HomeMy WebLinkAbout95-01588
STEPHANIE L. RUPP,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND cotlNTY, PENNSYLVANIA
.
.
vs.
: NO. 95-1588
CIVIL TERM
.
.
MICHAEL L. RUPP,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PR!Q{ JUDGB: Kevin A. Hess
CUS'lOOY calCILIATION &MlARY REP<Rl'
IN AccaulANCB WITH cnmBRLAND ocumc RlILE OF CIVIL PRO "'" 'IlRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Children who are the
subjects of this litigation is as follows:
~
Arnie Elizabeth Rupp
Justin Michael RUpp
BIRTHDATE
CURRENTLY IN CUSTODY OF
July 25, 1983
April 27, 1987
Plaintiff/Mother
plaintiff/Mother
2. A conciliation Conference was held on March 5, 1996, with the
following individuals in attendance: The Father, Michael L. Rupp, with his
counsel, John H. Broujos, Esquire, and the Mother, Stephanie L. Rupp, with
her counsel, Bradley L. Griffie, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
111r.~(L
Date
iI I (I 'rte
f1<-~/,4-i'~I' dc. "
Dawn S. Sunday tJ
Custody Conciliator
'\'"-
with the Children, which may be consecutive or non-consecutive, upon
providing notice to the other party by May 1 of each year.
8. The parties acknowledge that the Children are currently
participating in counseling and agree that the Children shall remain in
their current counseling program, in which the parties may participate as
deemed appropriate by the Children's counselor.
9. The Father shall provide transportation for all exchanges of
custody under this Order.
10. The parties shall keep each other advised immediately in the event
of serious illness or medical emergency concerning the Children and shall
further take any necessary steps to ensure that the health and well being of
the Children is protected. During such illness or medical emergency, both
parties shall have the right to visit the Children as often as he or she
desires consistent with the proper medical care of the Children.
11. Neither party shall do anything which may estrange the Children
from the other party, injure the opinion of the Children as to the other
party, or hamper the free and natural development of the Children's love or
affection for the other party.
12. This Order is entered pursuant to an agreement of the parties at a
Custody COnciliation Conference. The parties may modify the terms of this
Order by mutual. agreement. In the absence of mutual agreement, the
provisions of this Order shall control.
BY THE COURT,
cc: John H. Broujos, Esquire
Bradley L. Griffie, Esquire
I\A CLL. \ E . )1~
Harold E. Sheely, P.J.
.
STEPHANIE L. RUPP, . IN THE COURT OF ccx-lMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-1588 CIVIL TERM
.
.
.
MICHAEL L. RUPP, . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
amBR OF CXXlRT
I ~ , 1-/
AND tDi, this day of
upon consideration of the attached Custody
ordered and directed as follows:
/))ll-\"\. , 1996,
COnciliation Report, it is
1. This Court's prior Order dated June 7, 1995, incorporating the
parties' Custody Stipulation executed in May 1995, is hereby vacated.
2. The Mother, Stephanie L. Rupp, and the Father, Michael L. Rupp,
shall have shared legal custody of Arnie Elizabeth Rupp, born July 25, 1983,
and Justin Michael Rupp, born April 27, 1987.
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 5:00 p.m. until the following Sunday at
5:00 p.m. The Father shall also have partial custody of the Children every
Wednesday evening from 5:00 p.m. until 8:00 p.m. During weekends when the
Mother otherwise has custody of the Children, the Father shall have a period
of partial custody on Sunday evening from 5:00 p.m. until 8:00 p.m. Up to
six times per year, the Mother may preempt the Father's alternating Sunday
evening period of partial custody by providing at least one week prior
notice to the Father of other plans for the Children on the upcoming Sunday
evening.
5. The parties shall share or alternate custody of the Children on
holidays as follows:
A. Christmas/Easter/Thanksgiving: The party who otherwise has
custody of the Children during the night immediately preceding
the holiday shall have custody of the Children until 2:00 p.m.
on the holiday. The other party shall have custody of the
Children from 2:00 p.m. until 8:00 p.m. on the holiday.
B. Memorial Day/July 4th/Labor Day: In even numbered years, the
Mother shall have custody of the Children on Memorial Day and
Labor Day and the Father shall have custody of the Children on
July 4th. In odd numbered years, the Father shall have custody
of the Children on Memorial Day and Labor Day and the Mother
shall have custody on July 4th.
6. Each party shall have an opportunity to have a reasonable period of
custody with each Child on the Child's birthdays every year.
7. Each party shall be afforded at least two weeks of summer vacation
llAAnLfy L. G.."",
M"",.U! R. c...,..
ANN. M. SH...""
GRIFFIE & ASSOCIATES
ATTORNEVSAND COUNSELORS AT LAW
200 NORTH HANOWA STREET
C.....IU!, PA 17013
(717) 243.5551
1 (800) 347.5552
FAX 717-243.5063
RooIN J. GosHORN
OF''''E MANACllA
November 2, 1995
c...........""" TRUST eo.u....
SUln 550, 14 NORTH MAIN SmEfT
C.......A..U"". PA 17201
(717) 267.1350
R.PLYTo: C.........
E. Robert Elicker, II, Esquire
Divorce Master
9 North Hanover street
Carlisle, PA 17013
RE: Rupp vs. Rupp
No. 95-1588
Dear Bob:
Mr. Houston recently made a proposal in this case that my
client has accepted. I am in the process of documenting the
agreement so that we can advise you imminently if, in fact, we
have a signed Agreement. At this point, I have advised Mr.
Houston of my client's agreement and, therefore, suggest that
neither party be required to file their Pre-trial statements on
Monday, November 6, 1995. As soon as we have a signed Agreement,
which we hope to be in the next several days, we will notify you
so that you may move to withdraw your commission.
Your attention is appreciated.
Very truly yours,
BLGjrjg
CC: Christopher C. Houston, Esquire
stephanie L. Rupp
STEPHANIE L. RUPP, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. CIVIL ACTION - LAW
:
. NO. 95 - 1588
.
MICHAEL L. RUPP, .
.
Defendant . IN DIVORCE
.
NOTICE OF PRE-HEARING CONFERENCE
TO: Bradley L. Griffie
, Counsel for Plaintiff
Christopher C. Houston
, Counsel for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover street, Carlisle,
Pennsylvania, on the loth day of June, 1996, at 2:00 p.m., at
which time we will review the pre-trial statements previously
filed by counsel, define issues, identify witnesses, explore the
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 4/10/96
E. Robert Elicker, II
Divorce Master
.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
E. Robert Elicker, II
Divorce Master
Trecl .10 Colyer
Office Manager/Reporter
West Shore
697.0371 Ext. 6535
March 21, 1996
Bradley L. Griffie, Esquire
GRIFFIE & ASSOCIATES
200 North Hanover street
Carlisle, PA 17013
Christopher C. Houston, Esquire
BROUJOS, GILROY & HOUSTON
4 North Hanover Street
Carlisle, PA 17013
RE: stephanie L. Rupp vs. Michael L. Rupp
No. 95 - 15B8
In Divorce
Dear Mr. Griffie and Mr. Houston:
I received a letter dated March 15, 1996, from Mr.
Griffie indicating that Mr. Rupp has "modified his position"
regarding a settlement issue and the case is not able to be
resolved by agreement. Mr. Griffie has requested that I proceed
with the filing of pre-trial statements and conference.
I had previously directed that pre-trial statements were
due on November 6, 1995, and on November 2, 1995, Mr. Griffie
wrote a letter indicating that Mr. Houston made a proposal which
his client accepted. Following that correspondence from Mr.
Griffie, nothing further was done in our office and the case was
put on hold pending the receipt by me of a signed copy of a
settlement agreement.
Inasmuch as the case has apparently not been able to be
resolved, I am directing each counsel in accordance with
P.R.C.P. 1920.33(b) to file a pre-trial statement on or before
Monday, April 8, 1996. Upon receipt of the pre-trial statements
I will immediately schedule a pre-hearing conference with
.
Mr. Griffie and Mr. Houston, Attorneys at Law
21 March 1996
Page 2
counsel to discuss the issues and, if necessary, schedule a
hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
STEPHANIE L. RUPP (CORNWALL),
PlaintilT
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
: NO. 95-1588
: IN DIVORCE
ANSWER TO CONTEMPT PETITION
AND NOW comes PlaintilT, Stephanie L. Rupp (Cornwall), by and through her counsel
of record, Bmdley L. Griffie, Esquire, and answers the Contempt Petition filed as follows:
I. Admitted. (presuming Richael is intended to be Michael)
2. Admitted.
3. Admitted.
4. Admitted.
5. Denied.
5a. Admitted.
5b. Denied as stated. It is denied that Mother did not send the children for their
visitation as required by the Order llI1l1 canceled the children's plane reservations prior to them
leaving. It is averred mther that Mother had plane reservations for the children and had tickets
for the children. Two (2) hours prior to their departure, the children, who are sixteen (16) and
twelve (12) years of age, refused to embark on the flight causing great stress and tunnoil
between the PlaintilT and the children in her attempts to have the children embark on their flight
to Pennsylvania for their Court Ordered visit with their Father. It is averred that the PlaintilT, at
no time, "canceled" the children's plane reservations.
5c. Denied. It is denied that Mother violated pamgmph 4 of the parties' Court Order
which provides for the Father to have telephone contact with the children. It is averred mther
that Father refused to telephone the children for a period of, at least, ninety (90) days and
admitted to the children, in writing, that this was the case. It is further averred that PlaintilT
never interfered with the children's use of Ihe lelephone and has routinely made the children
available at the lime scheduled for telephone calls in the Court Order. It is further averred Ihat
Father did not call the children for, at least, a period from May 5, 1999 through July 25, 1999.
5d. Denied. It is denied that Mother (Plaintifl) has violated paragraph 5 of the
Agreement which requires her to provide Father (Defendant) with copies of all doeumentction
provided to her by each of the children's schools within ten (10) days of receipt thereof. It is
averred rather that Plainti ff has made specialarrnngements for the Defendant to receive direct
Respectfully sub milled by,
mailings from the children's school and, in fact, has frequently been in contact with the
children's school. It is further averred that in addition to the direct mailing that Defendant
received from the school, Plaintiff provides report cards and other materials that she received
from the school directly to Defendant despite the fact that this routinely provides Father with
duplicate mailings of such documentation.
7. Denied. To Plaintirrs belief, based upon Defendant's actions, Plaintiff docs not
believe that Defendant truly desires to see the children for summer visitation and, in fact,
believes that his actions and conduct renectthe fact that he docs not wish to have a relationship
with the children as much as he wishes to create turmoil in the Plaintirrs life.
WHEREFORE, Plaintiff requests your Honorable Court to dismiss the Contempt Petition
filed in this action.
. Ie, Esquire
y Ii Plaintiff
North Hanover Street
YCarlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE:
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EMILY LONG HOFFMAN
Allorney at Law
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108-1475
(717) 233-1112 FAX (717) 234-2234
"
JUl 2 0 1999tP
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STEPHANIE L. RUPP,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
v.
NO. 95-1588
MICHAEL L. RUPP,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
You, Stephanie Rupp and Michael Rupp. are ORDERED to appear in person before t:'n\.J r'\ \.
~{'\,~\ ,f.'A" .CUSlodyConciliator.at~ \J, tb\r\ ~\-.\ \-\(r~\(.\hsgl
p~ on A~0S\ '5". \'H1 at_
l o'clock +.m. for a Custody Conciliation Conference. At such Conference. an effort will be made to
resolve the issues in dispute; or if this cannot be accomplished. to define and narrow the issues to be heard by the
Court, and to enter into a Temporary Order. All children age five or older may. at the request of either attorney or
party. be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a
temporary or pennanent Order.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty A venue
Carlisle. PA 17013
(717) 249-3166
1-800-990-9108
FOR THE COURT:
Date:~
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STEPHANIE L, RUPP,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1588
MICHAEL L. RUPP,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CONTEMPT PETITION
AND NOW, comes Defendant, Michael L. Rupp, by and through his attorney, Emily
Long Hoffman, Esquire, and in support of his Contempt Petition avers as follows:
1. Richael L. Rupp, defendant (hereinafter "Father"), resides at 32 Evergreen Street,
Apt. 12, ThompsDntown, Pennsylvania 17094.
2. Stephanie L. Rupp, Plaintiff (hereinafter "Mother"), resides at 1897 Boca Raton
Drive, Lake Oswego, Oregon, 97034.
3. The parties are the parents of two minor children namely Arnie Elizabeth Rupp,
born July 25, 1983 and Justin Michael Rupp, born April 27, 1987.
5. Mother is in contempt of this Order for the following reasons:
4. The parties entered into a custody stipulation which was made an Order of this
Court on January 6, 1997, a copy of which is attached hereto as Exhibit "An.
a. Pursuant to Paragraph 3.(a) father is to have custody of the children from the second
Saturday after school has ended during the summer vacation months until the second Saturday
prior to the beginning of school.
b. Mother did not send the children for their visitation as required by the order and
cancelled the children's plane reservation prior to them leaving.
c. Mother has also violated Paragraph 4 which provides Father telephone contact with
the children and has not called Father at another appropriate time.
d. Mother has violated Paragraph 5 of the agreement which requires her to provide
Father with copies of all documentation provided to her by each of the children's schools
within 10 days of receipt thereof
7. Father desires to see his children for his summer visitation.
WHEREFORE, Father requests that this Honorable Court find Mother in contempt and
pay for and arrange the children's transportation to and from Pennsylvania and pay his
anomey's fees and costs for enforcing the order.
Respectfully submined,
By:
{1Y
EMILY LONG H FMAN, ESQUIRE
Sup. Ct. 1.0. # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108-1475
Date: 7/20/99
(717)233-1112
.. '
STEPHANIE L. RUPP, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v. . CIVIL ACTION - LAW
.
.
.
MICHAEL L. RUPP, : NO. 9S-lSBB CIVIL TERM
Defendant . IN CUSTODY
.
ORDER OF COURT
AND NOW, this t:,#... day of J;u y-tl1Rj
7
, 199', the
attached Stipulation and Agreement is hereby made an Order of
Court and all prior Orders on this matter are hereby vacated.
BY THE COURT,
,Iv Muur& - P /;)12.f
J.
TRUE COpy FROM RECORD
In Testimony whereof. I.here unto set my hand
on' ... uaJ"'" ~..
\.Thl~, ~Yp 1 ~~
CUSTODY
STIPULATION AND AGREEMENT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSt,LVANIA
c::: :s f;;l
CIVIL ACTION - LAW --.::(;;;,. ~
t';L' :;:: i':;~
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NO. 95-158B CIVIL TERM ;;~C: I ]
IN CUSTODY ~_. w ';)
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STEPHANIE L. RUPP, .
.
Plaintiff
.
.
v. .
.
:
MICHAEL L. RUPP, :
Defendant .
.
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between stephanie L. RUPP,
(hereinafter referred to as "Mother") and Michael L. RUPP,
hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Amie
Elizabeth Rupp, born July 25, 1983 and Justin Michael Rupp, born
April 27, 19B7, (hereinafter the "children"); and
WHEREAS, the parties are presently divorced and living in
separate residences; and
WHEREAS, the parties wish to have the Court vacate their
prior agreement and Order of Court dated March 15, 1996.
WHEREAS,
the parties wish to enter into a
modified
agreement relative to custody and partial custody of the
children.
NOW, THEREFORE, in consideration of the mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as follows:
1. The parties shall have joint legal custody of the
children.
-----..
2. Mother shall have primary physical ot the children.
3. Father will have periods of temporary or partial
physical schedule on the following schedule:
(a) From the second Saturday after school has ended for the
children during the summer vacation months until the second
Saturday prior to the beginning of school tor the following
school year;
(b) During the Christmas holiday season for a period of one
week, alternating those weeks on the following schedule:
(i.) the period from the day after
school ends for the Christmas/New Years
vacation season for a period of one week
(seven days); and
(ii.) for a period of one week beginning
eight days prior to the children's return to
school and continuing for a period of one week
(seven days) to the day before the children
return to school following the Christmas/New
Years' holiday vacation and with Father having
the first period herein for Christmas 1997.
(c) Every other year for the spring school recess period
beginning on the Saturday following the last day of school before
the recess begins until the Saturday prior to the end of the
school recess, with Father having the spring recess for 1997 and
each odd-numbered year thereafter. In the event Father will be
,
unable to exercise this period of temporary cutody,
notify Mother no less than forty-five (45) days prior
first day of the spring school recess.
(d) At other times as the parties may agree.
4. Father shall have telephone contact with the children on
a weekly basis with the phone call to be made at 7:00 p.m. on
Wednesday evenings EST. In the event the children are not going
to be available at that time, Mother shall take responsibility
for placing the call to Father one or two days prior to that time
to allow the children to speak with Father at that time, or to
advise Father of another appropriate time when the children can
have telephone communication with Father. Father shall, in
addition, be permitted to have telephone contact with the
children at other times during the week, should he so desire.
5. Within ten (10) days of the beginning of each school
year, Mother shall provide Father with copies of all
documentation provided to her by each of the children's schools,
including school calendars, school rules and regulations,
information regarding the children's teachers, and similar
information. In addition, within ten (10) days of receipt of any
report card, deficiency report or similar reports evidencing the
children's grading, Mother will provide a copy to Father.
Further, Mother will notify the children's schools that Father
has shared legal custody as provided hereinbefore, and as such,
the schools shall respond to any inquiries made by Father
concerning requests for information regarding the children's
SChooling.
he
to
must
the
6. The parties agree that Mother shall be responsible for
the costs of transporting the children to the Father for his
period of physical custody of the children during the
Christmas/New Year's holiday season and for the costs associated
with transporting the children for his period of physical custody
during the summer vacation season. The parties shall equally
share the costs associated with transporting the children for
their period of physical custody with Father during spring
vacation or spring break, as provided for herein. In the event
that either party fails to return the children pursuant to the
terms of this paragraph after the other party has incurred the
expense for transportation, the party who fails to comply with
the terms of this Agreement shall be responsible to compensate
the other party in the amount of three times the expense
associated with providing the cost of transporting the children,
along with any other remedies any Court of appropriate
jurisdiction deems reasonable.
7. In the event Father has need for child-care services
during his extended periods of temporary physical custody as
provided for herein, he will notify Mother in advance of the
name, address and telephone number of the individual that he
wishes to use for this purpose.
8. The parties will keep each other advised
relative to any emergencies concerning the children
further take any necessary steps to insure that the
well being of the children is protected.
immediately
and shall
health and
9. Neither parent shall do anything which may estrange the
children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
10. Any modification or waiver of any of the provisions
this Agreement shall be effective only if made in writing
only if executed with the same formality as this stipulation
Agreement.
11. The parties desire that this stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
CUmberland County, acknowledging that the Court of Common Pleas
of Cumberland County has jurisdiction over the issue of custody
of the parties' minor children at the time of entry of this
Order.
of
and
and
12. The parties agree that in making this Agreement,
has been no fraud, concealment, overreaching, coercion, or
there
other
unfair dealing on the part of the other.
13. The parties acknowledge that they have read and
understand the provisions of this Agreement. Each party
acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
.,....--;' '"
. .
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
WITNESS:
Date: Id//I#I/
.
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.6TE HANI~ L. PP
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COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
On this th...J~ day of f) J.~
, 1996, before
me, the undersigned officer, personally appeared Stephanie L.
Rupp, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
.
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COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Leah A. Miller, Notary Public
Canlsle BolO. Cumbenand County
My Commission expires April 17. 2000
COUNTY OF CUMBERLAND
On this the /lM
)
) SS
)
of .J.e.c'<..'">-nb~
, 1996, before
day
me, the undersigned officer, personally appeared Michael L. Rupp,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Contempt Petition was served upon
the following person by first class U.S. Mail:
Bradley L. Griffie, Esquire
200 North Hanover Street
Carlisle, PA 17013
By:
~lIY ..bm;lIo1.
s---cr.k.~
Emily Long Hoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 7/20/99
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. ..~e ~er,of ~998,! both: ~bil~~ a#m'p~.cf. tOI.lea~.h airiU:com#o~~ ~,~. ~a~~tIiBt: :'.;,,: . : .
