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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF i[~~e PENNA,
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NANCY L. WILSON
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I ,95-767 CIVIL
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CHARLES E. WILSON
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DECREE IN
DIVORCE
AND NOW, ' .. .$,<:;'f? Tl::7 ,~c;-!.., \i....., )ql{l,2,QOll, ,
II is ordered and
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decreed that "" ,t:J~!'l,C:~ ,~.., ,I'!~ ~~,~~, , , , , . ,,', , , " , , , , " , , . " " plaintiff,
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are divorced from the bonds of matrimony,
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
There are no outstanding issues.
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NANCY L, WILSON.
Plnillliff
IN TJ IE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
vs,
NO, lJ5.110767 CIVIL
CIIARLES E, WILSON.
DelclIllnllt
CIVIL ACTION - LA W
IN DIVORCE
!'I{AECII'E TO 'mANSl\11T nECOIm
TO TIlE PIWTlIONOTARY:
Trnllsmilthe record. togelher wilh the following inliJrllllllioll. 10 Ihe cOllrllor enlr)' of n divorce
decree:
J. Ground for divorce: irrelrievllhle hrenkdowllunder Seelioll 3311I(c) .JJQ I (d)( I) of the
Divorce Codc, (strike out illnpplicnhle seclioll)
2, Date IInd manlier of service oflhe Complnint: Mnreh 10. 1995. hy certified mail nddressed to
the Defelldant.
3. Complete either paragraph (II) or (b),
(a) Date of exec uti 011 of the IIftidavit of cons en 1 required hy Seclion 3301(c) ol'lhe Divorce
Code: byPlnintiff: 09/01/00 ;byDelclldnnl: 09/01/00 ,
(h)( I) Dnte of execution of the IIf1idavit required by Section 3301(d) of the Divorce Code:
; (2) dnte of filing nnd service of the I'i,lintifl's aflidnvitupouthe respondent:
4, Relaled claims pending: no clnims were raised.
5. Complete either paragmph (a) or (bl,
(a) Dnle and manner of service oflhe notice of inlentionlolile pruecipe to trnnsmit reeord,n
copy of which is allached:
(h) Dale Plaintiffs Wniver of No lice in Serlion3301(e) Divorce was filed with the Prothonotary:
MAILED to Prothonotary on OU/05/00.
Dnte Defendanl's Wniver of Notice in Section 3311I(e) Divorce wns filed with the
ProthonoUlry: MAILED to Prothonot,ary on 9/05/00.
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Leonard Tlnlner, Esquire
Supreme Court 1.0. #06589
BOSWELL, SNYDER, TINTNER & PICCOLA
315 N. Fronl Street
PO Box 741
Harrisburg, PA 17108.()741
(717) 236-9377
Allomeys for Plaintiff
v.
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA.
NO. 9J-- tfc I 0 !--(}i...L .j M.-,l^-/
NANCY L WILSON,
PLAINTIFF
CHARLES E. WILSON,
DEFENDANT
: CML ACI10N - LAW
: IN DIVORCE
NOTICE TO .D.J<:FEND AND CM.IM RIGHIS.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are warned that If
you fall to do so, the case may proceed without you and a decree of divorce or annul-
ment may be entered against you by the Court. A judgment may also be entered against
you for any other claim or relief requested in these papers by the Plaintiff, You may
lose money or property or other rights Important to you, Including custody or visitation
of your children.
When the ground for divorce is indignities or Irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors Is
available in the Office of the Prothonotary, Cumberland County Courthouse, 1
Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this llst Is kept
as a convenience to you and you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and
your spouse. If you desire to pursue counseling you must make your request for
counseling within TWENTY DAYS (20) of the date on which you received this notice,
Failure to do so will constitute n waiver of your right to request counseling.
.
m:\h\famlly\ wilsou,dlv 2/9/95
Leonard Tlnlner, Esquire
Supreme Court 1.0, #06589
BOSWELL, SNYDER, TINTNER & PICCOLA
315 N. Front Street
PO Box 741
Harrisburg, PA 17 108.{174 1
(717) 236-9377
Allomeys for Plalnllff
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NANCY L. WILSON,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
v.
NO.
CHARLES E. WILSON,
DEFENDANT
CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW COMES the Plaintiff, Nancy L. Wilson, by her counsel, Leonard
Tintner, Esquire, and Boswell, Snyder, Tintner & Piccola, and complains of the
Defendant, Charles E. Wilson, as follows:
Comvlaint Under ~330J(c) or ~330J(d) of The Divorce Code
1. Plaintiff is Nancy L. Wilson, an adult individual curren11y residing at 506
Beacon Hill Road, New Cumberland, Cumberland County, Pennsylvania 17070.
2. Defendant Is Charles E. Wilson, an adult Individual, currently residing at
506 Beacon Hill Road, New Cumberland, Cumberland County, Pennsylvania 17070.
3, Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least 6 months previous to the filing of this
complaint,
4. Plaintiff and Defendant were married on March 1,1975 In Carbon County,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the
parties.
6. The parties separated in February, 1995.
7. Neither of the parties in this action is presently a member of the Armed
Services of the United States.
8, Plaintiff has been advised that counselling Is available and that Plaintiff
may have the right to request that the Court require the parties to participate in
counse\1ing, but avers that she does not require or request counselling.
9. The marriage is Irretrievably broken.
10, Plaintiff requests the Court to enter a Decree in Divorce
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving
the marriage between the parties.
COUNT I
Eau/Jab1e Distribution
11, Plaintiff incorporates the allegations of paragraphs I through 10 by
reference as if set forth at length herein.
12, During the course of the marriage, the parties have acquired numerous
-2-
items of property, both real & personal, which are held in Joint names and In the
Individual names of the parties hereto,
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure
by the Defendant, to equitably divide the property, both real and personal, owned the
parties hereto as marital property.
RESPECTFULLY SUBMITTED,
BOSWELL NYDER, TINTNER & PICCOLA
By:
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DATE: February 9,1995
-3-
NANCY L. WILSON,
PLAINTIFF
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO,
CHARLES E. WILSON,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I, Nancy L. Wilson, Plaintiff, hereby verify that the facts contained In the
foregoing Complaint In Divorce arc true and correct to the best of my knowledge,
Information and belief. I understand that false statements herein arc subject to the
penalties of 18 Pa.C.S.A, ~4904 relating to unsworn falsification to authorities,
DATE: ;) -(i -1>
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, NA CY L. WILSON
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Leonard TllIlner, Esquire
Supreme Court 1.0, #06S89
BOSWELL, SNYDER, TINTNER & PICCOLA
315 N. Frout Street
PO Box 741
Harrisburg, PA 17 IOS.o74 I
(717) 236.1)377
Attorneys ror Plaintiff
NANCY L. WILSON,
PLAINTIFF
IN TIlE COURT OF COMMON I'LEAS
CUMBERLAND COUNlY, PENNA,
v.
NO. 95-767 CIVIL TERM
CIVIL AcnON - LAW
IN DIVORCE
CHARLES E. WILSON,
DEFENDANT
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
COUNlY OF DAUPHIN
55,
I, Leonard Tlntner, Esquire, being duly sworn according to law, depose and say
that I am the attorney for Plaintiff, NANCY L. WILSON, and that I did mail a true and
correct copy of the Complaint in Divorce filed in the above matter, by certified mail,
return receipt requested, deliver to addressee only, CHARLES E. WILSON, on
February 14, 1995. to 506 Beacon Hill Road. New Cumberland, Pennsylvania, 17070.
receipt card attached hereto ns Exhibit "A."
'sw~orn to and subscribed
be re me this II day
\ of l~rLh ,1995,
h'~.LV-.--tT" J- Jv~c.\.,
NOT AR Y PUBLIC _
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Jlsromlll: r. 1;111'..., Ilov>I')' Public
Hon'I,I,"I'\1, 1'1. O'''P;'ln Cou;,tj'
~y c,,~'lhrlon E'P'rtlf :10". 21. 1~96
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NANCY L. WILSON,
PluintilT
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
"S.
NO. 95-00767 CIVIL
CIIARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VIT OF CONSENT
Pursuont to Pa, R,C.I', Rule 11)20,72
I, A Complllint in Divorce under Section 3301(c) of the Divorce Codc was liIcd on
Fcbruary 13. 1995.
2. Thc murriage of I'laintifi' and Defendunt is irretrievably broken and ninety days have
elapsed from the dale of filing nnd service of the Complain!.
3, I conscntto the entry ofa Iinnl Decree in Divorce eithcr aftcr service ofa Notiec of
Intcntion to Request Entry of the Decrce.
I verify thutthe statemcnts Illude in this Affidavit arc true and correct. I undcrstand that
false stlltelllcnts herein lire 11111de subject to the pcnlllties oflS I'll, C,S, Scction 4904 relating to
unsworn falsilication to lIuthorities.
09/01/00
DlIte
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N CY L'!jJILSON
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NANCY I., WILSON,
Plnintilf
IN TIlE COURT OF COMMON PLEAS
OF CW...IBERLAND COUNTY,
PENNSYLVANIA
'IS,
NO, 95-00767 CIVIL
CIIARLES E. WILSON,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO IU~QUEST ENTRY
OF A IlIVOnCE J)ECREF. UNnEn SECTION ~3111fc) OF TilE D1VOnCE COJ)~
I. I consent to the entry of a Iinal decree in divorce without notice,
2. lundcrstnnd thntlmny lose rights concerning nlil11ony, division of property, lawyer's
fees, or expenses if! do not claim them before a divorce is grunted.
3. I understand tlmtl will not be divorced untiln divorce decree is entered by the court
nnd tlmtn copy of the decree will be sent to me immediately nller it is tiled with the
Prothonotary ,
I verify thntthe statements mnde inlhis Al1idavitnre true nnd corrcet. I understand Ilmt
fnlse statemcnts hercin arc mnde subject 10 the penalties of ] 8 Pa, C.S, Section 4904 rclating 10
unsworn falsilication to nuthoritics.
09/01/00
Dntcd
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N~ Y. \ ILSON
NANCY L. WILSON.
Plnintiff
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
vs,
NO, lJ5-00767 CIVIL
CHARLES E, WILSON.
Delcndnnt
CIVIL ACTION - LA W
IN DIVORCE
AFFIDAVIT OF CONSENT
Pursunntto I'll. R,C,P, Rule IlJ20,72
I. A Complaint in Divorce under Section 3301(e) of the Divorce Code WlIS liIed on
February 13. 1995.
2. The mnrriage of Plaintiff und Delcndunt is irretrievubly broken lInd ninety duys huve
c1upsed from the date of filing und service of the Compluinl.
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3. I eonsentto the entry ofa tinal Decree in Divorce either'ulier service ofu Notice of
Intention to Request Entry of the Decree, .
I verify that the statements mude in this Afliduvitare true uml correct. lunderstund thut
lillse statements herein ure Illude subject to the penulties ofl8 I'u, C,S. Section 4904 relnting to
unslVorn fulsitieution to lIuthorities.
09/01/00
Date
~4, c6! tnk
CH/\ES E. WILSON
: I
NANCY I., WILSON,
Pluintiff
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
CHARLES E. WILSON,
Defendunt
NO, 95.()()767 CIVIL
CIVIL ACTION - LA W
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF TilE DlVOR~E ~ODE
I. I consent to the entry ofa Iinul decree in divorce without notice,
2. I understand thutll11uy lose rights eoncerni'ng ulimony, division ofproperty,luwyer's
fccs, or cxpcnscs if I do not claim thcm bcforc a divorcc is grunled,
3. I understund that I will not bc divorced until u divorce dccrce is entered by thc court
and that u copy of thc dccrce will be scnt to me immcdiutely ancr it is liIed with the
Prothonotary.
I vcrify IImt the statemcnts made in this Affidavit are true and correct. I understund that
falsc statcmcnts hercin arc made subject to the penal tics of 18 Pa, C.S, Section 4904 relnting to
unsworn falsilication to authorities,
09/01/00
Dated
C~A ~ cfJ {~j( '1.1 '"""
CIIARLES E, WILSON
NANCY L. WILSON,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHARLES E. WIL~bN,
Defendant
CIVIL ACTION - LAW
NO. 95 - 00767 CIVIL
19
IN DIVORCE
STA'rUS SHEET
DATE:
ACTIVITIES:
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NANCY L, WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, 95 - 767 CIVIL
CHARLES E. WILSON,
Defendant
IN DIVORCE
RE:
Pre-Hearing Conference Memorandum
DATE:
Monday, February 28, 2000
Present for the Plaintiff, Nancy L. Wilson, is
attorney Samuel W. Milkes, and present for the Defendant,
Charles E, Wilson, is attorney Michael L. Bangs,
This action was commenced by the filing of a
divorce complaint on February 13, 1995, raising grounds for
divorce of irretrievable breakdown of the marriage, The
parties will sign and file affidavits of consent and waivers
of notice of intention to request entry of divorce decree
prior to the hearing so that the divorce can be concluded
under Section 330l(c) of the Domestic Relations Code.
The complaint raised the economic claim of
equitable distribution. Although Mr, Grubb (wife's prior
attorney) mentioned that there was a claim for counsel fees
and costs, no pleading has been filed raising that claim.
There is no claim raised by either party for alimony.
The parties were married on March 1, 1975, and
separated February 12, 1995. There are three children of
the marriage, two of the children are emancipated and
counsel have indicated that the youngest son who is probably
a senior in high school is living with the father.
Wife is 46 years of age and resides at 494 Spruce
Road, New Cumberland, Pennsylvania, where she lives alone.
She has a bachelor's degree and is a school teacher in the
West Shore School District. Her annual gross income is
$51,000.00. Wife is directed to file an income and expense
statement within two weeks of the hearing to be scheduled.
She is currently paying child support to husband in the
amount of $400,00 per month. She is not receiving any
spousal support or alimony pendente lite from husband. She
has not raised any health issues.
Husband is 51 years of age and resides at 506
Deacon fli 11 Road, New Cumberl and, Pennsy1 vania, where he
lives, as previously noted, with the youngest son. fie is a
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high school graduate and has some college courses, He is a
business man and has owned some companies involving computer
and copy equipment and has sold those business and is
currently engaged in sales as an employee of the purchasers
of the bURlnesses. The name of the company with whom he
works is PennLantic Corporation. His net biweekly income is
$022,00. Husband has not raised any health issues.
Currently he is covered under wife's health insurance plan
with her employment; husband is able to pick up health
insurance coverage through his current employer but there
may be a cost to him and he should provide information as to
the cost of that coverage.
