lo,m, 21 mln,; and Copying, assombllng, and sending the lonn to tho tRS, 20 mln, II you hove commenls concerning the accuracy of these tlma estimates 0' suggestions lor making this form more ITEM 5e75 (8409) simple, we wculd be happy to hear from you, Vou can write to both the IRS and the OHice of Managemenl and Sudget at the addresses listed In the Instruct,ons for Form 1040, Form 1040A, or Form 1040NR. General Instructions Section relerences ore /0 Ihe Inlernal Revenue Code. Purpose of Form Use Form 8606 to repon your IRA contributions Ihat you choose to be nondeductible, For example. If you cannot deduct all of your contllbut'ons because of the Income limits for IRAs, you may wan I to make nondeductible contllbutlons. Also use Form 6606 to "gure the baSiS in your IRAlsl and the t..able pan 01 any d,stllbutions you received In 1994 II you have ever maCe nondeducllblo conlllbutions, ~ Dale '. Vour basis Is Ihe total of all your nondeduclibls IRA contributions minus the tOlal 01 all nontaxable IRA dist,ibutlons received. Ills to your advantage to keap track 01 your basis because Ills used to ligure Ihe nontaxable pan of lutura distributions. Note: To ligure you, deductible IRA conl,lbutions, use tho Instructions lor Form 1040 or Fo,m '040A. whichever applies, Who Must File Vou must fila Form 6608 for 1994 11: · Vou made nondeduclible contrlb~tlons to your IRA for 1994. or · Vou received IRA distributions In 1994 and you have ever mode nondeductible contributions to any of your IRAs. Foon 8606 1199., , ,', '''', '''--'''''''''';:''j'~--','' , ... \,'. -. ....~. .-.........~~ - ~ . . - ~"~..,.., t. , . Schedull 0 (Fo,m 1040) 1U94 .... P.go 2 AIIIICh",I"1 Sequlnce No. 12 ' Naml('1 thown on F'orm 1040. 00 nol I'll.' name 411(j 'OCIII! securlly nu""b., II I(;n~~ 11~.r I'de, I Your locl.l ..curlty numb'r 345 130 !35C.=1 . Short-Term Capital Gains and Losses-Assets Held One Year or Less (Continual/on of Part II (I) Otsc~tlon 01 (b) o.lO (el Oale lold (dl Sa!" p"c. I') COil 0' IQ LOSS (UlllAIN property ( .ampll: acquired olh., baSI' II (e) i, mot' th.n ld), lI(dl i. mOlo th.n (0), 100 an, XYZ Col IMo.. d'.,;, ;''.1 (Mo., day. Vr.1 'lee page 0.31 (see paoe 0.3) subttacl (dl rrom {el subtract ('1 ftom Cd) 20 . . I . : j , . ! , . , , . . . j . i ! , j , I I , I 21 Short.lerm tOlals, Add columns (d). (Q. and 1 : _ i ! (g) of line 20, Enter here and on line 2 . 21' ! 1 . Lonn- Term Capital Gains and Losses-Assets Held Mora Than Ona Year fContinuatlon of Part I/J 22 Sol ;lDH Ce'Tlo'1 q. 7-<;1./ ~;J70; i i LJ 81 1c,t<.J (1.,./&.", "'.F. Ill. Cl1 -, ~~"": i ; S6l~ :r ~ v~". F.,JJ IQS<;: Iqll! , I.jt.d VIlP. , ~lJP'"v ..1 r'Nh"., i't,F VA" I i . (,,~ II Id ~"'J~OI FIDJS ~..;l1-~ I lJ~ I 311 fl: ;::) 48'1 i ! , . I I i i I ! : i I ! I ! , I I i i , . I I ! . I i i . I : . j I ! I 23 Long.lerm lotals, Add columns (d), (Q, and 123 73'15 f:~~~~I~ II."J, I (g) or line 22, Enler here and on line 10 ~~'x'" :-;,~'. ~ ~ ~,,~ ';;:,~~."0:''\: -s ~<> .$e T<< So .. . .\1 ANNUAL PERCENTAGE RATE, '" , The cosl 01 your credil .s.ye.rlyr'le. " FINANCE I ,CHARfiE , lh. doll.r .mounllhe credil willcosl you, .I;.!" I. ',..' AmoLintFlnanced The ,mounl 01 credll proVided 10 you or on your beh,Il, Total of Payments ~; '".;rotal Sale Price:,;, ;'::,:'" I' I The ,moun I you will h.ve p.ld .lIer yOU The Inl.1 cosl 01 your purcnase on ',..' h.ve m.de .11 scheduled p.ymenls, cred,l, IncI"dlng YOUI dowop.ymenl of. . 'I! ",.... '-';,I' ,- 'I, , .",. i'''''' \ __."'I'~ $ '1.1'.,U~OO.OO "c" ", i i:loY,l.lllr:a " I, ./.....;,. ,,;',1 $ 1047/r.n ,$ 166l4.,!I.l II, '. oj ~ ;.' ,', ;.11 ;.b.', % $ 992~J/, $ '>462. 51! '" e means an estimate .1., I," ..I" "'Ii' .j Security: Yo" are giving. ,"clllily 1.1".sll. 'he 100101 vehicle' being rl\lrcha~ed.. ;,.'q Prep.ymenl: II yo" o'y nil ""y, you will nol h.ve 10 p'y, p.n.lly. " You, P,ym.nl Schedule will be: No. 01 P.ym.nls Amollnl 01 P'ym.nls b $ m.!17 $ , , .. Wh.n P. menls Are 011. Monlhly, b'Rinning t ~\'[ 1 ~ t it , 19~'f FIII'If"': $ . 0 ,.,0 lal. Charge: II , p.ymenllsl.I.. you will he charged 2% 01 ,ny p,ymenl.moll.' lor each monlh, 01 p,,1 01 , monlh glealer 'h,n 10 d.ys, Ih., it rem.ins unp.ld, .. .' .' .', ,,' '-,1.. :".., See below and any. olher Contract documenls',o(.riy .dd,lio",llnlorm.lion .bolll nonp.ym,nl, delaull, any required rep.ymenlln 11111 b,lore Ihe scheduled d.I" .nd preplym.nl , relundsand penalties. ,. ", . I. ... " . II', 1111111 ,~ In thll Conlf,cl, w..re.,;: ,nOnDY ,MIlAT.' TOYOTA 'hIS,II'f. ,. , Slgn.lUre 01 Buyer to be insured for Singte Crl!dillile In.uranu . Whatfs your aoe1 . Yeaf. Thli 'Conir,cll. between Seller and Buy.r:AII disdosures have buenmade by'Seil.r. Sell.r Inl.'nds 10 anion Ihl. Conlfiltlto Iha Assignee namldbelow. ' , , , , . . , .. Signature 01 BUYlr to be inslllld for Single Credll Accident &: Ileallh Insllronce Whlll.y.ulao.l' 2.' "j . '.' ." I, ;~I . .t Signalurl!l nl bOlh.8uy.rs to belnsur.d , Ii lOf Joint Credil Ufe Insurance .".. , " ", " SElLEA r.i1i;!:':' t..'\lft',l. ~~"(JY{)'J.A itemization 01 Amount Financed Cash Price", ,... 'I",.. wi'" ,..;' S I, g. ',:H ,'li,11d,t 6J05 CA.'lLIGL!: 1'11:1:: UCCl!ANIC!:nUnc PA 17055'" T'IIIDownp.ym"l , ,"', N.m. Addrlll lip Code ..$ 1 I " ," Y.II.i.. ARLl::tJ~ A'GAT,LA b 120LINII DRIVE C,\Rf.lI1Lr. !'A" 17013 Unp.id Cash Price Balance . 'I" " lhe Buve'rlsl. I . '. " ,,:. , ,.,' '" . I ' =S n I' I " . N.m'I.J , Addl'" Zip C.d. To CredillnsuranceComplOY' "'" lither. Is mall Ih.nane Buyer, each willb'e obllgaled, separlt,ly andtoOllher, for all sums due us and the performance of all oOlellments provided In thi. . ... .., ,. j" ,'!i .1". Conlract. 2 +$, '"". L' i,l'1" I Th.llrms shown In the boxes above or. pllr1 01 Ihi. Conuac!. You hlve.oreed 10 purchllse, under Ih.ler'ms DI Ihls Conlrllcl.thu following mOlorvehltl.., To Property Insurance Company'II.,.:.", IInd liS erlralqul m.nl. whIch Is called the 'Vehide" in thIs Conlllct. . 3 +$" ;n(, . N/U. y""nd MI.', S"i.. Body Slyl. ,N., Cyl. Truck TOD C.p"ily S"I.I Numbar To license Tagsaod Reglslralion,., '''' . . 'II ' 4 +S. ~.,l! NEll ~4 TOYOl'A PASCO CI' . J'J'2F.T."~U3P.0162214 To lien Fee . ,h '..,., ','I'''''''' Equlpp.d 0 AJ.D p,S, 0 AM,FM SI"" 0 5 Spd, Dlh" 5 ..". '+$" . " . '.' .', ,'. wilh 0 A,C, 0 p,w,D AM,FMTop. 0 Vi.yl Top" To. ".' ..',j, , 6 +$ '" .'....1....". J "ut"i You hay. traded In .! '., , ":,, .. , " . Ih. 'ollow!nov.hiclo: 1983 ,IIONOA ACCORD $ 4900.0u -$' NIJ~=$',90n.OO To FA SAI.JI:!:I1;A'I" ", ,..,~" d. . VaarandMe" "Series Gross Allowance Still Owing NeITrade./n 7 .!.., +S I. .I",,,,j,. PROPERTY INSUnANCE: You.re required I. .bl.in ond m.inl.iA Ih.loliowlAO I""'A" on Ih. V.hicl.. BUTYOU MAY CHOOSE TIlE AGENT DA Am.unt Financed ,'. h' ',<" ,." , BAOKER DFYOUR CHOICE: . , '. I IXJ $ III' IXJ $ tlJA 0 Illhlu7) =$ ,.;1,1,,1\ AUlomobi · Physlul Oamag. In. uranu: Com rehensivlI fa; . Oedll~lible Collision ; Towing and labor; DOlhe;IO.ieribe).' ,.,n'"N ^ .,.. ,"'Io'illilld I. . .J :"j' ",,' ..I':'I:lHI!" .:n II .breIAi.ii'h,ouOh us, 'hltOll ,I Ihl.IAsu",;. i. $ HI ^ "NI ^' 'in'OIh.. heoinAIAuonth. d"..llhi. COAII'e1, Th" 1,,"reA", ,N.I T~a~:.I~' '.; "'"I,';',~ ~',;'~i;',:;,,;: will be provided Ihrough us Dnlt IIlhe premium Is Ineluded In IhD Amounl Financed shown 81 ,Iohl. . . $ It 900. OO..l _ ,.,l, """, CREDITlNSURANCE IS NDTAEOUIAED: Subjocll.ICC.pIIDtl hy Ih,I,,",rnomedhelow. .rodi""uranco i....iI.hl'lh"uuh "' '''lh''"m.llhl'Cllh Cownpayment ..... "" '. " Conuict .tlh. caSls'shown bilow, Slnol. CrediIUf.ln.urarce and Single Crer/it Accident & HllIlth Insufance or. avsiloblelo any' on. Duyer signing . +s 1300.00,1, ,', ,,', . below 'or lnsuf.nte. Jelnl Clldillife Insllllnte Is available 10 both Buy.rs s10nhlQ b.low '0' In.uranu. No c:redillnSUfantD will be ptoridld unlus lhe lIt1proptilte statem.nt!s) Is slgn.d by Ihl Buyer(s) to be Insured and lh. co.l.shown below ore included In Iho Amounl Financed.ISulhe f.lDT/CE OF Tola'Oownpayment PADPDSEDCAEDITINSUAANCEon,lh...""...ld..r . ,. " ,.,. , ..', '.! ! ',,'. ji'=$16200iOO.-J:ln; , . ,'. '. . i I. I" ! .. t. ., ,~ I. \,' I'. : ;. . ,'.' '.. , " , " I" ' ;,' j' . \ <.'., ,... ~ I II.' I:''';' BnlgAlno. you won, Si'OI. Clldit 1II.lnsu"A", ..Byslg.lno, YOII wenl'Sinul. Clldil Acclden' & H..hh .'.1 ,By,.lgnlno. you both w'"\ J,inl Credll.U1.lnsure','~'\i1rHIW whIch tosl. S Insurance. whlthcoS!s S which COSI.. 'j, ';"'1" ,~at,lr';l"':' four ages? I, _Vllrs r. ."" ',1' :~y,.il ,:, Vean " 1", . "',.',. "',' " ,!.J .'.,t..' i Insurer. DOlher PAYMENT SCHEOUlE: You lorulo PIlY us the Total Sale Price lor Ihe V.hicle by making the TOlal Downpaymenll1nd tleylng u.the Amount Financed, pluslnlltest.ln the numb.r and .mount of monthly paymenls shown In the Payment Schedule, Payments Drlt due on or bllor.the lime day of each monlh IS thelinl peymenl dllID. Paymenls must be mllde al ant ofliu of; ',.' I.,.: ',I '.' ,', ',I '. , DAUPHIN DEPOSIT DANK AND TRUST COMPANY , ,..,,:; .,:.'.: 0' j .1 ; r'!1 ,.,.. I; I'~., ,,,,:.; . ,'~ ", " ! IIhe "Aulgnu"). j HOW THE TOTAL OF PAYMENTS IS,CDMPUTED: Th. I.III ., P.ym..'I'I. Ih..um ollh. . , P"P'"yas SIC""'y 'ar "p'ym..' .I'~. Con're'l.lI.wmr. you "."wl.dg.lh.llh.l.wgii" A~ouril FIAen"d endlh. FinaA"Charg., Th.FIA.A"Charo.eansiuss.,.ly.flDlIII.,eampulld, 'UI. IIOht 0,.'1..11 In eny.1 YO" prop,"y whl,h I. In our p.ue..lon'il.AY lim.