, WOUI~'~~e allowed th~.to~;~e FPeriOd of~e that ~~YW()~~~~SP~~:i~~#t~~:; .:,r,:[ :"1""
. but Fa~er ~ould not acc.o~o~te, ~h' request and the chi1drenw~re ~lttr~rlY di~Pleasfd .~d i;. ;j,
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. desp~n~t ~~erth~ bUlkOr~?ir:~lmf] SPlint ippennsylvania.~e ~~er.~~~arntty attch1p1cd' ;1;. i ' :. .
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. to spend ~<<:io~' ~f jUs ~~~pi{~~.W;ith:tlie:clii~et1-ovenli~~~er.,.~~if\\:3s ~tiepielY::,:, (:
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. limited \$.eno'ne.co.hsidei:'$ili.~:~xt~4ed;~rio9..!Jf~e:th~y.~~~r~~.:11i~y.*bi\(ihos(a~~ir j! :.'.,,: '.
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Of course...tjl~ chil~n: are aro-.involved i~ extracUrric)o!l~ :ac~ViU~ 'at thefr bi~~. i~ !: :f.
Oregon: rhiC~ 'were. affe~ted by theif'inability to .ta)ce part ~. .p.~e~s~p.ri.p~~~.~.,:~~~~,; ~~ ii:' .::! . ." .
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· similar aspects of their routine life. i i . I .
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1l1en. even though the Court Orqer provided for the children tospend'their 1999 !spring i,
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break in PeMSylvania, Fath~r never followed up on that and the spring bre~ simply ~cnt by I:
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without:ty request on his part for th~ children to be here. Shortly after the spring breakJ' eriod, !. . t
however.: the children began contacting their Father again, asking if the summer of 199 i could I
include a'reduced period of time rather than what is required on the Court Order. Again. !Father !
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responded indicating that he was extremely hurt by their request and refused to accommodate in
any fashion. In fact, Father had no contact whatsoever with the children for three month~ in the
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Jothcr has attemPte~' 'io do Wh~~ 'she can to de~eloP ~ ~ette~ ieiati6n~hi~' ~etweb the :: l' i
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". '.:-l:Ietwee~ l:e 'hi1cJ.n:i1luid.thcil.Flitlicr.:{.;iIS~yc': 'liniited:When:the:childl .rt'mo~ecHo'li'l~ "'Wjili, "r';:,l, ;.: .~;.(.'
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. . . ':telling th&~.iIii\:l ;Slie ';;(;uid:b~gb:t:koiibk.:f~~CoD.terb~~~Ui:eY\iid.'hor,.gQ~:~ugg~~tiiigth;ki.b,ey. ',rJ;;. .,~:: 'r,.
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requests,ty. attempting t.~ chan.ge, the .an:angements belVieen :n.ow; :and~~id y;e~; ~d. ~.ill~ili.ig !':" . i
. th~irc~~~c~: witp. ~e~f' ;f~~l:fj~~.~~e~pt to.:t1J:~.~,ly~~~!Iss: ~p.m:e.}~~~~~:P~ri<?d;.of '\..,
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: childreq.itliat s1!e haddbne,thls:1li1d;.:QY doing so, should be !n.apos!tiof') to:help.them' 5c:;c'~c;:a.:: '
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mare ac~eptable visita:tion schedule for the year 2000. Urifortunately, 'evi:'n this effcrtdi~'not ii',:' ,
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. assist hC1j in seeming any cooperation from the children. . ! !~,
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The cbjldren have expr~ssedfear of their Father. Th~ children h*vebe~n distraug\\t ~ver ii'
, :' ~ I i
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being fotced into a totally unaccept~ble situation from their perspectiye and h!lve bee1 u.pset :!.
over thei~ Father's unwillingness to maturely discuss this type of issue with ~em'and undJrstand 1
. !
their side of the story.
Mother's present husband has substantial frequent flyer miles available to bim so Mother
intended to redeem some of those miles for the tickets to fly back to Pennsylvania. Beginning
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over the ~ast three (3) Y,earS :has doJi,c :riothing m!lre tluinPlJsh t1iem f'urther away. fro~ their
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Father in ~at relationship.
II DEFJNDANT . 't1\mSSES ," ", .'. '" ;. ,,' .,,',,' i. ;f:
'\ WI H't:' " : ," ',:-~..,;, "I":~"!:' ;:-::"~" . .1,." ' ,;,.; ;..,..,. ""':,': 'f< '",; :, ,"1" , ,.,'
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A,!,' : St~hlmic:k::~~n:~it,~~~ to:,tii~:ciic~~~~ "~tihoiuJJg~~~#~ ; its': ;1;,,\ : ';',~
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~'. arid the irto~~Jtive 'visitJ!'in~~:,ease.~ ~Ji iui,ih~,:?riiSl0g,n~o~atio~,~:,ili~p,~~~lr~ in; :H:" ': ,I,
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, ,I , . B~,.' \ George to~~;U~ ~Jio.'t~~JCo~.,:,il1iW:husb:.riq';:maY-:~,:re;')n~tid:fd"tesJfy,bY. '1\';.,: .:,' ,;:
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teJep~on~ as to ~:Co~waJI:~ ?n~~,,~~'rtS :to ~~ th~ ,c~~n,:~~i~::N;itlt ~,~~;~~~:~5, n:, \,;':i
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" well as any, iSsues relat~d;t~, theiallekatfmi ~t Moth~rdid not,'ti.Id::app~riat~'aCdobs,to,f.e6uc. ::' i', '..,', ':
'.- ..-.' ~"::'~c'''..,' ":>".:.._;.~:":"..:" !. 'j'" i~.'~::..~_,~,,-.I';~:,~'..~.,'.>.~"~.'.:.:.....il~... :
:aklirie tick~tsfor,th~~hildi~;io'~cinieti~eriiisYlv~ia." : ;': .::;: ',: '; ,,; ::XI:.; '. ';;!: :~
. ,,' ~f. ';!~o~~' ~~cili~: :'~~:'~~'!is:::~e; :~idi~!s:kL~I~~:;~~: ~4~~:'&~J..:h~~e' 'ftl:i. ~: ;:,'i
eounsele{ r~l~tive to~ese:i~~~es, "The ~o~ns~lo~ w~:s,~~~,~y:~o~~,+.~'~~o4'+~~ve L I ' ,
, ~om~ind~~endei1L~oice~~ngt() de~elop someacc6~odatioh \With ~e~Iiiidren for ili~'to ',: i
': . r-. -: :'/ ':; :;--;:". ::,;h....f..:::~ ,'\ ::.,.. ~-:::'.; ":',i- \.:,~ .~~,.. ";~::. j':;' '" ~
be agr~Dle' to visiting their Eath:er. :' ", '., ," , ' ,', :',' .'; ," , :'. " I .' "~,
,r. " . _~;' _:,' .', ": _..'l,.~'"..;, . :\';-i','-':~,~'~'" . ,..::..', ~r:"
D[. , ~e Eii~a~t~'RuPP~d JuS~nMi~ha~i' R~p;~e ili~ ~~~ ~h:l~eri.;:+~ther..:r: r-;
, \Viii requ~sfihe o~po~ity f~r,:tbe ~hil~n t'o present their pb~\ti~qOt~*.<ici~/,~~::<, ~:'!:,i);,'::, ;[: ~'; I
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i..' " , . I RespectfullVl'submi,tt'e,',d,,:.',' ; e':":, ::;,1' ';'''' 1'1:;" I:
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B a ri ulre
Attorney for De enllimt ,
200 North Hanover Street
Carlisle, PA 17013
(717) 243-555 I
{SOO} 347.5552
~Jd:::t' :so ~."'b I-I:,l-ll
STEPHANIE L. RUPP,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 95-1588
MICHAEL L. RUPP,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S MEMORANDUM
1. Position
It is Father's position that Mother is in contempt ofa court order. The Custody Order
provided Father with summer visitation. Mother contended that she had tickets and that the
children refused to embark on their flight two hours prior to their departure. Evidence will show
that Mother never redeemed the tickets as required two days prior to the flight, thus, the tickets
were never issued.
2. Defendant's Witnesses
A. Michael L. Rupp, Defendant, father of child
Defendant will testify with regard to matters concerning his missed summer
visitation with the children and why he believes Plaintiff is in contempt of the custody order.
B. Delta Air Lines Representative
Representative will testify that the tickets were never redeemed as required by
June 24, 1999 and the ticket was therefore canceled.
C. Nadine Rupp, Michael Rupp's Mother
Will testify regarding conversations relating to the visitation.
D. Roberta Womer, Michael Rupp's Fiance
Will testify regarding conversations relating to the visitation.
Date: \ \/11 1(1'1
~espeetful1y submitted:
L' I
Emily Long Ho an, Esquire
Sup. Cl. ID # 66307
105 North Front Street
Harrisburg, PA 17108
(717)233-1112
,
CERTIFICATE OF SERVICE
1 hereby certify that a true and correct copy of the attached document was served upon
the following person by U.S. Mail on this day:
Bradley L. Griffie, Esquire
200 North Hanover Street
Carlisle, PA 17013
Respectfully submitted,
By: ,UJ. '
Emily Lon Hoffman, Esquire
Sup. Cl. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 11/11/99
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IN TIm CIRCUIT COURT FOR THE STATE OF OREGON
FOR TIm COUNTY OF CLACKAMAS
In the Matter of the MaIriage of )
) .
STEPHANIE L. RUFP. ) No. 98 06 367
o.k.:!.. STEPHANIE CORNWALL. )
) AFFIDA vrr OF STEPHANIE L.
Petitioner. ) RUPP/CORNW ALL
)
and )
)
MICHAEL L. RUFP. )
)
Respondent. )
STATE OF OREGON )
) ss.
County of Clack:ll:nas )
t. Stephanie RUPP/Cornwall. lleing :irst duly sworn. depose md say:
..
I JIll the ?emioner 10 the :1bove.~ntltled matter.
,
The children born oithis mamage:l1'e Arnie::. Rupp. oorn juiy :'5. 1983.
md Justin M. Rupp. born Apnl :7.198;,
! --\fFIDA 'lIT OF STEPHANIE L. Rl:P!"CORNWALL
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3.
The children are desirous ofbavi.ng visitation modified as follows based
Il"!lon their ages and wishes:
(a)
To have visitation with Respondent for no less than thiny (30) days during
the months of June thIOugh July. The children wish to remm to Oregon on or berote
August I, due to recreational and ~chool activities which begin during the month of
August.
(b) To continue to have Christmas. visitation ye:lriy with Respondent for a
period of approximately one week. or as their school schedule permits.
(c) To discontinue Spring Break visitation with RespondenL
(d) To discontinue scheduled Wednesday telephone contaCt with Respondent,
but pemritting telephone contaCt with Respondent at any reasonable time during the
week.
(e)
As a result of visitation issues with the children. they are cun:ently seeking
professional assistance through Dr. Thomas Deshler in Oregon City, Oregon.
4. Child support for the children should be modified due to a change in
circumstanCes. Petitioner has recently purchased a home in which the mortgage is solely
her responsibility. Additionally, changes in employment for both parties suggests a
rec:llcula1ion of support to be appropriate at this time.
'J'J
--
5. ...IJso in regard to the visitation and support arrangements. Petitioner feels
,~.,
~...
it to be :norc re:!Sonable for the parries to share the coSts ofmmsporring the children [0
:'~
md from Pennsylvania for se:!Sonal VIsitation ~qually. Presently, the tinanclal burden
,~
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solely lies with Petitioner.
::. _ ,~F!DA VIT OF STEPHANIE L. RUPP/CORNW ALL
,~E &. ~CHIl.1.llC
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DATED this /7111 day of J~ 1998.
##LJ~I'~'~/~H'n/L-
/Stepbanie . RuppiComwall
Petitioner
-til-
SUBSCRIBED AND SWORN TO BEFORE ME this \ \ - day of June,
1998.
't~/~~
No Ubllc or Oreg:;;
My C"mm;~!rion E:cpires: 7;'(~
I I
. OfflCI,\LSEAL
APmLJl.SCH::
~IllI.G55lZlI
. IIY~EJI'lIIQ.AIU"Ull.
26
3 - AFFIDA vrr OF STEPHA1'i1E L. RUPPfCORNW ALL
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IT IS FURnIER OIlDERED AND ADJUDGED that both parties file and serve on the
Other their Uniform Support Affidaviu not less than five days before said bearing dale.
DA1'ED this -:1V day ofJuly, 1999,
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Page
ISI PAllUCK o. GILROY
CIRCUIT COURT JUDGE
rr IS SO MOVED:
DATED this "0''1-' day of July, 1999,
BLAKE &; DUCKLER, LLP
-
-----
Larry J. Blake, Jr., OSS /#87112
Attorney for Petitioner
.............
NOTICE TO RESPONDENT
M the beariog on p~tioner' 5 contempt motion. you have the right to be
represented by cOllll!el. If you cannot afford an attorney, tbe COllrt may be
required to appoint one for you. Further. you must personally appear in the abnve
entitled coun cue at the date and time speCified in this order, If you fi.il to appear
in conrt at SIIch date and time. you may be arrested and held in c:ustody for the
puIllose ofbeinR brought before the court to answer the contempt charges which
have been made Igainst you,
2 _ MOTION AND ORDER TO SHOW CAUSE
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IT IS FUR.11IER ORDERED AND ADJUDGED that both parties liIe and Sel'Ve on the
I
other their UnifonD Support Affidavits nOl less than five days before said hearing dare.
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~
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DATED this ~ day of July, 1999,
ISI p~lR'CK g, GILROY
CIRCUlT COURT ruoGE
IT IS SO MOVED:
8
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BLAKE & DUCKLER. LLP
10
II
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Larry J. Blake, Jr., OSO 1187172
13 Attorney for Petitioner
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DATED this :1"1-' dlY ofJuly, 1999
-
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NonCE TO RESPONDENT
At the hearing on petitioner's contempt motion, you have the right to be
represcoted by counsel. If you cannot afford an attorney, Ihe coon may be
required to appoint one for you, Further, you must personally I{1pear In the above
entitled coon cue It the date and lime specified In this order. !fyou wi 10 appellC
in coon at such date AIId time, you may be arrested and held in custody for the
purpose of being brought before the coon to answer the contempt chuges which
have been made against you.
"
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Page 2 _ MOTtON AND ORDER TO SHOW I;AUSE
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IN TIlE ClRcurr COURT FOR THE STATE OF OREGON
FOR THE comrTY OF CLACKAMAS
In the Matter of the Maniage of )
) 98 06 38'7
STEPHANIE L. RUPP, ) No.
o.k.a. STEPHANIE cORNWALr~ )
) AfFlDA vrr OF STEPHANIE t,
Petitioner. ) RUPP/CO!tNW ALl.
)
and )
)
MICHAEL L. RUPP. )
)
Respondent )
STATE OF OREGON )
) 55.
CoUIItY of Clackamas )
I. Stephanie RupplCnmwall. beinll first duly sworn. depose nod SR~P
1.
( .un rhe Petitiuner in the 3bove entitled maner,
2.
The cbildn:n born ortllis mamsge nre Amie E RUIlP. born July ~5. 1983,
,-
and Justin M. Rupp. born April 2'/. 19111,
I _ AfFIDA VIT OF STEPHANIE L. RUPP/CORNW ALL
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The children ue desirous of having visitation modified as follows hll!ed
upon their ages and wishes:
(a) To have visitation with Respondent for DO less lhan thirty (30) days durinll
the months of June through July. The children wish 10 ~rum 10 Oreaon on or before
Augusl I. due to tecreatiouaJ and school activities which beain during the month of
AUgust.
(b)
To continue to have Christmas visitation yearly with Respondent for l\
period of approltiJDately one week, or as their school schedule pennits.
(c) To discontinue sprina Brc4k visitation with Respondent.
(d) To discontinue scheduled Wednesday telephone contaet with Respondent.
but permitting telephone contaCt with Respondent a1 :my ~asonable time during the
week.
(e) As a result of visitation issues with the children. they are curmrt1y seeking
professional assistanCe through Dr, Thomas Deshler in Otegon City, Oregon.
4. Child support for the children should be modified due to a chanae in
circulllSWlces. Petitioner has recently p\IfCwed a home in which the mortgqe is solely
her responsibility. Additionally, changes in employment for both parties suggests a
tecalculatioD of support 10 be appropriate at this tI1ne.
"
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Also in regard 10 the visitation and support arrangements. Petitioner feels
s.
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it 10 be more re3Sonable for the panics 10 share the costs of tranSJlorting the children to
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lII\d from Pennsvlvania for sCllSono.l visitJIlion equ:1lly. Presently, the financial burden
solely lies with Petitioner.
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:2 _ AFFIDAVIT Of STEPllAl'lIE L. RUPP/CORNW ALL
"uy-LJU-!:JI~ \..Iu......&.
\ DATED this /71lY day of JUDC.1998.
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##""iI4!t'/j?"''''''JL
/Slepbmie . RupplComwall
Petitioner
SUBSCRIBED AND SWORN TO BEFORE ME thiJ \,1; day of June,
1998.
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Page
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No c of Crego
My Commission Expires: -r(~
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3 _ AfFtDA VIT OF STEPHANIE L. RUPP/CORNW ALL
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.. PETITIONER'S
" EXHIBIT
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LF11
STEPHANIE L. (RUPP) CORNWALL,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
: CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
NO. 95-1588
: IN DIVORCE
PLAINTIFF'S PRE-TRIAL MEMORANDUM
I. PLArNTIFF'S POSITIONI HISTORY OF CASE.
The Mother's position in this case is that both of these teenage children have had
difficulties in their extended summer time visits with their Father here in Pennsylvania. Prior to
the summer of 1998, both children attempted to reach an accommodation with their Father that
would have allowed them to reduce the period of time that they would spend in Pennsylvania,
but Father would not accommodate their request and the children were extremely displeased and
despondent over the bulk of their time spent in Pennsylvania. While Father apparently attempted
to spend periods of his vacation time with the children over the summer, this was extremely
limited when one considers the extended period of time they were here. They spent most of their
time with a babysitter.
Of course, the children are also involved in extracurricular activities at their home in
Then, even though the Coun Order provided for the children to spend their 1999 spring
Oregon, which were affected by their inability to take pan in pre-season practices, camps, and
similar aspects of their routine life.
break in Pennsylvania, Father never followed up on that and the spring break simply went by
without any request on his pan for the children to be here. Shortly after the spring break period,
however, the children began contacting their Father again. asking if the summer of 1999 could
include a reduced period of time rather than what is required on the Coun Order. Again, Father
responded indicating that he was extremely hun by their request and refused to accommodate in
any fashion, In fact, Father had no contact whatsoever with the children for three months in the
spring. Father simply insisted that the children would come and that was the end of the story
from his perspective.
Mother has attempted to do what she can to develop a better relationship between the
children and their Father, even though their relationship was always strained. The relationship
between the children and their Father was very limited when the children moved to Oregon with
their Mother approximately three years ago.
Mother has tried various angles to get the children to accept the current situation and visit
without the ongoing request for a reduction in their time with their Father. This has included
telling them that she could be in trouble for contempt if they did not go, suggesting that they
could be in trouble for contempt if they did not go and indicating she would accommodate their
requests by attempting to change the arrangements between now and next year and facilitating
their contact with their father in an attempt to maturely discuss some reduced period of
visitation. Despite her many attempts, nothing seems to work going into the beginning of the
summer of 1999,
In the late spring of 1999, Mother initiated proceedings in Oregon to modify the Custody
Order as that Court now has jurisdiction of the issue of custody of the children, She advised the
children that she had done this and, by doing so, should be in a position to help them secure a
more acceptable visitation schedule for the year 2000. Unfortunately, even this effort did not
assist her in securing any cooperation from the children.