The parties own real estate as listed below and
counsel have stipulated to the values as stated after the
location of the property:
494 spruce Road, New Cumberland,
Pennsylvania
$ 09,000,00
Lot adjoining 494 Spruce Road,
New Cumberland, Pennsylvania
$ 27,000.00
506 Beacon Hill Road, New
Cumberland, Pennsylvania
$130,000.00
Lots 10 and lOA Ridge Road
Fairview Township
$ 70,000,00
The property at 494 Spruce Road, New Cumberland,
Pennsylvania, has a current lien against it of around
$51,000.00 (an updated payoff figure should be provided) and
the property at 506 Beacon Hill Road, New Cumberland,
Pennsylvania, has a mortgage lien of $70,000,00 and a line
of credit lien which is currently around $15,000.00.
Counsel for husband has indicated that husband had paid down
the line of credit loan to around $1,500,00 at time of
separation and since the separation wife has added debt to
that loan so that it is currently at an amount of
$15,000.00, Husband has been paying the mortgage and line
of credit. Wife has been paying the mortgage for the Spruce
Road property,
The parties had lent money to a Jon and Jane Owens
and husband received the payoff on those funds and applied
most of money to debt. He does acknowledge, however, that
$2,000,00 was left after payment of debt and he will agree
that that should be added as a marital asset. Wife on the
other hand, says that husband received the $25,000.00 and
all of those funds should be designated as an asset subject
.
to distribution, Husband will provide evidence as to how he
applied the monies to payoff debt from the payoff of that
mortgage.
The parties had listed on the pretrial statements
some vehicles and after looking at the value and lien
against the Firebird, the parties agree that the Firebird
and Buick have more or less equal value. Therefore, the
only issue apparently is the value of the 1982 Ford
Conversion van which husband says is worth $500,00 and wife
says is worth $1,500.00, There is also an issue raised
about a 1978 pickup truck which husband gave to his father,
Husband said that in his opinion the truck had a value of
around $500,00. If wife thinks that value is wrong, she
should establish evidence to show that the value of the
truck was more.
Husband acknowledges that he has a 1972 Pontoon
boat in his possession which has a value of $2,000.00.
Husband was the operator and owner of three
businesses during the course of the marriage, West Shore
Imaging Systems, Wertz Business Equipment, and the Copy
Store, Husband sold the businesses pursuant to an agreement
in 1998 for a value of $130,000,00. From the sale proceeds,
$96,239,22 was used to pay debt; the balance which husband
acknowledges is subject to equitable distribution, is being
paid to husband on an installment basis. Part of the
consideration of the sale of the business was that husband
would be able to retain employment with the purchasers. The
agreement specifically speaks to the compensation of husband
and apparently after October 2000 husband will be on a
strict commission payment for his services without the
benefit of any salary. It is noted, however, the that
commission arrangement only kicks in after the balance due
under the terms of the agreement is paid to husband. Mr,
Milkes does indicate that there is also a statement in the
agreement dealing with part of the income received by
husband designated as commission payments. Mr, Bangs'
income statement does not address any commissions but Mr.
Bangs indicated that he will check with his client to see if
any of the $990,00 biweekly gross amount stated involves the
payment or includes the payment of any commissions as
opposed to straight salary. Mr, Milkes points out that
there is also a dispute regarding the purchase of the three
businesses as noted, specifically that the Copy Store was
not included with the sale of the West Shore Imaging Systems
and Wertz Business Equipment business.
The pretrial statements list some checking
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accounts which were in the name of the businesses and
according to Mr. Bangs those accounts were turned over to
the purchasers.
Mrs. Wilson is raising an issue that apparently
has been a continuing problem in the resolution of this
case, namely, that husband sold the businesses without her
knowledge and that the amount that he received was not a
fair and reasonable sum. She believes that this
transaction was less than an arm's length transaction and
that the businesses should have been valued for considerably
more than husband received. To that end, Mrs, Wilson is
going to hire a business evaluator to attempt to establish
her position with regard to the value of these businesses,
We will schedule a separate hearing to hear the testimony of
the expert and any testimony that husband may want to offer
in response on a separate day and then schedule a hearing to
take the balance of the testimony on the remaining equitable
distribution issues.
The parties own a time-share in Florida with a
debt of around $5,000.00, Husband has been paying the debt,
Wife is of the opinion that the time-share is worth as much
as the debt that is owed. The problem, however, is that
neither party wants the time-share. Wife's position would
lead us to the conclusion that if it is worth the debt, then
husband can assume the debt, and wife gets credit for a
portion of the alleged value of around $5,000.00 based on
the percentage of distrihution ultimately applied. If the
property, however, has no value, then husband and wife need
to determine whether they should continue to make payments
on the outstanding debt. Conversely as opposed to wife
getting a value credited to her, if there is no value then
wife will be charged with a portion of the debt which
husband has assumed,
There is an issue with respect to household
tangible personal property and counsel have apparently
provided some lists to each othel, Some of the problem
involves who got what items of property and ultimately then,
of course, trying to determine the value of property that
each party received. The Master suggests that once the
parties can establish where the property is located they
should have the property appraised. Wife claims that
husband received $6,000.00 worth of tangible personal
property and husband says he got four items.
Wife is claiming that husband received tax refunds
from the filing of joint tax returns for 1994 and 1995.
Husband claims that he used that money in lieu of support
.
for the children and to pay debts. Wife's position is that
he should account for those funds and they should be put
into the assets of the marriage for purposes of
distribution.
Mr. Bangs has indicated that he will provide
a 1998 and a 1999 income tax return to wife from his client.
Mr. Bangs has requested in exchange copies of wife's 1998
and 1999 income tax returns,
Wife has a pension with PSERS and husband's prior'
counsel had the pension valued and that statement is
attached to Mr, Bangs' pretrial statement. There has been
some discussion as to that value's validity and Mr. Bangs is
going to discuss that issue with his client and may pursue
having another look at the value. There is also a question
raised by Mr. Bangs as to whether or not wife has any stocks
and bonds and Mr. Milkes has indicated that he is not aware
of any such assets, Mr. Milkes will provide Mr. Bangs a
copy of wife's current pension statement,
In order to keep this matter on track, the Master
is going to ask that Mr, Milkes provide to Mr. Bangs within
one month of today's date the name of his business evaluator
and that within two weeks of the hearing, which will be for
the purpose of hearing the business expert, Mr, Bangs should
have the written report in hand for his review.
A hearing to take the testimony of the expert is
scheduled for Monday, August 7, 2000, at 9:00 a.m. Notices
will sent to counsel and the parties,
E, Robert Elicker, II
Divorce Master
cc: Samuel W. Milkes
Attorney for Plaintiff
Michael L. Bangs
Attorney for Defendant
NANCY L. WILSON,
Plaintiff
IN THE COUR~' 01' COMMON Pl.EAS 01'
CUMOERLAND COUNTY, PENNSYLVANIA
NO. 95 - 767
vs.
CIVIL ACTION - LAW
CHARLES E. WILSON,
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING IIEAlUNG
'1'0: Nancy L, Wilson , Pla in tiff
Samuel W. Milkes , Counsel for Plaintiff
Charles E. Wilson , Defendant
Michael L. Bangs , Counsel for Defendant
You are directed to appear for a hearing to take
*
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the 7th day
of August ,2000, at 9:00 a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
BY/ ~1e(~r~
, ) f( l (, '\
/ ~rge E. Hofler, President Judge
Date of Order and
Notice: 2128/00
oy:
Divorce ~laHter
II' YOU DO NOT IIAVE A LAI'IYER OR CANNOT AFFORD ONE, GO TO 01<
TELEPHONE THE OFFICE ~;E'I' FORTH BEL0\1 TO 1'1 NO OUT 11HERE YOU CAN
GET LEGAl, HELl'.
Cil~lI\LI~LANIJ CllIINTY 1l,\I~ M;~;(}C 1 AT ION
:! I.II\EIlTY AVI,:NilE
CAIlI.I~il.l.:, 1',\ I-lOll
TFI,EPilllNI': ('11/) ;',\'1- llh"
* TESTIMONY WII,(, BE LIMITED TO TilE EXPER'r TESTIMONY AND TilE
OWNERSHIP 01' HUSBAND'S BUSINESSES,
.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Stroet
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Tracl .10 Colyer
Office Mnnager/Reporter
West Shore
697.0371 Ex\. 6535
August 11, 1999
William L. Grubb, Esquire
3105 Old Gettysburg Road
camp Hill, PA 17011
Michael L. Bangs, Esquire
302 South 18th Street
Camp Hill, PA 17011
RE: Nancy L, Wilson vs, charles E. Wilson
No. 95 - 00767 civil
In Divorce
Dear Mr. Grubb and Mr. Bangs:
By order of Court of President JUdge George E, Hoffer
dated August 4, 1999, the full-time Master has been appointed in
the above referenced divorce proceedings.
A divorce complaint was filed on February 13, 1995,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claim of equitable distribution. No
other economic issues have been raised in the proceedings.
I am going to assume that grounds for divorce are not an
issue and that the parties will either sign affidavits of
consent or have been separated for a period in excess of two
years. Based on that assumption, I am directing each counsel in
accordance with P.R.C,P. 1920.33(b) to file a pretrial statement
on or before Monday, September 13, 1999. Upon receipt of the
pretrial statements, I will immediately schedule a prehearing
conference with counsel to discuss the issues and, if necessary,
schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
I
.
I
I
I
Mr. Grubb and Mr, Bangs, Attorneys at Law
11 August 1999
Paqe 2
NOTE: Sanctions for failure to file the pretrial statements are
set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING
COUNSEL.
* FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE
MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING
VACATED.
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F"X 717-7JII.7,17'1
E~mail: 1Janh",IOl.w@palllllinc,cllll1
July 31, 2000
E. Robert Elicker, II, Esquire
Office of the Divorce Mastcr
9 North Hanover Strect
Carlisle, PA 17013
RE: Wilso/lI'. Wilso/l
No, 95-00767
Dear Mr, Elicker:
As a follow up to my telephone call with Tracy, enclosed YOll will find two Marriage
Settlement Agrcements signed by Mr. and Mrs, Wilson, As I indicated to Tracy on the phone, [
received a Petition to Withdraw as Counsel by Sam Milkes and a Rule to Show Cause and [
understand that that is finalized or is soon to bc finalizcd, Soon after receipt of the Rule to Show
Cause, [ received a call from Mrs, Wilson indicating she is representing herself.
[ understand that you willscnd an Order to the court relinquishing your jurisdiction of the
case and then we can proceed with the finalization of the divorce,
Very truly yours,
lU (1 J^ f) n 0 ~1 f?JUlM I. .
Mich~"L.~ - 07 LG~
wsc
Enclosures
cc: Mrs. Nancy L, Wilson
Mr, Charlcs E, Wilson
Sumucl W, Milkes, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
MICHAEL L, BANGS, ESQUIRE
302 SOUTH 18th STREET
CAMP HILL, PA 17011
I'
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Office of Divorce Master
9 North Hanover Street
Carlisle, Pennsylvania 17013
WILLIAM L. GRUBB. ESQUIRE
3105 OLD GETTYSBURG ROAD
CAMP HILL. PA 17011
Office of Divorce Master
9 North Hanover Streel
Carlisle, Pennsylvania 17013
WILLIAM L. GRUBB, ESQUIRE
3105 OLD GETTYSBURG ROAD
CAMP HILL, PA 17011
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NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
,.'
v,
: NO. 95-00767 CIVIL TERM
CHARLES E. WILSON,
Defendant : IN LAW - DIVORCE
,
,
, ,
I
,
i
I
I
PLAINTIFF'S 1)lmTRIAL STATEMENT
Nancy L. Wilson, Plaintiff, by and through her counsel William L. Grubb,
Esquire, hereby tiles this Pretrial Statement pursuant to Pa, R,C.P. 1920.33 and
respectfully states as follows:
MARITAL ASSETS VALUE DATE VALUE LIEN
1. 494 Spruce Road 1998 89,000,00 54,000,00
New Cumberland 13,000.00
renl property
2. adjoining lot to 1998 27,000,00
494 Spruce Rond
real propcrty
3. 506 Beacon Hill Road 1998 130,000,00 70,000,00
New Cumberland 15,000,00
real property
4. Lots 10 and lOA Ridgc Rond 1998 70,000.00
Fnirvicw Township
renl property
5, Mortgage, Jon & Jnne Owens 2/29/95 24,549.95
Cumb, Co, Book 1247 Page 226
6, Wifc's PSERS pcnsion 1995 31,662,57
7. 1994 Pontine Firebird 1997 9,000,00 3,000,00
8, 1972 Pontoon Bout 1997 1,500,00
9. 1991 Buick
1997
5.400,00
10. 1982 Ford Conversion Vun
1997
1,500.00
II. West Shore Imuging Systems
sole proprietorship
1995
Undetermined
us of this dute
12. Wertz Dusiness Equipmcnt
sole proprietorship
1995
Undetermincd
us of this dute
13. Copy Store
Gettysburg, PA
sole proprietorship
1995
Undetermincd
us of this dute
14. Checking Account, WSIS
PA Stute Dunk
1997
10,000.00
IS. Checking Account, Wertz
PA Stute Dunk
1997
8,000.00
16. Checking Account, WSIS
1st Nutionul Dunk
1997
28,000.00
17. Checking Account, Copy Store
Finunciul Trust Bunk
1997
8,000.00
18. Florida time shure
1998
4,987.50
6,000.00
4,987.50
19. Personal Property in Husbund's 1995
possession
The parties have ugreed to uccept thc opinion of real estute ugcnt Craig A. Wilson,'
a person unreluted to the parties, us to the value of the real properties. A copy of his
opinion letter is attuched us Exhibit "A".
A copy of the Mortgage referred to in above Item 5 is attached us Exhibit "0".
NON-MARITAL ASSETS
Vulue
\. None
2
EXPERT WITNESSES
The PlaintifTmuy cull:
John A. Plesic
Denjamin Wooten, Wooten & Knissley
Thc Pluintiffrcscrvcs the right to cull udditionul cxpcrt witncsscs upon
rcusonublc noticc to Dclendant.
LAY WITNESSES
The Plaintiff may cull:
Nuncy L. Wilson, Pluintiff
Churles E. Wilson, Dcfendunt (us on cross cxuminution)
Larry L. Bixler, Jr.
Ronald Roseberry
Sally Plunk
Wandu Etnoyer
The Pluintiffreserves thc right to cull udditionul witncsscs upon rcasonublc
notiec to Defendunt.
The Plaintiff reserves thc right to supplement this stutement prior to trial.