>"" ".,. '., darlY'A 'h. oulllendono b.lenc. ollh. AmouAI F1A'A,"d, Th. finance Ch"O' .h,WlI .b,v. has REINSTATEMENT'II II.. pos mloA 01 Ih. V.hicl. bmuII oly'''d''"I'yoII m.y wilhour' been Compul.don Ihe,slumptlonlhllt allpaymcnls \\'iI/be received on Ih.lr .cheduled dUll dales. . we sit, lI.ny paym.nt I. late, you'will be obligllled 10 pay male Finance Charge than Is shownbecaul8 of, epproVIII: regltln possession 01 the V~hlcl. ~~ pllylng us aU pasl dUll pllym.nlsl late charges and . IhladdillonallnllreSl which IIttrulI,lfyou pay elllly.the Finance Charge will be 'ess. The amount , .relurnedltem charges. ourcoslsol SUit and: If you were In defau,lI mar. than ~5 dllY' whln W'look. 01 Ih.Increllleor dect.lISe will b'l8l1ected In 1hllllSI payment. which. II10n; wilh Ihe.TollIl 0' poss.sslon ollh. Vehlcl., Our costs of lak,"g possession. rep'lrlng and stann; the Vehlcl. which. ' Paymlnls. willb. modified ICcordinglt, VoumllY prepay all or IIny part nf Ihe balance due alany lie authori18d by IlIw. ,. ...' .....,t. .,. ." ......_...<1....,. lime wilhout penally or premium, lATE CHARGE: You agree 10 payus alai. c1l1rgD of 2% of anyparment .mounllor each monlh. or p.rt of. monl" DlIlIlerthan 10 days, thllt il islall, SECUAITY AGREEMENT: T. lI"re Ih. p.ym'AI 01111 '"10' du. end Ih. p"lormen" .1 .11 required oblig'lionl und.rlhJs ConUllct, you grant liS ISPctllilylrllefost In Iha VlIhlLlll.ln .lIllarll (catled ""culSlon.") alleched 10 the Vehicleal Dny IlIler limo, ondin anyprDueds of Ihe Vchltlo. Including Insurann proueds. II annlhlU SIIClllllt olJ18ement or mongaoe covlllno prop.tly rOll own olhll Ihan the Vehicle nnw ..hlS h'''~llIn you and liS. wa wair. lhll rillhllo 11.11111101 OilIer Bt signloo h~low, we o~'l!e 10 soli Iho Vlllllde 10 yOll \Jndlr Iha lerms ollhis ConlfllCt. We oliO aulg" rhis COlllrocllo Iho "Assignlle" niltlled abovo In accordance with Ihe Assianmenl nn the ro"""ld. 0 V/lTIIDUT nrCOUnSf; 0 VIITII fUlL nECOllnSI; 0 VlITtI nEPllnCIIASE, IF THIS CONTRACT INVOLVES THE SALE OF A USED VEHICLE. THE INFOR', MAllON YOU SEE ONTHE WINOOW FORM FOR THIS VEHICLE IS PARTOF THIS CONTRACT. INFORMATION ON THE WINOOW FORM OVERRIOES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. ADDITIONAL TEAMS AND CONDITIONS: TIllS CONTRACT CONTINUES DNTiIE REVERSE SIDE, YOU Ani DDLlGAIED TO All TIlE TIAMS Dfl111S CDNTAACTwtllCII APPEAA ON TIlE fRONT, AND RIVERSI SIDES, " NOTICE TO BUYER-DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENTITlED TO AN EXACT COpy OF THE CONTRACT YOU SIGN, KEEP IT TO PROTECT YOUR LEGAL RIGHTS. ISIAlI nUVER -,-~L&Ul-~ aQ.o..o... ISIALI DUVlR ;BYYEry ACKNDWl~G~S R,EPPPT OF A COMPLETED COpy OF THIS CONTRACT AT THE TIME OF SIGNING. BllYTA ~L.~~~~ v..O_\LQ..... BUYEA 8.um"'''UfRlOAU''.1MMlI NOTICE: SFF. RF.VF.RRF RIRF FOR IMPnnTMIT 1"~nn"OTln" BY. '-.' I....!':;., (SEALI ISEAll .,.:.:~- . .................. .................................................. -......... ............... ......... .... ................ ..... .:-;: I 000 ,~ 000 5-, I 000 ~. M V ,'. I lAlIllA U. I ':' + + + [:: l.l!l III III .l!l ~ III ... ~ .l!l \Il .l!l ,~ .l!l ....1:"Et:"";:-:::I-;::.--;::....~t: C\I ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ $ ~ ~ c~....::~::o::EE....::=[/l m 1>- ~>. >.,,~>.>-~>.>.'E in = ~ ~ ~ I~ ~ ~ I~ ~ ro ~ ~ ~ ~ N " Q.Q.Q.Q.Q.Q....Q.Q.Q.Q.Q.Q.;: ill ~ 10 0 0 0 0 0 .;. 0 I') I') I') I') I') ~ '"0 IN N N N I'- I'- - It; I') M I') I') M tl ~ ill) Il) Il) Il) W W ~ I') I') I') I') I') a. \Il lAlAlAlAf/tlA;itl7lAlAlAlAlA, '~ l~ ~ ~ ~ ~ ~ .:. ~ ~ ~ ~ .: ~ 0 a: I ('.,J(\JN(\JC'\I_C\l---- 10 0 0 0 0 0 0 0 W N Il) Il) m N ooooo!=:ll)omv<O 'C ~'I 0 m <0 0 I') N W I'- W N u o:tO<O-NNI')WWmll) ~ _ --NC\.I- '-C\lM .:g ::: ' I , ~I I ~'I '--"'n. ~ >1 I . u Ii) .-x , I 0: j< I - \Il W - ~Io 0 0 0 0000 o:t o:t Iti 0 o:t I') NI tl a: ... J OOOOONN 0')1,()(") re Cl -l Qj ,::, _ ommN(')Il)Il)CO-<OW ~ ... " 1;1 o:tWI'-N-~~~S!~~ ~I <l: ... g >. 0:, ~ ' , ~ >- >1 a. !: 1- io 0 0 0 0 0 0 0 0 0 0 0 0 (') (') " <DNNNNNNNNNNNNI') (') "?l Si .' _ Il) Il) Il) Il) Il) Il) Il) Il) Il) Il) It) Il) 10 0 Cl ~5"l;f~~~!2~~~~~~~~1l) C\I I'- ~ .r.. -I a. 0 - _OOOOOOOOWIDI')OIDO !: ;:<DNNNNNNNmmW(')1D Il) ':; Cl-It)Il)It)'<l'o:tlti<ommlD(')10 r- iii " ;:,o:t (') I') I'- 0 - o:t I') I') I') (0) 10 Cl 1:1 ~ ---C\lN-- (') ..:: '0 ~ 0- i.:, , I -E \- io ~ N (') V It) W t-- 18 m 0 ~ N M j, o. 1<0 <0 <0 <0 <0 <0 <0 <0 <0 m m m m .E ,N N N N N N N N N N N N N in ,- IE B B B :g ~ :g :g :9 :g :g E :9 .9 "1 Ie Q .. 10 - N (') '<l' Il) W I'- <0 m 0 _ N M ,~ E ~f!2e!Et2S!2S!2~t12t12~~~~ ,:>-, ,:;: Cl cn~~...-""''''-'''-------- .:.:; V u. I ::- I I- INCOME AND EXPENSE STATEMENT OF WI\'\.. Tb\.,. ~ c...c...A,. SSN"'-/; .~o . S~6l,..DRII DATE~ THIS STATEMENT MUST BE FILLED OUT (If you areself,employed or If you are salaried by a business of which you are owner In wholo or In pori, you musl also fill out the Supplemental Income Statement which appears on the last page of this Incomo Dnd Exponoo Statement.) . (a) Wages/Salary III _ Employer & Address \2 E:{,v~ 1J.(rz(~;;""P-rJ Job Title/Description t:: ,,, . Pay Period (weekly, llt:weeltl~, monthly) ,. \,J I U; ....Nr/l.Ly , Gross Pay per Pay Period ......................................................................................................,..,..,....... $~ 0_ Payroll Deductions: Federal Withholding ......,....,......$ Social Security ,......,..,..,....,........$ Local Wage Tax ..........,..,............$ State Income Tax ....,............,..,..$ INCOME Retirement ......~...........................$ Health Insurance ........................$ Other (specify) ...:!I!/.f.,,"".r.:,..,....$ ACOI,.,""'A~ l=it.Q,lIl!M..,......,..,$ all W. "'IS""""'" fr. Ch'LLo/rl.e. ft. l{gtf.l.a "ZoIO . 31 f/ ., L 11, 0<:- (. foil. Gb 11.) 0 B'~ ,I In 10" .0<:> .' ,........................$. ~ Net Pay per Pay Period ....................................................................................11................"............",. S~ ~ ~~-1- (b) Other Income Interest/Dividends ...,............,....,$ Penslon/Annulty.........................$ Social Security ..,........,........,......$ Rents/Royalties ,............,...........,$ Expense Account ..,....,~........,..,..$ Gifts .............................................$ Unemployment Compensation .$ Workmen's Compensation ....,..,$ Total, Other Income ..........,............$ Week Yoar Monlh $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ INCOME AND EXPENSE STATEMENT OF W A \.0 T1ZI\... LJ.<...A I verily Ihallhe slalomenls mado In Ihls Ineomo ami t.pUIISO 51010' ment are true nnd correc!.1 understand thai tnlno slnll1lnnnla horoln ore mado sub/eel 10 Iho ponalllos 01 IS PaC,S, 4004 101011110 10 unsworn lalsllleallon 10 aUlhorlllus, (\ ~ Da'e:lJ.lwl"r_If__ .1.1~1:l. A'l~ r fllorlln o'iTiiUrui,i1Riil DRO #405 , Household Child Household Child Week Week Month Month EXPENSES Home Mortgage/Rent ........................................ $ $ $ $ Maintenance ........................................... $ $ $ $ Utilities (telephone, heating electric, etc.) ........................................ $ $ $ $ Employment (transportetlon, g"oo lu no hes) ............................................. o. $ $ $ $ , ' Taxes Real Estate .............................................. $ $ $ <tS,q:l. $ Personal Property................................... $ $ $ $ Income ...................................................., $ $ $ $ Insurance' Homeowners ........................................... $ $ $ $ Automobile .............................................. $ $ $ ~,.(Jo $ Life/Accident/Health ......,........,..,........,.. $ $ $ (60.00 $ Other ......................................................to $ $ $ $ Automobile (payments, fuel, '8'00 repairs) ........................,........................ $ $. $ $ Medical Doctor, Dentist, Orthodontist......,..,...... $ $ $ 110.00 $ Hospital................................................... $ $ "'$ $ Special (glasses, braces, etc.) ............... $ $ $ 1.\ .GO $ Education Private, Parochial School....,......,....,...... $ $ $ $ Coil eg e..... ................... ................. ............ $ $ $ ~~ ,"0 $ Personal Clothing ................................................... $ $ $ '\~.oo $ Food ......................................................... $ $ $ 130.1>0 $ Other (household supplies, \!. 3. "6 barber, etc.) .......................................... $ $ $ $ Credit payments and loans ..,.........,......, $ $ $ $ Miscellaneous Household help/child care ...........,........, $ $ $ $ Entertainment (Inc, papers, -h.jo books, vacation, pay TV, ate,) ............ $ $ $ $ Gifts/Charitable contributions ..,........'.. $ $ $ 51. ,~ $ Legal Fees ,...........,............,......,..,..,..,...., $ $ $ 1'20. Oil $ Other child support/alimony payments .........,....'..,......................,.... $ $ $ $ Other (specify) ..,...."..........,......,......,............. $ $ $ $ Total Expenses ............................................. $ $ $ \o"\1.~'L $ , . - '. PROPERTY OWNED Checking Accounts ........ ........ Value L_LI ~O $ $ ',).~'a~ $ $ ~ 1'J,'ldJ_ $ 3/,000 $ /~, 000 $ qq,c06 $ CM.s ." j"'''rT'''~ I "(:2. )J:"",,^ ~o;! IJ""ill $..2:J...<:a9.- ~IJnWlitJ:",~' I (j3.-.M- $ 7.000 $ I.'J,;)g.;'o Ownership' H W J __V' --- --~ --- V - - --;:;r --.::r - - --~ --- ---r - - --::;;r Coverage' H W C v v' """"V'" V- - IT" lJ- '""'"iT IT - r.- v' = 8, Attach to this statement a copy of the following documents relating to the business. profession. partnership, joint venture, corporation or similar entity. (1) the most recent Federal Income Tax Return, and (2) the most recent Prollt and Loss Statemen!. Description it! 0, Name and Address (If different than C) of accountant, controller or other person in charge of financial records: Savings Accounts ""'"'''' ........... Credit Union ,..,..,....,........ .................... N UT1J.lL / ,,(. L1A Invrll/l.,.t [alN': ~tzA i-lr:rtvt ~ Stocks/Bonds .................. .................. Real Estate ....,....,......,...., Other ................................ ................................ Total, Property.........,........... INSURANCE Hospital..,......,..........,..,.., Medical............................ Company 'kilo>. (ll<S<f/R~vFCJ'E/J) 1 1 . Policy No, Health/Accident ..,......,.... Disability Income ............ 0<:1-'11>- D~ Other (dental, etc.) ....,..... ' -. - 'rl- ('H . Husband, W . Wife, J . Joint. C . Child) , ~'I .,. SUPPLEMENTAL INCOME STATEMENT A, This form must be filled out by a person who (check one): _ (1) operates a business or practices a professlonj or _ (2) Is a member of a partnership or Joint venturej or _ (3) Is a shareholder In and Is salaried by a closed corporation or similar entity, C. Name and Address of business: Telephone Number e, (1) Annual Income from business ......"..."",,,,,,,,,........,,,,,,,,,,,,,,,,..,,....,,,,,,.....,,,,,,,,,,,,,,,,,,,..,,.,, S (2) How often Is Income received? """"....",...."""..,...."..".."".."""",,,,,,,,,........,..,..,....,..,,..... S (3) Gross Income per pay period ...,......,............"",....,,,..........,......,,....,......,,,,,....,..,,........,..,,.., S (4) Net Income per pay period .".....,...........,.."......,..,..,.......""..""..............".........."."......,..,.., S (5) Specific deductions If any .........................,...........,.............................................................. S .---' . ....-"..'--.....-.. .- -......--.--...-..-...-..'-.-.. r 780 :~:. .:.') - ",WArn" D.!c2ALC,p:.j ,):'"'~::''''l ~~:. 114 "WIlLOWlt, I I 0.., UIlllILL'" lrot' ~ ~~_._ _1'0,::) .trtt", ~,~~r,:r~c:I.t:-1.\~.....f~__~_~_._.~_...J s S,O~ I .yl-"~. LkJoJD~H'YW~__. ."""t ftFA~~~!~!,~~Y ~~! . 1:03 L 10L. 7 cO I: -' '.i'''8L. 7 Sl,,,' a 780 .,'00000 '.i cOOO.,' ! ". -\....-",...-..._~."" .- ~....-...; --..-._..--~ r.._....._,..._,..._...,_......_...._t...-...~-,...-.r...--,.1. ;:......::!.aWA'T~"D:cbLC.'''''';'':. ...b'....~ 787 r c~.:,~;,~'::'" .::., ,. \ l~' .'. . ,,84 ..,..", ( ! ~~:'::',:" ~"'.l i~!lr.~~--,----- S sZo ~ I ____.~!vl!:'_~!.!~ :~-=~[_,,:_ __ . __..0"'.... 1 ft FA~~~ ~~!:~~Y -'Il . \~ M. (11\ ~ nn I -':~1 1 1"1 ;-~~J-;:a&:lm~1 '::.i;k~~~; r"~""-'--"-' .' ~ <1.WAl.t," D:1IAnA~::' 11'(. """Low.r. C...IlL~L.. ,.... IrQI3 786 ):e.~~~:J..! ' _1_~I:tL_,,83 ...."" --,-- A_ ~ .~.... .;..... . s ~oo "TOt-I, 6'AL.t.A;~:...r'------ ;-- . ;'-~:1 S! ~ .."OU'J ItI-lD .'_"",' .. "..". II :;---_._~~: FAJl!:1'~~!~:'!:J~~~::_I\~~', ~ 1Cll./..0': e' 5.:a ~jj~...j02.~,._~:.?.22,:::~~,?~J -.,or-"~_"" . ' . . l I I I'"'"-,..._'..._,..'-'..._,..._Z..._...._.....--"_._..~ , WALTI. D. aALLA l. B05 I I ''''WILLOWS'.' r '7. "'4 f I . 'c""W'S~'t.''':'''l'Qu'''' ",'-..." ." "..r:;J, I ....l1Im '. To v \ C;; ""'"I..A.. . __ __ t, i~~sJ1( 50 4~ I ;"LJ,~Nib~-~'._:_ff ;=q-....: .u~.-'_:_~~DOllA.S I FARMERS TRUST COMPANY j ;;:'1 ; U C1 !~! ' , '.lOi....I"_I.U......"lM. .:..._~. : ~ -~L ' " I 30lt7 cOI: "S''''8lt75lt" 0&65'" '~'6oooo.l:.~..0~..~ _lo..,_.....~..._-~ -- ~._^""-'~...-.....!o-.-..~_..._'....-..1 wACn';D,aA'''. t if 7991 B09 " .... '." .. t~~~il~L~f.1:Jii" ,.- .. jO). 'J."/ ..... . 0 W~,~T.I!~~L:AI\~ "tA ft& . <+0 ,.-_____..1'0. ...""" c...lluU...,.....'roI3... ..- ~ _"'1':'. . .... ..I,Q"""_I. "'''11I1 ., r; ----- 00 . , "'...... I "'11I"" NI A-L'^, ...~~.:~,.....,^ __ ~ ,'~'.:::::'" ~ 00 ""''''~I . ""'-',_.. ....~-!7';SJff'..".. . ~o L.l '. Ull'-L,l..~~::~ ~:_ _.. ,S ",20 - ( 1'"'. Vf3;~(2.etJ.'TtJ'~, itf.. 1:''-'..-:_0'''''' '_e_.UI!IU>il*P__:r.';'.e-.:ft:'f_--.- 0""'" ! ftFARM c. ,:II" - ,," I ,:; \ ERS TRUST COMPANY -, JAIl' 0 li;I, ., ".. ':.";',i . I U.......I'.......U._,_. tc" ~ _ ~: ~FAR,.~.~~!~~~~!i.~q~~y....-.J~.::LJ AA' f. I ..-- --- I', -- ! ~'. ...... ~~(I..(.l....I I t.,'~~,~~~,?,~:_,~,a ~ 7 :. ~"' /J 7;":' ~~~~ib 5 /000"__ :1i.~ 7 /O~: . .' ~.:~~~ 7: l ~:, :O'~O q ,._~?~~o..::,~?~,-, ." _..._.....___.~.~...-...__..."'--"'_'" .-n"-_.~.~-'.01.~.... ....-......-.'( WALnnD.OALU 820 ... WALTl:nD.OALLA 821 l 114 I. W&l.lOW It. I c...1ULXf\u..O'!lr"l."')- ~o.."'".;t'1J\ 6A jl UIlUULI'",- 11'l1".". :-~~_Z.I~t.__.. _l~_~. ..'FIIIlI' ;!~.. C::,UIUSLl.l'I..trOlJ.. .__ ~,..;,~ "ei "''''111 t. ~ ::~..::... ~~...-...( Q I \ o. flr. .G.A,I...L. (>.":.;:;.=__ __. s IS"'~ ___ ___ ____ '" ".__ '_ _..'..~.h.._....,sS'to"-'1 _ON{; .,III!.N,f,RGD "Ft'PTtt. 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'vt1t1/~ I-Iu~;~s?' :t:NrY .4 FAPMERS TRUST~' \ 'W'I: c~.._.",,,...;u'3~-'- DOLL.\l1 I I - 1:01I10~1l01: "5"a~15~" 1508 100000510001 OR I GI~!t\L n 1 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2 3 ARLENE A. GALLA, PLAINTIFF VS. 9S~ !;Jf() NO. 1-195-8 1992 4 5 WALTER D. GALLA, 6 DEFENDANT 7 B 9 10 DEPOSITION OF: ARLENE A. GALLA 11 TAKEN BY: INTERVENOR 12 BEFORE: ELLEN SWAYZE REISSER REPORTER, NOTARY PUBLIC t~ 13 PLACE: MAY 19, 1995, 1:10 P.M. KNUPP & KODAK, P.C. 407 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA DATE: 14 15 16 17 18 19 ..'") ~~ L~ "t,:C .:~ rtl'J'''''' ~...:~I'I., (",C a- :0: 20 - 22 ~:' i; f -.. ", ' .'~: ',! \-,_1,.'\ C .. >: ~~ n en . ll1t1 ~ . : ;4 ::x: ~... j'- ."~; .l:.. 21 23 ~ 24 25 v GEIGER a LORIA REPORTING SERVICE, ;UOQ PARK DR, SUITE D, HOG., PA t7llo 717'S.,.t!SOB OR 1'800'222'.571 2 I, i , ('j 1 APPEARANCES: 3 CHRISTOPHER.C. HOUSTON, ESQUIRE FOR - PLAINTIFF 2 4 ROBERT L. O'BRIEN, ESQUIRE FOR - DEFENDANT n' I,', I' 5 6 KNUPP & KODAK, P.C. BY: GARY J. IMBLUM, ESQUIRE 7 FOR - INTERVENOR 8 9 10 11 12 .. 13 14 15 16 17 18 19 20 21 22 ,., 23 24 fz \"J 25 { GEIGER a LORIA REPORTING SERVICE, 2..00 PARK DR., SUITE B. HOG. PA 17110 717'15041011108 OR 1'000'222...1571 3 (\ 1 TABLE OF CONTENTS 2 WITNESSES 3 FOR THE INTERVENOR DIRECT CROSS REDIRECT 4 Arlene A. Galla By Mr. Imblum By Mr. Houston 4 34 5 31 6 7 8 9 10 11 EXHIBITS 12 ANTIONETTE EXHIBIT NO. MARKED AND PRODUCED ~ 13 5 - Income and Expense Statement of Arlene Galla 18 14 15 16 17 18 19 20 21 22 23 24 25 '-' GEIGER 6 LORIA REPORTING SERVICE, 2408 PARK DR, SUITE D, HOG, PA 17110 717'~4HS08 OR ,.000-222'4571 4 1 ARLENE A. GALLA, called as a witness, being 2 sworn, testified as follows: 3 4 DIRECT EXAMINATION 5 6 BY MR. IMBLUM: 7 Q Arlene, my name is Gary Imblum. I'm the 8 attorney for Antionette Galla. You've been asked to come 9 today for depositions relating to your support matter 10 against Walter; and more specifically, Antionette's action 11 to intervene and to collect alimony from Walter. 12 You're represented here today by your S'" , ....;i.. 13 attorney, Chris Houston. If at anytime when I'm asking you 14 questions if you need to talk to Mr. Houston, you can do so. 15 You can go into a separate part of the building. 16 If I ask you anything that you don't 17 understand or you want me to clarify, you can do that during 18 the questioning. Do you understand those instructions? 19 A Yes. 20 Q Are you under the influence of any drugs, any 21 medication, any alcohol? 22 A No. 23 Q When were you and Walter married? August 30th. I never can remember if it's '85 24 A t"J 25 or '86. I think it's '86. QEIGER It LORIA REPORTING SERVICE, il~08 PARK DR.. SUITE e, HOG. PA 17110 717.!I.41.ISOO OR 1-000'222'411517 /-~'. 1 2 agreement? 3 4 5 Q And you and Walter did not have a prenuptial A No. Q Do you have any type of informal agreement as 5 to what would happen if the two of you got divorced as to 6 how assets would be divided up, et cetera? 7 A 8 Q 9 A Half each, I guess, whatever. Have you discussed that? Well, it's never been an issue. We just 10 assume that when we breakup that half is going to be his and 11 half will be mine. 12 Q .Ii'. ~(;J ..,b 13 A 14 Q 15 bills for the residence? 16 A All right. Now, where do you work? Cumberland County Nursing Home. Who pays the bills, the joint bills, or the All of our checks go into a checking account 17 and it's done through that. 18 Q 19 A 20 Q 21 A And who physically makes the payments? Writes the checks? Yes. I do. Most of them. Sometimes he'll pay one 22 or two, I don't know. A car payment or whatever. 23 Q 24 that Walter earns is earmarked for certain bills and the Is there any allocation such that the money 25 money that you earned is earmarked for certain bills, or is v GEIGER a LORI" REPORTING SERVICE, 2408 PARK OR., SUITE 9, HaG, PA 11110 111'S4HSOB OR I'BOO'222'4~71 6 1 it all pulled and then you pay whatever bills you can out of 2 it? 3 A 4 Q 5 A Yes, that's right. It's all pulled. When you married Walter, what did he own? He had an ancient Plymouth Horizon and that 6 was all. He was -- there was nothing. He was a neighbor of 7 mine and we rented and there was nothing. 8 Q 9 bank? 10 A 11 Q 12 A "',\ f;" . .V,o..> 13 Q Did he have any investments, any money in the No, he had nothing. Pension plans? No. What do the two of you presently own? You 14 have a house, right? 15 A 16 Q It's mortgaged. yes, we have a house. What's the value of the house, in your 17 estimation? What do you think it's worth? Well, you've 18 talked to a realtor, haven't you? 19 A Yes. She indicated the value would be based 20 on how quickly we wanted to sell and when we put it on the 21 market. 22 Q Did she give you some range as to what you 23 could get for the house? 24 25 120. GEIGER 1Ii LORIA REPORTING SERVICE. 