The children have expressed fear of their Father. The children have been distraught over
being forced into a totally unacceptable situation from their perspective and have been upset
over their Father's unwillingness to maturely discuss this type of issue with them and understand
their side of the story.
Mother's present husband has substantial frequent flyer miles available to him so Mother
intended to redeem some of those miles for the tickets 10 fly back 10 Pennsylvania. Beginning
approximately one or two weeks prior to the children's leave, they indicated that they were flatly
refusing to go despite Mother and Mother's husband talking to the children about the need to go,
the fact they should maintain a relationship with their Father and similar arguments to support
their position that the children should visit. The children continued in this position until the day
when they were to leave. On that day, the parties' 16 year old daughter went to her bedroom
crying and sobbing, refusing to go to the airport with her Mother. The parties' son similarly was
sobbing and crying, begging his Mother not to literally drag him out to the car to go to the
airport. Mother's husband was not present at the time so she was unable to get his physical
assistance in somehow trying to physically force the children into the car, into an airport and
onto an airplane. Under those circumstances, the children did not come to Pennsylvania which
resulted in the filing of the Petition lor Contempt.
[n the meantime, Father has retained legal counsel in Oregon and their ongoing
negotiations relative to a modification of the present Order, which includes a proposal that
appears to be close to being accepted where the children's time in the summer would be reduced
to one month. [f that agreement is reached, then some of the issues that have been creating the
problems over the past two (2) years in the summer vacation period will have been resolved.
It is the Mother's position that she did everything within her power to force the children
to come to Pennsylvania, but, at their ages, her ability to physically force them to come is
obviously limited and, therefore, she did not take any willful action that should cause the Court
to find her in contempt. [n addition, she is bringing the children to Pennsylvania for the
contempt hearing in order for them to express their position to the judge, if necessary, even
though they are already involved in the litigation in Oregon, Mother has advised the children
that they should expect to spend some time with their Father while they are here in Pennsylvania
over the weekdays before Thanksgiving, although the Court may need to intervene to discuss
with the children what periods of time they are willing to spend with their Father. While Mother
does not believe the children should simply dictate when they will and will not see their Father,
she is keenly aware that essentially shoving the custody and visitation Order down their throat
over the past three (3) years has done nothing more than push them further away from their
Father in that relationship.
II. DEFENDANT WITNESSES,
A. Stephanie Cornwall will testify to the circumstances surrounding the prior visits
and the prospective visits in this ease, as well as the ongoing negotiations in the pending ease in
Oregon.
B. George Cornwall, who is Ms. Cornwall's husband, may be requested to testify by
telephone as to Ms. Cornwall's ongoing efforts to have the children visit with their Father, as
well as any issues related to the allegation that Mother did not take appropriate actions to secure
airline tickets for the children to come to Pennsylvania.
C. Thomas Deschler, Ph.D. is the children's counselor with whom they have
counseled relative to these issues. The counselor was secured by Mother in an effort to have
some independent voice in trying to develop some accommodation with the children for them to
be agreeable to visiting their Father.
D. Arnie Elizabeth Rupp and Justin Michael Rupp are the parties' children. Mother
will request the opportunity for the children to present their position to the Court.
Respectfully submitted,
~'
rupp ,11m
v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1985-1588 CIVIL TERM
STEPHANIE L. RUPP,
Plaintiff
MICHAEL L. RUPP,
Defendant
CIVIL ACTION - DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
AND NOW, comes the Defendant, Michael L. Rupp, who submits the Pre-
Trial Statement in accordance with Pa.R.C.P. 1920.33(b), as
follows:
I. LIST OF ASSETS
(l)(i) MARITAL ASSETS
ITEM
1. Real Property
14 E. Oakwood Dr.
Carlisle, PA
(Home sold on
11/27/95 )
VALUE
DATE OF
VALUATION
NON-MARITAL
PORTION OF
VALUE
LIENS OR
ENCUM-
BRANCES
99,900.00 11/95
($34,394.71
-sale
proceeds)
NIA PSECU
$37,016.79
$19,296.09
2. H's State 15,517.00
Employees' Retirement
System Retirement Plan
3. Investments
12/31/94
NIA
N/A
A. Still in Existence
(I) 109.792 shares of
McDonald's 5,270.02
(2) 2.9576 shares of
Chase Manhattan
3/29/96
NIA
NIA
217.38
3/29/96
NIA
NIA
(3) 125.015 shares of
Wendy's 2,281.52
3/29/96
N/A
NIA
ITEM
VALUE
(16) 118.607 shares
of Atmos Energy
Corp. 2,727.96
(17) 52.009 shares
of Allied Group 2,067.36
(18) 1.234 shares of
Phoenix Growth Fund 31.26
(19) 1.426 shares of
Phoenix Capital
Appreciation Fund 21.63
(20) 2.075 shares of
Phoenix International
Fund 27.52
(21) 2.795 shares of
Phoenix Worldwide
Opportunities Fund 26.83
(22) 32.607 shares of
AFLAC 1,018.97
(23) 1.5690 shares
of Founders World-
wide Growth Fund
33.29
TOTAL VALUE -
26,052.Bl
B. Liquidated by
Defendant
(l) Mas1and's Stock 1,610.63
(2) Invesco Ind.Inc. 2,954.19
4. H's 1989
Chevrolet Beretta
3,000.00
5. W's Household
Furnishings
3,000.00
NON-MARITAL LIENS OR
DATE OF PORTION OF ENCUM-
VALUATION VALUE BRANCES
3/29/96
N/A
N/A
3/29/96
NIA
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
N/A
N/A
N/A
NIA
N/A
N/A
current
N/A
NIA
current
N/A
N/A
rmI
VALUE
DATE OF
VALUATION
NON-MARITAL
PORTION OF
VALUE
LIENS OR
ENCUM-
BRANCES
6. H's AIG Life
Insurance Policy
#U860038l4
unknown
N/A
N/A
N/A
7. W's AIG Life
Insurance Policy
IIU86003815
unknown
N/A
N/A
N/A
(l)(ii) NON-MARITAL ASSETS
LIENS OR
DATE OF ENCUM-
ITEM VALUE VALUATION BRANCES
I. H's Household $3,000 Current N/A
Furnishings
(2) EXPERT WITNESSES
The Defendant has a diagnosis of Bipolar Affective Disorder. Dr.
Richard Fonte, a psychiatrist, and Cheryl Shope, a licensed
psychologist, may be called as a witnesses to testify concerning:
(1) the Defendant's diagnosis and the condition's relationship to
the Defendant's past behavioral problems and spending habits, and
(2) the prognosis.
(3) TESTIMONY OF OTHER PERSONS
Karen Cumberledge, supervisor at LCB Comptroller's Office, may be
called as a witness. Defendant reserves the right to call others
that may be identified as being necessary at the Pre-Trial
Conference.
3. PA State Employees'
Federal Credit Union
Acct. #0176465988 Ll-PSL
Loan
4,228.56
(2,642.93 -
Mari tal)
Unknown
Unknown
4. PA state Employees'
Credit Union - VISA
Acct. #0176465988
7,008.40
(4,347.90 -
Mari tal)
Unknown
Unknown
5. Vehicle Lease for
1994 Ford Aerostar in
Wife's Possession
Unknown
Unknown
Unknown
PURPOSE
AMOUNTS/DATES
OF PAYMENTS
SINCE SEPARATION
EVIDENCE IN
SUPPORT OF
CLAIM
1. Mortgage on
Marital Residence
Unknown
HUD-l
2. Mortgage on
Marital Residencel
Equity Loan
Unknown
HUD-l
3.
Various Charges
Credit Card Purchases
None
Unknown
None
4.
Unknown
5.
Vehicle Lease
None
Unknown
(11) PROPOSED RESOLUTION OF ECONOMIC ISSUES
A. Alimony, Alimony Pendente Lite, Counsel Fees and Costs -
Husband believes that Wife has an earning capacity greater than her
current earnings. Nonetheless, Husband is willing to agree to pay
alimony in the sum of $75 per month for a period of two years from
the date of the entry of the final divorce decree.
B. Equitable Distribution - Husband proposes the following plan
for equitable distribution:
INCOME AND EXPENSE STATEMENT OF
MICHAEL L. RUPP
SSN 176 - 46 - 5988 DRI 23.653 DATE 411/96
THIS STATEMENT MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of
which you are owner in whole or in part, you must also fill out
the Supplemental Income Statement which appears on the last page
of this Income and Expense Statement.
INCOME
(a) Wages I Salary Commonwealth of PA
Employer & Address PLC8 Comptroller's Office, Harrisbur~. PA
Job TitlelDescription Accountant - Inventory Control Section Chief
Pay Period (weekly, bi-weekly, monthly) Bi-weeklv
Gross Pay per Pay Period...........................$ 1.484.25
Payroll Deductions:
Federal Withholding....$ 224.93
Social Security......,.$ 113.54
Local Wage Tax.........$ 14.84
State Income Tax.......$ 41.56
Retirement.............$ 74.21
Health Insurance.......$
Other (specify)........$
Unempl. Compo ........$ .45
....... .$
Net Pay per Pay Period.............................$ 1.014. 72
(b) Other Income Week Month Year
Interest/Dividends.......$ $ $
Pension/Annuity..........$ $ $
Social Security..........$ $ $
Rents/Royalties..........$ $ $
Expense Account..........$ $ $
Gifts. . . . . . . . . . . . . . . . . . . . $ $ $
Unemployment Compensation$ $ $
Workmen's Compensation...$ $ $
Total, Other Income.......... .$ $ $
I verify that the statements in the foregoing pleading are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
$ 80.00
$ 250.00
$ 80.00 $
$ 100.00 - BantruDtcv
*to be determined-PSECU loan accts
$ $
EXPENSES
Home Week
Mortgage/Rent...............$
Malntenance.................$
Utilities (telephone,
heating, electric, etc.)..$
Employment (transportation,
lunches) .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Month
$ 300.00
$
$ 131.00
$ 155.00
Taxes
Real Estate.................$
Personal Property...........$
Income.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Insurance
$
$
$
$
$ 65.00
$
$
56.00
Homeowners.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Automobile.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Life/Accident/Health........$'
Other.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Automobile (payments, fuel,
repairs) .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Medical
Doctor, Dentist, Ortho......$
Haspi tal. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Special (glasses, braces,
$ 330.00
$ 50.00
$
etc.)........................................ .$
$ 75.00
Education
Private, Parochial School...$
College.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Personal
Clothing.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Food.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
$
$
Other (household supplies,
barber, etc.).............$
Credit payments and loans...$
Miscellaneous
Household helplchild care...$
Entertainment (inc. papers,
books, vacation, pay TV,
etc.)........................................ .$
$ 100.00 $
$ 25.00 $
$ 150.00 $
$ 550.00 $
$ $
Gifts/Charitable Contrib....$
Legal Fees.................................... $
Other child support/alimony
paynlents.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. $
Other (specify}...............$
Total Expenses................$
$2.497.00
Year
$
$
$
$
$
$
$
$
$
:I>
$
$
$
$
$
$
$
$
$
$
*The Defendant agrees that approximately $4.400 of the PSECU debts are his
responsibility.
2
ft' '
~
COMMONWEALTH OF PENNSYLVANIA
STATE EMPLOYES' RETIREMENT SYSTEM
STATEMENT OF ACCO~NT AS OF DECEMBER 31. lii4
.mu>lIr ."" S\I" ~Ior's' Rotlr_n' .r.... (SERS! pro.ldU .ach _r .lth curr.n. r.llr_t account Inlor..tlon which should
bo holplul 'n ,..d.ruand'lIIJ .he bonerlts pro.lded br th. rallr....n. plan and In doing "nonelal plaM'ng. IhlS 'U'-'" wa.
pr.pared u.lng .he da.a recorded In rour raW_nt account IS 01 o.c.-r 31. 1..4. and IS .ubJ.ct '0 Ilnal audit br .1>4 SERS In
accord"'" with app II cabl a la. and r.lIUlallon.. PLEASr REFER TO THE REVERSE SIDE FOR IMPORTANT
INFORMATION ABOUT YOUR STATEMENT.
PREPARED FOR. M L RUPP
OBI-1BO-26200
SEO-086431
5612
ACCOUNT BALANCE
REGUlAR ill
..lane. as 01 n-3l-U $13.255.40
1994 Activit,.
Contr lbullon. $ I .697.35
L~ SI.IlI Payments
Arr..rS Payments
AdjustmenU-
CreeB ted Interest $564.25
Balance.S of 12.31..'4 $15.517.00
Arraars Balance .s af 12-31-'4 -
.ld Ultmant' reflect correctionS to our account about which
"" 176-46-5988 EMP I: 041355
Oat. 01 Ilrth. AUGUST 15, 1\155
SUI MALE Region Codet 7
Mor..l Rattr_nt Oat,' tUGUST 15. 2015
Creelt led Service as 0 12-3 ..,.. ~
Class Slrvice
A 8.2636 YRS,
Coverage T)'pe FULL
Contrtbutlon Kate
Ftnal An".;' S.lal""
1"4 Retirement Covered Earnings
551 Mon-COvered Earntngs
Jotnt Coverage Converston Amount
Mandator, Debt
_____TAXABLE BREAKOOWN OF
15.001'
, $32.865.78
$33.946,81
I
I
ACCDUNT-----
Tal-Deferred Contrtbutions
+ Prevtous'y taxed Contrtbuttons
+ Credtted Interest
. Account II'anee as of 12-31-'4
$13.295,82
$2,221. 18
$15,517 .00
ou have been nottfled.
I.nellt ..tlmat.. ar. pr.pared lor oomber. who ho" r..ched Normal R.tlrement Ag. and lor member. who ho.. at I.a.t 10 ,.ar. of
credl'ed ..r'lc, lor Rogular R.tirement and at l...t 5 r.ar. 01 credited ..r.lc. for DI.abllltr R.tlr...nt IStat. police and
Enforcement afficers have no ~tntmum servtce requtrement for dtsabtltty rettrement).
If rou tonelnat. prIor to attaIning .1Iglbll Itr for ....n.hlr bon."", that" prior to bacOOllng .ested. rou would be .nlltled '0
recetv. your account ba'ance ~tnus any debts to the commonwe.lth .s of your dAte of termtnatlon.
BENEFIT ESTIMATES
FUl.l. RETIREMENT .. Thts optton provides the maxlaun month',
beneflU to yoU for lHe. Jf you die before recelvtng 70ur
tot., ,cCUT'lJlated deduct tons. tho ba'ance wll' be patd to
your baneftciafy(Ies).
OPTION 1 _ This option provtdes reduced month'y banefltS to
you for 'lfe. All IIlOflth', u.n.fit$ .,. reduGod fr",,, tN
Presont Value. Any ba'ance r_Inlng at your death wtll be
patd to your beneftctary(t,s}.
PRESENT VALUE - Death leneftt lIder Option 1 or I death
1n st.te servlce.
OPTION 4 _ You IIIIY recetve .11 or . portion of )'our
accUIIJlated deducttons lcontrtbutlonS .nd Inter.st) In . ,~
s"'" or Insta"..."t payments .nd r.cIWI reduCed month',
benefits und.r one of the other rettrement options. Optton 4
Is avallab'. on'y at the ttme of rettrement and may not
..ceed your accumu'ated deduCttonS.
FULL RETIREMENT ADuUSTED UNDER OPTION 4
OPTION 1 ADuUSTEO UNOER OPTION 4
ADuUSTED PRESENT VALUE UNDER OPTION 1 WITH OPTION 4
Current IS of Projected to Norma'
12-31-,. RetfrllfDOflt
N/A N/A
N/A N/A
N/A N/A
N/A N/A
N/A
N/A
N/A
N/A
N/A
N/A
MAXIMUM DISABILITY - You "",.1 bo medlcall, certllled br ~ERS $912.94
Hedlca' Eaamlners to be phystcal1y or _nta", fnca~ab'. of
performfng your current job dutle,. OPTION 4
WITHORAWAL 15 NOT AVAILABLE WITH A OISABILITY
RETIREMENT.
'REFER TD COOES A THROUGH R ON THE REVERSE SlOE OF THIS FORM FOR AN EXPLANATIDN OF THE FDLLOWING CODES
AS THEY APPLY ,TO YOUR BENEFIT ESTIMATES: L. 0
AOOITIONAL RETIREMENT OPTIONS ARE AVAILABLE. PLEASE TELEPHONE YOUR SERS REGIONAL RETIREMENT COUNSELOR
TOLL-FREE (I_BOO-633-5461) FOR OUESTIONS CONCERNING YOUR BENEFIT RIGHTS OR THIS STATEMENT OF ACCOUNT.
- -~.....
--~.. ---
10/11/1934 11:00
71 7-2495755
OBRIEII BARIC SCHERER
PAGE 04
.
IT IS ORDERED THAT
1. The debtor's plan, as modified, is confirmod.
2. That as of October 1, 1995, and each month
thereafter until further order of the court, the debtor shall pay
to the trustee, Charles J. DeHart, III, P.O. Box 410,
Hummelstown, Pennsylvania, 17036 the sum of $9,000.00 broken down
as follows I
A) First 12 monthly payments of $50.00 eachr
B) 13-24 months payments of $100.00 eachl
C) 25-36 months payments of $150.00 each:
D) 37-48 months payments of $200.00 eachr and
E) 49-60 monhts payments of $250.00 each.
BY THE COURT
s.&P 2 1 1005
1iT1lO~iifTWOidsll!i
Dated:
Bankruptcy Judge
')7119195
10: 19 A~
Charles J. ~~""l, I:!
(ASE REPORT
FRO~ 0./20/95 10 07/19195
PAGE
lUDGE
XICi!AEL L, RUpP
CASE I 19500772
PET FILED
PLAN r:LED
QATE ISl ~EETI~G
DATE CO\FIRXED
DATE CLOSED
0.00
0~/20/95 STATUS
0~/20/'5 TRUSTEE EIP X
06109195 TRUSTEE CO~P X
o
2.50
2.50
257 ~AL~Ul 80TTOX ROAD
mLIS'.E PA 17013.
CO:1~E1(fS:
~AY~E~i
50.00
PAYXENTS/XO I
PERCENT PLAN 100.00
KIN 8AL
UNDlST FORWARD
O.vO
C1I Creditor Nale Cl prj Kd 'er "0. All Sch
ADDr Debl FrQ All Due
lnt Earned All Paid
hlance Assi~ned SI
000 ROBERT L. O'B 09 12
.00
0.00
0,00 0
0.00
0.00
0,00
0,00
0.00 2
;OTA.S
0.00
0,00
0,00
1).00
0,00
0,00
O,Ov
TDiA~ ~:T RECEIPTS.
iOiAL ?A!D TRUSiEE CO~? .
:OTA~ pAID TRUSTEE El' -
TO;AL 'AID CREDITORS,
UNDiSTRl9LTEO FOR,ARO .
PLAN GALANCE .
0.00
0.00
0.00
0.00
0.('0
9.000.00
BASE PLAN
9,vOO.OO
.-...... ,IE, DA;~ ....-...-
0~/20/95 1 50.0v
0~/20/96 1 100,VO
04/20/97 1 150,00
04120/99 I 200.00
0./20199 1 250.00
10/11/1994 11:00
717-24'35755
PAGE 61
OBRIEN BARIC SCHERER
UNITED STATES BANKRUPTcY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
MICHAEL L RUPP
BCY #
~R 13 PI..A.~
PLAN SUMMARY:
CLASS 1: Priority Claims and Taxes. 100% in Plan.