EXHIBITS
Plaintiff intends to present thc following Exhibits:
I. Statement of value of real propcrty, attuehed as Exhibit "Au.
2. The business valuution once performcd. The business vuluution cannot be
completed until discovery hus been completcd regurding the various
business entities owned by thc purtics.
3. Depositions of Husbund.
4. Dcposition of Lurry L, Bixler, Jr.
5. Dcposition of Ronuld Roscberry.
6. llusbund's Fcdcrallncomc Tux rcturns lilr vurious ycurs.
7. Intcrrogutorics of Delendunt.
3
8. Mortgugc from Jon and Janc Owcns to Dclendallt.
Thc Plaintiffrcservcs thc right to introducc and use udditional cxhibits upon
rcasonable notice to Dcfendunt.
INCOME
As determined ut the March 5, 1999 support conlerencc, Ilusbund hus a nct
incomc of $1 ,757.57 per month und Wile u net income of $2,829.89 pcr month. Wife
however, contends thut Husbund's actual incomc is eonsidcrably grcatcr, und is dcrivcd
from busincss cxpensc uccounts.
Husband's stated unnuul ineomc has rcmaincd ut $24,740.00 sinec utlcust 1993.
Yct thc muritul busincss more thun triplcd in size from 1993 to 1997. Fedcral Incomc
Tux returns show an increase in gross receipts from $300,708.00 in 1993, to
$1,014,920.00 in 1997.
EXPENSES
Wife has submitted an expense report ut the support conferencc on March 5,
1999, and will submit an updated expense report ut the time of the prc-trial conference.
PENSION INFORMATION
The Plaintiffs pension account with thc Pcnnsylvaniu Public School Employces
retirement System is Iistcd as u marital asset.
Defendant has not discloscd any pension, annuity or retircmcnt type accounts as
of this date.
COUNSEL FEES
The Plaintiff claims counscl fees, costs and expenscs in that she lucks the
financial resources to conduct and maintain an adequate legal defense to this action.
Husband has, by his actions and inaction, refused to fully disclose the true nature and
value of assets. His conduct has been and continues to be vexatious and dilatory, and hc
hus engaged in bad. faith negotiations.
Husband has attempted to conccal the true naturc and extcnt of various marital
asscts under his control, and has wasted and dissipated marital assets. On or about
Oetobcr 22, 1998 Husband entered into an agreement to sell and transfer various marital
asscts, without thc knowlcdgc or consent ofWifc, forcing her to scck the protcction of the
Court und obtain a Temporary Order Restraining the Disposition of Property, to prevent
4
furthcr waste and dissipution of murital usscts. A copy of thc Ordcr is ullllehcd liS Exhibit
uCH.
Husband has control of the bulk of thc purtics' usscts, IInd thcreforc is in 11
position to frustrute thc Wifc's uttempts to resolvc this cuse U1nieubly, neccssituting hcr
use of legal counsclto pursue this matter through u master.
Thesc actions and inaction of Husbund huvc causcd unneecssury und undue Icgal
costs and cxpenses to Pluintiff. Pluintiff requests attorncy fces, costs und cxpcnscs bc
uwardcd to hcr for this action. Wife hus retained Icgal counsel ut un hourly.rutc of
$125.00 per hour and an itemizution of charges for services rendered und costs for thcsc
proceedings will be presentcd at the time oflriul.
DISPUTED ECONOMIC ISSUES
Valuutions of the various sole proprictorship business cntities both at datc of
separation and present date arc in dispute. Husbund entered into un agrcemcnt to sell
ccrtain assets for less than aetuul value, thereby contributing to thc wuste und dissipation
of murital assets.
Actual ownership and control of certain marital business entities, including The
Copy Store, remain with Husband. Husbund contends that he sold The Copy Store,
howcver the sworn deposition of one of the alleged owners indicates that it was not
purchased.
Husband contends thut all of the assets of the marital business entities, including
West Shore Imaging Systems, Wertz Business Equipment and The Copy Store, werc
transferred to Larry Bixler Ilnd Ronald Roseberry through their business entity, Pennlnntic
Corp. However, in the deposition of one of thc buyers, the buyer denies purchasing The
Copy Store and indicates that the only assets purchased were used vchicles, store fixtures
and the customer list.
Discovery us to the location and extent of the l11urital ussets is continuing, und a
complete and accurate valuation cannot be completed until there has been full disclosure
by Dcfcndant.
MARITAL DEBT
V AWE DATE
AMOUNT
I.
Busbess loan
First Union Bunk
1998
35,000.00
upproximatc
5
PROPOSED RESOLUTION OF ECONOMIC ISSUES
The Plnintiffproposcs the following resolution ofthc cconomic issucs:
To be distributed
to wife:
VALUE
1.
494 Spruce ROlld
Ncw Cumberland
rcal propcrty
22,000.00
2.
adjoining lot to
494 Spruce Road
real property
27,000.00
3.
Lots 10 and lOA Ridge Road
Fairview Township
real property
70,000.00
4.
Wife's PSERS pension
31,662.57
5.
Lump sum Cash payment
undetermined
To be distributed V AWE
to husband:
1. 506 Beacon Hill Road 45,000.00
New Cumberland
real property
2. 1994 Pontiac Firebird 6,000.00
3. I'ersonul property now in his 6,000.00
possession
4. Mortgage, Jon & June Owens 24,513.37
Cumb. Co. Book 1247 PlIgc 226
6
NANCY L. WILSON, : IN TIlE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 95-00767 CIVIL TERM
CIIARLES E. WILSON,
Defendant : IN LAW. DIVORCE
CERTIFICATE OF SERVICE
I, WILLIAM L. GRUDB, Esquirc, certify that I have servcd a copy of thc
forcgoing Pluintill's Pre-trial Stutemcnt on thc individuul listcd bclow by depositing the
sal11e in the Unitcd States Mail, First Class, postage prcpaid, ut CUl11p Hill, pcnnsylvaniu:
Michael L. Bangs
302 South 18th Street
Camp Hill, PA 1701 J
Date: )...tX 13 1'1<;'$
u
l j;L-rWp .{
Willial11 L. Grubb, Esquirc
3105 Old Gcttysburg Roud
CUl11p lIil1, PA 17011
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ALL TIIAr C&IlTMU h'ocl. of hnd l1utote in tho Dorough at Lemoyne,
County at Cumbnrland, Stole at PennlylYftnh. bounded nnd ducribnd
al CollowlI, to wlt.
--
UElrlQ lot. number 73 and 74 ln a plan of loti known 41 plon number
lhree, of florth Rivorton. PA, lhe aaid phn be1ng ncorded in tho
~ccordnr'a off1co tor Cumberlftnd County, pennlylvon1a, at Carlille,
in Deed Dook J, Volumo 4. Pago 40,' Said lata frontlno leventy (701
(eet on tho aouth aido of State Street. Said lot numbered 74 ..
fuclending back an even width, ana hundred and fifUen (1151 feet f
,narc or leu. to an aUey. Said lot numbered 73 extending bACk an
cvrm width, one hundred aod cleven (111) feet, marc or hu, to ao
aUny,
IIAVWG TlICnCOU [:neCTED a dwelling houae known a8 736 Statc Stroot"
L~maync. I'cnnllylvania.
DCING I'ART or Tile S^HE rACHISES which the Eatate of Kennath Kallar
and Charlt:tSE.WLlaon. by deed dated Dccembor 70 . 1991, and to be
rccordud in till! aeriC'1 of tha Rocorder of Do~tor Cumberland
County. grant ad ond conveyed unto Jon O~cn' and Jane Owen..
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LOAN DATA
Loan amount: $25,000.00
Annuallnlerest rate: 10,00%
ierm In years: 20
Payments per year: 12
First payment due: 111194
PERIODIC PAYMENT
Entered payment:
Calculaled payment: $241.26
CALCULATIONS
Use payment of: $241,26
1 st payment In table: 1
Table
AMORTIZE,XLS
TABLE DATA
Table starts at dale:
or at payment number: 1
Tile teble uses tile calcu/ated periodic payment amount
unless you enter a value (or "Entered payment",
Beginning balance at payment 1:
Cumulative Interest prior to payment 1 :
25.000.00
0.00
Payment Beginning Ending Cumulative
No. Date Balance Interest PrlnclDal Balance Into rest
1 1/1/94 25.000,00 208,33 32,92 24.967,08 208.33
2 2/1194 24.967.08 208,06 33,20 24,933,88 416,39
3 3/1/94 24.933.88 207,78 33.47 24.900.41 624,17
4 4/1194 24.900.41 207,50 33,75 24,866,66 831.68
5 5/1/94 24.866,66 207,22 34,03 24,832.62 1,038.90
6 6/1194 24.832,62 206,94 34,32 24.798.31 1,245.84
7 7/1/94 24.798,31 206,65 34,60 24.763,70 1,452.49
8 8/1/94 24.763,70 206,36 34,89 24,728,81 1,658,86
9 9/1/94 24.728.81 206.07 35.18 24.693,63 1,864,93
10 10/1/94 24,693,63 205,78 35.48 24,658.16 2,070,71
11 11/1/94 24.658,16 205,48 35,77 24.622,38 2,276,19
12 12/1/94 24.622.38 205.19 36,07 24.586.32 2.481.38
13 1/1/95 24,586,32 204.89 36,37 24.549.95 2,686,27
14 2/1/95 24.549,95 204.58 36,67 24,513.27 2,890.85
15 3/1/95 24,513,27 204,28 36.98 24,476.30 3.095.13
16 4/1195 24,476.30 203,97 37.29 24,439.01 3.299.10
17 5/1195 24,439,01 203.66 37.60 24,401.41 3,502,75
18 6/1/95 24,401.41 203.35 37.91 24,363,50 3,706.10
19 7/1/95 24,363,50 203.03 38,23 24,325.28 3,909.13
20 8/1/95 24,325,28 202.71 38.54 24,286.73 4,111.84
21 9/1/95 24,286.73 202.39 38.87 24,247.86 4,314,23
22 10/1/95 24,247.86 202,07 39,19 24,208.67 4,516,29
23 11/1/95 24,208.67 201. 74 39,52 24,169,16 4,718.03
24 12/1/95 24.169,16 201.41 39.85 24.129.31 4.919,44
25 1/1/96 24.129,31 201,08 40.18 24.089.13 5.120.52
26 2/1/96 24.089.13 200.74 40,51 24.048.62 5.321.26
27 3/1/96 24.048.62 200.41 40.85 24.007.77 5.521.67
28 4/1/96 24.007,77 200.06 41.19 23,966.58 5.721.73
29 5/1/96 23.966.58 199.72 41.53 23,925,05 5.921.45
30 6/1/96 23,925.05 199.38 41.88 23,883.17 6.120,83
31 7/1/96 23,883.17 199.03 42.23 23,840.94 6.319,86
32 8/1196 23,640,94 198,67 42.58 23,796,36 6,518,53
33 9/1196 23,798,36 196,32 42.94 23,755.42 6,716.65
34 10/1196 23,755,42 197.96 43,29 23,712.13 6,914.81
35 11/1196 23,712.13 197.60 43.65 23,668.47 7,112.41
36 12/1/96 23,668.47 197,24 44,02 23,624,46 7,309.65
37 1/1197 23,624.46 196.67 44.38 23,560.07 7,506.52
38 2/1/97 23,560.07 196,50 44,75 23,535.32 7,703.02
Page 1
AMORTIZE,XLS
39 3/1/97 23.535.32 196.13 45.13 23,490.19 7,899.15
40 4/1/97 23,490,19 195,75 45.50 23.444,68 8,094.90
41 5/1/97 23.444.68 195.37 45.88 23,398.80 8.290.27
42 6/1/97 23.398.80 194.99 46,27 23,352.54 8,485.26
43 7/1/97 23,352,54 194.60 46.65 23.305.88 8,679.87
44 8/1/97 23.305,88 194.22 47,04 23,258.85 8.674.06
45 9/1/97 23,258.65 193.82 47,43 23,211.41 9,067,91
46 10/1/97 23,211.41 193.43 47,83 23.163.59 9,261.34
47 11/1/97 23.163.59 193,03 48,23 23,115.36 9,454.37
48 12/1/97 23.115,36 192.63 48.63 23,066,73 9,646.99
49 1/1/98 23,066.73 192.22 49.03 23,017.70 9,839.22
50 2/1/98 23.017.70 191.81 49.44 22,968,26 10,031,03
51 3/1/98 22,968.26 191.40 49.85 22918.41 10,222.43
52 4/1/98 22,918,41 190.99 50.27 22,868.14 10.413,42
53 5/1/98 22.868.14 190.57 ' 50.69 22,817.45 10,603.99
54 6/1/98 22,817.45 190,15 51.11 22.766.34 10,794.13
55 7/1/98 22.766,34 189.72 51,54 22,714,80 10.983.85
56 8/1/98 22.714.60 169.29 51.97 22.662.84 11.173.14
57 9/1/98 22,662,64 188.86 52.40 22,610.44 11.362.00
58 10/1/98 22.610,44 188.42 52.84 22,557.61 11,550.42
59 11/1/98 22.557,61 187,98 53.28 22.504.33 11,738.40
60 12/1/98 22,504.33 187,54 53.72 22,450,61 11.925.94
61 1/1/99 22.450.61 187.09 54.17 22,396.44 12,113,02
62 2/1/99 22,396.44 186,64 54,62 22.341.83 12,299.66
63 3/1/99 22,341,83 186,18 55.07 22,286,75 12.485.84
64 4/1/99 22,286,75 185,72 55,53 22.231.22 12,671.57
65 5/1/99 22,231.22 185,26 56,00 22.175.22 12.856.83
66 6/1/99 22.175,22 184.79 56.46 22,118.76 13.041,62
67 7/1/99 22.118,76 184,32 56.93 22.061.83 13,225.94
68 8/1/99 22,061.83 183,85 57.41 22,004.42 13,409.79
69 9/1/99 22,004.42 183.37 57.89 21.946.54 13.593,16
70 10/1/99 21.946,54 182.89 58.37 21.888,17 13,776.05
71 11/1/99 21,888,17 182.40 58.85 21,829,32 13.958.45
Page 2
I \ " " ,'. ' ,t I. " ',', .' ",' ;', ' .." ~ ': . ~
NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767 CIVIL TERM
...-CHARLES E. WILSON,
Defendant
CIVIL ACTION LAW
IN DIVORCE
TEMPORARY ORDER RESTRAINING DISPOSITION OF PROPERTY
AND NOW, this I 'f (~ day of 'D~ u..,~ .\', 1998, the Pl~intiff having
filed a petition nnd verified that immediate nnd irreparable loss nnd damage may result to
her before the matter cnn be heard on motion, upon consideration of the Plt:intiffs
uttached petition, thc Defcndant, Charles E. Wilson, is hereby enjoined from transferring,
encumbering, concealing, selling, removing, disposing, or alienating nny business entity
or interest, personal property, or other marital property owned by them individually, or
nny form of co-ownership, or in any other person's or entity's name until further Order of
this Court. -tt l' J I
A l~tljQ./.u6-oT\ w~cll7cl- hl~ QJ.~LJ .s~6.t<=l. K>~ /I
6Pl1\Il)~CJ I w.;>JJ,::.J "y v.'c.71cd <-J,(( !:,<; \?C.tJ fl""~f 1
"2rtt.G ,'c'7...rs:{ J <!..,It,w p:u11 .
v BY THE COURT:
) t?(, -f;,' a1
(j .