2408 PARK OR. 5UITE Q. HUG., PA 171\0 717'!UIH!iOD OR l'OOO.222'4S71 ~ A Anywhere between a hundred thousand and maybe 1 Q 2 A 3 Q 7 And who is that realtor? Darilyn Dolindio. She's with Century 21. And you have a mortgage. What do you estimate 4 you owe on the mortgage, if you have any idea? 5 A 6 Q 7 pension plan? 8 A 9 Q $75,000. Now, Walter has a pension. Do you have a It's a retirement plan. And is there a certain percentage that you 10 contribute to it each year? 11 A 12 Q ...." "~"t:' .<~. 13 14 15 house? 16 17 18 Yes. What percentage is that? A Five percent. Q Has there been a robbery recently at your A Yes. Q Can you tell me about it? Well, it was a Tuesday morning and my husband A 19 always wakes up early and goes to work. And he awakened me 20 up about a quarter to seven and asked me where computers 21 and briefcases and all was and perhaps I had misplaced it. 22 I got out of bed and we noticed that his 23 computer desk had been gone through and my handbag and 24 credit cards and everything had been removed from my bedroom 25 and taken into another room and gone through. ~ GEIGER II LORI. REPORTING SERVICE, HOD PARI< DR, SUITE e, HUG, PA 17110 717'&4H~Oe OR 1-000'222'4877 " ,.-..., t:J 13 8 1 And a camera was taken and two computers, 2 software and it was gone. 3 Now, this was in the morning when you first Q 4 realized this? 5 Yes, when we got up. A 6 The night before when you went to bed do you Q 7 know if the computers were still there? 10 A Q your purse? A Q A Q A Q On my bedroom dresser. 8 Yes. 11 Yes. 12 Where was your purse? 15 Yes. 17 your bedroom while you were sleeping and take these things? 18 19 20 21 22 23 24 25 \"J A Yes. Q So your purse was gone through, credit cards were taken, they took the computers. A Cash. Q Cash. And what else? Anything else? A A camera. Walter's software, computers. Q What kind of records are kept on the computer? Personal records of yours and Walter's? OEIGER A LORIA REPORTING SERVICE, 2409 PARK DR. SUITE D, HOG. PA 11110 717'!5UI!508 OR 1'800'222'.577 'c,:t ;):::'~ ..,;',~;;-~ ~-:.":_.~\3~1 :.' ':";'J .->.'.....:i'4:.,t , <Cj;~';'?,tt~~t , ..~ ~.~.:;.!t!ti~.: > , ~ 'l'l:;<.j " ~.:'r,~:t\,": _'!l\il'7.1 _\~;~til1o 1 2 3 4 5 6 7 8 9 10 11 12 t;) 13 14 15 16 17 18 19 20 21 22 23 24 25 V 9 I, j: , [i A I don't generally use the computer. Q Walter keeps these? A Yes. And the files were gone through. We \' " have a file cabinet and the drawers were opened and there il was a space where taxes were that was gone through, so I I I don't really know what's gone from there. f computer? Q Do you know what records he keeps on the A No. I am not Q I know you're not A a computer person. I have my own computer that's -- an old one that he gave to me. And, you know, I use the typewriters and things like that and it was up in the dining room area and it was left there on the floor. They did not take it. They did not take it? Q A Q records? A Q A No. Do you know if he keeps bank records, tax No. Does he keep ledgers? No. He's not a -- he doesn't keep up with that stuff generally. Q Did you ever hear of a program named Quicken, does he have anything like that? GEIGER a LORIA REPORTING SERVICE. 2"'00 PARK DR.. SUITE D, HOG" PA 17110 717.!5<4H'OO OR I'DOO'2:i12.,tl577 1 A . ..c.;.....-- 10 I know he has one called Derived that has math 2 and he has one called Ami Pro. But he's usually doing the 3 electronic stuff on it with pictures and numbers. I don't 4 pay much attention. 5 Q Have either you or Walter transferred any 6 assets, either given away or sold any assets since you've 7 been married? 8 A 9 Q 10 A Yes. Can you tell me what? Well, it's on our tax returns when we transfer 11 investments from one investment to another. It's always 12 been documented. 1":'. ,n' 13 Q But can you expand upon that for me? Do you 14 have investments that you've transferred? 15 A 16 Q 17 A Yes. What investments? Periodically as one investment doesn't do 18 well, we'll redeem it and put it in something else. 19 20 21 Q What kind of investments are we talking about? perhaps mutual funds or something like that. A Q What other types of investments are there 22 besides mutual funds? 23 That's all. one time we had stock in one A 24 company, but we've sold it. I~ 25 GEIGER 6 LORIA REPORTING SERVICE, 2408 PARK OR. SUITE B, HOG" PA 17110 717,'."'1100 OR 1'000'222'.'577 Q Would there have been anything beyond stock .~ 11 1 2 3 4 5 6 7 8 9 10 11 12 ,:;) 13 t,,- . 14 15 16 17 18 19 20 21 22 23 24 25 V and mutual funds? A No. Q Was any of the stock or mutual funds in Walter'S name alone? A No. Q What did you have stock in? A Hershey Foods. Q Can you give me an idea of when that would have been sold? A well, I believe it was on our last taxes. It's the record that you have there. Q on '94? A I believe. It would be on one of the schedules. schedule A or Schedule B. MR. HOUSTON: Just to speed things up, it's page 2 on schedule D. BY MR. IMBLUM: Q Sold 20th Century selected and balanced mutual funds. In whose name was that in? A Joint. Q Invesco funds technology and financial mutual funds? A Joint. Q And Hershey Foods? A Joint. GEIGER . LORI~ REPORTING SERYICE, ..0. P~R. DR, SUITE B, HOG, P~ 17110 717,..,,"GB OR ,'.GO,...,..77 /', 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 c;:> v 12 Q And where did the money go? A It was reinvested into other funds. Q Now, in past years were there any others that were transferred like that? A Oh, yeah. Q Do you recall the names? A Well -- Q If you remember. A I always shift from one to the other, but every time theY're documented on my tax returns. Q You try to go to the best mutual funds or -- A Yeah. If something isn't doing well, I do that. Q Do you have a broker who does this for you or how do you go about -- A No. I took an investment course myself and I handle this myself. We did have a broker once for some insurance who taught the course, but I'm not involved with him. Q Since you've been married have any of your investments been in Walter's name alone? A No. Q Have any of them just been in your name? A Yes. Q May I ask why you had some in your name and GEIGER a LORIA REPORTING SERVICE. 2400 PARK DR. SUITE D, HDG.. PA 17110 717'841-1500 OR 1'000'222'''577 1 2 3 4 5 6 7 8 9 10 11 12 (;) 13 14 15 16 17 18 19 20 21 22 23 24 25 V 13 none in Walter's name? A You can ask. Q Would you answer? A Well, I've been married before and I have two children by that husband and I received child support from him for 15 years or so since my children were very young. Initially I needed the money desperately when I was. first divorced. But as time went on I began working and being more able to take care of myself and I began to save the child support money that I didn't use and this is what these accounts have been used for. And subsequent investments have been made in my name. Q So whenever you invest the child support money, you invest it in your name alone? A Well, originally I invested it under my childrens' names. But when my children became teenagers, they found out about it and my son and I had a problem with that because he wanted to have it. And so I discontinued using my childrens' names for investments and I have put them in my name alone. Q When did you and Walter start to have marital difficulty? A Probably one year after we were married. Q And at what point, if ever, did you maintain separate bedrooms? GEIGER 6 LORIA REPORTING SERVICE, 2408 PARK DR, SUITE D, HDG.. PA 17110 1I7'~,U'1~OB OR 1'000'222'4:171 ~.- i::;l v 14 1 A Very early '90s, I guess. 2 Q And is it fair to say that it's been a long 3 time since the two of you have had sexual relations? 4 A Very. 5 Q Given the status of your marriage over those 6 years, why haven't you filed for divorce sooner than you 7 have? 8 A I have two children who went through a very 9 bad time with my previous marriage. And it was my desire to 10 try to maintain a stable home for them until they reach the 11 time of independence. 12 I also have maintained my separate life. Six 13 years ago I took a job on weekends. I work weekends 14 15 16 17 18 19 My children are almost ready to be on their 20 own. It will be another couple of years, so -- 21 Q Is that why you chose to file for divorce in 22 February? 23 A I will have to say our marital relationship 24 has become much worse over the past few years because of 25 many other stresses. exclusively overnight, 12 hour shifts. My husband works through the week. He goes to AA meetings almost every night and falls asleep. I have my own life, my own children, my own friends and he has his. GEIGER Ii LORIA. REPORTING SERVICE, z..on PARK DR, SUITE D. HOG, PA 17110 717'~n1508 OR "800-;22'''577 1 Q 15 Was Antionette Galla's attempt or our attempts 2 to collect alimony on behalf of Antionette Galla, was that a 3 motivating factor to any degree in your filing for divorce? 4 A 5 Q I have always planned to file for divorce. But was it to any extent a motivating factor 6 in your filing, even to a slight degree or to some degree? 7 Did that enter into your decision in filing for divorce? 8 A It probably has caused me to move the proces) 9 along a little bit. More quickly. 10 Q Now, in November of 1992 you and Walter 11 entered into a support agreement. 12 A ..., (,,.I 13 Q Yes. Can you tell me why you entered into a support 14 agreement at that time? 15 A That was done with the motivation to maintain 16 my marital residence. 17 Q Well, you had testified that prior to this 18 time, and correct me if I'm wrong, you were pulling your 19 money and paying bills. 20 Did that system breakdown that you had to 21 collect support from Walter or did something change in that 22 way that you had to now collect support from Walter? 23 A I wanted to assure that my residence would be 24 maintained for my family. 