CLASS 2: All Other Secured Claims. Liens to be retained. regular payments to
be made outside Plan.
CLASS 3: Allowed Unsecured Claims. Pro rata of those filing proofs of claim.
Amount & Duration:
First 12 monthly payments of S50.00 each
13-24 months payments of 5100,00 each
25.36 months payments of S150.00 each
37-48 months payments of S2OO,00 each
49.60 months payments of $250.00 each
Total of S9.000.00.
PLAN
I.
PROPERTIES AND FUTURE EARNINGS SUBJECT TO THE
SUPERVISION ANp CONTROL OF THE TRUSTEE;
1. The Debtor submits to the supetvislon and control of the Trustee all
or such portion of the Debtors' future earnings or other future income
as is necessary for the execution of the Plan. including:
A The monthly amounts which shall be paid to the Trustee from future
earnings.
B. Other property: Additional sums as necessary to fund the Plan;
'19'34 11:00
7l7-',2.l'35755
OBPIE!I BARIC SCHEPER
-
() I
PAGE 1)3
)'" ,( t.,
('/,,,~.t;',. ,,/ /..),,//,,"/
f r.'~p '1/.)(,/91
-.._-_.....~.-. .-
HQU~bCu.jf:CSttRT '
~SoW.V
. SEP 2 IIW5 -I
. ~~$'l A. L"n~' '
CIer1< cf *Ill !;Cr.:lf\.'j>>...y-tOM NO,
De u Clerll
IA
MICHAEL LLOYD RUPP
Debtors Per
1-95-00772
(Chapter 13)
IN RE:
Social Security Number: 176-46-59B8
9RDER CONFIRMING PLAN
The debtor's plan filed on April 20, 1995, as modified
by an Answer to objection to Chapter 13 Plan filed August 9,
1995; and
It having been determined after hearing on notice:
1. That the plan complies with the provisions of
Chapter 13 and with other applicable provisions of the Bankruptcy
Code;
2. That the filing fee and any other amount required
to be paid before confirmation have been paid;
3. That the plan has been proposed in good faith and
not by any means forbidden by law;
4, That the value, as of the effective date of the
plan, of property to be distributed under the plan on account of
each unsecured claim is not less than the amount that would be
paid on such claim if the estate of the debtor were liquidated
under Chapter 7 on such date;
5. That each holder of an allowed secured claim
provided for by the plan and the holder Of each secured claim
retain the lien securing such clai~, and the value on the
effective date of the plan, of property to be distributed under
the plan on account of such claim is not less than the allowed
amount of such claim; and
6. The debtor will be able to make all payments under
the plan and to comply with the plan;
'OHN H, BROUJOS
HUBERT X, GILROY
CHRISTOPHER C, HOUSTON
BROUJ05, GILROY B HOU5TON. p, c.
^1TORNEYS ^T lAW
4 NORn-. HANOVER STREET
<=^RLISLE, PENNSYLV^NI^ 17013
April 8, 1996
E. Robert Elicker, II, Esquire
Divorce Master
Office of the Divorce Master
Cumberland Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
RE: Rupp v Rupp/No. 1985-1588
Dear Bob:
Enclosed please find the Defendant's
submission in the above-referenced m
Pre-Trial
.
yours,
Chris~PhJr C. Houston
kb
Enclosure
cc: Bradley Griffie, Esquire
Michael L. Rupp
711-243.4574
NON-rOLL fOR HARRISBURG ^fU:AI
711-700-1600
fAA1243-8221
Statement
for
II tA/
. r /r
~~dleY L. Grl
GRIFFIE & ASSOCIATES
Attorneys and Counselors At Law
NOV 2 3 1999
100 Nurth lIanonr Slnrl
Carll.I., PA 17013
(717) %43.5551
1(800)347.555%
FAX 717-%43-5063
November 19,1999
Robin J. GOlhorn
I.rlll A"l.llal
38 Nortb Mila Sir...
Cbambtnbul'l, PA 17%01
(717) %67.1350
The Honorable Edward E. Guido
Judges Chambers, 4th Floor
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
R.ply Co: Carll.l.
VIA FACSIMILE AND U.S. MAIL
RE: Cornwall v. Rupp
Dear Judge Guido:
Enclosed herein, please find the Plaintifrs Memorandum in the above-captioned action.
This is for a hearing scheduled for Monday morning, November 22, 1999.
Very truly yours,
-~cI'-~4&: ~ J
Bradley L. G/ime
BLGlklg
Enclosure
cc: Emily Long Hoffman, Esquire
(via facsimile)
Stephanie L. Cornwall
--..~ --...-.
STEPHANIE L. (RUPP) CORNWALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
: NO. 95-1588
: IN DIVORCE
PLAINTIFF'S PRE-TRIAL MEMORANDUM
I. PLAINTIFF'S POSITIONI HISTORY OF CASE.
The Mother's position in this case is that both of these teenage children have had
difficulties in their extended summer time visits with their Father here in Pennsylvania. Prior to
the summer of 1998, both children attempted to reach an accommodation with their Father that
would have allowed them to reduce the period of time that they would spend in Pennsylvania,
but Father would not accommodate their request and the children were extremely displeased and
despondent over the bulk of their time spent in Pennsylvania. While Father apparently attempted
to spend periods of his vacation time with the children over the summer, this was extremely
limited when one considers the extended period of time they were here. They spent most of their
time with a babysitter.
Of course, the children are also involved in extracurricular activities at their home in
Oregon, which were affected by their inability to take part in pre-season practices. camps, and
similar aspects of their routine life.
Then, even though the Court Order provided for the children to spend their 1999 spring
break in Pennsylvania, Father never followed up on that and the spring break simply went by
without any request on his part for the children to be here. Shortly after the spring break period,
however, the children began contacting their Father again, asking if the summer of 1999 could
include a reduced period of time rather than what is required on the Court Order. Again, Father
responded indicating that he was extremely hurt by their request and refused to accommodate in
any fashion. In fact, Father had no contact whatsoever with the children for three months in the
spring. Father simply insisted that the children would come and that was the end of the story
from his perspective.
Mother has attempted to do what she can to develop a better relationship between the
children and their Father, even though their relationship was always strained. The relationship
between the children and their Father was very limited when the children moved to Oregon with
their Mother approximately three years ago.
Mother has tried various angles to get the children to accept the current situation and visit
without the ongoing request for a reduction in their time with their Father. This has included
telling them that she could be in trouble for contempt if they did not go, suggesting that they
could be in trouble for contempt if they did not go and indicating she would accommodate their
requests by attempting to change the arrangements between now and next year and facilitating
their contact with their father in an attempt to maturely discuss some reduced period of
visitation. Despite her many attempts, nothing seems to work going into the beginning of the
summer of 1999.
In the late spring of 1999, Mother initiated proceedings in Oregon to modify the Custody
Order as that Court now has jurisdiction of the issue of custody of the children. She advised the
children that she had done this and, by doing so, should be in a position to help them secure a
more acceptable visitation schedule for the year 2000. UnfortUnately, even this effort did not
assist her in securing any cooperation from the children.
The children have expressed fear of their Father. The children have been distraught over
being forced into a totally unacceptable situation from their perspective and have been upset
over their Father's unwillingness to maturely discuss this type of issue with them and understand
their side of the story.
Mother's present husband has substantial frequent flyer miles available to him so Mother
intended to redeem some of those miles for the tickets to fly back to Pennsylvania. Beginning
approximately one or two weeks prior to the children's leave, they indicated that they were flatly
refusing to go despite Mother and Mother's husband talking to the children about the need to go,
the fact they should maintain a relationship with their Father and similar arguments to support
their position that the children should visit. The children continued in this position until the day
when they were to leave. On that day, the pllrties' 16 year old daughter went to her bedroom
crying and sobbing, refusing to go to the airport with her Mother. The parties' son similarly was
sobbing and crying, begging his Mother not to literally drag him out to the car to go to the
airport. Mother's husband was not present at the time so she was unable to get his physical
assistance in somehow trying to physically force the children into the car, into an airport and
onto an airplane. Under those circumstances, the children did not come to Pennsylvania which
resulted in the filing of the Petition for Contempt.
In the meantime, Father has retained legal counsel in Oregon and their ongoing
negotiations relative to a modification of the present Order, which includes a proposal that
appears to be close to being accepted where the children's time in the summer would be reduced
to one month. If that agreement is reached, then some of the issues that have been creating the
problems over the past two (2) years in the summer vacation period will have been resolved.
It is the Mother's position that she did everything within her power to force the children
to come to Pennsylvania, but. at their ages, her ability to physically force them to come is
obviously limited and, therefore, she did not take any willful action that should cause the Court
to find her in contempt. In addition, she is bringing the children to Pennsylvania for the
contempt hearing in order for them to express their position to the judge, if necessary, even
though they are already involved in the litigation in Oregon. Mother has advised the children
that they should expect to spend some time with their Father while they are here in Pennsylvania
over the weekdays before Thanksgiving, although the Court may need to intelVene to discuss
with the children what periods of time they are willing to spend with their Father. While Mother
\>'iNvi\1,~SNN3d
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A'CilGC,',' ,. iQ
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S'IEPHANIE L. RUPP, . IN THE COURT OF ccx-lMON PLEAS OF
.
Plaintiff . CUMBERLAND cotlNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-158B CIVIL TERM
.
: CIVIL ACTION - LAW
MICHAEL L. RUPP, .
.
Defendant . IN CUSTODY
.
PR!Q{ JUDGB: aaro1d E. Sheely
CUS'lOOY cncn.IATION &MlARY REP<Rl'
IN AccaulANCB WITH cnmBRLAND ocumc RlILE OF CIVIL PIlC- '''''IiJRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
aJRRIlNl'Ly IN ~""'UJ~ OF
Arnie Elizabeth Rupp
Justin Michael RUpp
July 25, 1983
April 27, 1987
Mother
Mother
2. A Conciliation Conference was held on september 9, 1999, with the
following individuals in attendance: The Father, Michael L. RUpp, with his
counsel, Emily L. Hoffman, Esquire, and the Mother's counsel, Kristen
Donsen, Esquire. The Mother, who resides in Oregon, did not attend the
Conference.
3. This Court previously entered an Order based on a Stipulation of
the parties on January 6, 1997. Under that Order, which contemplated that
the Mother was moving with the Children to Oregon, the Father was to have
partial physical custody of the Children during the summer school vacation
beginning the second Saturday after school terminates. The Father filed
this Petition for Contempt alleging that the Mother failed to send the
Children for their period of summer custody with the Father. This matter
was not resolved at the Conference and it will be necessary to schedule a
Hearing .
4. The Father's position is as follows: The Father stated that he was
looking forward to spending the summer with the Children in accordance with
the Court ordered custody arrangements and was devastated when he learned
the Children were not coming at the last minute. According to the Father,
the Mother purchased the airline tickets for the Children's flight to
Pennsylvania but then contacted the Father's mother by telephone and advised
that the Children threw a fit at the airport 2 hours before the flight was
to leave and refused to go. The Father stated that he contacted the airline
and was advised that the Children's tickets had been canceled 2 days prior
to the flight. The Father believes it is inportant for the Children to
maintain their relationship with their Father and that the summer period of
custody is necessary to continue the bond between them. The Father feels
that there would be no problem with the Children coming to Pennsylvania for
the summer if the Mother would encourage the relationship between the
Children and the Father. The Father believes the Mother is alienating the
Children from him. The Father also expressed concern that the Mother
interferes with his telephone contact with the Children by either staying in
the room or putting him on the speaker phone. Further, the Father indicates
the Mother does not have the Children return his telephone calls when he
leaves messages. The Father filed this Petition for Contempt seeking
make-up time for the 9 week custody period he missed. The Father requests
that he be permitted to have additional time with the Children over their
Thanksgiving break, the Christmas holiday and Spring break next year. The
Father believes the Mother should be responsible for the costs of
transportation for the make-up time and for his legal expenses in enforcing
the current Custody Order.
5. The Mother's position is as follows: According to the Mother's
counsel, the Mother denies the Father's allegations that she is discouraging
the Children's relationship with their Father. The Mother denies canceling
the airline tickets 2 days prior to the fligt:':. The Mother has asserted
that she took the Children to the airport on the day of their flight but the
Children, who are ages 12 and 16, absolutely refused to go. The Mother
denies she is in violation of this Court's Order.
6. It should be noted that the Mother has filed a Petition in Oregon
to decrease the Father's periods of partial custody with the Children. A
Hearing is scheduled in that matter in mid September. The Father is
objecting to the Oregon Court's jurisdiction.
7. The Conciliator recommends an Order in the form as attached
scheduling a Hearing on the issue of COntempt. However, the COnciliator
encouraged the parties to confirm the facts with regard to cancellation of
the airline tickets through billing or airline records, the outcome of which
may facilitate the parties' efforts to resolve the COntempt issues without
the necessity of a Hearing. In the event a Hearing is ultimately necessary,
it is expected to require one-half day or less. Further, it is requested
that the Hearing be held before Thanksgiving, as the Father is requesting a
period of make-up custody over the Thanksgiving school break as one of the
issues to be addressed at the Hearing.
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Date
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Dawn S. sunday, Esqu re
CUstody Conciliator
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AND tDi, this2-tf day of
consideration of the attached Custody
and directed as follows:
6( -r('!~
Conciliation Report,
, 1996, upon
it is ordered
STEPHANIE L. RUPP, . IN THE COURT OF COOMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. . NO. 95-1588 CIVIL TERM
.
MICHAEL L. RUPP, CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
aIDER OF CXXlRT
I. A Hearing is scheduled in COurt Room No. -d.. of the
C~rland County Court House, on the 9'-6h day of ~UAIl.~ /997
199~ at q: 00 tL.m., at which time testimony will be taken 1n this
case. At the Heanng, the Mother, Stephanie L. Rupp, shall be deemed to be
the moving party and shall proceed initially with testimony. Counsel for
the parties shall file with the Court and opposing counsel a memorandum
setting forth each party's position on custody and also setting forth a
list of witnesses who will be called to testify at the Hearing along with a
summary of the anticipated testimony of each witness. This memorandum
shall be filed at least ten (10) days prior to the Hearing date.
2. Pending the Hearing, this Court's prior Order of March 15, 1996
shall remain in effect.
3. The parties agree to cooperate in exchanging information
pertaining to the Mother's proposed relocation of the Children to Oregon
and agree to continue their efforts to reach an agreement on custody
arrangements which will be in the best interest of the Children. If the
parties require the assistance of the Conciliator in finalizing a custody
agreement prior to Hearing, counsel for the parties may contact the
Conciliator to schedule a Conference.
BY THE COURT,
en / {~
\""f - _/
arold E. Shee , P.J.
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.
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Bradley L. Griffie, Esquire - Counsel for Plaintiff
Christopher C. Houston, Esquire - Counsel for Defendant
c.. f;'('V~ /1//3/'16.
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L_
STEPHANIE L. RUPP, . IN THE COURT OF ccx-IMClN PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 95-15B8 CIVIL TERM
.
.
.
MICHAEL L. RUPP, . CIVIL ACTION - LAW
.
Defendant IN CUSTODY
PR!Q{ JUDGB: Harold E. Sheely
aJS'lOOY calCILIATION &MlARY REP<Rl'
IN ACCXlUlANCE WITH ClImERLAND ocumc RULE OF CIVIL PROCEOORE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
BIRTHDATE
alRRENTLY IN CUS'lOOY OF
Arnie Elizabeth Rupp
Justin Michael RUpp
July 25, 1983
April 27, 1987
Plaintiff/Mother
Plaintiff/Mother
2. A COnciliation Conference was held on October 15, 1996, with the
following individuals in attendance: The Mother, Stephanie L. Rupp, with
her counsel, Bradley L. Griffie, Esquire and the Father, Michael L. Rupp,
with his counsel, Christopher C. Houston, Esquire.
3. This Court previously entered a Custody Order in this matter on
March 15, 1996, reflecting the agreement of the parties at a Custody
Conciliation Conference. Under that Order, the parties had shared legal
custody, with primary physical custody to the Mother and partial custody to
the Father. The Mother filed this petition to Modify the prior Order based
on her desire to relocate the Children to Lake oswego, Oregon.
4. The Mother's position on custody is as follows: The Mother is
engaged to marry a man who resides in Lake Oswego, Oregon. The Mother
proposed that she and the Children move to her fiancee's home, which is a
three bedroom condominium in a town similar in size to Carlisle. The
Mother believes that the move will be beneficial for the Children based on
her conversations with the Children's counselor and the daughter's school
counselor and teachers. The Mother stated that the Children want to move
to Oregon and have developed a good relationship with the Mother's fiancee
during his four or five weekend visits. The Mother proposed a partial
custody schedule under which the Father would have custody of the Children
during the entire summer with the exception of the week following the end
of the school year and the week before school resumes, over the Christmas
vacation for one full week and in alternating years over the spring break
for one full week. The Mother proposed that the Father pay transportation
costs for exchanges of custody during the summer only, which would be
approximately $500.00 to $600.00 per round trip ticket.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
STEPHANIE L. RUPP,
Plaintiff
MICHAEL L. RUPP,
Defendant
NO. 95-158B CIVIL TERM
IN CUSTODY
O~DER OF COURT \
AND NOW, this t. IJ- day of ..-j-c---<,,-I...( L-t.."-Y , 1991. the
attached stipulation and Agreement is hereby made an Order of
Court and all prior Orders on this matter are hereby vacated.
BY THE COURT,
-. O-^-1\ ~~
J.
,
2. Mother shall have primary physical of the children.
3. Father will have periods of temporary or partial
physical schedule on the following schedule:
(a) From the second Saturday after school has ended for the
children during the summer vacation months until the second
Saturday prior to the beginning of school for the following
school year;
(b) During the Christmas holiday season for a period of one
week, alternating those weeks on the following schedule:
(i.) the period from the day after
school ends for the Christmas/New Years
vacation season for a period of one week
(seven days); and
(ii.) for a period of one week beginning
eight days prior to the children's return to
school and continuing for a period of one week
(seven days) to the day before the children
return to school following the Christmas/New
Years' holiday vacation and with Father having
the first period herein for Christmas 1997.
(c) Every other year for the spring school recess period
beginning on the Saturday following the last day of school before
the recess begins until the Saturday prior to the end of the
school recess, with Father having the spring recess for 1997 and
each odd-numbered year thereafter. In the event Father will be
unable to exercise this period of temporary cutody,
notify Mother no less than forty-five (45) days prior
first day of the spring school recess.
(d) At other times as the parties may agree.
4. Father shall have telephone contact with the children on
a weekly basis with the phone call to be made at 7:00 p.m. on
Wednesday evenings EST. In the event the children are not going
to be available at that time, Mother shall take responsibility
for placing the call to Father one or two days prior to that time
to allow the children to speak with Father at that time, or to
advise Father of another appropriate time when the children can
have telephone communication with Father. Father shall, in
addition, be permitted to have telephone contact with the
children at other times during the week, should he so desire.
5. within ten (10) days of the beginning of each school
year, Mother shall provide Father with copies of all
documentation provided to her by each of the children's schools,
including school calendars, school rules and regulations,
information regarding the children's teachers, and similar
information. In addition, within ten (10) days of receipt of any
report card, deficiency report or similar reports evidencing the
children's grading, Mother will provide a copy to Father.
Further, Mother will notify the children's schools that Father
has shared legal custody as provided hereinbefore, and as such,
the schools shall respond to any inquiries made by Father
concerning requests for information regarding the children's
schooling.
he
to
must
the
6, The parties agree that Mother shall be responsible for
the costs of transporting the children to the Father for his
period of physical custody of the children during the
Christmas/New Year's holiday season and for the costs associated
with transporting the children for his period of physical custody
during the summer vacation season. The parties shall equally
share the costs associated with transporting the children for
their period of physical custody with Father during spring
vacation or spring break, as provided for herein. In the event
that either party fails to return the children pursuant to the
terms of this paragraph after the other party has incurred the
expense for transportation, the party who fails to comply with
the terms of this Agreement shall be responsible to compensate
the other party in the amount of three times the expense
associated with providing the cost of transporting the children,
along with any other remedies any Court of appropriate
jurisdiction deems reasonable.