TRU~ COpy FROM RECORD
In Te~i!rr:oio~' \~hGrC<1:, I haro unto SQl lilY hand
arn.1tho ~ici said C at Cclr1lskl, Pa.
Thl '../'I-~ !lilY, 19 OJ.--> :\
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IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NANCY L. WILSON.
I'I1Iintiff
CIVIL ACTION - LA W
CHARLES E. WILSON,
Delendant
NO. 95.0D767 CIVIL TERM
INCOME AND EXI)ENSE STATEMENT
OF
C/lAnLES E. WILSON
INCOME STATEMENT
I.
PcnnLlIntie Corp.
$990.00 bi-wcekly gross
(167.24) taxes
$822.76 bi-wcckly
TOTAL B1-WEEKLY INCOME
$822.76
(tpennLantic Corp. reimburscs Defendunt, on uvcragc. $576.00 monthly for milcuge cxpcnse)
MONTHLY EXI'ENSES
I-Iome
Mortgagc/Rcnt
Utilities
Scwer
Wutcr
Telcphonc
Ilcuting
E1cetric
$832.00
$186.42
$ID.OO
$38.00
$30.00
$56.42
$52.00
Employment (lrunsportlltion, lunches)
$20.00
Tnxcs
Rcul Estlltc, l'ersonalProperty und Income
$367.00 totul
I nsurunce
Autolllobilc, Ilolllcowncrs, Fire
$713.00 totlll
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,
Automohile
$215.00
Fucl
RCJl(lirs
$15.()()
$200.00
Pcrsonul
Clothing
Food
Othcr
BlIrbcr $15.00
Credit p(lYl11ents lInd 10(ln
$500.00/yeur
$280.00/l11ollth
$15.00
$50.00
Misecll(lneous
Entertuinment
PlIyTV
Gills/Charitablc Contributions
Lcgal fees
$50.00
$27.00
$20.00
$2,300.00
TOTAL MONTHLY EXPENSES:
$1,394.00
Rcs. pcctfully subl11ittcd, .' )
, /;-
IlAtJ!j{ 7 11 /
MICIIAEL L. BANGS
Attorney for Dclend(ln /
302 South 18th Strcct
Cump Hill, PA 17011
(717) 730.7310
Suprcmc Court ID 1141263
COMMONWEALTII OF PENNSYLVANIA
)
(
)
ss:
COUNTY OF CUMBERLAND
CHARLES E. WILSON, bcing duly sworn uccording to law. dcposcs and says thutthe
fncts sct forth in the forcgoing Ineol11c and Expense Statement are true and correct to the best of
his knowledge, infornlation and belicf:
CU~/JJ~
C. RLES E. WILSON
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,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-00767 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NANCY L. WILSON,
v.
CHARLES E. WILSON,
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
AND NOW, this Iq 1iray of March, 1999, withdraw the appearance of Johnson, Duffie, Stewart &
Weidner and KEIRSTEN W. DAVIDSON and DAVID W. DeLUCE, as attorneys for Defendant, Charles E.
Wilson, In the above-captioned action.
JOHNSON, DUFFIE, STEWART & WEIDNER
By:~LJ.01~..v...,
Kelrsten W. Davidson
David W. DeLuce
PRAECIPE TO ENTER APPEARANCE
AND NOW, this Iq 11::Lday of March, 1999, enter the appearance of Defendant, CHARLES E.
WILSON, pro se, in the above-captioned action.
By:-CLaJ.~!Jj PIJ~
Charles E. Wilson
:121244
~
~ERr/FICA IE OF SERVICf
i,
AND NOW, this 19th day of March, 1999, the undersigned does hereby certify that she did this date
serve a copy of the foregoing Praecipe to Withdraw Appearance and Praecipe to Enter Appearance upon the
other parties of record by causing same to be deposited In the United States Mall, first class postage prepaid,
at Lemoyne, Pennsylvania, addressed as follows:
,
I
[
I
William L. Grubb, Esquire
3105 Gettysburg Road
Camp Hili, PA 17011
JOHNSON, DUFFIE, STEWART & WEIDNER
By: G~b LJ ~ JJL,
Kelrsten W. 'Davidson
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NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMDERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 CIVIL TERM
CHARLES E. WILSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO WITIIDRA W AN APPEARANCE lllld TO ENTER AN APPEARANCE
TO THE PROTHONOTARY:
Pleasc withdraw my appearance as counsel of record for the above-captioned Plaintiff.
Date:
(
onard Tintner, Esquire
315 North Front Street
I-Iarrisburg, PA 17108-0741
TO THE PROTHONOTARY:
Please enter my appearance as counsel of record for the above-captioncd Plaintiff.
Respectfully,
Dalc: 7/, I(, {1/
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Willial11 L. Grubb, Esquire C)
3105 Old Gellysburg ROlld
Cllll1p I-lill, PA 17011
(717) 763-5580
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NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 CIVIL TERM
I'
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CHARLES E. WILSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO ENTER AN APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance as counsel of record for the above-captioned Plaintiff.
Respectfully,
Date: It Is-fen
WL- j! hlt
William L. Grubb, Esquire
J.D. # 72661
3105 Old Gellysburg Road
Camp Hill, PA 17011
(7 I 7) 763-5580
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NANCY l. WilSON,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND. . SS:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
vs.
CIVIL ACTION - lAW
CHARLES E. WilSON,
Defendant
NO. 95-00767 CIVil TERM
MOTION FOR APPOINTMENT OF MASTER
CHARLES E. WILSON ( 1 Plaintiff I X 1 Defundant moveR the court to appoint a (.!Iastar
with raspectto the following claims:
X ) Divorce
) Annulmant
) Alimony
) Alimony Pandenta lito
X ) Distribution of Proparty
) Support
) Counsel Fees
) Costs and Expenses
and In support of the motion states:
1. Discovery is com pi eta as to the clelms for which tho appointment of a Master Is
requested.
2. The Defendant I X ) has ( I has not appeared In the ectlon ( I personally ( X ) by
his attornay. Michael L. Bangs, Esquire.
3. The stetutory ground Is) for divorce (lsl lare): 3301 lei.
4. Check the appllceble paregraphls), by check mark:
) The action Is not contested.
) An agreement hes been reachad with raspectto the following claims:
(X ) The action Is contested with raspect to the following clelms:
Equitable distribution.
5. The action ( I Involves I X ) does not Involve complex Issues of law or fact.
6. The hearing Is axpected to taka one-half 11/21 days.
Date:
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7. Additional Information, If any, relavant to the motion: N/A.
fur ! ~
Attorney for Defendent
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
I'ENNSYLV ANIA
NANCY I.. WILSON,
I'lnlnliff
CIVIL ACTION - LAW
CHARLES E. WII.SON,
IJclendnnl
NO. 95-00767 CIVIL TERM
OIU>ER
AND NOW, this __:l..._f1'- duyof 4~, 1999, upon
eonsidcrutionofn Motillnlhr Appointmcnt of Mnster filed in this matter by Defendnnt, it is
herchy OlmElWD thnt E I!~~ ~c'4 ,Esquire, is appointed Master with
respcettothc l'i.l!lllwillg clnim(s): cquitnblc distribution.
BY TIlE COURT,
Johnson, Duffie, Stewart & Weidner
By: Keirsten L. Walsh
I.D. No. 78243
301 Market Street
P. O. Box 109
Lcmoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Defendant
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-767 CIVIL TERM
NANCY L. WILSON,
vs.
CIVIL ACTION - LAW
CHARLES E. WILSON,
IN DIVORCE
Defendant
PRAECIPE TO ENTER APPEARANCE
AND NOW, this j j'ilJ day of August, 1997, enter the appearance of the undersigned on behalf
of the Defandant, Charles E. Wilson, In the above-captioned action.
JOHNSON, DUFFIE, STEWART & WEIDNER
BV:~tNi17vJ yj ul~
Kelrsten L. Walsh
:155995
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NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMDERLAND COUNTY, PENNSY.LVANIA
v.
: NO. 95-00767 CIVIL TERM
CHARLES E. WILSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF
INTERROGATORIES TO DEFENDANT
TO THE PROTHONOTARY:
Please be advised that on July 23, 1997, an original and two
copies of the Interrogatories of plaintiff, Nancy L. Wilson, were
served upon defendant, Charles E. Wilson, 506 Beacon Hill Road,
New Cumberland, PA 17070, by First Class, certified, return
receipt, u.s. Mail.
Respectfully,
Date: ~z3/?1
j~l~
William L. Grubb, Esquire
1.0. # 72661
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
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NANCY L. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this the
'[57 Ii
day of
oj oL.~r
, 1998, it
is Ordcred that a hcaring on the PlaintiIT's Petition For Special Rclief shall be held on
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a.m.~'ln Court Room
, 1998 at . .j'" (,(,)
I , Cumberland County Court 1.louse, Carlisle, Pennsylvania.
.
BY THE COURT
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NANCY L. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this the
duy of
, 1998, upon review of the
Plaintiffs Petition for Special Relief, it is hereby Ordered and Decrecd that:
a) Defendant Charles E. Wilson shall cause the payments to the equity loan
with PA State Bank which encumbers the plaintiffs residence to be made current and
kept current until such time as the Equitable Distribution Count is resolvcd through a
Property Settlement Agreement entercd into by the partics or until further Order of the
Court.
..
b) Defcndant Charles E. Wilson shall cause the payments to the equity lonn
with PNC Bank which cneumbers thc dcfendant's rcsidenee to bc made current and kept
current until such time as thc Equitable Distribution Count is rcsolvcd through a Property
Settlement Agreement entercd into by thc parties or until further Order of the Court.
DY THE COURT
J.
NANCY L. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this the
day of
, 1998, upon review of the
Plaintiffs Petition for Special Relief, it is hcreby Ordered and Decreed that
is appointed Tl1lstee to operate, oversee nnd manage
the sole proprietorship known as West Shore Imaging Systems, and to operate the marital
business in trust for the benefit of the plaintiff and defcndant, nnd that the trustee is
Ordered to bring and keep the second equity loans which encumber both of the marital
residences current, until such time as the Equitable Distribution Count is resolved through
a Property Settlement Agreement entered into by the parties, or until further Order of the
Court.
BY THE COURT
J.
NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S PETITION FOR SPECIAL RELIEF
AND NOW comes Nancy L. Wilson, by and through her attorney, William L.
Grubb, Esquire, and seeks special relief to preventthc waste dissipation of marital assets
and avers the following:
1. Nancy L. Wilson, plaintiff, resides at 494 Spruce Street, New Cumberland,
PA 17070, Fairview Township, Pennsylvania.
2. Charles E. Wilson, defendant, resides at 506 Beacon Hill Road, New
Cumberland, PA 17070.
3. Title to the real property and dwelling at 494 Spruce Street, Fairview
Township, York f:ounty, is held by plaintiff and defendant as tenants by the entirety.
4. Title to the real property and dwelling at 506 Beacon Hill Road, New
Cumberland, Cumberland County, is held by plaintiff and defendant as tenants by the
entirety.
5. The plaintiff filed a Complaint in Divorce under S3301(c) or S3301(d) of
the Divorce Code, with a count for Equitablc Distribution, to the above caption and
number.
6. The propcrty at 494 Spruce Road is occupied by the plaintiff and is
encumbered by a first mortgage to National City Mortgage, of which the paymcnts are
current and are made by the plainti ff.
7. Thc plaintiff and defcndant caused the property at 494 Sprucc Street to be
encumbered by an equity loan by PA State Bank, for the use and benefit of their busincss
venture and murital assct, Wcst Shore Imaging Systcms, a sole proprietorship.
8. Defendant, through West Shore Imaging Systcms, had been making the
paymcnts on the cquity loan with PA State Dank, which encumbers plaintiffs residence.
9. Defcndant has not caused the paymcnts to be made for the last two months
on the equity lonn with PA State Dank.
10. P A State Bank has notificd plaintiff that the loan is in default and that
foreclosure proceedings will begin Novcmber 2, 1998, against the property at 494 Spruce
Street, the residence ofthe plaintiff.
il. Foreclosurc will cause substantial hardship to the plaintiff in that she will
be dispossessed of her place of residence.
i2. Foreclosure will cause dissipation and waste of the marital assets.
13. Thc property at 506 Beacon Hill Road is occupied by the dcfendant nnd is
encumbered by a first mortgage to Harris Savings Bank, of which the payments are
current and are made by the defcndant.
i4. The plaintiff and dcfendant cuused thc property at 506 Beacon Hill Road
to be cncumbercd by an equity loan by PNC Bank, for the use and benefit of their
business venture and l11arital properly, West Shorc Imaging Systems, a sole
proprietorship.
15. Defendant, through Wcst Shore Imaging Systcms, had bcen muking the
payments on the cquity loan with PNC Bank, which encumbers defcndant's residence.
16. Delendunt, through Wcst Shorc Imaging Systems, hus not caused the
paymcnts to bc l11adc for the last two months on thc equity loun with PNC Dank.
17. Dcfcndnnt's continued Ihilurc to makc loun payments places the loan in
jeopurdy of defuult, and potentiul forcclosure procccdings.
18. Foreelosurc will cause dissipation and waste of the marital asscts.
19. , Defendant continues to control the marital business known as West Shorc
Imaging Systcms, to the cxclusion of the plaintiff.
20. The actions of the dcfendant, or luck thereof, in keeping the loans for West
Shore Imaging Systems current, is causing waste and dissipation of the marital asset
known as West Shore Imaging Systems.
WHEREFORE thc plaintiff prays this Honorable Court to Order the defendant to
bring the equity loans current and to continue to kecp the loans currcnt until such time as
the Equitable Distribution Count is rcsolved through a Property Settlement Agreement
entered into by the parties or until further Order of the Court, or;
IN THE AL TERNA TIVE, the plaintiff prays this honorable Court to Order that a
trustee bc appointed to operatc, oversec and manage thc sole proprietorship known as
West Shore Imuging Systcms, und to opcrutc thc marital business in trust for the benefit
of the pluintiff and defendant, und that thc trustcc be Ordercd to bring and keep the
aforcmentioned cquity louns currcnt.