25 Q v Why were you worried about your residence? GEIGER ft LORIA REPORTING SERVICE, 2"08 PARK DR., SUITE B. HOG, PA 17110 717'eI"H~08 OR 1'800'222'.577 1 A 2 Q 3 A 4 Q 16 ----} I guess I felt threatened. By? By Tony Galla? Yes. Yes. And at the point that you entered into the 5 spousal support agreement, were you aware that Tony Galla 6 was being more aggressive in trying to collect alimony from 7 Walter? 8 A 9 Q I was aware of it. And you wanted to preserve the house and 10 that's one of the reasons why you entered into this support 11 agreement? 12 A -"~. t;..1 13 Q Yes. When you discussed entering into the support 14 agreement with Walter, did Walter say why he was willing 15 to pay you support? 16 A Walter Galla is a very generous man. He 17 always has been. And he was very willing for me to maintain 18 that actually probably hoping that we would not divorce. 19 Q 20 How was that arrived at? 21 A How did you come up with the $1800 figure? Well, we went through a budget first of all, 22 I guess you have copies of that, of how much money is 23 necessary for maintaining the house. 24 Q And so you felt that you needed 1800 a month , V 25 from Walter to maintain the house? GElDER a LORIA REPORTING SERVICE, 2..08 PARK DR. sUITE D. tioa., PA 17110 717'~I"'1~OO DR "800-222'04517 1 2 3 4 5 6 7 8 9 10 11 12 C') 13 .."'.. 14 15 16 17 18 19 20 21 22 23 24 25 U ( , .__.r' 17 A Yes. We have a very large mortgage payment. Q Did Walter ever say to you that he wanted to enter into the support agreement so that Antionette couldn't attach his wages? A No. Q I'll show you what was marked as Antionette Galla Exhibit No.3. It's entitled Motion to Void Separation Agreement. On the last page of that document it has a date that it was served on Antionette's attorney. I believe it's December 4th of '92. Is that correct? A Yes. Q Now, this is around the same time that you and Walter entered into the spousal support agreement, which is Antionette Galla Exhibit No.2. The support agreement is dated November 21, 1992. So whenever you entered into the support agreement, were you aware that Antionette was being more aggressive in trying to collect alimony and that Walter was trying to fight that? A Well, Antionette Galla has been aggressive all through the years. It has been continuous, I guess. Q Were you represented by counsel when you were entering into this spousal support agreement or did you get advice of counsel? G[laER a LORIA REPORTING SERVICE, 2.108 PARK DR. SUITE O. HOG, PA 17110 717"Afol'OQ OR 1'800'2:22'4577 ~~\ 1 A 2 Q 3 A 4 Q 18 Yes. Can I ask from whom? Mr. O'Brien. Now, the money that you received, the $1800 per month, what did you apply the money towards? A All the bills, which is listed in the expense report that you have had the opportunity to review. MR. IMBLUM: Maybe we can mark this , \ I I I i' I 5 6 7 8 9 Antionette Galla Exhibit 5. 10 (Income and Expense Statement of Arlene Galla 11 marked Antionette Galla Exhibit No.5.) 12 BY MR. IMBLUM: o 13 Q I'm going to show you Antionette Galla Exhibit 14 No. 5 and ask if you can identify that? 15 A I assume it's the same one that I reviewed 16 when I came in today. 17 Q 18 A Does it look like the same one? Well, I ,haven't checked all the numbers; but I 19 assume it's the same as I provided. It looks like it. 20 Q So according to this budget, if I'm correct, 21 you have a net income of 186B.B8 a month? 22 A 23 checks. 24 Q 25 A GEIGER 6 LORIA REPORTING SERVICE, 2"'08 PARK DR, SUITE O. HDG, P4 17110 717""1-1'08 OR I.OOO'222'.U77 u Well, approximately. I have to look at my Approximately? Approximately. 1 2 3 4 5 6 7 8 9 10 11 12 (:> 13 14 15 16 17 18 19 20 21 22 23 24 25 --.J 19 I It t I I Q And then you receive 1800 a month from Walter? A Yes. \,~ il Q well, actually YOU're not receiving 1800 a month anymore, are you? A No. , I I I I : MR. HOUSTON: I was just noting the back of this is dated December. BY MR. IMBLUM: Q As of December 6th then you were receiving the 1800? A Yes. Q Have you managed to make any additional investments or save any money since December of '94? A No. Q NoW, at the time you entered into the support agreement you continued to reside together? A Yes. Q And were you still trying to reconcile at that point, you and Walter; is that a fair statement? A Yes. Q And at one point, if ever, did you give up on the attempt to reconcile with Walter or have you given up on the attempt to reconcile? A Well, I guess there comes a point when you argue and the stress in your household is too much and it GEIGER 6 LORIA REPORllNG SERVICE, a"08 PARK DR.. SUITE D, HBG, PA \7110 717'1541011508 OR ,-QOO'2U'."77 1 2 3 4 5 6 7 8 9 10 11 12 <:> 13 14 15 16 17 18 19 20 21 22 23 24 25 I ~ 20 was affecting my children. Q And when did that point come when you decided not to try to reconcile? A I guess in the spring. Q Of this year? A Of that year. Q Of '95? A Of '94. It's been happening all along, I mean, the tension. Q I'm trying to figure out a general point in time when you decided not to try to reconcile with Walter anymore. And is that spring of '95, spring of '94, when? A Well, I filed for divorce in February. of ' 95? Q A Q you ,decided A Q A Yes. So would that have been about the time that That would be the time. okay. Did Walter rent an apartment in 1993? Yes. Q Did you ask him to move out? Did he move out voluntarilY? A It was a joint decision. Q And I understand that he came back in December of '93? GEIGER. LORIA REPORTING SERVICE. zoo. PARK DR, SUITE a, HaG, PA 17\1G 717'50\'lS08 OR ,.800'Z22.0S77 1 2 3 4 5 6 7 8 9 10 11 12 0 13 14 15 16 17 18 19 20 21 22 23 24 25 , '-' 21 A Yes. Q Was that an attempt to reconcile? A We were having financial problems affording all this and legal bills were mounting rapidly and we couldn't afford it. . Q Now, in the fall of '94 Walter increased his federal withholding taxes. Do you know about that? A Yes. Q Do you know why he did that? A To accommodate our taxes. Our income tax bills that were coming up for the following year. Q Did the fact that Antionette was trying to attach his wages A No. Q have any bearing on that decision? A It did not. Q Do you know if either of your children received tax refunds for 1994? Let me give the background of that question. You and Walter did not claim them as -I dependents on your tax return this year -- A No. Q -- is that correct? This is the first year that you did not? A Yes. O[IOER a LORIA REPORTING SERVICE, 2408 PARK DR. SUITE D, HOG, PA 17110 717.e..He08 OR ,'800'222',U77 22 .~-- -', 1 Q So as a result did that benefit their tax 2 filing and did they get a refund as a result? 3 A Well, my son worked part time at Dunkin Donuts 4 and I assume that he made under the amount, so he probably 5 got some taxes back. 6 And my daughter filed her own taxes and she 7 got some money back this year, yes. 8 Q Can you tell me why the decision was made not 9 to claim them as dependents this year? 10 A Yes. 11 Q Okay. 12 A My son has been out of our home for almost two () -'''f'I 13 years. He's 18 now. During the first year he was in and 14 out of our home. He was living with another family because 15 of stress at our house. 16 And the second year he was away, which was 17 this past year. He was totally out of our home and moved in 18 with another family. 19 And consequently his father who had been 20 paying support to me for all these years and I discontinued 21 our domestic relations agreement because his father was 22 going to assume total support of this child. 23 My husband is not in this country. So it was 24 not an option of my son to go to his father, so he's been 25 staying at a home. So we determined that my husband would ..."/ GEIGER a LORIA REPORTING SERVICE. 2408 PARK OR. SUITE 8, HOG, PA 11110 717'~""1~08 OR 1'800,222.,,&77 23 ,I I " !, ,"," I \ 1 file claim support of my son for this past year. 2 And my daughter came home from college and 3 spent one year working, so consequently she filed her own 4 taxes and she is self-supporting at this time. 5 Q 6 their father? 7 A So you're no longer receiving support from Well, my daughter is 20 so I haven't received B support for her for two years. 9 And my son has turned IB and he'S graduating 10 from high school next week. 11 Q 12 A And has support officially stopped for him? That stopped a year ago or more I guess. o 13 So our tax status changed drastically and it was not 14 something that we could anticipate. 15 Q 16 the market? 17 A 18 When do you anticipate putting your house on very soon. Q NoW, I understand that you and your attorney 19 are formulating an offer for a settlement agreement between 20 you and Walter. 21 22 23 24 25 v A settlement agreement? A Q A marital settlement agreement? A separation agreement? A Q They go by different names. A Yes. QEIGER a LORIA REPORTING SERVICE. 2400 PARK DR., SUITE 8, HOG., PA 17110 117'!!Iol""OB OR "000'222."'577 1 2 3 4 5 6 7 8 9 10 11 12 'I :.) 