7. In the event Father has need for child-care services
during his extended periods of temporary physical custody as
provided for herein, he will notify Mother in advance of the
name, address and telephone number of the individual that he
wishes to use for this purpose.
8. The parties will keep each other advised immediately
relative to any emergencies concerning the children and shall
further take any necessary steps to insure that the health and
well being of the children is protected.
---.- ~ '
9. Neither parent shall do anything which may estrange the
children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
10. Any modification or waiver of any of the provisions
this Agreement shall be effective only if made in writing
only if executed with the same formality as this stipulation
Agreement.
11. The parties desire that this Stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
Cumberland County, acknowledging that the Court of Common Pleas
of Cumberland County has jurisdiction over the issue of custody
of the parties' minor children at the time of entry of this
Order.
of
and
and
12. The parties agree that in making this Agreement,
has been no fraud, concealment, overreaching, coercion, or
there
other
unfair dealing on the part of the other.
13. The parties acknowledge that they have read and
understand the provisions of this Agreement. Each party
acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
t.
WITNESS:
Date'. j.:; ~,,' Ii,:, I ,/r J '/ d.
~ -S'i~~~NIE<~~~
Date:l~Jl'ljql. '1f~ ,/ f<'1f
I MICH EL L. RUPP
COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
On this the,JOfi, day of 1).J.{:f./rt..I.I.f.~
, 1996, before
me, the undersigned officer, personally appeared Stephanie L.
Rupp, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
~dJ J!l 0;:ifLv
COMMONWEALTH OF PENNSYLVANIA
)
) SS
)
J)~ Co e -r,.J.t..-
Notarial Saal
Lllh A, Miller, Notary Public
Carilsle 80ro, Cumberland County
My Commission Expires April 17 . 2000
COUNTY OF CUMBERLAND
On this the / jll} day of
, 1996, before
me, the undersigned officer, personally appeared Michael L. Rupp,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
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STEPHANIE L. RUPP,
Plaintiff
.
.
.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION
NO. rrf ~/5 y r
- LAW
CIVIL 1995
MICHAEL L. RUPP,
Defendant
IN CUSTODY
ORDER OP COURT
AND NOW, this
1--
1-~
day of
1995, the attached Stipulation and Agreement is hereby made an
Order of Court and all prior Orders on this matter are hereby
vacated.
BY THE COURT,
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CUSTODY
8TZPULATZOB UD AORBIlMBBT
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between Stephanie L. Rupp,
(hereinafter referred to as "Mother") and Michael L. Rupp,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Amie
Elizabeth RUpp, born July 25, 1983 and Justin Michael Rupp, born
April 27, 1987 (hereinafter the "children"): and
WHEREAS, the parties are presently separated and living in
separate residences: and
WHEREAS, the parties wish to enter into an agreement
relative to custody and partial custody of the children: and
NOW, THEREFORE, in consideration of the mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as follows:
1. Mother shall have primary physical and legal custody of
the children.
2. Father shall have supervised visitation with the
children as agreed upon by the parties.
3. The parties will attempt to make arrangements for both
parents to spend time with the children on each holiday as they
may agree.
4. The parties will keep each other advised immediately in
the event of serious illness or medical emergency concerning the
children and shall further take any necessary steps to ensure
that the health and well being of the children is protected.
During such illness or medical emergency, both parties shall have
the right to visit the children as often as he or she desires
consistent with the proper medical care of the children.
5. Neither parent shall do anything which may estrange the
children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
6. The parties desire that this stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
CUmberland County, and further acknowledge that the Court of
Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor
children and shall retain such jurisdiction should circumstances
change and either party desire or require modification of said
Order.
9. The parties agree that in making this Agreement, there
has been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
10. The parties acknowledge that they have read and
understand the provisions of this Agreement. Each party
acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
WITNESS:
Date: S.at-Ifs-
, ~
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/ST PHANI2 L. R P
Date: .f!.l~ \1\ s
fY1~ ;J.. ~
MICHAEL L. RUP
COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
On this the ,;14- t!J day of
/ J!a?/ ' 1995, before
personally appeared Stephanie L.
me, the undersigned officer,
Rupp, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
Notarial Seal
Robin J. Goshorn. Notary Public
Carilsle Boro. Cumberland County
My Commission Expires April!7. 1999
/7 - ~
. r) 1-/11 18 /i~ lH..'~
COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
if/i,
On this the' day of
/lIC\,Y'
, 1995, before
me, the undersigned officer, personally appeared Michael L. Rupp,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
;
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"(Phil.,
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; Notaridl Seal
I Koren F. Byers. NOlary Public
CarlIsle Bora. Cumberland County
".'. _~"mmIS!ilor: ~l(pjms March 18. 1999
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STEPHANIE L. RUPP. . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VB. . NO. 1588 CIVIL 1995
.
MICHAEL L. RUPP,
Defendan t . IN DIVORCE
.
DATE:
4 9 96
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STATUS SHEET
ACTIVITIES:
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STEPHANIE L. RUPP, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . CIVIL ACTION - LAW
.
. 95-1588 CIVIL TERM
.
MICHAEL L. RUPP, .
.
Defendant : IN DIVORCE
PRB-TRIAL STATEMENT OF PLAINTIFF.
STEPHANIE L. RUPP
The above-named Plaintiff, Stephanie L. Rupp, by and through
her counsel of record, Bradley L. Griffie, Esquire, files the
following Pre-Trial statement, pursuant to Pennsylvania Rules of
Civil Procedure, 1920.33(b):
I. LIST OF ASSETS
Item
Number
Asset
Valuation
Value ~
$34,411.05 present
Non-Marital
Portion
IJJm
1.
Escrow funds
from sale of
real estate
None
None
2. :: 1987 Beretta 3,500.00 present None None
(Defendant)
3. Life Insurance 889.52* 05/95 None None
AIG Ins. Co.
(Defendant)
4. Life Insurance 67l.99* 05/95 None None
AIG Ins. Co. (Net value)
(Plaintiff)
5. State Employees $15,838.04* D.O.S. None None
Retirement Systems
(SERS) (Defendant)
6 . Stock investments 28,176.47* D.O.S. None None
(Defendant)
7. IRA 42.81 D.O.S. None None
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The parties appear to agree that the date of separation in
this case was February 6, 1995, and therefore the issue of the
date of valuations for the various marital assets is set, at
least with respect to those assets which would be dated for the
date of separation.
It is submitted that the life insurance
policies, particularly that of the Defendant, must be re-valued
to bring it to a current cash value. This is true relative to
the Defendant's life insurance policy in that the Plaintiff
maintained the premiums on this policy since the date of
separation.
In addition, the various stock investments held by the
parties need to be re-valued for their current value or a value
as close to the date of hearing as is possible.
In addition, the Defendant's SERS retirement account will
need to be valued as close to the date of hearing as is possible,
using a coverture fraction to determine the value of the marital
portion. The Defendant's date of hire with the Commonwealth of
...;
Pennsylvania will cause him to vest in his pension at a time
prior to the hearing date in this matter.
Therefore, an
actuarial valuation will need to be made of the Defendant's
pension.
The figure provided in the List of Assets as to the
value of the pension on February 1995 is only the employee
contributions through that date.
The parties' various assets, where relevant, are identified
on Exhibits attached hereto.
A comprehensive statement
identifying the individual stock investments and their date of
separation values is listed as Exhibit "A". Behind that Exhibit
1
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"A" are photocopies of statements, where they were available to
the Plaintiff, indicating the value of those stocks at the time
of separation, or at other dates if so noted.
The following Exhibits are attached to identify the
following marital assets:
of the parties: Exhibit "B" -
statement on value of life insurance policy for Plaintiff at the
date of separation: Exhibit "C" - statement on cash value of life
insurance policy for the Defendant at the time of separation;
Exhibit "D" - statement as to the SERS value as of December 1994;
Exhibit "E" - statement as to the value of the SERS account as
of February 24, 1995: Exhibit "F" - statement of Defendant's IRA
value as of December 1994.
Il:. IlXPBRT WITNESSES
It is anticipated that an expert witness will be necessary
to value the Defendant's pension once it has vested.
At the time of preparation and filing of the Pre-Trial
statement, it is not anticipated that additional experts will be
necessary.
III . WITNESSBS
It is anticipated that other than the Plaintiff, it is
unlikely that additional witnesses will be necessary in this
case. In the event that the Defendant challenges the Plaintiff's
right to a divorce in this case, additional witnesses will be
called, as necessary, to identify the indignities that the
. .
Plaintiff had to endure while with the Defendant.
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The Plaintiff reserves the right to set forth and call
additional witnesses upon review of the Defendant's pre-Trial
statement and upon conclusion of the Pre-Hearing Conference in
this matter.
IV. BXHIBITS
The Exhibits which have been previously attached hereto will
be presented as Exhibits in the proceedings.
In addition, the
following exhibits will be presented:
Exhibit "G" - statement
from Forest Park Nursing Home reflecting the part-time status of
the Pl,aintiff's employment as of February 27, 1995: Exhibit "H" -
:', .
A photocopy of the Defendant's W-2 for 1994 reflecting his total
gross income for that year: Exhibit "I" - A copy of the parties'
1993 Federal Income Tax Return: Exhibit "J" - An Order of Court
dated June 7, 1995, reflecting the parties' initial arrangement
relative to custody and visitation of their two minor children:
Exhibit "K" - A copy of the Order of Court entered on March 15,
1996, reflecting the present state of the parties custody and
visitation arrangements: Exhibit "L" - A copy of the Court's
Order of December 29, 1995, relative to support outlining the
.....
agreed upon support amount which was entered by the parties at
the time the parties had reached a comprehensive agreement in
this case: Exhibit "M" - A statement indicating the balance due
on the parties 'PSECU Visa and PSECU Personal Service Loan (PSL)
as of the end of January 1995: Exhibit "N" - A statement from the
Defendant's Boscov'S checking account reflecting indebtedness
incurred by the Defendant after separation for which the
Plaintiff is not responsible: Exhibit "0" - A statement from the
l
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~
pennsylvania state Employees Federal Credit Union visa Account
that the parties held which reflects a dramatic increase in the
parties' Visa Account with PSECU which includes substantial post-
separ.at:ion debt incurred by the Defendant, and for which
the Plaintiff should not be responsible: Exhibit "P" -
statement from Fidelity Investor Card visa Gold Account of which
the Plaintiff is not aware and for which she should not be
responsible.
In addition, it is anticipated the parties will submit their
1995 Federal Income Tax Return to reflect their income for 1995.
It is also anticipated that an actuarial evaluation of the
Defendant's pension will be secured upon his vesting in his
pension with the Commonwealth of Pennsylvania.
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. ......,
Plaintiff reserves the right to provide additional exhibits
and documentation upon receipt and review of the Defendant's Pre-
Trial statement and upon the conclusion of the Pre-Hearing
Conference in this matter.
More particularly, the Plaintiff
expects to submit documentation reflecting the present value of
the parties' stock investments.
V. GROSS INCOMB
The Plaintiff will submit a photocopy of her 1995 Federal
Income Tax Return at the Pre-Trial Conference.
Her sole
empluyment is her sole source of income
Vl:. IlXPIINSIlS
Plaintiff will prepare and submit a routine monthly Income
and Expense statement as prepared and provided by the Cumberland
County Domestic Relations Office for support cases, which
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document will be submitted in advance of the pre-Trial
Conference, and will be used as an Exhibit in these proceedings.
VII. PBHSIOHS
As previously stated, the Defendant's pension will vest
imminently and will need to be appraised. The valuation of the
Defendant's pension will necessitate the submission of an
Exhibit. It may necessitate testimony from an expert.
VIII. COUNSBL PEES
The plaintiff has requested and should be provided with
attorney's fees associated with these proceedings. plaintiff is
unable to afford her counsel fees, and based upon the parties'
net equitable estate, the need to proceed with this matter
through a Master's Hearing is not necessary, but rather, this
matter should have been resolved by agreement.
It is further
submitted that the Defendant did, in fact, make an offer which
was accepted by the Plaintiff.
However, once the Plaintiff
accepted the offer through preparation and forwarding of an
appropriate comprehensive Separation and Property Settlement
Agreement, which was forwarded within the time-frame of
Defendant's offer, the Defendant then modified this position
contrary to the position he had taken over several months of
negotiations.
Furthermore, during the period of negotiations
which led to the agreement which the Defendant refused to sign,
the Plaintiff agreed to sell the parties' property by signing an
Agreement of Sale on October 1995.
In addition, when the
Defendant filed for bankruptcy individually, and the Plaintiff
needed to provide an Answer to a certain Petition filed by the
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PSECU to the bankruptcy proceedings, Plaintiff did not file an
Answer due to the fact that the parties had reached comprehensive
agreement in this case which addressed resolution of paying the
outstanding debt due to PSECU.
Under these circumstances there is no question that the
Defand~nt has caused tremendous unnecessary expense for the
parties through attorney's fees and other expenses, and further,
that the Defendant is far better able to provide for the payment
of attorney's fees than is the Plaintiff.
IV. PBRSONAL PROPERTY
Personal property has been distributed to the parties'
mutual satisfaction.
.'
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X. MARITAL DEBT
Marital debt as previously indicated includes a personal
service loan to PSECU, and a Visa Credit Card Account to PSECU.
In addition, the Defendant has incurred additional debt at
Boscov's and through a separate Visa account which is post-
separation and non-marital.
XI. PROPOSED RBSOLUTION OP THE ECONOMIC ISSOl!lS
It is submitted that the resolution of the economic
providing for 65% of the marital assets to be provided to the
Plaintiff is fair equitable and reasonable in this case. The
Plaintiff is the primary custodian for the parties' young
children. She had been working part-time throughout the latter
portion of the parties' marriage and there is no reason for
..
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anyone to expect that she should modify her part-time employment
position. This allows her to be home at the time the children
come home and to provide them with necessary parental guidance.
It is particularly important that the children have the
mother's parental guidance in this case since the children are in
counseling due to the actions of the Defendant. The counseling
is an additional expense to the Plaintiff and has been
necessitated by the actions of the Defendant while the parties
continue to reside together, prior to their separation.
In addition, the Defendant secured his Master's Degree while
going to school during a period of time that the parties were
married.
This was only made possible by the plaintiff's
willingness to take care of all family needs while the Defendant
concentrated on securing his Master's Degree.
In addition, as
indicated previously, the Defendant has filed for bankruptcy and
therefore, will be vested of any substantial debt. The debt will
be due ..and owing from the marital estate and the Defendant will
essentially be "debt-free".
Furthermore, the spending of the Defendant that was
exhibited at the time of the parties' separation is reflective of
his overspending during the parties' marriage.
This is
particularly true during the latter parts of the parties'
marriage, prior to separation. The Defendant should be forced to
accept responsibility for his spending habits and this should not
be a further burden or encumbrance on the plaintiff.
.
.
,
..
Once the final values are secured relative to the stock
investments and all other necessary values secured relative to
the most recent values on the marital assets, then they should be
divided on a 65/35 basis. This primarily will be resolved by the
Defendant retaining his interest in his SERS pension account and
with the Plaintiff retaining the net proceeds from the sale of
the parties' jointly held residence. Additional cash from the
parties' investments will also be due to Plaintiff.
In addition, alimony should be provided by the Defendant to
the Plaintiff for several years in order to allow her to become
financially independent of the Defendant. This should be in an
. ....~~~.~~.
amount equivalent to the amount that would be provided to her
through the payment of alimony pendente lite or spousal support
as provided under the Pennsylvania Rules of Civil Procedure
relative to support.
In addition, the Defendant should be responsible for the
attorney's fees by the Plaintiff in pursuing this matter. The
Defendant's actions have been the sole cause of extensive
litigation and attorney's fees which are being incurred and will
continue to be incurred due to Defendant's unreasonableness.
Further, Defendant is better able to afford the extra expense of
attorney's fees which he has created.
Respectfully submitted,
re
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stock Investments
Comnanv
Valuation
J2An
Value
Southeastern
Michigan Gas
568.14
02/95
Invesco -
IMF Cash Reserve
637.42
12/94
12/94
InVafll<9 -
Industrial Income
Fund
5,67l.18
637.42
RPM
409.99
01/95
12/94
12/94
12/94
McDonald's
3,173.08
Berger 101
Berger Small
Co. Growth
1,405.36
632.33
AT & T
1,843.28
02/95
12/94
12/94
12/94
12/94
01/95
AFLAC
1,096.34
1,918.99
1,301.47
1,701.34
1,480.10
Atmos Energy Corp
Alliad,'Group
Wendy's
Central Maine
Power Company
Motorola
Phoenix Funds
(4 accounts)
74.03
01/95
12/94
96.16
Neobold's
1,888.05
12/94
11/94
Chase Manhattan
Corp.
The Agler Fund
105.29
25.00
07/94
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- EXHIBIT "A" -
.
Estimated increases
in value to 12/95
unknown
622.62
3,555.12
unknown
unknown
1,699.06
810.45
unknown
unknown
2,446.27
unknown
2,609.69
1,532.49
unknown
unknown
unknown
179.67
unknown
,
."
ACCOUNT NO,; 1032195
TAX ID NO" 116-46-5988
CJ CHANGI DtVIDI!!l,D OPTIONS:
Sind dNtdend ch~ on lint numbe' 01 IN'"
(ANDIOA) 'alOVo" lhl rOlnamsno number oItha;;;--
CJ OpnONAL CASH PAYMENTS ARIINVESTIO MONT
Chectl .nclo~od 10' S 1$25 mll'lf'
po' pllymenl. ".000 rnlt.tfnum po' monlhl
.
SOUTHEASTERN
MICHIO^N O^S ENTERrRISES
QUARTERLY STATEMENT
CJ CERTIFICATE FOR SOME OR ALL SHARIS:
Sol'd . CI",r~I' 101 IhlS number
01 sha,,,
MICHAEl. L RUPP .. STEPIWlIE L RUPP
JTIIROS
14 E OAKWOOD DR
CARliSLE PA 17013-9385
CJ OEPOSIT OF CERnFlCATE(S) FOR SAFEKUPING:
Enclosed III .Inlflclllllor do\lOId InIO the plan
fOllhll nt.mbet oIshI,o.
o Chanoe of adelless IUSI feVelSI 'Ida)
(X)
_.
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(X)
S<<ond~IUf.I'pn~ Dale
cs.. rev.... 'or 8ddlt1ON1 InIOffNt'on.
~----~-~~~~------------------------------------------------------------------------------------------------------
QUARTERLY STATEMENT NAME: MICHAEl. L RUPP .. STEPIWIIE L RUPP ACCOUNT NO. 1032775 TAX ID NOJ 176-46-59
2/15
1G11lIl11lG BAlMCE
DIVIDEIlI REIIlVESTO
2'1.82
DlVIDENO DMDENO TAX NI!T DIVIDE'
RATE AMOUNT WlTHHE1.D
.200 5.96 .00 S.
AMOUNT PIlICE SHARES TOTAL SHAR
, PER SHARE 'TIWlSACTal
29.
5.96 18.85 .32 JO,
DATE OF
RECOAO
2/03/95
DMDENO
SIWlES
.00
REINVESTEll
SIWlES
2'1.82
TOTAl.
SIWIU
2'1.82
DATE
TRANSACTION DESCRIPTION
SHARES
j
I'lIAII AllOIIIIS
AI..L IHOI.JINII TO:
IMPORTANT -
.