Rcspeetfully submitted,
J~\00. !?b~U,
Date: I_I
tl{"l~
William L. Grubb, Esquire
Attorney for the Plaintiff
3105 Old Gettysburg Road
Campl-IilI,PA 17011
(717) 763-5580
VEIUFICATION
I veri fy that the stutcments made in this document arc true and correct.
understund that fulsc statements hercin arc l11ude subject to penulties of 18 Pa. C.S. ~
4904, relating to unsworn fulsification to authorities.
./
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NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDA VIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMDERLAND
I, WILLIAM L. GRUBB, Esquire, being duly sworn according to law, depose and
say that lam the attorney for the plaintiff, and that I did mail a true and correct copy of
the plaintiff's Petition for Special Relief, filed with the Prothonotary to the above caption
and number this day, to the individual listed below, attorney for the Defendant, by
depositing the same in the United States Mail, First Class, postage prcpaid, at Lemoyne,
Pennsylvania:
Keirsten L. Davidson, Esquire
JOHNSON, DUFFIE, STEWART & WEIDNER
P.O. Box 109
Lemoyne, PA 17043-0\09
Datr: lojZ7/tjg
.
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William L. Grubb, Esquire
3 I 05 Old Gettysburg Road
Camp I-lill, PA 17011
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
On this, the7.:/'!>- day of OC'T{jt;([( , 1998, before me the undersigncd
officer appeared William L. Grubb, known to me (or satisfactorily proven> to be the
person whosc name is subscribed to the within instrument, and acknowledged that he
exceuted the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set I11Y hand und official scal.
:.rcJ;'Ikl.'?J /f vtdt
otar)' Public
Nolorlol 5001
Susan M. Grubb. Nolory Publlo
Lowo, AI/on Twp,. Cumborlond County
My Commission E,plros Juno 21, 1099
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NANCY l.. WIl.SON.
Pluinliff
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
)
)
)
)
)
)
)
NO. 95-00767 CIVIL TERM
CIVIL ACTION - LAW
CHARLES E. WILSON,
Dctenuant
I'J{E-TIUAL STATEMENT IN ACCOIWANCE WITH I'll. RC,I', 1920.33(b)
1. LIST OF ASSETS
Vuluc
Date of Valuation
u)
506 BClleonllill Roau
New Cumbcrlunu, PA
$130,000.00
Currcnt
b)
494 Spruec Rouu
Ncw Cumbcrlund, PA
$89,000.00
Current
c)
Lot lIdjoining 494 Spruce Roau
Ncw Cumberland, PA
$27,000.00
Current
d)
Lots 10 unu lOA, Ridgc Rouu
Fairvicw Township
$70,000.00
Currcnt
c)
Wifc's pension
$31.662.57
02/10/95
I) Husbunu's formcr busincss $130,000.00 as of datc OfSlllc
Wcst Shorc Imuging Systcms lInd Octobcr, 1998
relatcd cntitics
(tnote that $96,239.22 ofprocccus havc bccnuscd to puy vurious ucbts ussociatcd
with business unu personul dcbt)
g)
Husband's 1994 Fircbiru
Unknown
h)
Wilc's 1991 Buick
Unknown
i)
Timc-shurc in Floriuu
Unsalcnblc
"'lIi()~ "'r..nl"llf"tr.MtNTIU'm~mU 1n.I""tll~K If
j)
Ilousehold goods and Iilrnishings
Unknown (proposul is to
dividc those in kind)
Non-Muritnl Portion
Licns or EnclImbranccs
n)
Nonc
mortguge - $70,000.00 to Hurris
sccond mortgage - $14,000.00 (npprox.)
(husbund hud puid sccond mortguge down to
$1,500.00; Wife uccessed this account two
times: first in Muy or Junc, 1999, second in
last two wecks rcsulting in current balance
. now of approximutcly $ I 4,000.00)
b)
mortgngc - $50,000.00
Nonc
e) None
d) Nonc
e) Nonc
f)
Dcbts totaling $96,239.22 have been paid
from the proceeds of the salc
Nonc
g)
h)
i)
None
Unknown
None
Unknown
None
current debt owcd is $4,987.50
j) Nonc
2. EXPERT WITNESSES
Nonc unlieiputcd.
3. WITNESSES
Churles E. Wilson
Nnncy L. Wilson
Larry Bixlcr, Jr.
"iIUOHt1tr..nllUUAI1:MtNTISt.lIUUlI'IIIO.I_tll'"''
i,
4. EXIIIIIITS
Ifno stipulation can bc reaehcd as to thc cxhibits. thc cxhibits will bc thc various documcnts
conccrning vuluutions ofthc propcrty which will includc uppruisals to documcnt the vuluulions
us Iistcd.
5. INCOME STATEMENT
Sce scpurutc doeumcnt.
6. EXPENSES
Sce sepurutc document.
7. I'ENSION INFORMATION
Providcd ubovc.
8. COUNSEL FEES
No c1uim.
9. PERSONAL J>ROI'ERTV
Dclcndant hopes to dividc thut in kind.
10. MARITAL DEBTS
Husband will prescnt a numbcr of marital dcbts that wcrc puid through thc procccds of the loun.
Additionully, Husbund continucs to puy the til11c-share dcbt which hus an outstanding bulunce of
$4,987.50. Husband ulso puid olTthcir child's school loan in thc amount 01'$2,600.00, and
maintaincd puymcnts onthc timc-shurc sincc scpnrutiou (thc scpurntion bulancc was
approximutely $7,537.84). Additionally, Husband hus paid taxes onthc Ridge Roud lots und will
scck cither repuYl11cnt of thosc or considcration of thosc in thc ultimatc distribution.
11. PROI'OSED RESOLUTION OF ECONOMIC ISSUES
Husband proposcs thut hc rctuin thc procccds Irol11thc sulc of thc busincss as wcll us the housc
that hc is rcsiding inut 506 BCllcon I I ill Roud, New Cumberland. Pcnnsylvunia. Wile should
rctuin thc rcsidcnce ut 494 Sprucc Roud, Ncw Cumbcrlund. us \Vcllus thc lIdjoining lot on Sprucc
Road. Shc should also rctain hcr pcnsion. Thc remuining lots should bc sold lInd the procccds
should bc split such as to cflectuatc u 60-40 split inlhvor of lIusbund, tuking into considerution
thc debts that hc is responsihlc lor und thc til11c-shurc. und the othcr debts hc has puid. Husband
YtlunN f"Ill!.tIlIAl. IrAnMrmil"" "'llfl.ltI.I....111\~ If
thinks this resolution is uppropriutc since hc eurns less tlllln Wile ulld hc hus custody llfthc
parties' minor child.
Rcspcctfillly submittcd.
/1/1,;()
MICIII\EL L. ANGS
Attomcy lor Dcfendunt
302 South 18th Strcet
Camp I-I ill , PA 17011
(717) 730-7310
Suprcmc CllurtlD 1/41263
, .
VfIUUNnr..llllA1.nAIUIl-HIIU'IU.t1UJl.llll,",1H'~ IJ
CERTIFICATE OF smVICE
II-IEREBY CERTIFY thut ( huvc this duy scrvcd thc lilrcgoing I)cfentlllnt's PrcTrill1
SllItemcnt hy depositing II copy of sUlnc in thc Unitcd Statcs l11uil, postagc prcpuid, at Camp
Hill, Pennsylvaniu. addrcsscd to the lilllowing:
Willium L. Grubb, Esquirc
3105 Old Gcttysburg Road
Cump Hill, PA 17011
DATE:
r
L ( I (lb ( c
WENDY S. CI1IESBRO
Paralcgul "
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GP
PENSION APPRAISERS INC.
P.O. Box 4396 · Allentown, PA 18105-4396
1-800-447-0084 · Fox 610-770-9342
E-MAIL: pcnapp@pcnslonappraisers.eorn
WWW: http://wIl1v.pcnslonapprolsers.eom
January 9, 1998
rReCiElVED
JAN 1 5 1998
JOI",..O
to....... . 1'0 ~
'-'.:;VIM/'r I'~D' D~FFIE
I I IH:IDNEn
Kelrsten L. Walsh, Esq.
PO box 109
Lemoyne, Pennsylvania 17043-0109
RE: Present Value of Nancy L. Wilson's Defined Pension
Benefit . File No. 01-06-98-033-0033B
Dear Attomey Walsh:
We have determined the present value of Nancy L. Wilson's defined pension
benefit by the PBGC Actuarial and Mortality Table Method as of
February 10, 1995 to be $31,662.57. ThIs calculation was derived from the
. followIng data:
BIRTH DATE: December 20, 1953
SEX: Female
MARRIAGE DATE: March 1, 1975
VALUATION DATE: February 10, 1995
PENSION PLAN: PA Public School Employees Retirement System
DATE EMPLOYMENT STARTED: February 1, 1981
(Assumed date pension holder began partIcipation In the plan)
DATE BENEFITS STOPPED ACCRUING: February 10,1995
(Assumed date pension holder ended participation In the plan)
ASSUMED DATE MARRIAGE ENDED: February 10,1995
AGE WHEN BENEFITS COMMENCE: 62 Years
"Valuators of Defined Pension Benefits for Equitable DistrIbution"
. PBGC Actuarial and Mortality Tables Method
January 9, 199B
Nancy L. Wilson - 01-06-9B-033-00338
Page 3
REDUCTION FOR NON.VESTING: 1.0000
Represents a reduction for the probability of service to 100 percent
vesting as equal to the portion already completed.
REDUCTION FOR MARITAL COVERTURE FRACTION: 1.0000
Represents that portion of the value of the beneflts attributable to
the marriage. The numerator of the fraction represents the total
period of time the pension holder participated In the plan during
the marriage and the denominator Is the total period the pension
holder participated in the benefits program.
Reduction for Non-vesting:
Reduction for Marital Coverture:
$ 31,662.57
x 1.0000
PRESENT VALUE BEFORE REDUCTIONS:
x 1.0000
VALUATION FOR EQUiTABLE DISTRIBUTION:
$ 31,662.57
.'...~~"....~,...~,.,..,.
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NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO WITHDRAW PLAINTIFF'S PETITION FOR SPECIAL RELIEF
To The Prothonotary:
Please withdraw thc Plaintiffs Petition for Special Relief filed on October 27,
1998, to the above caption and number.
Respectfully submitted,
lJ~~.L.
Date: Ibl20 I Cj e,
William L. Grubb, Esquire
Attorney for the Plaintiff
3105 Old Gettysburg Road
CmnpHilI,PA 17011
(717) 763-5580
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NANCY L. WILSON,
Plaintiff
CHARLES E. WILSON,
Defendant
NO. 95-0767 CIVIL TERM
ORDER OF COURT
AND NOW, this 30tt-day of October, 1998, a Praecipe To Withdraw Plaintil1's
Pctition for Special Rclief having bcen filcd on October 30, 1998, the hcaring prcviously
scheduled for Novcmber 2, 1998, is CANCELLED.
BY TI-IE COURT,
William L. Grubb, Esq.
3105 Old Gettysburg Road
Camp Hill, PA 17011
Attorney for Plaintiff
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Kcirsten Davidson, Esq.
David DeLuec, Esq.
301 Market Street
Lcmoyne, PA 17043
Attorneys for Defendant
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NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON, CIVIL ACTION - LAW
Defendant IN DIVORCE
TEMPORARY ORnER RESTRAINING mSPOSITION OF PROPERTY
AND NOW, this , 'tIt.. day of f)cu.....[" /f, 1998, the Plaintiff having
filed a petition and verified that immediate and irreparable loss nnd damage may result to
her before the matter can be heard on motion, upon consideration of the Plaintiffs
attached petition, the Defendant, Charles E. Wilson, is hereby enjoined from transferring,
encumbering, conecaling, selling,. removing, disposing, or alienating any business entity
or interest, personal property, or other marital property owned by them individually, or
any form of co-ownership, or in any other person's or entity's name until further Order of
this Court. 1/ j
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NANCY L. WILSON,
Plaintif f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORnER
AND NOW, this the
day of
_' 1998, it
is Ordered thut a hcaring on the Plaintiffs Petition to Prevent Disnosition of Proncrtv
shall be held on
,199_at
a.m.lp.m.
in Court Room
, Cumbcrland County Court Housc, Carlisle, Pennsylvania.
BY THE COURT
J.
NANCY L. WILSON,
plaintiff
IN THE COURT Or COMMON PLEAS Or
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
IIETlTION TO PREVENT DISPOSITION OF MARITAL II\tOPERTY
AND NOW comes Nancy L. Wilson, by and through her attorney, William L.
Grubb, Esquire, and seeks special relief to prevent thc wastc dissipation of marital assets
and avers thc fol1owing:
I. Plaintiff is Nuncy L. Wilson, an individual rcsiding at 494 Spruce Strcet,
New Cumberland, I' A 17070, Fairvicw Township, York County, Pennsylvania.
2. Defendant is Charles E, Wilson, an individual residing at 506 Bcaeon Hill
Road, Ncw Cumberland, Pennsylvania.
3. Plaintiff and Defcndant are husband and wife, having been married on
March I, 1975, in Carbon County, Pennsylvunia.
4. Plaintiff tiled a Compluint in Divorce under S3301(c) or s331(d) of the
Divorce Code, to the abovc caption and number on Fcbruury 13, 1995. Said Complaint
includes u Count for Equituble Distribution ofthe muritlll assets.
5. Plaintiff and Defendant, as tcnants by the cntircties, arc thc owners of
prcmises und dwellings at 494 Spruce Strcet, Fairview Township, York County, 506
Beacon Hill Road, Ncw Cumberland, Cumberland County, and a certain lot locatcd on
Ridgc Roud, Fairview Township, York County, and the contents of thereof as murital
property.
6. At the timc of separation, husbund and wifc owned, as u solc
proprietorship, sevcral business entitics which included Wcst Shorc Imaging Systems and
Wcrtz Business Equipment, with a place of business in Lcmoyne, Pcnnsylvania, The
Copy Shop with u plucc of business in Gcttysburg, Pcnnsylvania, and West Shore
Imaging Systems, with u place of business in Selinsgrovc, Pcnnsylvania, all as marital
property.