13 14 15 16 17 18 19 20 21 22 23 24 25 V 24 Q Generally do you contemplate the assets being divided 50/50 between you and your husband? A I assume. Q Are there any assets now of any substantial value that are in Walter's name alone? A Not that I know of. Q Does he have a boat? A Yeah. Q All right. That was purchased while the two of you were married? A He had that boat I think before we got ~arried. I can't remember. Q So when you got married he came in with he had a boat, a car? A It's not exactly -- it's more like a rusted a flat-bottom boat. It's not exactly a luxury It's more a liability at this point to tell you the hulk of liner. truth. Q I appreciate you telling me that. Thank you. A And he can surely take it with him. Q Is it a fishing boat? A Yes. It deserves to live under a tarp. Q And stay there, I guess. A Yes. I don't know whose name the boat is in, I really don't. I have no idea. GEIGEft , LORIA REPORTING SERVICE, 240B PARK DR., SUITE B. HOG, PA 17110 717.S4Hsoe OR 1-000'222'..'77 ,~ ., C) 16 17 18 19 25 1 In the spousal support agreement marked as Q 2 Antionette Galla No.2, it says that the agreement is meant 3 to protect the property and interest of Arlene Galla. And it also says that in addition, all jointly i.,' i l 4 5 held property will remain in control of Arlene Galla during 6 this period. 7 putting those sentences in there, was that B motivated at all by Antionette trying to collect alimony? I, 9 It was motivated to protect my marital assets. From Antionette? A 10 Q 11 Anything that may threaten them. A 12 Q Before you entered into the separation 13 agreement, it's my understanding that Walter would deposit 14 his paycheck in this checking account and then all the bills 15 would be paid. A Yes. Q How did Walter get spending money then? He used his ATM card. ! I- I A Q You wouldn't give him so much money out of his 20 paycheck or something like that? 21 22 A No. Q He would just use his ATM card and whatever he 23 needed he took from the account? 24 u 25 A Yes. Q Since Walter has been paying you the $1800 a GEIGER a LORIA REPORTING SERVICE, 2400 PARK DR. SUITE D, HOG. PA 11110 717'S4HS08 OR "DOO'2U'4S77 26 -, 1 month or whatever you've been receiving from Walter pursuant 2 to the spousal support agreement, has Walter had access to 3 any of that money or any of the other money that you have? 4 In other words, has he been making withdrawals 5 from any of this money or been receiving any money from you? 6 A Well, our finances have been difficult lately. 7 Extremely so. I have been giving him cash. 8 Q How long of a period of time have you been 9 giving him cash? Have you been giving him cash since the 10 spousal support agreement? 11 A Well, we had a joint checking account for a 12 long time mainly because his other checking account was () 13 seized and he is not able to have one, so we have been using 14 the joint account. However, the joint account is going to 15 be gone soon. 16 Q So with this joint account he's been writing 17 checks out of it and also he would take cash out of it, is 18 that right? 19 A Yes. 20 Q And is the joint account where you would 21 deposit the support money that you got, is that right? The 22 support money that you received pursuant to that agreement, 23 you deposited that into the joint account? 24 A Well, I'm not using the joint account for that ,. i' J 25 anymore. I have my own account. This is only my name and GEIGER a LORIA REPORTINO SERVICE. 2400 pARK DR. SUITE O. HBO., PA 17110 717'!)41'HI08 OR I'BOO'222'4577 . 1 2 3 4 5 6 7 8 9 10 11 12 ,) 13 14 15 16 17 18 19 20 21 22 23 24 25 V 27 it's what we have devised since the divorce has been filed. I have my own account. There is a joint account that Walter has been using. Q Let me try to put this in perspective then. since February of '95, since you filed the divorce, you set up a separate checking account? A Yes, my name alone. This is it. Q And from February till now have you deposited those support checks into that account or into the joint account? A I put money in the joint account to cover what I need to cover. Q And you put the rest of the money into your account? A Yes. I have automatic -- like my mortgage payment, you know, that comes out automatically has been drafted out of the joint account and it has taken me months to get them to change it, you see. And I have automatic drafts that are coming out of the joint account, so I have to put money in there in order to cover it so that I'm not defaulted; so this is what I'm trying to do right now. So there has been money put into the joint account, although I'm almost ready to close it. GEIGER a LORIA REPORTING SERVICE. 2.08 PARK DR. SUITE B. HBG, PA 17110 717"41-1'08 OR 1-800'222'4577 '", 1 28 ':1 I Q From February of '95 till now, Walter's had 2 access to the joint account, he's written checks against it 3 and also withdrawn money from it? Well, he additionally uses it for payment of 4 A 5 his credit card bills for his job, too. 6 Q Now, let's take the period from November of 7 '92 through February of '95. 8 A November of '92? 9 Q I'm sorry. November of '92 when the spousal 10 support agreement was entered into. Let's take when you 11 started to receive support from Walter. From that point to 12 when you created this separate account in your name. -:) (; 13 14 15 .....,I A Yes. Q During that period of time you received 16 support from Walter? A Yes. Q That went into the joint account? A Yes. Q All of it? A Yes. Q And then Walter had access to that account to 17 18 19 20 21 22 make withdrawals and to write checks? 23 A Walter did not have a checking account. 24 Q other than the joint account? 25 A Yeah, it was seized. GEIGER a LORIA REPORTING SERVICE. 2..08 PARK DR., sUITE D, HOG. PA 17110 717'~.H~OB OR 1'800.222.4517 '-", 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 <J '-' 29 Q Okay. Okay. A So he had no way to pay bills in any manner except carrying large amounts of cash around, so that was permitted by me. Q Okay. I just need to get the facts straight. A I have no desire to do anything angry with him. Q And I didn't mean to imply that at all. I just need to get the facts straight as to how this was set up. Last summer you took a trip to Arizona with Walter? A Yes. Q Can you just tell me basically why you went out to Arizona? A Because I want to move there. Q Was your purpose in going a vacation? A No. Q Was it to look to relocate? A Look to relocate. Q Did you and Walter spend a lot of time together when you were out there? A No. Q Did you have the same hotel room? A Yes. He had his own bed. GEIGER a LORIA REPORTING SERVICE, 2408 PARK DR., SUITE D. HaG., PA 17110 717.541-1500 OR 1'000'222-4577 , _, --(:_ "...... :.:-.,...."...M . -:+ , . .,..,. .J'~'~ .." I...~~_.._).lf~: -, .~-.,\ 1 Q 2 A 3 Q 30 okay. Was he doing -- Business. __ his business and you were looking for a 4 place to relocate? 5 A 6 Q 7 A 8 Q 9 the area? 10 A 11 Q That's right. Can I ask why Arizona? I love Arizona. No connections there, no ties, you just like No. It's beautiful. Have you and Walter engaged in marital 12 counseling the last few years? , 'J '-' 13 A 14 Q 15 A Not the last few years. When would that have been? The first few years we were married we did. 16 Subsequently it's been individually. I have had extensive 17 counseling over the past few years for myself. 18 Q When you and Walter were in marital counseling 19 together you saw Peter Wilms? 20 21 A Yes. Q If walter were able to settle his differences 22 with Antionette, would that affect the status of your 23 marriage? 24 25 '--- A No. MR. IMBLUM: I have no other questions. GEIGER a LORIA REPORTING SERVICE. ;l408 PARK DR.. SUITE D. HOG., PA 17110 717.e4H&DB OR \'BOO';lZ;h4!!11 31 ! 1 MR. O'BRIEN: I have no questions. 2 3 CROSS-EXAMINATION 4 5 BY MR. HOUSTON: 6 Q You had testified regarding the proposed 7 distribution of assets through the divorce process and you 8 talked about looking at an approximately 50/50 split, right? 9 A Yes. 10 Q You weren't including in that in your 11 thinking, however, those assets that you brought into the 12 marriage; is that correct? ) '-' 13 A No. 14 MR. IMBLUM: I understand that. I understand 15' it would only be marital assets. 16 MR. HOUSTON: I just wanted to clarify that. 17 BY MR. HOUSTON: 18 Q The money that you've been receiving from 19 domestic relations, have those funds been necessary for you 20 to maintain the joint obligations, including the marital -- 21 maintaining the marital residence? 22 A Those funds have been used in part over the 23 years I've been married, yes. 24 Q But YOU've been using those funds for those 25 purposes, is that correct? ,..) GElaER a LORIA REPORTING SERVICE. 2400 pARK DR. SUITE D, tlDO, PA 17110 717".&1'''00 OR 1-800'222''''77 i . 32 ::J 1 A Over the years not all of it. 2 Q I'm talking about now the support payments 3 that you're getting from domestic relations. 4 A Are you talking about my childrens' funds? 5 Q I'm talking about the domestic relations 6 support payments from Walter. I'm not talking about your 7 childrens' support payments. 8 A Have they been used? 9 Q Let's start allover again. The money that 10 you've been getting from Walter -- 11 A Yes. 12 Q -- through domestic relations -- 13 A Yes. 14 Q -- have those funds been necessary for you to 15 be able to maintain your marital residence and the joint 16 obligations that you have with Walter? 17 A They have been crucial. And since they have 18 been cut we have been experiencing major ,problems, 19 especially with additional legal fees, dental bills, et 20 cetera. 21 Q What are you getting now, for the record, in 22 the way of support? 23 A $433 twice a month. 24 Q Did you recently take another trip to Arizona 25 this year? I'm talking about 1995. -"') ,-; GEIGER iii LORIA REPORTING SERVICE, 2406 PARK DR.. SUITE B. HOG. PA 17110 117'541'1!508 OR 1-800-222..S77 ..........: '.,) J 33 1 A Yes, I have. 2 Q Did Walter come with you? 3 A No. 4 Q Why not? 5 A Why not? 6 Q Why did you go? 7 A I went with my daughter. My daughter and I 8 went out to look at the area. 9 Q Why did you go out? 10 A To see if she wants to move with me. 11 Q Why wasn't Walter along on that trip? 12 A Because he isn't in my plans at all. 13 Q And is ,it your intention to list the marital 14 residence for sale? 15 A Yes. 16 Q Is there anything that you're waiting to have 17 done to the property? 