SOlITHEAST'ERN
1 I
.. lIE NOlI CM HlU CERTIFICATES FOR SAFElCEEPIH' II
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YOU SHOUlD RETAIN YOUR LATEST STATEMENT UNT1I. YOU IlEctM! THE NEXT ONE. HOWEVER. THE LAST STATEMENT OF EACH CALENO'
YEAII SHOUlD Bl! RETAINED PERMANEHT\, Y FOR ACCOUNTlNO PlJAPOSEI.
nDMAl. TAX_MAT1OH WIU. AlIINTTO YOU 1'1IIOII TO JAHUAIIY 31" OF EACH YIAII.
..11..111\1.... OUi IlIlft.,...,.
INVESTOR Inti SHAREHOLDER SERVICES
TOLL FREE 1,800-255-71107
-OIl -
111101987,2200
FAX (111019117"570
TOTAL SHARES
SHARE BALANCE
'IEAIl-TO-OATE
DMIlENDS
<<)IWATIPlSfAlE'T . ~o 110."
IIOAT HUAOH. IoICMOAH ....t.5CIlt
30.14
5:
t~) INVESCO FUNDS
INVESCO l'undA Gmup.lnc.
P,O. BOA 17371)(,
Denver. CO M1I217.J7l1ti
I.MIHI.~2~.HIIH~
PAL: I.M,"I.~2~.III1HS
Investment Swrunarr.
From January /. December 3 . /994
1."11I,,,111....1111,,11.1.1....11.1..1,,1.1..,,11.1..11..1.1
MICHAEL L RUPP
STEPHANIE L RUPP JT TEN
.4 EAST OAKWOOD DRIVE
CARLISLE. PA 170\l.938'
Page / of J
Account Swnmary
As of December 3/, /994
Number Share Market Percent or
Account Number I Fund Name or Shares Price Value Holdings .
Reguliu Accounts -
.' -
I
Acct. No; 485672.0 .' -
-
-
INVESCO Industrial Income Fund 539.086 $10,5200 $5,671.18 89.89% -
IMF . Cash Reserves Fund 637,420 $1.0000 $637.42 10.11% -
-
-
Total Market Value $6,308.60 100.00%
."
Investments by Objective Category
(s.. ,..,.,..,'01. oftIW "'''m.nl f"" ill, of fund, by toI,,.,,.)
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Category;',.!',,;,,..,
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Money Market...-
Tax. Free
Income
Balanced/ Asset Allocation
, Equity Income
Growth
Value:
International
Strategic/Specialty
Regular
Accounts
10.11%
0.00%
0.00%
0.00%
89.89%
0.00%
0.00%
0.00%
o oo~
100.00%
Interested In . limd that balances dock and bond In'festments? Call us to nnd
out more about INVESCO's Balanced Fund. Please read the prospectus, which
Includes management rea and expenses, carerully berore you Invest.
Retirement
Accounts
0,00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
o oo!.
0.00%
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~~'~ ~'EJNY~TMENT PiAN STATEMENT
REINVESTMENT AOE~~I ,
KEVCORP SHAREHOLDER SERVICES
P.O. lOX 6477
CLEVELAND, OHIO 44101-1477
(216) 737-5745
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FOR SHAREHOLDERS OF.
RPM INC
AccOtrlt Hu.b.,..
U-SZ5-'"
Taxpayer tD
l7'-U-59aa
..cord Dat.
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ra....l. D.t.
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MICHAEL L RUPP
14 E OAKWOOD DR
CARLISLE PA 17013-9385
PARTICIPANT RECORD DATE 'SHARES1"~-
,I;H,. VOU~,:,~~~~., ': ~~:'l'!~Ii~~~I~~~
CURRENT IALANCE. :";
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I.:; CURRENT INVESTMENT,
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Gro.. Aeount on Shar.. Held
au IS' In ,... 1ft
.11 5,05
Tax Withheld
IS'
Net AItount Vol...t.ry
It, Contrlbutl 1ft
5.05 ...
S.rvlce
F_ III
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In...t_t
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.' .: <,'::',:f,
,:, TRANSACTION ACTIVITY 1995
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Dot
01-11-'5
11-5'-'5
T,......ucUon
.0 I
'ALAHCE FDRl/ARD
IHVESI"EHT
Tr.".~tlon
Aaount ...
Co. t or Proceed.
rSh..,t.
Shar.. Thi.
T... tJ
'01_. A It...
Tr t
21.Ml
.: "~,' 21...Z"
5.05
1....5
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YEAR TO DATE - 1995
Gro.. Aeow1t on ShIlr.. Held
. Y It 1 1ft
Tox Wllhheld Vol.......
ft Contrl It,
.11
...
5,05
.00
RETAIN AIOVE STATEllEIlT WITH YDUR TAX RECORDS
512-0179<15-040
........--..... ..............
tA.:r~,Ht.fic -........
r!APP!l~~!f~HAHG.~ i;YOI.UNrARY ~UR,CHA~E, fO~M,!ll :-'I{iTHDflA WAe'FOD..~J.s:.;;:e~.;~~w:ilHR'ii1
Wli:.:",..~. ' --w~._.tt~...."'d..,w:..:._.f;..;....I4O''''h'''''''lt --- ~"!:".~Uk"""""t~_
RPM INC
I VtII.IIlTAI' COIlTUIUTICllI
Account Hu.lMir Taxp.yer ID
RI'Il 16-525-90' 17'-~.-s'aa "_
HICHAEL L RUPP btl..tocl In...t...t Dot.. Thla P...I04I
14 E OAKWOOD DR '2-Z'-'S lS'lI-'S 15'51-"
CARLISLE PA 17013-9385
YOW' Vol...t.ry Contribution C.. .. Fr_
t 25." 10 I 5....... P.r Honth
....1110 YOUI ~Ptlyabltt tn:
TO CHAHllE YOUR AGORESS tPlea.. Iype at plonl new oKJcl.ossl
Slr..t
Society NaUomll Bank
po. BOX 5411
O:LEVLlJlND.O'"O ..101.,.17
CU.
Stal.
Zip
l'h:05tt wrtlo At:i.ounl numtlet on Check.
SJgneture..'
Dol.
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PlJr.
McDonald's Corporation
, Dividend Reinvestment and
Stock Purchase Plan
for Shareholders
Save llus statement lor yo"r reeorus,
MICHAEL L RUPP & STEPHANIE L
RUPP JT TEN
1~ EAST OAKWOOD DR
CARLISLE PA 17013-9385
I..J
By Milli
MllJuunltl''\ Shalf-I"..." St'l\l'l ...t
rll!;l \~Ilf,':"'f) ."Il~U l.lIU1p:lll\,
P l) On.. 21",1) I
J",sey C,I" ~IJ 0,3U3 25'31
By Phonr.
US i,'I,lt '"nil','
, III It , MI" C;IL.:K It 'ItlO'll~1 :n;!!',1
011"""(""""''''''
1,:0' 2~2 ,19'.JI,)lCall ~oilecll
By Facsimile: '.201 ,222,4962
Company Code
Account Numb.,
09823
15168-50432
Sequence Number j/~l #\t.""""!itf,1""'~ l.SP C"I\ f
Sllt.m.nl Oil.
9.002.0~8
12/16/94
DETAILS OF LATEST DIVIDEND PAID
Record Oil.
p.y.ble Oell
Dividend Rnte
O.le
12/16/94
Transaction Oescripllon
DIVIDEND PURCHASE
Slwes in Cel'1,ncnte
am on _ Dale
Plan Shares on
Record Dal.
ToI.1
DIYldends Pmid
Nel
Dividendi Paid
Tn. Withhold
ACCOUNT TRANSACTIONS
Shnre Balance
In Plan Account
109.409
Trnl15:1ction Amount
(in U,S, dollD..l
6.55
Price Per Slim.,
in U,S, dolla...
29.002
Transnction
Shares
0.226
BY
OF
ELIMINATE
DEPOSITING
THIS STATE
HE RISK OF LOSS OR D STRUCTION F YOUR STOCK CERTIFICATE
THEM INTO YOUR ACCOU T. INSTRUC IONS TO DO S ARE ON BAC
ENT. OR CALL THE ABO E NUMBER,
YEAR- TO-DATE SUMMARY
Opllonal Cash
1.620.00
Nel Olvidend.
21,29
TOIDi Cash
1.6~1,29
00IaCh _
_.-.
McDonald" Corporation
Dividend Reinvestment
and Stock Purchase Plan
PI_ retum thle lann 10:
. Mc;OonaId'. Sha'8hOId. SenrIC8I
,;:.... FnI CNcaQo Trust Compeny
:+ j',~ P.O.Sox;3531
:~t MICHAEL ~'Ifil~71t'~EPHANIE L
~~~~~~~A~i ~~WOOD DR
~~~~~E PA 17013-9385
';r~"\ --,.,
~~,",!-f' ~ .
':PA.
&;"",
~:':f.-, '-
.;-,i".:
09823 15168 50432 64
os. , 43'
Md) '75M 1~~"1
SM ~ Ic'f drt~ ."'''tC'I.,....,
Shares Withdrawn
0,000
ShDle. Sold
0.000
Transaction Form
~~~
U,s. Soclol_ty Of Tul,D, -
I 176-46-5988 I
...... ._11 ~,..
,..., ClIIo_ T_' c:..._
CERTIFICATE DEPOSIT
IlopOtlt _laNd cOfllf1calollllnlO
~.~tld.'~"
DIITI
WITIIDRAWAI.. eon_ PIon POll_lion
I..... ._10... OR Sol \11Io _ 01_
"",_01_ ondlo_'_
L:IITIJ ITIIIJ
ACCOUNT ClOSURE
O CSoM my ec:count and I..... . ctrtIftcat. tor
llluI_onde_'Of.".,---
o CIoH my _~ II PIon -- ond
""" . check
ADDRESS CHANGE, SHARE TRANSFER
O Pte.M mark boa IInd compItll Oiher IkM
ofrorm
AInOu1'
-
u.s..
Nut entJcIpatIJd ...J..to._Ill....
f1/16/95 . 02/01/95
O __,....ouppIyal
en Iddrulld....un 11I..11=1111
Signature.
If IOOINf'IIIe tit,........,..............
---...---
.....on... .~
~
McDonald's Corporation
Dividend Reinvestment and
Stock.Purc~ase Plan
for Shareholders
SolVe thIs statement tor your lecolds
Uy Mall:
Mc.Uul1nllr'l SharNIIJI(k~ "'i"'~II.,tt'
Fllsl <:hlf':1liIO.lllf'tl Cnt'II';UlY
p 0, Bo. ~':(1I
Jersoy C'ly, NJ O;JUJ'~5U'
MICHAEL L RUPP & STEPHANIE L
RUPP JT TEN
14 EAST OAKWOOD DR
CARLISLE PA 17013-9385
Rocord Date
Peyabla Do..
Olvld.nd ROIl.
11/30/94
12/16/94
00.06000
Company Codo
09823
By Pllano:
I) I: ",,,, Cifl;",.-,
I "'~IM'1 S'CKII'''('OG?I.;"~r.1
n'''t~ t:ltfl"":~~
1'2U"~22 '~YIlU ICaIl callecll
By Facsimll.: ',201,222,4962
Account Number
15168-50432
Sequence Number ,fcJr "'ltH!!/'I..t/,"",,: 1,0:" CI!I, I
Statement Oat.
9,002,048
DETAILS OF LATEST DIVIDEND PAID
5h<ns n Cef1l1Icat.
onn on _ 01110
Pfan Shar.s 011
Record Dale
TOlal
Dividends Paid
o
109.183
ACCOUNT TRANSACTIONS
Do.. Transaction O..crlpUon Transachon Amount
(In U,S, dollal.'
01/03,194 BALANCE FORWARD
01/03/9lf OPTIONAL CASH PURCH 50.00 56.538
01/17/94 OPTIONAL CASH PURCH 50,00 57.190
02/01/9lf OPTIONAL CASH PURCH 50.00 60,765
02/16/94 OPTIONAL CASH PURCH 50,00 61.328
03/0l/9lf OPTIONAL CASH PURCH 100.00 60,979
03/1B/9lf DIVIDEND PURCHASE 3.30 59,8lfO
03/18/9lf OPTIONAL CASH PURCH 150.00 59.8lfO
Olf/04/94 OPTIONAL CASH PURCH 50.00 57,790
Olf/18/9lf OPTIONAL CASH PURCH 50,00 56.707
05/02/94 OPTIONAL CASH PURCH 200,00 60.075
05/16,194 OPTIONAL CAS~ PURCH 50.00 58.180
06/01/94 OPTIONAL CASH PURCH 100.00 61.311
06/17/94 DIVIDEND PURCHASE 4.90 30.249
06/17/94 OPTIONAL CASH PURCH 670,00 30.249
06/24/94 S'rOCK SPLIT
07/01/9lf OPTIONAL CASH PURCH 50.00 28.855
09/16/9lf DIVIDEND PURCHASE 6.54 27,419
OpUonD;1 Cash
Shales PurchaSed
Shares Deposltltd
~PA." McDonald's Corporation
: Dividend Reinvestment
and Stock Purchase Plan
. ..' P1_ retum thla ronm to:
;;, McOonaId's SIwehoider Services
First 00caa0 Trust Company
P,O, Bo. 13531
Newsrk NJ 07188,0001
MICHAEL L RUPP a STEPHANIE L
RUPP JT TEN
.. 14 EAST OAKWOOD DR
~", ,CARLISLE PA 17013-9385
.~. .' ~
09823 15168 50432 64
QS.14I)I
UrOtl~I'I'~1
StoP to..'1Mr Iry ""'~I _-=tt, 11"1____.
YEAR-TO-DATE SUMMARY
N.t Dividend.
Tolal Cash
Slack Spill
Shares Withdrawn
Transaction Form
U,S, Soclot Security Ot Tax I,D, _
I 176-46-5988 I
Amc.v>r
enclDSea
WITHDRAWAl. Continue Plan PonIcJpaIIon
Itlue cenlncal, for OR S.I thIa number of Ih...
.... numbel 01_ and _ a_k
ITIIIJ ITIIIJ
ACCOUNT CLOSURE
O CIoN my account end ..... . certlne.', for
..IuI....... and a cIleck lOt any Iroct_ -.
O DR
Clota my accounl. tel .. Plan shetn and
..sue . check
ADDRESS CHANGE, S.....RE TRANSFER
O Pfe... maftIa baa Ind compte,. othef tide'
o"Otm
12/16/94
Tax Withheld
Not
Dividends Paid
6,55
0.00
6.55
Transaclion
Sha,es
Share aalance
In Plan Account
27,286
28,170
29.0lf4
29,867
30.682
32,322
32.377
3lf,88lf
35.7lf9
36.631
39.960
40.819
42.450
42.612
6t!,761
107.211
108.94lf
109.183
0.884
0.87lf
0.823
0.815
1,6lfO
0,055
2.507
0.865
0,882
3,329
0.859
1.631
0.162
22.149
42.450
1.733
0,239
Sh.... Saki
~~
...... e_k ~ lee
'Irs. __ T_ 1:"',,_
U.S.$
No.t..___cIeI...
f1/16/95 a 02/01/95
O __mea~af
pre Id.1J. llirwtuntll... ~ _
Signatures
" eccounI"", JoInt terwlcJ...... ............
........ "..,... '"'* be..... ..... .
...,... 0l'I .... ...........
STATEMENT PERIOD
JAN 1: 1994 THROUGFt DEe 30. 1994
'~
'J . ...~.. ~
..,~.!'y. ~I~.#....."..
'1111 1:1'" I I; 1"1 "1"
Page 2 01 J
THE BERGER ONE HUNDRED & ONE FUND TRANSACTION SUMMARY
ACCOUNT: o.u-0199391199O SSN: 176.46-5988
MICHAEL L RUPP ..
STEPHANIE L RUPP JT WROS
CONFIRM TRADE DESCRIPTION DOLLAR SHARE SHARES THIS TOTAL
DATE DATE AMOUNT PRICE TRANSACTION SHARES
BEGINNING BAlANCE 90.1B6
01{10 01{10 SHARES PURCHASEO 50.00 11. 940 4.IBB 94.914
01{24 01{24 SHARES PURCHASEO 50.00 12.030 4.156 99.130
02{OB 02{08 SHARES PURCHASEO 50.00 12.040 4.153 103.2B3
02{23 02{23 SHARES PURCHASEO 50.00 11.880 4,209 101.492
03{10 03{10 SHARES PURCHASEO 50.00 11.110 4.210 111.162
03{24 03{24 SHARES PURCHASED 50.00 11.630 4.299 116.061
04{04 04{04 SHARES PURCHASED 50.00 11.010 4.511 120.51B
04{04 04{04 EXCHANGE TO SHAll CO. 250.00 11.01D 22.5B4 91.994
04{IB 04{18 SHARES PURCHASED 50.00 11.010 4.541 102.535
04{22 04{20 INCOME REINVEST .03 3.0B 10.140 0.281 102.822
04{2B 04{2B SHARES PURCHASED 5D.00 11. 100 4.505 101.321
05{16 05/16 SHAMES PURCHASED 50.00 10.910 4.583 111.910
05{31 05{31 SHARES PURCHASED 50.00 11.260 4.44D 116.350
06{13 06{13 SHARES PURCHASED 50.00 11.15D 4.484 120.834
06{21 06{27 SHARES PURCHASED 50.00 10.850 4.608 125.442
07/11 07/11 SHARES PURCHASED 50.00 10.920 4.579 130.021
08{04 08{02 INCOME REINVEST .04 5.20 11.280 0.461 130.482
11{11 11{08 INCOME REINVEST .025 3.26 11.460 0.284 130.766
12{30 12{28 INCOME REINVEST .037 4.84 10.680 0.453 131.219
ENDING BAlANCE 131.219
THE BERGER SMALL COMPANY GROWTH TRANSACTION SUMMARY
_ ACCOUNT:3U-01994161U5 SSN: 176-46-5988
MICHAEL L RUPP" !!
STEPHANIE L RUPP JT WROS 8
CONFIRM TRADE DESCRIPTION DOLLAR SHARE SHARES THIS TOTAL
DATE DATE AMOUNT PRICE TRANSACTION SHARES
BEGINNING BAlANCE 0.000
04{04 04{04 EXCHANGE FROM 101 FUND 250.00 2.490 100.402 100.402
04{18 04/18 SHARES PURCHASED 50.00 2.480 20.161 120.563
04{28 04{28 SHARES PURCHASED 50.00 2.520 19.841 140.404
05/16 05/16 SHARES PURCHASED 50.00 2.450 20.408 160.812
05{31 05{31 SHARES PURCHASED 50.00 2.480 20.161 180.973
06/13 06{13 SHARES PURCHASED 50.00 2.460 20.325 201.298
07/11 07/11 SHARES PURCHASED 50.00 2.370 21.097 222.395
11 {II 11{08 INCOME REINVEST .0033 0.73 2.840 0.257 222.652
ENDING BAlANCE 222.652
IIIIIIII
UI -'t100_ 00) 0000 000.".'000017'524 ""0
STATEMENt PERIOD ,
..IAN I, '1994 THROUG~: DEe -30, 1994
., ~ -
..!j".~' . -.,....
'"1/111;1,11:11\1"
PIg. 3 01 3
PLI!ASI! DETACH AND USI! TD IW(I! CHAHlJI!S TO YDIIR ACCOUNTlS)
THE BERGER FUNDS
FUIIl IWE
BERGER ONE HUNDRED . ONE FUIIl
BlAGER SlW.L ClIMPAII'I GROWTH
ACCDIIIT IILIIIlU
0DDD044-DI99J9I199
0000345-01994151(8
MICHAEll RUPP &
STEPHANIE l RUPP ..IT WROS
14 EAST OAKWOOD DRIVE
CARUSlE PA 17013-9385
MAIL THIS STUa TO: II!RGI!II fWlDS, P.D. lOX 411111i ICAHSAS ClTY, .., 14141-1111.