7. On October 22, 1998, Defendant did enter into an Agrecmcnt of Salc to
sell or transfer the business entity known as West Shore Imaging Systems, to the
exclusion of and without the knowledge or consent of thc Plaintiff, the full and complete
details of which huvc yet to be revealed to Plaintiff. A true nnd correct copy of the
Agreel11ent as filed in the Office of the Rccorder of Deeds, Miscellaneous Book 592, Page
661, is attached hereto, made a part hercof and market as Exhibit A.
8. By transferring said items of marital property, the Defendnnt has
wrongfully, intentionally, nnd maliciously prevented PlaintiIT from excrcising her right
nnd ownership interest in said business in ordcr to dcfcat un equitable distribution or
similar award.
9. The conduct of Defendant as heretofore stated has been a misappropriation
of marital property, and may be a waste and dissipation of the marital assets.
10. Said translcr und coneeahncnt of thc marital propcrty is to the Plaintiffs
great detrimcnt.
II. PllIintilThas no adcquate rcmedy at 11Iw.
12. InUlledintc nnd irreparable is being euused by Dcfcndnnt's conduct, which
is deleuting Plaintifl's claims of Equitable Distribution.
13. Further immediate and irreparable loss and damagc may rcsult should
Defcndant continue to scll and transfer additional businesscs or marital asscts.
WHEREFORE, Plaintiff prays for equitable relief as follows:
(a) thut an injunction issue preliminary and until hearing and finally thereafier,
enjoying Defendant from disposing, transferring, encumbering. concealing, selling,
removing or alienating any business, business cntity, or busincss asset, realty or
personalty, or any other marital asset known or unknown to the Plaintiff,;
(b) that your Honorable Court issue an order requiring un accounting of all itcms
of marital propcrty in Defcndant's possession or control, and that no further disposition,
transfer, encumbering, concealing, selling, removing, or alienating take place without
further order oflhis Court;
(c) thllt your Honorable Court attach said items of marital assets;
(d) such other rcliefas your Honorable Court may deem appropriatc;
(e) award attorney's fees, costs and expenses
BY:
L-' ;.0Jb .( _
illiam L. Grubb, Esquire
3105 Old Gettysburg Roud
Camp Hill, PA 17011
763-5580
Attorncy for Plaintiff
VERIFICATION
I verify that the statcmcnts mudc in this document ure truc and correct. I
undcrstand that fulse statcmcnts hcrcin arc mude subject to penalties of 18 Pa. C.S. !i
4904, relating to unsworn falsification to authorities.
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AGREEMENT OF SALE
THIS AGREEMENT OF SALE Is made this ~day of O~tOMfJ . 1998, by and
between CHARLES E. waSON ('Seller'), and PENNLANTIC CORP. ('Buyer'),
Buyer and ~eller,lntendlng to be legally bound, hereby agree as follows:
1. SALE AND PURCHASE:
a, The Property. Seller shall sell to Buyer, and Buyer shall purchase from
Seller, all ofthe following property (the 'Property'), on the terms and
. , conditions set fonh herein:
:"
I. All alsets, fixtures, equipment, fumlshings, Inventory, vehicles,
customer lists, aceounts receivable, and the name and good will of
Selle(s business known as WEST SHORE IMAGING SYSTEMS,
located at 30 North Fifth Street, Lemoyne, Pennsylvania. A list of
amts Is attached heno as Ellhiblt A.
2.
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PURCHASE PRICE AND PAYMENT:
a, The Furch,se Price. The purchase price for the Property shall ue the sum
of One Hundred Thirty Thousand Dollars (St30,000,00).
b. Pavroent ofPurcha.e Price. The Purchase price shall be paid by Buyer to
Seller as follows:
i. A cash payment of Fort}' Four Thousand Dollars (S44,000,00) at
closing, and the remainder oflhe S 130,000.00 to be paid wilhin 60
days.
iI Any and allliabllltles oflhe buslnmshall be paid from tile proceeds
of the closing, A Ust of liabilities to be paid Is attached hereto as
Exhibit B. These liabilities do not include accounts payable owed
to vendors or monthly operating bills, moneys owed to Invenlory
financing companles, or standard business expenses,
3. DUTIES AND OBLIGATIONS:
a,
SeUer shall reUnqulsh any and all right., title, and/or tnterest in Ihe above
Property to Buyers upon execution of this agreement,l\I1d shall execute any
and all documents necessary to effectuate the traOlfer of said right, title
and/ or Inlerestlo Buyer.
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b, Seller hereby agrees not 10 compele wllh Duyer, in any way whatsoever for
. period of five (5) years, and within a distance of 100 mile radius of
Harrisburg~ Pennsylvania,
c, Seller represents that he has made full disclosure of all liabilities, In the
event there shall be any other liabilities or obligalionsthal Buyer shall be
liable for, Buyer shall have Ihe righlto collect said amount, plus rmonable
costs and attorney's fees, from Seller, and Seller shall indemnify Duyer for
such liabilities and expenses,
4. EMPLOYMENT AGREEMENT:
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a. . Buyer agree to hire Seller for Iwo years, as salesperson, upon execution of
this agreemenl. Payment shall consist ofS 350,00 per week, plus
conuiUsstOris 'figured a140% ofthe net profit on sales, Health insurance
and reas'onable expenses are to be Included.
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b, Duyer agrees to' pay Sel1e't'a salary of S 495.00 gross, per week, until
balance of S 130,000.00 purchase amount Is paid. Should commissions
pluslhe aforementioned S 350.00, exceed the S 495.00, that emount alone
shall be pald.
IN WITNESS WHEREOF, the parties have hereunto selthelr hands and seals as oflhe
date first above written. .. . '., ""
WITNESS:
SELLER:
aAf)" ~ (J.JL~__
Charles E. Wilson
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ATIEST:
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b'3..ss.mOEO #/0 S'B"1l TO OEFOne lIt TJjOS
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"~",'aMl:'4:" '/ .', . ".;.\ ;:, \ Ronald Rose erry ~
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NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Ternl
CHARLES E. WILSON,
Defendant
: IN LAW - DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
I, William L. Grubb, Esquire, being duly sworn
,according to law, depose and say that I am the attorney for
Plaintiff, NANCY L. WILSON, and that I did mail a true and
correct copy of the PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
AND INSPECTION OF DOCUMENTS in the above matter, by
certified mail, return receipt requested, to David W.
DeLuce, Esquire, attorney for the defendant , on December
10, 1998, to P.O. Box 109, Lemoyne, Pennsylvania. Receipt
of the same was acknowledged on December 11, 1998, as shown
by the return receipt card attached hereto as Exhibit "Au.
~L~~~ ~~ire
Sworn to and Subscribed
before me this C; lA, day
of J(}J1lJnrr 19ft- .
~ f)JdNv // x1/UL-1?
Notary
Nolarlal Saal
Susan M. GlUbb, Nolary Public
lowar Allon Twp.. Cumberland County
My Commission E'plros Juno 21, 1999
foo R:
oR -CompIel'I1.'ml1 an4'or:l '0( IddItlonaI HMclI.
-; 'CompItl.lt.mI 3, .', and 4b,
I 'Prinl 'fiJf6 name and Iddrlll on thl rlvtf'H ollhl. loon 10 thai WI can rllurn thl,
canllo illu.
'ArI.a, tN. totm 10 the frorI 01 the mallp1Ke, or 00 the back II apace don not
II .t;:!R~ R~pI RMlUfNlld" on the malpIece below IhI artlde f'lUfMtr.
'Ii 'The RelLI'Il RICe/pi wlllhow to whom &hi artld. WII deMrad and lhe dltt
Ii dollvwod.
'll 3, Mcf. Addr...ed to:
Ji UMro W.Dd."c..r- . (;,!,Q.,
i 301\'''~''''\l>"('(-;.. ..r~..,l~"" ~ LJ.iO.....t'
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LI'.",oy,J~. lb. l7a >(?- 010,/
6. R.c.lved By: (Print Neme)
I also wish to r.c.lv. the
following ..rvices lfor en
.,w.f..):
1. 0 Addr....... Addr... t
2. 0 R..trIct.d D.llv.ry ~
Consult pastmesl.r lorl... .J!.
4a. Mcf. Numb.r D
7- S-18 37(., (Pu a:J
4b. Sorvlca Typ.
CJ R.gl.t.red ~ Cartlfted '"
CJ Expro.. Mall CJ Insured 1
Jl R.lum RecoWor Men:I1.",Io. CJ COD
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Domest c Return Receipt
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Exhibit "A"
NANCY L. WILSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
CHARLES E. WILSON,
Defendant
No. 95-0767 CIVIL TERM
ORDER OF COURT
AND NOW, this Z1~J day of January, 1999, upon
consideration of Plaintiff's Motion for Sanctions for Failure To
Produce Documents, a Rule is hereby issued upon the Defendant to
show cause why he should not be required to produce the
documents requested by Plaintiff.
RULE returnable within 20 days of service.
By the Court,
WILLIAM L. GRUBB, ESQUIRE
3105 Old Gettysburg Road
camp Hill, PA 17011
For the Plaintiff
-
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1/$/7'1.
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DAVID W. DeLUCE, ESQUIRE
P.O. BOK 109
Lemoyne, PA 17043-0109
For the Defendant
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NANCY L. WILSON,
Pluintifr
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Ternl
CHARLES E. WILSON,
Defendant
: IN LA W - DIVORCE
RULE TO SHOW CAUSE WHY SANCTIONS SHOULD NOT BE
GRANTED FOR FAILURE TO PRODUCE DOCUMENTS
AND NOW, this
day of
, 1999,
upon motion of William L. Grubb, Esquire, attorney for
plaintiff-petitioner, and on consideration of the within
Motion For Sanctions For Failure To Produce Documents, it is
hereby ordered that defendant-respondent show cause why, if
any, the prayer of the within motion should not be granted.
Rule returnable the
day of
of the Cumberland County
1999, in Court Room
Court House, Carlisle, Pennsylvania.
BY THE COURT:
J.
NANCY L. WILSON,
I'laintifi'
: IN TI-IE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Tern!
CHARLES E. WILSON,
Defcndunt
: IN LAW - DIVORCE
ORDER OF COMPLIANCE AND SANCTIONS FOR FAILURE TO
PRODUCE DOCUMENTS
AND NOW, this day of 1999, upon
consideration of the motion of plaintiff, Nancy L. Wilson,
by her attorney, William L. Grubb, Esquire, and after
hearing thereon, in accordance with Rule 4019 of the
Pennsylvania Rules of Civil Procedure, the Court finds that
defendant has willfully violated the Pennsylvania Rules of
Civil Procedure for failure to produce documents as
requested in Plaintiff's First Request for Production and
Inspection of Documents, which justifies the entry of this
Order, and therefore,
ORDERS:
(1) that the defendant-respondent is hereby directed to
produce documents for the abovesaid Plaintiff's First
Request for Production and Inspection of Documents within
ten (10) days of the Order of this Honorable Court and to
produce books and records as well as any other information
concerning any personal, partnership or business assets,
stock or other holdings, so that the plaintiff-petitioner
may review same.
BY THE COUR'I':
J.
includes a Count for Equitable Distribution of the marital
assets.
5. In accordance with Rule 4005 of the Pennsylvania
Rules of Civil Procedure, plaintiff's attorney served upon
defendant, through his attorney, as of course, a Request for
Production and Inspection of Documents,
seeking the
appropriate
financial
information
necessary
towards
resolution of the above claims, a copy of which is attached
hereto and made a part hereof, marked Exhibit "A".
6. Service was made on December 10, 1998, by
depositing them in the U.S. Mail, First Class. A Notice of
Service was filed with the Prothonotary, a copy of which is
attached hereto and made a part hereof, marked Exhibit "B".
WHEREFORE, plaintiff moves the Court to enter an order
under Rule 4019 of the Pennsylvania Rules of Civil
Procedure, since defendant-respondent has failed to respond
and produce documents as requested, as follows:
(1) directing defendant-respondent to answer the
above-served Request for Production and Inspection of
Documents within ten (10) days of the order of this
Honorable Court and to produce books records as well as any
other information concerning any personal, partnership or
, ~., ,. . -f ._._._~~,ort""'""1, .
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business assets, stock or other
holdings, so that the
plaintiff-petitioner may review same;
(2) that the Court enter such sanction order with
regard to the failure to answer interrogatories as is just
under Rule 4019 (c) (5) of the Pennsylvania Rules of Civil
Procedure;
Respectfully submitted,
Date: ~'79?
l L)D~/-M (;,.
William L. Grubb
Attorney for Plaintiff
3105 Old Gettysburg Road
Camp Hill, PA 17011
763-5580
--
NANCY L. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-00767
CIVIL TERM
CHARLES E. WILSON, CIVIL ACTION - LAW
Defendant IN DIVORCE
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION AND INSPECTION OF
DOCUMENTS . .
To: Charles E. Wilson
C/O David W. DeLuce, Esquire
P.O. Box 109
Lemoyne, PA 17043-0109
PLEASE TAKE NOTICE that you are hereby, pursuunt to Pennsylvania Rules of
Civil Procedure No. 400 I, et ~, to serve upon the undersigned, within thirty (30) days
after service of this Notice, your Responses in writing under oath to the Following
Document Requests.
Dated)::k.... / " . 1998
By:
1 J)O -L-' j~ ):Qt-z, ,
William L. Grubb, Esquire
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
G:" >cdi ';"6 n-
'1 A 1
INSTRUCTIONS
If you object to the production of any documcnt on thc grounds that thc utlorney-client,
attorney work-product or any othcr privilege is upplieable thcrcto, you shall, with rcspeet
to that document:
(u) State its date;
(b) Identify its author;
(c) Identify each pcrson from whom the document wus received;
(d) Identify caeh person who rcceivcd it;
(c) Identify each person to whom the document was sent;
(I) State the present location ofthe document and all copies thereof;
(g) Identify each person who has ever had possession, custody or control of it
or a copy thereof; and
(h) Provide sufficient information concerning the document and the
circumstances thercof to explain the claim of privilcge und to permit the
adjudication of the propriety of that claim.
As referred to herein, "document" includes written, printed, typed, recorded, or
graphic matter, however produced orreproduced, including correspondence, telegrams,
other written communications, data processing storage units, tapes, contracts, agreements,
notes, memoranda, analyses, projections, diagrams, drawings, minutes of meetings, or uny
other writing (including copies of any of the foregoing) regardless of whether you, your
former or present counsel, agents, employees, officers, insurers, or uny other person
acting on your behalf, are now in possession, custody, or control.
Thc purpose of the inspection is to aid pluintiff in thc preparation of thc trial of
this case. The items to bc produced for inspection and photocopying arc the following:
I. The application und all other memoranda, documents, balance sheet,
financial report, financial inlormation, papers and books in the possession or control of
the defcndant or defendant's aeeountunt relating to the Business Line of Credit from
CoreStates Bank as refercnced in Answer #2 to Interrogatory #17 of Defendant's Answers
to Plaintiffs First Set ofInterrogatories to Defendant.