18 A We have some painting to finish. It's been 19 difficult lately because of the rain, but that's all we have 20 left to do I think. 21 Q When you say we have left to do, was there 22 some advice given to you by somebody regarding what you 23 needed to have done to the property before you listed it? 24 A Yes. The realtor came and did an inspection 25 and she gave us several things that we needed to do prior to GEIGER a LORIA REPORTING SERVICE. 2400 PARK OR, SUITE D, HOG., PA 17110 717'~4H'08 OR 1'800.aa2'4!577 \ , -..-) ..;;;--- 34 1 listing snd vs've jnst sbout seeoeplisbsd tbe.. uxcept fo' \ ! , ; 2 the painting. And gutters. MR. HOUSTON: 1 don't have anything else. 3 MR. IMBLUM: 1 have just a few questions. \ ; i 4 ThanK you. 5 6 REDIRECT EXAMINATION 7 8 On December 8th of '94 there was a hearing in , \ ! \ 9 BY MR. IMBLUM: 10 tbe csse bstV.sn Antionetts and Wslts' OS to suppo,t. It's my ,ecollection thst yOU ve,e in ths cou,t,oon thst dBY, io Q 11 12 13 that correct? 15 Q Can 1 asK whY yOU attended that hearing? 14 A YeS. WhY? 16 A YeS. Were YOU there -- 17 Q MR. O'BRIEN: Because she was ordered to. 18 MR. IMBLUM: Under subpoena? I'm trying to 19 20 remember. Off the record. 21 ,DlscUSeion ues held off the ,eco,d.' 22 BY MR. IMBLUM: would YOU have attended the hearing if YOU 23 Q 24 weren't subpoenaed to testifY? MR. IMBLUM: Off the record again. 25 """ . "". ..',..,~ """, .... .... ~. ,.." .. ." .. "'" "'..""...' .........." I '-' ... '\ " C) 14 15 16 17 18 19 20 21 22 23 [' ...., - ,. ;.-", 35 1 (Discussion was held off the record.) 2 BY MR. IMBLUM: 3 Q Were you subpoenaed to testify at the hearing 4 on December 8th? 5 A No. 6 Q Why did you attend the hearing on December 8th 7 of '94? 8 A I believe an attorney asked me to go. Mr. 9 O'Brien asked me to go. 10 Q Did you attend simply because Mr. O'Brien 11 asked you to go? 12 A Yes. 13 Q Was there any other reason that you attended? A Absolutely none. MR. IMBLUM: I have no other questions. (The deposition was concluded at 2:05 p.m.) ( STATE OF PENNSYLVANIA SS. 24 COUNTY OF DAUPHIN 25 \_j GEIGER A LORIA REPORTING SERVICE. 2400 PARK DR, SUITE D. HOG, PA 17110 717'!54H!li08 OR "800'222'41517 , !-.. 36 .- i 1 I, Ellen Swayze Reisser, a Reporter 2 Notary-public, authorized to administer oaths within and for 3 the Commonwealth of Pennsylvania and take depositions in the 4 trial of causes, do hereby certify that the foregoing is the 5 testimony of ARLENE A. GALLA. 6 I further certify that before the taking of 7 said deposition, the witness was dulyswornj that the 8 questions and answers were taken down stenographically by 9 the said reporter Ellen Swayze Reisser, a Reporter 10 Notary-public, approved and agreed to, and afterwards 11 reduced to typewriting under the direction of the said 12 Reporter. ') " 13 I further certify that the proceedings and 14 evidence contained fully and accurately in the notes by me 15 on the within deposition, and that this copy is a correct 16 transcript of the same. 17 In testimony whereof,I have subscribed my hand this .30~h~ aY~May, ~ ,I hereunto 9~ / 18 19 20 REPORTER 21 My commission expires: 22 June 26, 1995 23 24 GEIGER a LORIA REPORTING SERVICE. 2400 PARK DR.. SUITE p, HOG.. PA 17110 717'541>1!500 OR 1'000,222,41577 .....) 25 ',' . ~..~ . INCOME AND EXPENSE STATEMENT OF t+ fLL (;Not C:, (\-t-l-t'r SSN ~..:::zQ.. a, c( Ru DR# DATE I'). \l,\~~ ,. I THIS STATEMENT MUST BE FILLED OUT (If you are self.employed or If you are salaried by a business of which you are owner In whole or In part, you musl also fill out the Supplemental Income Statement which appears on the last page of this Income and Expense Statemenl.) INCOME (a) Wages/Salary C ' C ('. Employer & Address LV VI p>61l.'-A-t-' 0 tSJ ;.J.- ?1:> LAlL1-VlNi' LIV'c-I,\Lu~~ Job Title/Description ~ Pay Period (weekIY,\llI'week!), monthly) Gross Pay per Pay Period .................................................................................................:.................. $ \;). b a . I (, Payroll Deductions: Federal Withholding ..................$ I:;~. u:!. Social Security ...........................$ '11 .0:>' I. Local Wage Tax ..........................$ I ") . c,~ ~ -/ Slate Income Tax .......................$ '.1~. \:) Retirement ......"..........................$ I :l.~ _ ,-" Health Insurance ........................$ I .. 9 n Other (specify) ............................$ .........................$ .........................$ '3 I. ~ S; Net Pay per Pay Period ........................................................................................................................ ~ ,"-'(" B. 88 'lfI/:J) (b) Olher Income Week Month' Year Interest/Dividends ......................$ $ $ Pension/Annuity .........................$ $ $ Social Security ...........................$ $ $ Rents/Royalties ..........................$ $ $ Expense Account .......................$ $ .. $ Gifts .............................................$ $ $ Unemployment Compensation .$ $ $ . Workmen's Compensation ........$ $_ $ StJ~?a"'T F~lu.~/o~l,'. . /iL{(,.3Z. Total, Other Income .......................$ $ -3'~ IS.'1.6 $ INCOME ANO EXPENSE STATEMENT OF I verify Ihallhe stalements modo In this Incomo and Expense Slale. ment are Irue and correct. I understand Ihal talse slalements herein are mado subjecl to Iho pcnallles 01 16 Pa.C.S. 4904 relating 10 unsworn lals IIcatlon to aUlho,llIes. ~ Oate:.f..,;l" ~ _ _ Pia nil 0 DRO #405 ,..~, '"f Household Child Household Child Week Week Month Month EXPENSES Home $~ Mortgage/Rent ........................................ $ $ $ Mal n tenance ........................................... $ $ $ lj 2.0, c:>t.> $ Utilities (telephone, heating ~~5 ,0('. electric, etc.) ........................................ $ $ $ $ Employment (transportation, lunches) ............................................... $ $ $ '.:2.0 . Q:.> $ Taxes Real Estate .............................................. $ $ $ 100,0" $ Personal Property................................... $ $ $~l .u9 $ Income' ..............................................~...... $ $ $ $ Insurance Homeowners ........................................... $ $ $ ;).9. 'II: $ Automobile ..............................'................ $ $ $ I f.,r.,. b7 $ Life/Accident/Health .............................. $ $ $ '30 . 00 $ Other ........................................................ $ $ $ $ Autom~blle (payments, fuel, o7't~.U. repairs) ................................................. $ $ $ ...,.... $ Medical Doctor, Dentist, Orthodontist................ 0 $ $ $ '1 0 . C1t> $ Hospital ................................................... ,0' $ $ $ $ Special (glasses, braces, etc.) ............... $ $ $ ;..5.<>0 $ Education Private, Parochial School....................... $ $ $ $ College ..................................................... $ $ $ 1!i .ou $ Personal Clothing ................................................... $ $ $ 7t;.oo $ Food ......................................................... $ $ $ 1'1,)".0":> $ Other (hoUsehold supplies, 3~L1o ba~ber, etc.) .......................................... $ $ $ $ Credit payments and loans .................... $ $ $ ';). S ~ , o() $ Miscellaneous Household help/child care ..................... $ $ $ $ Entertainment (Inc. papers, books, vacation, pay TV, etc.) ............ $ $ $ "70.0<-> $ Gifts/Charitable contributions .............. $ $ $ t',e .00 $ Legal Fees ......."...................................... $ $ $ I S c. . 00 $ Other child support/alimony payments ............................................. $ $ $ $ Other (specify) ............................................... $ $ $ ~D .uu $ Total Expenses ............................................. $ $ $ 3 (, ~1 .11 e $ , .~... ,," '. PROPERTY OWNED Checking Accounts ........ Description Value Ll/So $ $ ";)..~o~ $ $ ~ 1'J,2t:P_ $ 3/, 000 $ /1,,000 $ q~. cQC-> $ CAilS ."f"rT"'~ I ~:L II:.IVM 9,9IJ""'4) $.2:J..~ r-1I~_A1I<'/J,!t.\ I (j3.;M- $ 1.00 Q $ '.',.::0 g" I:> Ownership' H W J __ V'. --- -_-!L --- -\7- --vr --::::r - - ==v - - --r- - - -;:7 Coverage' H W C '-' II --.;- -V- - ITIT- ---v- IT - -;r tI = B. Attach to this statement a copy of the following documents relallng to the business, pror~sslon, partnership. Joint venture, corporation or similar entity. (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. Savings Accounts ........... ........... Credit Union .................... .................... !olIJru,IL 1,,(.. LIA hlllill;H( :raiN: :I:/ZA i./,7Yvl ~ D. Name and Address (If different than C) of accountant, controller or other person In charge of financial records: Slacks/Bonds .................. Real Estate ...................... Other ................................ ................................ Total, Property..................... INSURANCE Company ALII'; (" "'0:<' / (1..Jf 1~I'Eu) . 1 1 Policy No. Hospllal ........................... Medical............................ Health/Accident .............. Disability Income ............ Other (dental, etc.) .......... {)i:1,.'I1l .D~L- ('H . Husband, W. Wife, J . Joint, C. Child) .,. .,. SUPPLEMENTAL INCOME STATEMENT A. This form must be fllfed out by a person who (check one): ~ (1) operates a business or practices a profession; or _ (2) 15 a member of a partnership or Joint venture; or _ (3) 15 a shareholder In' and 15 salaried by a closed corporation or similar entity. C. Name and Address of business: Telephone Number E. (1) Annual Income from business ............................................................................................. S (2) How olten 15 Income received? ............................................................................................ S (3) Gross Income per pay period ............................................................................................... S (4) Net Income per pay period ......"..................................................".........."........"................. $ (5) Specific deducllonslf any .................................................................................................... $ \J OJ w 3 .J., 'J -..c AJ ,Q.. J J ~ ir. (() .~ \J' ~ I:'J \-- ~ 0 " .. ",i'1 1-' .. ..;:-..... IJ,'Cl ..:1 , )': "lI U.;r- :r: ,'):~ Po:' ' ~ l ~;I' U.. " -'~_I ,.J ~< c. : (; l-:'~ VI ~ (i,I.I, ...' ... ~ li\ 0: ',(i.l -< ( (I. .'_IU- T ....'l; '1 l), r- :3 .J ~ u u' r.) \l ul,j $0 't 1Il ..: ~ ..: fl< >0 'CH l'l e-o s:~ 0 z ~ '<l' Z " 0 lOCI ~ - .~ 0 ..: ..: m Z ~ w 0( U H H": . m 0 ~ z 0' ::a ~:j): .... H ~ 0( u ~ " .... e-o ~ !:Xl ~ ~ ~ I1l CI": . U u 0 w 0 > >- '1<1 I>:: CI., ..: Ii 0 III 0 H I>:: z Z 10 ~ I>:: III Z I1l '11l H z z e-o I1l ~ H e-o":e-o III H z ... I>:: ~ Hl1le-o m :> S .. P I1l ~zl1l . H 0 W 0 p.. I1lZ 0 U ~ ..I U U HH Z III ~ III 1>::0 Ii: ~ ::; I1l 1<1 ..:e-o II: ':I: 0 ~ 0( e-o u z H , . . ,: . . . . '. . .. . . , . .. '\ '. IN RE: WALTER GALLA ARLENE GALLA and ANTOINETTE J. M. GALLA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA : QS- S"IO Ci.....\ ~f1-~ : NO. ~56 ef 199<1 : CIVIL ACTION-LAW ORDER AND NOW, 'hi. fL~y of ~ ( , 1997 "POO ,"vlow ollhs Petition To Terminate Escrow, a Rule is issued upon the parties to show cause why the escrow account should not be delivered to Arlene A. Galla. SAID Rule-to-Show-Cause returnable ~ days from the date of service hereof. J. l' ,. . " ;' q V:~'.','\l,l\~'~\;?,:,\ \1.... ..-.' "'.J' ":\Ir;:] ~,. '(\II:\J U;J.... ,J t., I" '\1 lb lJ,U. .. Ndr:..'~" 1,.,., ',;.' ;~.;:O ~8UJl) mid , . '. '. , \ IN RE: WALTER GALLA ARLENE A. GALLA and ANTOINETTE J. M. GALLA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : 9S- S^,O c?i"t'( 'klL"'\. : NO. 05C af 19Q4 :CIVIL ACTION-LAW PETITION TO TERMINATE ESCROW 1) Petitioner is Robert L. O'Brien, Esquire, of 17 West South Street, Carlisle, Pennsylvania 17013. 2) Petitioner is one of three escrow agents involving the above captioned parties. Attached hereto is a copy of the escrow agreement. 3) Petitioner has proposed a division of the escrowed funds and has not been able to achieve a resolution that would provide for release of the funds. 4) Petitioner believes that the passage of two years should have been more than sufficient time to resolve the issue of the escrow. WHEREFORE, Petitioner requests that the Court issue a Rule upon the parties, to show cause why the funds currentiy in the escrow 10 wit $3,077.00 not be paid to Arlene A. Galla. Respectfully Submitted, O'BRIEN, BARIC & SCHERER B;~6~~ . Robert L. O'Brien, Esquire I.D.#28351 17 Wesl South Street Carlisle, Pennsylvania 17013 717-249-6873 '. I . '. .. -"" . ... .' " ' " , eSCROW AGREEMENT - rH .5 THIS AGREEMENT, made this Z" - day of f'}~ ,199;: by and between ARLENE A. GALLA, WAL TEA D. GALLA AND ANTIONETTE J.M. GALLA (hereinafter referred to as Arlene, Walter and Antoinette respectively) WITNESSETH WHEREAS, Court of Common Pleas of Cumberland County Pennsylvania on October 23, 1995 issued an Order in the case (If Arlene A. G:Jlla v. Waltar D. Galla, No. 95-0540 which is attached hereto and incorporated herein by reference. Said Order specifys, inter alia, that upon the sale of the marital residence of Walter D. Galla and Arlene A. Galla the proceeds of same shall be held in a joint escrow account with Attorneys of Antoinette J.M. Galla, Walter Galla and Arlene Galla as joint escrow agents; and WHEREAS, Gary J. Imblum, Esq. is the Attorney for Antoinette J. M. Galla, Robert L. O'Brien, Esq. is the Attorney for Walter Galla and Christopher C. Houston, Esq. is the Attorney for Arlene Galla. NOW THEREFORE. and in consideration of the mutual promises herein contained, and intending to be legally bound hereby the Parties hereby agree as follows: 1. Appointment of Escrow Agents. Arlene, Walter and Antionette hereby , " . ' . . ,. .' I , \ " appoint Gary J. Imblum, Esq., Robert O'Brien, Esq., and Christopher Houston, Esq., as Joint Escrow Agents. 2. Delivery of Escrowed Funds. Arlene and Walter have simultaneously with the execution of this Agreement delivered to the Joint Escrow Agents for deposit, funds in the amount of $3,077.00. 3. Release 01 Escrowad Funds. 'vVithdrawal from the escrow shall only be made upon the signature of the Joint Escrow Agents. The division of the Escrow Funds shall be in accordance with a Court Order or Agreement of the parties. 4. Expenses, All charges and expenses of the Joint Escrow Agents, if any, shall be paid from the Escrow Funds. C dIU.' 6-S NO~- 7".:> t::-x C f:5- 0 /1. [OIJ:'- f'~ 0'-: nJ.1T'~r- (N I rE:---, 2. lNp.. f'r. ;} II. ./'" 5. Limitation of Liability of Joint Escrow Agents. The Joint Escrow Agents shall act under this Agreement only as Joint Escrow Agents and shall not be responsible or liable in any manner whatsoever for the sufficiency, correctness, ganuiness or validity oi any instrument or signature thereon. 6. Indemnification of Joint Escrow Agents. Walter, Arlene and Antoinette jointly and severally agree to indemnify and hold the Joint Escrow Agents harmless from all suits, claims, actions, judgements. losses, liabilities, fees, costs, expenses, damages or other charges which may be imposed upon or incurred by the Joint .:.. . . Escrow Agents in connection with the performance of their duties hereunder except with respect to any of the foregoing incurred as the result of tho Joint' Escrow Agents' bad faith or gross negligence. 7. Notices. Notices hereunder shall be in writing, sent by messenger or by regular United States mail, postage prepaid, and shall ba considered as having been given upon receipt. All notices shall be sent to the respective parties at the address set forth below or at such other address as shall have been given in writing to each of the parties hereunder. Arlene A. Galla c/o Christopher C. Houston, Esq. 4 North Hanover Street Carlisle, Pa 17013 Walter D. Galla c/o Robert O'Brien, Esq. 17 W. South Street Carlisle, Pa 17013 Antionette J.M. Galla c/o Gary J. Imblum, Esq. 407 N. Front Street, Harrisburg. Pa 17108 8. Headings. The headings used herein are for convenience only and are not to be used in interpreting this Agreement. 9. Entire Agreement and Amendments. This Agreement contains the entire agreement among the parties hereto. Any agreement hereafter made shall be ineffective to change. modify, waiver, release. discharge, terminate or effect the ..-'-... I,. . abandonment of this Escrow Agreement, In whole or in part, unless such . agreement is in writing and signed by the party against whom enforcement of the change, modification, waiver, release, discharge, termination or the effecting of the abandonment is sought. , O. Termination. This Agreement shall terminate at such time as the Escrow Funds are no longer held by the Joint Escrow Agents as provided in paragreph three (3) above, at which time the Joint Escrow Agents shall be released, discharge, and acquitted of all obligations and liabilities hereunder and any claims or surcharges made by or on behalf of any party to this Agreement. 11. Counterparts. This Agreement may be executed in separate counterparts each of which shall be an original of this Agreement and which, when taken together. shall constitute the entire Agreement among the parties hereto. IN WITNESS WHEREOF, This Agreement has been duly executed as of the day and year first above written. WITNESS: ARLENE A. GALLA !~ &. ~ a.&-. WA'L TER D. GALLA ANTlONETTE J.M. GALLA WALTER GALLA ARLENE GALLA and ANTOINETTE J M GALLA I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 95-540 CIVIL TERM I I CIVIL ACTION - LAW RESPONSE OF ANTOINETTE J.M. GALLA TO PETITION TO TERMINATE ESCROW AND NOW, comes Respondent, ANTOINETTE J.M. GALLA, by and through her attorneys, Knupp & Kodak, P.C. and respectfully responds as follows: 1. Admitted. 2. Admitted. 3. Admitted. ., 4. Admitted in part and denied in part. The escrow proceeds should be distributed to Antoinette J.M. Galla due to the extremely large alimony arrearage owed to Antoinette J.M. Galla by Walter Galla. i , , , ' -/' I '.. ..-,-;:_ ~ < ,.. I.. " ... .', :' . . WHEREFORE, Respondent respectfully requests that the Court issue an Order distributing the escrow funds to Antoinette J.M. Galla. Respectfully submitted, DAK, P.C. fr By street 17108-1848 Datedl q- '-'I{: fl1 Attorneys for Respondent L.------/ .. CERTIFICATE OF SERVICE I, Gary J. Imb1um, Esquire, hereby certify that I have served a copy of the RESPONSE OF ANTOINETTE J.M. GALLA TO PETITION TO TERMINATE ESCROW on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Dauphin County, Pennsylvania addressed tOI ROBERT L O'BRIEN ESQUIRE 17 WEST SOUTH STREET CARLISLE PA 17013 CHRISTOPHER C HOUSTON ESQUIRE 4 NORTH HANOVER STREET CARLISLE PA 17013 Street .17108-1848 DATEDI--3 '7 ~ ~1 Attorney for Respondent , , ;:.J,' <, . . .,. ,-~,.... ~ . \ \ ". . ' , \ "\" . c.A. I' i: I I I. (' . ~) Co) C .oJ ",I ,- " "1; i , . ~ l !-.q li}j' .Cr 1 ',._ , .'! , .J ,t]"' '. l~ .!~ ,:V ,Cr' , i .'l) I;M"" .. ,1,\ '.-, , , '"H.' . . : . ~ ~j ;:.)111 ;.. .. :";:! :'.: ~J' ~~J ~.'. t" -~