TO CHAHlJI! THE AIIOYI! INfDIlMATIDN, PLEASI! CHl!CK TH S IDX C AND SEI! INSTIllJCTIDNS DN IIMIlI',
IIIIIIII
IAS _11'10_ 00' ??oo 000....." 000lnu. 1M)
f,piL<
i
. AT&T
, MICHAEL L RUPP . STEPHANIE L
RUPP .IT TEN
SItAAEOWNEn DIVIDEND nEINVESTMENT
AND STOCK PUnCIlASE PL^.N
Hlnl:'lll ro, T,u PlJIP05t''t1
ACCOUNT NO. 16572-83525
TAX 10 NO. 176-~6-5988
DATE 2/09/95
0~56080
STATEMENT OF ACCOUNT
"'="
DIVIDEND REINVESTMENT INFORMATION AS OF nECORD DATE
- - ttoki f' - -Iin_ Sh_ I ralal !nral~ I Dhrldond J DI.ldond. an
c~:~ I;orm ~: ~~l:~':n.: sr.t," In P'ln RI'ICS) En,ollt'd ShAre. .SI
o 36.873 36,873 0.33 12,17
Tn Wlth~ld
ISI
Net DMdfnd Amount
(II
12.17
2/01
0.00
i
,
L._ __
I -
D..c~pUan a" '
r...-
START BALANCE AS- -
OF JAM 1, 1995
DIVIDEND PURCHASE
TAXABLE DIV INCOIlE
YEAR - TO - DATE TRANSACTIONS
Oolllr Amount :::i~..,:..1 Nel Ooll;1r ' P:~~::~:c:'
III ,..".. -- i Amounllll P Sh (SI
I """"" I ,.r Of. '
,
1:'118.,,1.
(S'
T'anl"cllon
Shlr..
. Ballne. or Shatn Held
b, Ag.nt In Your
pt8ft Account
12.17
12.13
1.00
11.17 ~9.7630
~9.6880
O,2Z~
36.873
37.097
-----....-..- -------....--...............-....................---.............................................-.................................. ........ ....... ..... ...... .............. .......... ..............--......-.........................
(Detach)
DIVIDEND REINVESTMENT AND STOCK PURCHASE PLAN
Supple menial Pnymenl And Accounl Chnnql' ru""
ACCOUNT NO.
16572-83525
i
I
I :
THANE YOU FOR PARTICIPATING IN THE DIVIDEND REINVESnIENT AMD STOCl: PURCHASE PLAM
I :' '
UPCOMING CUTOFF DATES FOR RECEIPT OF SUPPLEMENTAL PAYHENTS (.100 MINIHUH) ARE:
FEBRUARY 28TH. KARCH 31ST AND APRIL 28TH. PLEASE MIL YOUR PAYIlENT IN SUFFICIENT
TIllE FOR IT TO BE RECEIVED IN OUR OFFICE BY THE CUTOFF DATE
L_.
. ATs.T
I
1",111",111"""11"11,1,1,,,,11,1,,1,,1,1,,,,11,1,,11,,1,1
MICHAEL L RUPP . STEPHANIE L
RUPP .IT TEN
1q E OAXVOOD DRIVE
CARLISLE PA 17013-9385
r n rUfCh:1!'l1" Ad''''IOI",,1 Shares PlenH
U;,... elll"f''' 0, U,1fW'Y Cl,rtrt Pnynblt! In
tI'"I"" !;10I1"'\ I It.... It " fn AfAr tPee",,,
UIlI" ^ 1 ^' ^"n"'t1t I~'nnht'f On Payment'
Do Nol ~nd e,l.h.
Amonnl Enelo"Nt ~
('Untmum S 100 r.., PR,,,,..n'
Mttllmum s~n.onn r.., C:tffonc'IM ,..)
08111 16512 83525 55
MAIL PAYMENr 10GETHER
WI rH nus FORM TO
AUURESS ON REVERSE.
COMPLETE REVERSE OF
FORM TO:
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'18-0110~
"".......". U OS ENERGY CoRPoRUIOIl
",..,,"'.. "IC AEL L RUPP , S1EPltANIE L
RUPP Jl 'Ell
,l,(f1IIHINlI 1100 10 2.0-9'"'0
,,,,,..,.... l6-"6-1988
(I"',........ 9560 0'
U..."....HII"'" 12/2Z1 "
IMPORTANT.AlL IlEQOOfD 1NF0IlMA'1OII
flEONllJt<<) liE IlEllE.....1ON Of lIIWIU IS
DEm rtJnNISlfEO 10 TIE tf'ERHAL REYEMJIE
BErMCE. nElAIH 1119 SIA1EMEN' Fen 't'CXJR IN.
YES'M(NT AND tAlC RECORDS
99~" "'iU'. '011 ADOInoMAllII'OIWnofIlHOlUiI"'"
IF IOU ItAYE ANY QUES'loIlS. CALL IIlYES'OR
REL 'IONS TOll FREE AT 1-800-136-JOOI
,,,0100..10.. : FULL DIYIOENO REINYESlftENf
III'IIUN I
I I ' , I """""" I '"'''''''''' I '
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1m ALAIlC~ FrWARO ]Z.O'I
A~" 0 ~O IT JO.OO 1.066
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1m, ollPANY , PAID Coft" ISS lOll .06
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COft" IS ON .0
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61Z8 ~~R ~~, ~~lU~ES(8 THlR~E H.U.8~1 18...160 .1,Z
61Z8 9680 APlT C O.~Z
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CONUIlUEO ON NE , PAGE
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il,Il'.ltIIlUI\lIUn
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~A~~A~~ ~ ftUPP I S'EPHANIE L
I~ E OAKWSoD DRIVE
CARLISLE PA 110 3-938'
L
.J
AMOUNT RIIIllllD' S
to.CJlllttUDII WOII'A'f'" to
DAN!< llf UCl510N
"IN 2,.00 "AK 60,000.00
toNrINUA~loN PAGE
"e-DlID
..~.."' "".. AI D~ ENERGY CORPORAl ION
IlIUUlAln. "It' l L RUPP , SrEf'H HIE l
RUPP r 'EN
"f(UINJUn 3100 10 20-9'''0
I"'~'I"I t 16--\6-'988
tI!\I'MIl"'" O~9'60 10 ,
""HIo4INII'-'1I 12/Z2/94
IMPORTANT....L IlEQI.II1EO 1I'00000llON
nEGAnOHO lIlE nEOEUPtlON Of' BlWlES tS
OEINO n.l"'SlIEO TO ltE .nEnNAL REVENUE
sef1YlCE REtAIN nt' SlAtEMENt ron YOUf1 N.
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~
IF loy "AVE ANY OUE51,ON\. tALL IHVES'O~
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HI AA" ^rES1"EN' 10.00 n'OO 18:UOO 10600
PA PA D Co""IS UN
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~~An yPo1Ya~EsI1 Co""lSi ON I6:Ugo
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2/19 "~A Y PAlh CO" IS ON .Ol
t,lt.
,rAil 1OI}o\II (,>>.lMCINMfCJlINI ""'1""'11\
In Ilvun
Plan Admlnlstralor:
Harris Trust' and Savings Bank
PO, eOl( A3309 '
ChIcago. IL 60690
ACCOUNT NUMBER SOCIAL SICURITY or TAX 10
ALLIED
(.110,-'..
RUP7056000
176-46-5988
DATE PRINTED: 12/28/94
2579
AC 01
MICHAEL L RUPP &
STEPHANIE L RUPP JT TEN
14 EAST OAKWOOD OR
CARLISLE PA 17013-9385
THE NEXT INVESTMENTS: 1-25-95.
2-27-95 & APPROXIMATELY 3-31-95
THE MINIMUM: $25
THE MAXIMUM: $5.000 PER MONTH
CHECK MUST BE RECVD BY THE 20TH
COMMON
~A"TICI'A fiNe SHARIS HlLO II'" YOU
TVP. 0' STOCIC NO. O. SHAIIIS DIVIDINO
Please use this lorm lor making an address change or inqUiry.
RUP7056000
MICHAEL L RUPP &
STEPHANIE L RUPP JT TEN
VOLUNTARY CONTRIBUTION U.S.$
ALLIED GROUP, INC
DIVIDEND REINVESTMENT PLAN
COMMON SHARES HELD IIY us
NUMB'R 0' SHAII.S DIVIDlNO
I PAG:
TOTAL
DIVIDENDS
50.8180
7.62
7.62
IIECORO PAVA"'. COMMON DEDUCTIONS NIT OIVIOlNOS
DATI DATE OIYIOEt<<J "ATE TAXES SIRVICE CHARCIS COMMISSIONS INVlSTED
12/12/94 12/20/94 .1500 7.62
TRANSACTION PUIICHASI MAIlltIT TAX BASIS all TOTAl. NIT DISCOUNT SHARU
, PRICE PAICI SHARU
OATI ITY" PlR SHAR. Pili S""R. ACQurRED OlOUCTIONS AMOUNT AMOUNT ACQUIRED Oft IALANCI
WITHDRAWN
01/01/94 'C8 40.9447
I
01/25/94 'VC 23.7500 23.7500 60.00 2.5263 43.4710
02/25/94 :VC 25.3200 25.3200 30.00 1.1848 44.6558
03/31/94 'VC 24.1250 24.1250 30.00 1. 2435 45.8993
03/31/94 I .2777 46.1770
IR 24.1250 24.1250 6.70
OS/25/94 'VC 25.2000 25.2000 :;U.OO 1. !I~41 48.16J.l
06/30/94 , , 48.4403 I
IR 25.8624 25.8624 7.22 .2792
06/30/94 :VC 25.8624 25.8624 55.00 2.1266 50.5669 !
09/30/94 'R 30.2300 30.2300 7.59 .2511 50.8180 '
12/20/94 :R 25.4604 25.4604 7.62 .2993 51.1173
TOTAL OTHl. OlOUCTlONS NeT AMOUN' OISCOUNT AMOUNT
OIVIOINOS CONTRIIUTI ONI 'AXU COMMISSIONS INVlSTED
YEAR
TO 29.13 225.00 254.13
DATE
SUMMARY 'Al( IAIIS 0' SHARU SHARIS You" CURRI~T AND AS 0' THE MAlUtlT
SHARU ACQU'RlD PURCHASED WITHOftAWN SHARI BALANCE THIS DA T. V""Ul
254.13 10.1726 51.1173 ' 12/20/94 '$ 1. 301. 46
I I
(See reverse side lor important inlormalion and explanalion 01 symbols,}
AUTOMATIC DIVIDEND REINVESTMENT PLAN AMERICAN STOCK
FOR: TRANSFER AND TRUST COMPA,
WENDY S INTERNATIONAL INC 40 WALL STREET
NEW,YORK, NY 10005
7],8 "121-8283
.t. .' ..._ ., "'u,,, .'L I,
RICOllD DATI
U/14/"l4
PAYA.LI DATI
SHAlles HILQ ..,
YOU ON
AICOAD DATI
SHAAIS HI!LD .,
US ON
AICOAD DATI
],], /2"1/"14
MICHAEL L RUPP & STEPHNIE L RUPP JTWRS
14 EAST OAKWOOD DR
CARLISLE PA 17013-"1385
TIlANIA~ 'T AMOUNT SUlYICI! Pillet! S....AU -II HI!LO TlIANIACTION "PI!
DATI Y 'D" PUIlClfAlI! C1f....Q11 PUllHAllI! PUACHAlaD .,us
P
.
01/01/"14 BALANCE FORWARD .. 84.014 51 Prior ,hi" balanc.
52 C.2sh rc-r:elvrd
01/10/"14 b2 200.00 .00 17.500 11.42"1 "15.443 5. CltIh od'u'lm.nl . CREDIT
02/J.0/"l4 b2 bO.OO .00 1b.750 3.582 "1"1.025 51 C.th 'djuslm'nl . DE8rT
03/10/"14 b2 bO.OO .OU 17.b25 3.404 102.42"1 eo Shari' purc:h..td wUh dlvld.r
03/21/"14 bO 5."14 .00 17.750 .335 102.7b4 prOClfll1
04/],],/"14 b2 100.00 .00 17.bOO 5.b82 108.44b I. Sha,.. Purch..td wUh dllCOu'
05/J.0/"I4 b2 50.00 .OU 17.238 2.~01 1U.347 procHdI
OS/2b/"I4 bO b.b8 .00 17.500 . 82 ],],1.72"1 12 Shar.. purch..td with ClSh
IJ Shat.. purchll'" "tit nth die
ObIloO/"I4 ~~ 55.00 .00 17.000 3.235 U4."Ib4 ... Sh,,., rwc"nd . STOCK CIVIC
071],],/94 100.00 .00 J.5.500 b.452 121.4J.b 15 Shr.. recefv'd . STOCk SPlI T
09/02/94 bO 7.28 .00 15.550 .4bB 121.884 II Shll.... CReDIT 8d'ullment
11/1U/94 b2 20.00 .00 15.23J. 1.313 123.197 70 PARTIAL WfTHDR.WAL. eMIIi
],],/29/"14 bO 7.3"1 .00 13.750 .537 123.734 In,*, 'or whof. 'hat..
" 'AnFlAL WITHDRAWAL. who'
thalli lold
12 P^ATIAl. WITHDRAWAL. ~rt,
'nu.d for wholl 'hi"'; t'.ctl
lold
73 'ARrlAL WrrHDAAWAL. aU!1
said: sharehalder remaIn.'" p'
.0 PLAN TERMINATION. .""11I..
Issued lor whale share.: "acUr
said
.1 PLAN TEAMlNATION. an sh..t
II SHARES TRANSFERRED
19 sty.u OESrr adjustment
BUlL)) YOlJf OWN RSHIP IN ~~NDY S VOLUNTA ~~ CASH PAyr ENTS
ARE INVEST D 0 OR ABOUT THE 10 H OF EAC MONTH. NO FEES.
.2U/MONTHL ~ "I . AND _20 l'-POO/ AN' UAL "A~( CHECKS PA~t BLE
TO AMERICA ST CK TRANSF toR/WEN. USE ENC SED ENVELO E.
I'~~ . ./ I S"YOU S"US COMBINED
0000022530 TOT A.. aKA"..
HelD .000 ],23, nil 1;>':1 -;
DETACH HElIE
AATI! PI" SHAAI!
a"oss AMOUNT
'Olt PlIllCHAII!
TAX wtTMlnll
HIT fUf.
'llIIPIIIIC,
7.39
.00
7.
For cesh Inyellmenls, wllhdrwwels, Ind chlnge ollddress, plelSe use lhls 'orm.
... boc:k 0/ 'ann ,..,..- P.nl., Wlthdr....,IC""'.... 0.._ '''''''''''''''1) Opllon" Cuh Inyu'm.n'
PR1Ht' ~RAUlIN Tll1I STYlI! Issue a Clnmeal. lor lhis .
number 01 shares
DETACH
Amounl enclosed
17b4b5988
Taxpayer 10 or SocIeI Security No,
.
or SeH thiS number 01 shares
$
Enter II above Is miSsing or Incorrect
.
Nexl anticipated
inveslment dale
Slgnaturels' AIII<>nl Owners must sill", Nemes mu,
be slgnttd err.r.lly AS shown on Ihi. '01 ,#.
b75B 00000225300
L
Full Wlthdra.al (TIt,mtfl:ue dtYlder'1d 'etn'feSlntenl)
Issue a cer1ificale for nil lull slimes :utd check 'or
fractional share
---_. -.----.-----
or
S.. an Plan shl1f~!I
.
Addre" ch""g_ Check bnl ..,.
fI' ",lIm !:fC.'" 01 t('lIU
.IAllo\il\t....'
CENTRAL MAINE POWER COMPANY
SHAIllHOlDER SlJMCtS . I:l EDtSON OR, . AUGUSTA, IN., CW336
, ltW'HOI'<< (2Il71~1 OR,'~
DIVIDEND REINVESTMENT AND
COMMON STOCK PURCHASI PLAN
ACCOUNT NUMBER TAX 10 NUMBER
000Il~835~ 11o-~6-5988
PlEASE SEND All INQUIRIES TO THE ABOVE ADDRESS,
FOR ACCOUNT CHANGES PlEASE SEE REVERSE,
'HICHAEL L RUPP &
STEPHANIE L RUPP JT TEN
14 EAST OAKWOOD DRIVE
CARLISLE PA 17013-9385
OPTIONAL CASH INVESTMENT STUll
PUASl RUURN lHIS Slue WIlH YOUR C"EOt.
MINIMUM OPTIONAl. CASH INYqTMlNT I!D,OlI,
~
HIC L RUPP 01
ACCOUNT NUMBER
000I2~835~ CDHH
MAKE YOUR CHECK OR MONEY ORDER
PAYABLE TO CENTRAL MAINE POWER CO.
I $
AMOUNl ENCLOSED
PlEASE PR'NI CHANCE OF ADDRESS ON REVERSE
STATEMENT DATE FOR CURRENT AllOCATION
TYPE OF
TRANSACTION
I DIVIDEND, PRICE I SHARES PUIlCHASED : SHARES HELD BY
CASH li'faMD: PER SHARE i OR WllHOllAWN : COMPANY FOR YOU IN PlAN
PRIOR BALANCE. 1 O~. 719
523.56 513.9090 1.69~ lU6.413
i
01/95, PLAN DIVIDEND
I
,
,
j
!
10~9 INFORHATlON WAS'ttAlIlED TU,'YUU,;lN_JANUARY.,
PLEASE RETAIN FOR YDUR"INCllHE TAX PREPARATION. '
THE NEXT CASH DEADLINE DArt IS FEBRUARY 10 FOR rH~
HARCH 1 PURCHASE.
SHARES HELD ON RECORO DATE
NET DIVIOENO
REINVESTED
TAX WITHHELD
IF APPlICA8lE
0.225
523.5b
.0.OU
54!l.~b
RETAIN THIS STATEMENT FOR YOUR INVESTMENT AND TAX RECORDS.
@ MOTOROLA lNO.
PI." Administrator:
Harris Trust and Savings Bank
P,O. Box A3309
Chicago. IL 60690
ACCOUNT HUM....
IOCIAL SICUftlTV or TAX 10
RUP2812500
176-46-5988
DATE PRINTED: 01/27/95
26377
MT 01
MICHAEL L RUPP
14 E OAKWOOD DR
CARLISLE PA 17013-9385
NEXT INVESTMENT 2-15-95
MINIMUM AMOUNT $25
MAXIMUM AMOUNT $5.000 PER QTR.
CHECK MUST BE REC'D BY 2-14-95
'VOLUNTARY CONTRIBUTION U.S.$
Please use this forn1 lor
n1aking an address change or inquiry,
RUP2812500
MICHAEL L nupp
~
~
MOTOROLA INC
DIVIDEND REINVESTMENT PLAN
~"'''TICI~'''TlHO SHAIIIIS HlLO BY YOU COMMON SHAltlS HlLD .., us TOTAl. I
TVP' 0' STOCK NO, 0' SH.....S DIVIDlNO NUM8l1t O' SNARlS DIVIDINO DIVIOINQS ;
COMMON 1.1826 .12 .12 !
,
I
.
..ICOM) 'AYASLI COMMON llIIlUC1lDNS NIT DIVIOPlOS
DATI 1IA TI DIVIDlNO ~ATI TAlIt" S...VI" CHAJlGII COMMIISIOIl$ INVISTIO
,
12/15/94 01/16/95 .1000 .12 ;
,
TlIANSACTION I'IJlICHASI MAlI"T TAll IASIS D' TOTAL NIT DISCOUNT SHAllas ,
, P11ICI '~'cl SHAMS
DAn. 'T_ OIOUCTIDNS AMOUNT AMOUNT ACQUIIIID Oft IAVICI
I' 1'IIl_' 1'IIl_ /oCQUIIIID WITHlIllA_
01/01/95 'CB 1.1826
, .1, ,
01/17/95 'R 62.5000 62.5000 .12 .0019 1.1845 i
, ,
, ,
,
,
.