2. All original and copies of correspondence, notes, memoranda, documents
and papers in the possession or control of defendunt or defcndunts accountunt relating to
any otTer or otTers to purchase, buy or bulk sale transaction of West Shorc Imaging
Systems or any other business interest or entity of the dcfendant.
3. The list of assets identified as Exhibit A to the Agreement of Sale dated
October 22, 1998, und recorded in the Office of the Recorder of Deeds in Mise. Book
592, page 661.
4. The list of liabilities identified as Exhibit B to the Agreement of Sale dated
October 22, 1998, and recorded in the Offiec of the Rceorder of Deeds in Misc. Book
592, page 661.
5. Schedule C from the 1995 Fcderal Income Tax Return for Charles E. and
Nancy L. Wilson.
6. Fcderal Income Tax retun:s, to include all submitted forms and schedulcs,
for the tax years 1996 and 1997.
7. All Agreements, Agreement of Salc, Salcs Agrecmcnt, Installment Sales
Agreement or other documcntation regarding thc salc, transfer, bulk sale or purchase of
the busincss known liS Wcrtz Business Equipment.
8. All expert opinions, reports, summurics or othcr writings in your custody
or control or in the custody or control of your attorney, uecountant, financial udvisor,
business brokcr or ugcnt which relate to thc vuluation, purehasc, sale or offer for Wcst
Shorc Imaging Systems, Wcrtz Business Equipment, or uny othcr business or cntity
which is the subject matter of this litigation.
9. All documents which you intend to rely upon or introduce at trial of this
litigation.
CERTIFICATE OF SERVICE
I hereby certify that on this/. 6 -6.day of December, 1998, a true and correct copy
of the foregoing PLAINTIFF'S FIRST REQUEST FOR PRODUCTION AND
INSPECTION OF DOCUMENTS was served upon the following by dcpositing smne
into the US Mail, first class, postage pre-paid to:
"
David W. DeLuce, Esquirc
P.O. Box 109
Lemoync, PA 17043-0109
DatedJ)~. 10 , 1998
,
By:_L~.or -:P~l.G,
William L. Grubb, Esquire
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
~.-
NANCY L. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMDERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Term
CHARLES E. WILSON,
Defendant
: IN LAW - DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
I, William L. Grubb, Esquire, being duly sworn
according to law, depose and say that I am the attorney for
Plaintiff, NANCY L. WILSON, and that I did mail a true and
correct copy of the PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
AND INSPECTION OF DOCUMENTS in the above matter, by
certified mail, return receipt requested, to David W.
DeLuce, Esquire, attorney for the defendant , on December
10, 1998, to P.O. Box 109, Lemoyne, Pennsylvania. Receipt
of the same was acknowledged on December 11, 1998, as shown
by the return receipt card attached hereto as Exhibit "Aff.
Sworn to and Subscribed
before me this C; Ill> day
of JOl7unr/ 19j!L .
'rtfJJdl'rv A ;/jmJ-?
otary
E" 1-1 ~Dn
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Notarial Saal
Su..n M, Grubb. Notary Publlo
Lower Allen 'IWp, Cumberland County
My Commission explro. Juno 21,1999
.. ED:
-3 .Complet.I~"nl1 anG/or 2 lor IddltlOnalHrvtcel.
Ii _Compfet.llemt 3. "', and 4b.
I . Prtne your name and Iddrtll on thl fIVI,., of thl, fonn 10 that WI can rllum IhI.
wd I. you.
-AIladl thll form 10 the front 01 lhe mallp1.ce, or onlNl blick Ulpace do.. not
po";'.
IJ _Wnlt"RMtim RlCWlpf RIQUNt~.on the rnallplece btIow Ihe article ruOOer,
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MICHAEL L. BANGS
ATIOnN~:\' AT I.AIV
:llJ~HOlJ'J'1I1H'J'IIH'J'U1':~:T . CAMP 1111.1.. PA 17lJII
PilON I': 717.7:1lJ.7:1I1l
FAX 7t7.7:1I).7:17,1
"'11I1111: tllul~"IIII\'(j(lIIh\lI""rin".I'llln
Scptcmbcr 10, 1999
E. Robert Elicker, II, Divorec Master
9 North Hanovcr Streel
Curlisle, PA 17013
RE: Nancy L. Wilson vs. Charles E. Wilson
No. 95-00767 Civil
Dear Mr. Elickcr:
Enclosed you will find a Pre-Trial Statement together with an Income and Expense
Statement that I file on behalf ofthe Defcndant. A true and correct copy of these documents has
been provided to opposing counsel as of this date.
Very truly yours,
~~~;,,~
.,
wsc
Enclosures
cc: Mr. Charles E. Wilson
William L. Grubb, Esquirc
NANCY 1.. WILSON,
PluintilT
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERI.AND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Term
CHARLES E. WILSON,
, Delendant
: IN LA W - DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
I, William L. Grubb, Esquire, being duly sworn
according to law, depose and say that I am the attorney for
Plaintiff, NANCY L. WILSON, and that I did mail a certified
Subpoenll to Attend lInd Testify in the above matter, by certified
mail, return receipt requested, to Charles E. Wilson, the
defendant, on March 31, 1999, to 506 Beacon Hill Road, New
Cumberland, Pennsylvania. Receipt of the same was
acknowledged on April 5, 1999, as shown by the return
receipt card attached hereto as Exhibit "AH.
[ 0,-QLMr~ '
William L. Grubb, 8squire
Sworn to and Subscribed
before me this rPlh day
of Ow"':; 1999.
I
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Notary
Notarial Saal
Susan M. Grubb, Notary Public
Lower Allan Twp., Cumbortand County
MV Commission Expires Juno 21,1999
CUA"h:~. lZ. Wd,!,olrJ
5"ou S el\c..w l~1 /l .e~1W
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NANCY L. WILSON,
PlaintifT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 95-00767 Civil Tcrm
CHARLES E. WILSON,
Defcndunt
: IN LAW - DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
I, William L. Grubb, Esquire, being duly sworn
according to law, depose and say that I am the attorney for
Plaintiff, NANCY L. WILSON, and that I did mail a true and
correct copy of the PLAINTIFF'S SECOND REQUEST FOR
PRODUCTION AND INSPECTION OF DOCUMENTS in the above matter,
by certified mail, return receipt requested, to Charles E.
Wilson, the defendant, on April 6, 1999, to 506 Beacon Hill
Road, New Cumberland, Pennsylvania. Receipt of the same was
acknowledged on April 9, 1999, as shown by the return
receipt card attached hereto as Exhibit "AN.
LJ] ~ I ~Q.e
William L. Grubb, Es~re
Sworn to and Subscribed
before me this I,Jh day
of ~ 1999.
\ frIJ<'1I1A'1) /1 /hld/;
Notary
No"",.' So.1
Su,.n M. Grubb, Nolary Public
Lowor Allon Twp.. Cumberlond CounlY
My Commission E.plro, Juno 21. 1999
,.
"
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11 .CompIete h1ml3. 4.. and 40.
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Exhibit "A"
NANCY L. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PEN~5YLVANIA
NO. 95 - 00767
vs.
CIVIL ACTION - LAW
CHARLES E. WILSON,
Defendant
.
.
IN DIVORCE
ORDER AND NOTICE SETTING HEARI!!Q
'1'0: Nancy L. Wilson
William L. Grubb
Charles E. wilson
Michael L. Bangs
You are directed to
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9
Hanover Street, Carlisle, Pennsylvania on the
of at
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
North
day
a.m., at which
~rt.
. rg. A:t.
President Judge
Date of Order and
Notice:
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBEP.LAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
NANCY L. WILSON
Plaintiff
: IN 'I'HE coun'/' OF COMMON PLES OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL AC1'ION . LAW
: IN DIVORCE
Please withdraw my uppeal'llnce ns counsel 1'01' Plaintiff, Nancy L. Wilson, in
the above captioned matter.
Dated:
CHARLES E. WILSON,
Defendant
: NO. 95-00767 CIVIL TERM
-,
Please enter my appearance as counsel for Plaintiff, NANCY L. WILSON, in
tho above eaptioned matter.
1'0 the Prothonotury:
Dated:
Oce- 1'-t,I't<T<'
_l Q ):O~A?~..Q~/
William L. Grubb, Esq. <..' ~!> .
3105 Old Gettysburg Road
Camp Hill, PA 17011
To the Prothonotary:
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VS.
: IN TI-IE COUR'1' OF COl\lMON PLES OF
: CUI\IBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
: IN DIVORCE
NANCY L. WILSON
Plaintiff
CHARLES E. WILSON,
Defendant
: NO. !JG.007G7 CIVIL TERM
AND NOW, this
ORDER OF COURT
RULE TO SHOW CAUSE
7 ~day of July, 2000, a Rule is issued upon the parties
in this nction to show cnuse why Sallluel ,",Y. MilItcs, atto1'1ley for the Plaintiff,
should not be allowed to withdl'aw liS counsel in this case. This Rule is returnable
within fifteen days of the date of this Order. If eithel' party has any objection to this
withdmwnl, the party shllll file n written rcsponse with this Court, stating the
mnsons for the objection. Service shall be made on the Defendllnt through his
counsel and scrviee shnll he mllde on the Plaintiff by first clllSS mnil nt her home
IIddress.
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7/7/M tJvl(~?t#t< $" a-4- Ak~
7/' /?'t' /J12~)' It-ta~#Y ~ a?j <3a'~ ". ~
NANCY L. WILSON
Plaintiff
: IN THE COURT OF COMMON PLgS OF
: CUl\IBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
VS.
CHARLES E. WILSON,
Defendant
: NO. 05.007G7 CIVIL TERM
MOTION TO WITHDRAW AS PLAIN'l'IFF'S COUNSEL
COMES NOW, counsel for the Plaintiff in the above action, Samuel W.
MilkeI', Jacobsen & r"lilkes, and requests of this Honorable Court that it allow him
to withdraw as counsel, for the reasons stated below:
1. On June G, 2000, the Plaintiff wrote to her attol'\ley, Samuel W. MiIkes,
stating that she had signed a settlement agreement with the Defendllnt,
thllt she felt disslltisfied with the progress of her case, and stating the
following: "It is my decision to release you from an~' further duties or
obligations concerning this case."
2. The Defendant is represented by Michael Bangs, Esq.
3. The Plaintiff is II teacher and is competent to make decisions about her
best interests.
4. The Divorce Mastel' has beellllppointed in this cllse. A conference with
the Divorce Mastel' and counscl was previously held and a hearing is
scheduled before the Mastel' for August 7, 2000.
5. Counsel is unaware of the contents of the settlement agreement entered
into by the parties.
Ii. TIn sed upon the Plnintifl's roquest, and the apparent settlement of this
cusu, COllllsuluHlts thutthis HOllol'uhlu COlll'tllllow him ]lul'miHsiollto
withdl'lIW fl'olllthis ClIse.
1,
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i
I
WHEREFORE, 1'01' the IIhove l'eIlSOIlS, Sllmuel W. ~lilltes I'equests of this
HOllol'lIhlu COUl't thllt it grllllt him ]lul'mission to withdl'uw liS eoul1sul fol' the
,
Plnintiff.
Res]luetfully suhmitted,
.'"
BY: Snmuel W. Milltes
JACOBSEN & MILKES
52 E. High Stl'eet
Cnrlislu, PA 17013
(717) 249.6427
(717) 249.8427 - Fllx
Attol'ney No. 30130
Dnle: July 7, 2000
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NANCY L. WILSON
Plaintiff
: IN THE COURT OF COMMON PLEASE OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 05.00767 CIVIL TERM
VII.
CHARLES E. WILSON
Defendant
nRTI'I'TFTn,\'I'p, OF SRTlVlnR
I, Dana A. Dunklc, hcreby certify that ntruc and corrcct copy of the Motion to
Withdl'llw all Plaintiffs Counsel, in the above captioned matter, wall duly served upon
the Plaintiff, Nancy Wilson by depositing it in the U.S. Mail, postage paid, on July 7,
2000, addressed as folJows:
Nancy Wilson
404 Spruce Road
New Cumberlnnd, PA 17070
I hereby verify that the statements mnde in the foregoing arc true and correct.
I understand that false stntementll herein arc lIlade subject to the penalties of 18
Pa.C.S. Section 4004, relnting to unsIVo1'l1 falsification to authorities.
Dated; _~)..Ji4.-1, ~ tea
()
~~~l'\(\ J\ J\JHI\ Y lQ
ma A. Dunkle \ .
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NANCY L, WILSON
Plllintiff
: IN 'l'1-m COUIt'!' OF C01\IMON PLES OF
: CUI\IBlmLAND COUN'I'Y, PENNSYLVANIA
VS.
: CIVIL AC'I'ION . LAW
: IN DIVORCE
CHARLES Eo WILSON,
Defendllnt
: NO. !)/i.007Ii7 CIVIL'I'ERM
MOTION TO MAKE RULE ABSOLUTE
COMES NOW, counsel for the Plllilltiffin the IIhove IIction, SlImuel W,
Milkes, Jllcohsen & l\Hlkes, IIl1d requests of this Honol'uble Court thut it muke the
Rule issued on July 7, 2000 ubsolute, ullowing couusel fOl' the Plllintiff to withdmw,
for the l'eusons stilted below:
1. On July 7, 2000, counsel for the Plllintiff filed II Motion, nsking thot he be
grunted permission to withdl'HW from this Cllse,
2. As stilted in the Motion, Pluintiff he felt disslltisfied with the progress of
her Cllse, IInd stilted: "It is my decision to l'l!leuse ~'ou from uny further
duties or obliglltions concerlling this cllse."
3. The Defendllnt is represented hy Michllel Bnugs, Esq.
4. A Rule WIIS issued on July 7, 2000, I'etul'nllhle in fifteen doys, to show
clluse why counsel should not he II1l0wed to withdruw from the case,
5. A copy of the Rule WIIS forwllrded to coullsel for the Defendant, Michael
Bungs, Esq., IIlld to the Plllintiff, on July 7, 2000.
Ii. Thel'l! hilS been no ohjection mllde to this request.
WHEREFORE, 1'0:' the IIhove I'CIISOIlS, SUlllucl W.l\Hlkes I'cquests of this
Honol'lIble Court thllt it J.(I'Ullt hilll pel'missioll to wit hdl'IIW us counsel for the
Plaintiff IInd thllt the IIttllched Order he entered,
Hespectl'ully suhmit ted,
/~~
BY: Samuel W. Milkes
JACOBSEN & MILKES
52 E, High Street
Cnrlisle, PA 17013
(717) 24!).G427
(717) 249.8427 . Fnx
Attorney No, 30130
Dnte: July 26, 2000
.,
vs.
IN 'rBE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA:
NO, 95 - 767 CIVIL
NANCY L,WILSON,
Plaintif f
CHARLES E. NILSON,
Defendant
IN DIVORCE
AND Nml,
ORDER OF COURT
th1, ~ d,y 0
2000, the economic claims r~ised
been resolved in accordance with a marriage settlement
agreement dated June 6, 2000, the appointment of the Master
is vacated and counsel can file a praecipe transmitting the
record to the Court requesting a final decree in divorce,
BY THE COURT,
~
t
er, P.J.
,(\~ O'.t
Capi>J'"'''' ~r
"'~~:o
~
cc:
Samuel W. Milkes
Attorney for Plaintiff
Michael L. Bangs
Attorney for Defendant
Fl m. CITICE
0"'1 ........./, ""'()T\lJV
. :.. .:.,' i" J: ~, .! 'I '. I,'
00 MIG -9 All B: 43
CU,'.Ii3!:iiJ.;,l) COU,'ITY
PENNS\l\'A.'\1A
MAIUUAGE SETTLEMENT AGnEEMENT
THIS AGREEMENT is made this 0 tII day of ,Ju /oJ! ,2000, by and
between Charles E, Wilson, 506 Beacon Hill Road, New Cumberland, Cumberland
County, Pennsylvania, hereinafier referred to as "'Iusband",
..AND-
NANCY L. WILSON, now of 494 Spruce Street, Fairview Township, York
County, Pennsylvania, hereinafier referred to as "Wife",
WITNESSETH:
WHEREAS, Husband alld Wife were lawfully married on March I, 1975 in
Carbon County, Pennsylvania; and
WHEREAS, diverse unhappy marital difficulties have arisen between the parties
causing them to believe that their marriage is irretrievably broken, as a result of which
they now live separate and apart from one another, the parties being estranged due to
such marital difficulties; and
WHEREAS, the parties hereto arc desirous of compromising and sellling fully
and finally their respective financial alld property rights and obligations as between each
other, including, without limitation by specification: each other, including, without
limitations: the sellling of all mallers betweellthem relating to the ownership of real and
personal property; and in general, the sellling of any and all claims and possible claims
by one against the other or against their respective estate, particularly those
responsibilities and rights growing out of the marriage relationship, inter alia past, present
or future spousal support or maintenallee, alimony pendente lite, alimony, counsel fees
and expenses, and equitable distribution, whether or not the parties reside together; and
WHEREAS, the parties have agreed on a selllement of all liabilities and have
agreed on a selllement of all property rights and differences existing between them; and
WHEREAS, the parties intend this Agreemellt to be a full alld complete Marriage
Selllement Agreement, providing for the absolute and final setllelllent of all their
respective marital and property and all other claims,
NOW, THEREFORE, in consideration of the premises alld of the promises,
covenants and undertakings hereinafter set forth and for other good and valuable
consideration, the receipt of which is hereby acknowledged by each of the parties hereto,
Husband and Wife, each intending to be legally bound hereby, covenant and agree as
follows:
I, SEPARATION, It shall be lawful for each party, at ulltimes hereinafter. to
live separate and apart from the other, at such place or places as he or she may, rromtime
to time, choose or deem lit, Each party shall he free from interference, authorit)' or
control b)' the other, as full as if he or she were single and unmarried, except us may be
necessary to eurr)' out the provisions of this Agreement. Neither purty shall molest the
other or attempt to enoeuvor to molest the other, nor compel the other to cohabit with the
other, or inuny way harass or malign the other, nor in any way interfere with the peaceful
exislenee, sepurllte uno upart from the other. The foregoing provisions shall not he Ull
uomission on the pari of either pUrl)' of the lawfulness or ulllawfulness of the causes
leading to their sepurlltion, A reconciliation will not void the provisions of this
agreement.
2, EFFECTIVE DATE, The effective date of this Agreement shall be the "date
or execution", delined as the date upon which it is executed by the parties if they have
each executed the Agreement on the same date. Otherwise. the "date of execution" or
"execution date" of this Agreement shall be delillcd as the date of execution by the pUrly
last executing this Agreement. Transfer of properly, funds an%r documents shall occur
on the effective oate unless otherwise specified herein,
3. AGREEMENT NOT A BAR TO DIVORCE. Both parlies hereto agree that
the marriage is irretrievably broken ano agree at the time of execution hereof to execute
allY and all affiduvits or other documents necessary for the parlies to obtain an absolute
divorce pursuant to Section 3301 (d) of the Divorce Code. Each pUrly waives the right to
request Courl ordereo counseling,
4, DEBTS AND OBLIGATIONS, Ilusband and Wife hereby mutually agree that
each is to retain their own debts ano obligations. Each party hereto represents and
warrants that he or she has no, and in the future will not, contract or incur any debt,
obligation or liability for which the other parly or his or her estate may be responsible or
liable, except as provioed for in this Agreement. Each parly hereto agrees to be solely
rcsponsible for the prompt and timely payment of the debts IlUW or hereafter ineurrcd in
his or her name und speeilieally uny debts secureo by any automobile, motor vehicle or
other property distributed to her or him hereunder. Eaeh parly hereto agrees to indemnil')'
and hold hannless the other from any and all claims, debts, obligations or demands made
against him or her by reason of debts or obligations incurred by him or her or identifies to
be paio by him or her in this Agreement.
5. MUTUAL.REALEASES, Husband and Wife hereby mutually remise, release,
quitclaim ano forever oischarge the other and the estate of such other. for all time to
come, and for all purposes whatsoever, from any and ull rights, title and interest, or
claims in or against the estate of such other, or whatever nature and wherever situate,
which he or she not has or utllny time hereafter may have against such other, the estate of
sueh other or an)' part thereof; or the right to take ugainstthe spouse's will; or all other
rights 10 Ofll surviving spouse to participate in a deceased spouse's estate. It is the
intenlion or Ilushand ano Wife to give to euch other by the exeeulion of this l\greell1enl a
lilli, cumplele and genernl relellse with respect to 11I1)' lInd ull property of lIny kind or
naturc, real, personal or mixed, which the other now owns or mu)' hcreufter acquire,
except, and only except, ull rights and agrecments and obligutions of whatsoevcr nature
arising or which may urise under this Agreement or for the breach of any provision
thereof. It is further agreed by each party thut this Agreement constitutes a full and final
resolution and selllement of all claims of an)' kind, and especially claims arising ullder
the Pennsylvania Divorce Code, which either purty may have against the other,
6, DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties
hereto agree that they have effected a mutually satisfactory division of the furniture,
household furnishings, appliances and other personal property and motor vehicles
between them and neither part)' will make any claim to any personal property now in thc
possession or control of the other except here ill provided, Husband hereby releases and
relinquishes any right, title or interest he may have had in the past or 1l0W has in Wife's
possession, Wife agrees that Husband shall, from and alter the date hereof, be the sole
and separate owner of all persollal property in Husband's possession, Wife hereby
releases and relinquishes any right, title or interest she may have had in the past or now
has in Husband's possession. Husband agrees that Wife shall, from and afier the date
hereof, be the sole alld separate owner of all personal property in Wife's possession.
7. WEST SHORE IMAGING SYSTEMS, Husband shall retain any and all right.
title and interest in and to any of the proceeds ofa certain Agreement of Sale involving
West Shore Imaging Systems. Wife hereby waives any interest in and to West Shore
Imaging Systems. It is the intelltion of this provision that all interest in West Shore
Imaging Systems be and remain with Husband, Husband shall assume all debt,
obligation, line of credit or liability for or in connection with the business entity kllown as
West Shore Imaging Systems, and shall indemnify and hold Wife harmless from the
aforementioned debts, obligatiolls, lines of credit and liabilities, Husband shall assume
liability for and release and hold harmless Wife from specifically, but not limited to, the
following debts, obligations and lines of credit: Personal Loall to Gregory Smith,
Busilless Loan from CoreStates Bank, selllement of purchase of Wertz Business
Equipment, all credit card use for business purposes, and satisfaction of allY debt to West
Shore Office Machines,
8. PENSIONS AND RETIREMENT ACCOUNTS. The parties hereto waive any
and all interest or claims which either may have in any individual retirement accounts,
401 (k) accounts, 403 (b) accounts, Keogh accounts, existillg pensions or similar
accounts of the other, including allY retirement type accounts of Wife arising from her
employment with the West Shore School District, and any retirement type accounts of
Husband,
9, ALIMONY, Each party waivcs, releases and gives up any claim, now or in the
future, for any spousal support, alimony, alimony pel/deme lite, or maintenance from the
other.
10, I3ANK ACCOUNTS, IIUSBAND and WIFE each lIeknmvledge that they
elleh own or possess eertllin bank aecoullts and similar accounts of financial instrumcnts
in their respective names, They hereby agree that each shall become sole owner of their
respective accounts for financial instruments and elleh hereby waives any intercst in or
claim to any funds, instruments or accounts held by the other in such instruments or
accounts.
II. MOTOR VEHICLES, With respect to motor vehicles owned by HUSBAND
and WIFE, both of the parties agree that the vehicles currently ill the possession of either
party shall remain the property of that party.
Each party shall be solely responsible for and debt secured by any vehicle listed
as his or her property, Each party shall be solely responsible for any insurance and any
other costs, including license, for each motor vehicle in the possession of the respective
party,
12. REAL PROPERTY, The parties arc owners ofcertaill real property known
and identified as 494 Spruce Road, Fairview Township, York County, Pennsylvania; Lots
10 and lOA on Ridge Road, Fairview Township, York County, Penllsylvania; and 506
Beacon Hill Road, New Cumberland, Cumberland County, Pennsylvania, Husband
covenants and agrees to convey to Wife, as her sole and separate property, the real estate
known as 494 Spruce Road, illcluding adjoining lot, and Wife covenants and agrees to
transfer to Husband the real estate presently owned by the parties and knmm as 506
Beacon Hill Road subject to all liens, encumbrances, casements and restrictions presently
existing thereon, The parties represent that they have, as of the date of this Agreement,
executed, acknowledged, and delivered to their respective attomeys, deeds to said real
estate conveying the same as above described and agree that the said deeds shall be held
in escrow by their respective attorneys pending the completion of the divorce action filed
in'this case. Upon completion of the said divorce action, the parties' respective attorneys
shall, without further direction or authorizntioll from the parties, deliver the said deed
unto each other's attorney, The real property loenled on Ridge Road, Fairview
Township, York County, Penllsylvania, sometimes referred to liS Lot 10 and Lot lOA,
shall be sold and the proceeds shall be split evenly between the two parties,
In consideration for the transfer of the real estate as herein described, both parties
shall take the steps necessary to refinance the existing debts against the real estate so as to
remove the other party from any and all liability for said debt. The parties agree that they
shall take the steps to refinance the properties within ninety (90) days of the date of the
transfer of the real estate as herein described, Pending said refinance of the debts, the
parties hereby covenant and agree to assume and pay in full the remaining balance of allY
mortgages or other loans now existing and presently constituting liens upon and
encumbering the said properties, lInd that they will indemnify and save each other
hannless from and all liability, expense, cost or loss whatsoever as a result of their non-
payment of or non-performance of said mortgage or other loan conditions.
13. COUNSEL FEES, Each party individually covenants and agrees that he or
she will individually assume thc full and sole responsibility for all other legal expenses
for his or her attorney, if any, and Court costs in conneetioll with the pending divorce
action and shall make no claim against the other for such costs,
14, ADDITIONAL INSTRUMENTS, Each oflhe 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, deeds, titles or documents that may be reasonably required to
give full force and effect to the provisions of this Agreement, including all papers
necessary to transfer title.
15, AFTER ACQUIRED PROPERTY. Each party shall hereafter independently
own all property, real, personal or mixed, tangible or intangible, of any kind, acquired b)'
him or her, with full power to dispose of the same in all respects and for all purposed, as
though he or she were unmarried,
16. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFER, The parties
hereby agree and express their interest that allY transfer of property under this Agreemellt
shall be within the scope and application of the Deficit Reduction Act of 1984,
hereinafier referred to as "the Act," and specifically the provisions of the Act pertaining
to property transfers between spouses and former spouses. The parties agree to sign and
file any elections or other documents required by the Internal Revenue Service to apply
the Act to transfers under this Agreement without recognition of gain and subject to the
carry-over basis provisions of the Act,
17, MODI FICA nON AND WAIVER, A modification or waiver of any ofthe
provisions of the Agreement shall be effective only if made in writing alld executed with
the same formality as this Agreement. The failure of either party to insist upollthe 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,
18. ENTIRE AGREEMENT, This agreement contains the entire understanding of
the parties, and there arc no representatiolls, warrallties, covenants or undertakings other
than those expressly set forth herein,
19, DESCRIPTIVE HEADINGS, The descriptive headings used herein arc for
convenience only, They shall have no effect whatsoever in determining the rights or
obligations of the parties,
20. INDEPENDENT SEPARATE COVENANTS, It is specifically understood
and agreed by and between the parties hereto that each paragraph hereof shall be deemed
to be a separate and independent agreement.
21. BREACH, Ifeither party breaches any provision of this agreement, the other
party shall have the right, at his or her election, to suc for damages for such breach, to
temlinate any further payments required to the other hercunder or seck such other
remedies or relief as may be available to him or her, and the party breaching this contract
shall be responsible for payment of legal fees and costs incurred by the other in enforcing
their rights under this Agreement, or in seeking such other remedies or belief as may be
available to him or her,
22. APPLICABLE LA W. This agreement shall be COilS trued under the laws of
the Commonwealth of Pennsylvania,
23. VOID CLAUSES. Ifany 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 provisioll shall be stricken from this Agreement, and,
in all other respects, this Agreement shall be valid alld continue in full force, effect and
operatioll,
IN WITNESS WHEREOF, the pnrlies have hereunto set their hands and seals the
day and year first above wrillen.
WITNESS:
WIFE:
~ ~ ~nJ;t~
Z1c~~Jht~
HUSBAND:
fi&h~ ~ !Iru?'~
Cil./lA a 4-c!! w~ --
N01AMI Seal
Ellen O. HilfnllloF'l. NOIMY PublIC
lornuyllll 00'0, CUmber1and Calmly
MyC:omfllluiOf\ F.rOlles ^n' 14, ?OO2
McmbOl, Pennsylvania AS5OClahOll 01 Notarres