.
,
, I
I
,
,
,
, ,
,
, I
I ,
, I
,
, i
,
,
,
I
I
,
. . TOTAL,' I::' " ' OIOUCTIDNS ' ,'. - .., ,.:-:
'",.i, 'OMft , NIT AMDUNT . DI'couiIT AMOuNT,,',
,'iOlVI_,,:."': :'c:o~lIIIUT'OIlI TAllU CDMMIU'DHS INIIlISTID , '
.. . '.,' ..'....)...
YEAR
TO .12 .12
DATE
SUMMARY TAX 1.u'1 D',)" ":,)r.IHARII,-. . ..........' YOUll CUIIIIIHT AND .u D' THE :<;\'>.':'((:;.,'
IllAIIU ACGliIlIID, :~.~;:;. PUttH\lcO' WI__" _ lAUIlCI ' TlUI DATI
.12 .0019 1.1845 I 01/17/95 '$ 74.03
, I
X.1710, pllIV.'.'U
(S~ reverM side for ln1portant inforn1ation and explanation of syn1bols.J
PHOENIX CAPITAL APPRECIATION PORT-A
PO BOX 1912
BOSTON IIA 02105
CONFIRMA nON 12/ 31/1994
THE
PHOENIX
FUNDS
.
1",111,.,111"".,11,,11.1,1.,..11.1,,1,,1.1,.,.11.1.,11,,1,1
MICHAEL L RUPP
STEPHANIE L RUPP JT WROS
14 EAST OAKWOOD DR
CARLISLE PA 17013-9385
If YOU HAVE A BROKER/DEALER,
PLEASE ADVISE US IN WRITING
THANK YOU
'DINT, NO, O. SOC, S'C, NO, 176.46-59BB
I Fund Na21 .....52"6 ;;'99 I Ch. S" IflEflfllNU 'ou.
'UNDIlCCOUNf .
, ON ALL
COIUl , NO If .
Tran.act I on 0 or n Shor.. ThIs o a I
of Tran.actlon Tr ".act t on Shar.. awr.d
BEGINNING BALANCE .000
r22 r21 SHARES PURCHASED 25.00 iP! I :aal 1: 21
/2 "I INCO/lE REINVEST .OB .O!
/2 /2 SHORTTER/I CG REIN .2 ~ .2 .Ol~ 1. ~
/2 /2 CAP GAIN REINVEST .O~ .1 1 .4 .00 I. l
t IHi PERIODIC PURCHASE - AC 2~.OO 1 .4 l. !~4 2. t
II CANCEL PURCHASE-ACH 2 .00 I .4 l. 4 1: l
I /2 INCO/lE REINVEST .0~2 J2 Ir~ . 4
12/2 12/22 SHORTTER/I CG REIN .2 4 1 .1 .02~ l. ~
12/2 12/22 CAP GAIN REINVEST .393 I .1 .03 l. 2
$24.34 AT
$17.13 PER SHARE
PHOENIX CAPITAL APPRECIATION PORT-A
MICHAEL L RUPP
STEPHANIE L RUPP JT WROS
14 EAST OAKWOOO OR
CARLISLE PA 17013-93B5
THE ;;
PHOENIX ~
FUNDS
To Inyost By Moll:
For pureh.... InlO thll IccOunt.
rllu'" 'hll Itub Ind your chick
In ",. tnclond .n..,.lo~..
For New Purch....:
Submit In Ippllullan found In Ih,
"a.~ctu. with. chick midi
PIy'blt to th. fund of your choice.
.... d rect nqu'.1 10
Shlr,hOld" S.rvlc.. or 'holnl_
l.pI,,, IS.. 'I""" tide lor
In'truCllon,..
To Moke Chlnge. Or Correction.:
1 11 11 11 Campi'" 'he "..,.,., ,Id. ,nd ptau .nQ9 in th, bu: below.
PHOENIX fUNDS
C/O sse & TRUST CO
PO BOX 1912
BOSTON MA 02105
111,""1,1,"1111.".1.1...1.11
",... und m, th, "QUI"d
lorms to ,elh,." ",tom.",
monlhly in...I"""". 0
flNVESTO-MATICI
.
i
i
,
.
AMOUNT 0' CHEC't
DEAUA IN'OAMATlON
't'l
I 000
,. 25.00 m'"'mum!
l~gllmlmmll~1
I~ -..",_ I.e,: e"". ".
{} 0000 71891230 000052652998 0000082
PHOENIX GROWTH FUND SERIES-A
PO 80X 1912 '
BOSTON HA 02105
CONFIRMATION 12/31/1994
THE
PHOBNIX
FUNDS '
,
i
1.0011I00.111,00.00110011.1.100..11.1"1..1.1.,,.11.1..11001.1
MICHAEL L RUPP
STEPHANIE L RUPP JT WROS
14 EAST OAKWOOD DR
CARLISLE PA 17013-93&5
IF YOU HAVE A BROKER/DEALER,
PLEASE ADVISE US IN WRITING
THANK YOU
9
.
.
r
lolHT, Ho, 0" SOC, SIC, HO, 176-46-598B
I 'und NOS 3 I '''52"(,;2'98 I c" S" t RUUIMCI 'OUR -
'UNO,IUDUllf !
, aM AU
c.. .a....tI
Tran.actlon of Transact t on Transaction Sha.... OWned I
BEGINNINr. BALANCE 1 :~~f
t/22 t/21 SHARES PURCHASED 25.00 21.4~ 1.164
/2~ /2~ INCOHE REINVEST .O~ .10 "'I 1 :~~l
II~i II~i PERIODIC PURCHASE - AC 2~.00 21. 0 t:ii~
CANCEL PURCHASE-ACH 2 .00 21. 0 1.1
INCOIIE REINVEST :~i~ .2~ l' .01 1.1 ~
12/2~ 12/22 SHORTTERH CG REIN .0 1 . 1 .OO~ I. I ~
12/2 12/22 CAP GAIN REINVEST .7 1 .91 I . I .04 1.22
ON 12/30/1994 YOUR ACCOUNT'S VALUE WAS
$24.09 AT
$19.60 PER SHARE
PHOENIX GROWTH FUND SERIES-A
MICHAEL L RUPP
STEPHANIE L RUPP JT WROS
14 EAST OAKWOOD OR
CARLISLE PA 17013-9385
THE ;;
PHOBNIX i
FUNDS
To In..st By Milt
For PUfch.... Into this account.
,.tUl'" thl, flub MlCI .,our check
In the enclo,.d a,...,elope,
For New Purch..es:
Submit an application found In th.
hOlputUI ""Uti. chIc" med.
Plyable to ,he fund of .,~ chole..
.... 'let lnqu r .. 10
Sh...hold., S...vlnl Of ....0."1.
lapuII ts.. ,...,.". ,Ide lor
In,'ructlon,'.
To Mike ChIng.. Or Carro.tlans:
111 '111 Comptl" 1ft. ,.ve'" .Id, I,.d pi Ice 1"(l9 1ft tM bu b,low.
!
,......lInd me tM '....I'et1
fo,ms to ICUv"1 1Ut000Ue
monthl, 1f",..lment.. 0
IINVIITO.MATICl
.
I
PHOENIX FUNDS
C/O SSB & TRUST CO
PO BOX 1912
BOSTON MA 02105
1I1.",,1.1.,,1II1,",1.11lI1.11
AMOUNT 0' CHICK
OIALlR INFOAMATION
, .
1 000
,s 25.00"'0'-
Illml~!mmll
{} 0000 7t8900tO 000052b52985 0000053
I. .1411". '.:1 "'7,,'41 "'41'
005t!0
Account Number
IA25-0010830 - A20
Tall: ID Number
I 176-Q6-S988
For the Period
110/01/9Q Through
Page
12!31/9Q
2
:'t,.::.,:,~,~..::~~,,,~.~~,~,~,,,:,,,, .,~., "
PORTFOLlO'PosITIONS
ACe
TYI'
UANTlTY
SECURITY
DESCRIPTION
PRICE ON
12131/94
MAlUCET
VALUE
POftTFlll.IO OIY RATE
PCT OR INT 'llo
ESTlMAmJ
ANNUAl INCOME
01
MONFt MAHEr FUND$
12,30 CORTlAND TRUST U S GOYT FUND
TOTAL MONEY MAlUCET FUNlIS
1.000
$12,30
$12,30
,65
,85
',50\
$0,55
$0,55
01
123
FnllmE$/OPTION$
MASlANO CORP
TOTAL EQUmES/OPTlONS
TOTAL VAL OF PRICED SECURITIES
15,250
$1,875,15
$1.115.15
1 111,05
99,35
99,35
100,00
$,20
$24,60
524,10
5,15
Prices shown .. supplied by 1ft outlide prlci"t SI,.,ice. lhey lie oll.n UNble to supply us with up-to"'th."'m1nut' informauon.
Thes. prices .. provided only ., . tlner" ",ide 10 the walue of your account
End .1 S_
Secwidn In rn/IY _ proleclld lot 52.500.000.
RE INVE ST/'IE NT SE RVI CE
THE CHASE /'IANHATTAN CORPORATION,
/'IICHAEl l RuPP /;
STEPHANIE L RUPP JT TEN
14 EAST OAKWOOD DR
CARLISLE PA 17013-9385
'I
IF YOU WISH TO UNO IN A'CASH PAYMENT TO PURe.
ADDITIONAL SHARES FOR YOUR ACCOUNT UNDER
TERMS AND CONOITIDNS OF THE AGREEMENT TEAP
AND REMIT THEUPPERPORTIONOFTHISFORMALONG,
YOUR CHECK OR MONEY ORDER PAYABLE TO'
/'IElLON SECURITIES TRUST CO.
10~16161016 RUPP-----/'IICHLdl00 OK-14~ I
DATE
.....OUNT
PION DIVIDE ND 8321 ,4000
I I
I ~.U""lI
OUI
I
1 11/15/'
CORPORA ION
IlHAAElI ACOUIRm P\.AN IlHAAE
!WITHDRAWN) IlALANCl!
I BAl FWD : I I I I 2g7:
1 I , I 0280
14 9 A 191 I 191 3C!l4880209 21 9'
I I I I I 3~3750000 I I
1 I I I P326 211u;
l' 9 A 1112 I 1112 3113039063
I I I I I 3~0625000 I I
I I I I I 2186'
l' 9 A 1113 I 1113 3",3781250 0329
I I I I I 3 ~7 500000
I I I I
I I I I I
I I I I I
I PlEASE' I FO~ PURPOSES.
I R TAIN TlfI STlAT ENT T X
I I I
I I I
I I I
I I
I I
I I
I I
I I
I I
I I
I 1
I I
I I
I I
I I
I I
316 316 10935 2,865
--.
......,),d1.
(.\\\\/., $,..!',,\
THE ALGER FUND
ALOER SHAREHOLDER SERVICES, tNC,
30 Monlgomery Slreet, Jersey CIIy, NJ 07302
DAILY CONFIRMATION STATEMENT
'a, Accaun.ln'ann.Uan, C.1I1.800.992.3883
'orward'ng and Add,..a CorrecUon Aequa.led
Your Accoun. HUIIIN, COlI""" Da..
Tu LD.
500042064-00 7-29-94
PO""ouo HAM.
176-46-5988
'AO NO.
SHALL CAPITALIZATION
I
I
II
V
.
I
r
o
"
MICHAEL L RUPP
14 EAST OAKWOOD DRIVE
CARLISLE PA 17013
D
.
A
L
I
"
T_
Oo..
T.....-on IleIClItplIon
DoIla,
Amounl
25.00
Price
Pwr_
20.35
Sha,.. Thla
TranUCUon
T_
--
1.229
7-29 AUTOMATIC PURCHASE
1.229
ON SELLING YOUR SHARES, YOU KAY PAY A SALES CHARGE.
FOR THE CHARGE AND OTHER FEES. SEE THE PROSPECTUS.
-"'01\__ CIlpftII_ _____ ___
"-leI TlIIo V_ _ 'T11Ia _ c............, Ponn Non c....l_ Ponn
0.00 0.00 0 1.229
T_
~
y
25.01
1.229
LOOKING FOR A COIfVENlElfT' NAY TO IIfVEST REGULARLY IIfT'O All ALGER EqUITY
PORTFOLIO? TRY ALGER'S Al./TONArIC IIfVESTNEIfT' PLAII. JUST CALL 1-800-992-3863
fOR Nt APPLICA!!ON AND fUlff./!ER INFOR!tATION I!tCLUOl/tG CHARGES ,~O E.'t.PE/tSES.
MICHAEL L RUPP
Your Accounl .......
INVEST BY MAIL
THE ALGER FUND
lNO MINIMUM)
500042064-00
u.. Thl. Seellon for Addre.. Change. Only
Portfolio
Cad.
07
10
II
12
14
IS
15
Portfolio Name
Money Markel
Income & Growth
Small Capitalization
Growlh
8alanced
M1dCap Growth
Leveraged AlICap
Amounl
Nom.
s
s
s
s
s
s
s
.... Add....
Clly
.Ia..
Z1p_
x
.....tu,. of .n ............ Own.,.
x
.......". o' .n ......,etecI 0wnerI
ALOER SHAREHOLDER SERVICES, INC.
30 Monlgomery Slreet
Jer.ey CIIy, N,J. 07302
TOTAL
I
To .......n hw"I""IInd~'I. 'he '-.ouftl you
.... -Ill 10,,""1 ....,..,he I'otllolo ",.....
..... ..... .....11' ........ to< THE ALOER FUND
, FOR IRA INVESTING, PLEASE INDICATE THE TAX YEAR OF THE CONTRIBUTION: _ OR ROLLOVER S
.... Uh
INVESCO FUNDS
INVr:SCO Funll. llrnur, Inc,
P,O, BIl~ 17371H\
()cnver, co 1111217.3711(,
I.HIHI.~~~.HIIH~
ItAL: I.HIHI,~~~,HIIK~
Investment Sununarr.
From Jallllary / - Dectmber 3 . /9901
111.111...111..11..11..11.1.1.11.11.1111..1.1..1111.1..11..1.1
MICHAEL L RUPP
14 EAST OAKWOOD DR
CARLISLE. PA 17013-938'
Pagl' / of 3
Account Summary
As of Dtcember 3/. /994
Number Share Markel Percent of
Account Number / Fund Name of Shares Price Value Holdings -
Regular Accounts -
-
Acct. No, 485672-4 -
-
IIF . Select Income Fund --
8.398 ~6.0300 ~50.64 50.32% ~
IIF - High Yield Fund 7.837 ~6, 3800 ~50.00 49.68% -
~
IMA. Multi Asset Allocation Fund 0.000 $9.5500 ~O.OO 0.00% -
Total Market Value ~100.64 100.00%
Investments by Objective Category
(S..,...,., lId, of/NISlo/""" [... 0 nl/ of jWtdll>1 eo""",,)
Catqory
Money Market
Tax-Free
Income
Balanced/ Asset Allocation
Equity Income
Growth
Value
International
Strategic/Specialty
Regular
Accounts
0,00%
0.00%
100.00%
0.00%
0.00%
0.00%
0.00%
0,00%
0,001.
100.00%
Retirement
Accounts
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0,001.
0.00%
Conslderlnll a focus on attractive market sectors--wlth global dlverslncationl
Call for the Worldwide Communications and Capital Goods Funds prospectus which
Includes manapment fees and expenses. Read It carefully before you Invest.
, ,
j
o INVESCO FUNDS
INVESCU FlIllds<< ;'11111', IIIC,
p,O, Box 1737116
DClIver. CO HII2 I 7.-'711(.
1,IUHI.~2~.HIIIl~
1',\1.: I,HIHI,~1.1,HIIK~
From Jalluary I. December 31, 1994
Page 2 of 3
Sununary of Distributions
Account Number / Fund This Period Year-to-Date
Distribution Type
IlF - Select Income Fund / Acct. No. 485672-4
Dividends $0.97 $1.71
/IF. High Yield Fund / Acct. No. 485671-4
Dividends $1. 35 $2.36
Long. Term Capital Gain $0.16 $0.16
Short-Term Capital Gain $0.09 $0.09
-
Account Activity .-
~
-
Account Number / Fund Transaction Shares this Share Dollar Amount -
..
Date Description Transaction Price this Transaction ~
-
IlF - Select Income Fund I Acct. No. 485671-4 -
~
01/01/94 Beginning Balance 0.000 $6,5700 $0.00
07/21/94 Purchase - EasiVest 8.117 $6.1600 $50.00
07/29/94 Dividend Reinvest 0.016 $6,2000 $0.10
08/31/94 DIvidend Reinvest 0,050 $6,1800 $0.31
09/30/94 Dividend Reinvest 0.054 $6, 1000 $0.33
10/31/94 Dividend Reinvest 0.048 $6.0600 $0.29
11/30/94 Dividend Reinvest 0.055 $6,0100 $0.33
12/30/94 DIvidend Reinvest 0.058 $6.0300 $0.35
12/31/94 Ending Balance 8.398 $6.0300 $50.64
IlF - High Yield Fund / Acct. No. 485671.4
01/01/94 Beginning Balance 0.000 $7,4300 $0.00
07/21/94 Purchase - EasiVest 7.440 $6.7200 $50.00
07/29/94 Dividend Reinvest 0.019 $6.7400 $0.13
08/31/94 Dividend Reinvest 0.064 $6.7300 $0.43
09/30/94 Dividend Reinvest 0.0,;7 $6.6900 $0.45
10/31/94 Dividend Reinvest 0.065 $6.6100 $0.43
11/30/94 Dividend Reinvest 0.068 $6.4800 $0.44
12/30/94 Dividend Reinvest 0,075 $6.3800 $0.48
12/30/94 SoT Gain Reinvest $.01225719 0.014 $6.3800 $0.09
12/30/94 L-T Gain Reinvest $,02022740 0.025 $6.3800 $0.16
12/31/94 Ending Balance 7.837 $6,3800 $50,00
GABELLI GL INTERACTIVE COUCH POTATO FO
PO BOX 8108
BOSTON HA 02266-8308 '
1,"111.,,11111I,"11,,11,1,1",,11,1,,1.,1,1,,"11,1,,11,,1,1
MICHAEL L RUPP
14 EAST OAKWOOD DR
CARLISLE PA 17013-9365
Tr.nuctton
~~u
~~l?
A/17
BEGINNING BALANCE
PERIODIC PURCHASE - ACH
SHARES PURCHASEO
PERIODIC PURCHASE - ACH
CANCEL PURCHASE-ACH
PERIODIC PURCHASE - ACH
~~u
m~
CONFIRMATION
'The
Gabelli
Funds
1-800-GABELlI
GABELLI & COMPANY, INC.
ONE CORPORATE CENTER
RYE NY 10560-1442
'DINT, NO, O~ SaC, SIC. NO, 176-46-5988
I 'un. '40';21 A6'0i"~;t:'88 I Co, fe'
Doll.r -.ont Sh..... Tht.
0' Tr.nuct I on 0
10.00
0.00
0.00
0.00
0.00
10.04
13:?~
10. ,~
10.42
Tot.
Sha.... Ilwned
.000
4.980
10.D20
11t.~1t1
IZ:xfH
4.980
5.D40
1t.~21
4. 21
It. 98
INTRODUCiNG................. THE GABELLI GOLD FUND.
A NO LOAD HUTUAL FUND. CALL FOR A PROSPECTUS AT 1-800-GA8ELLI (1t22-3551t) .
READ THE PROSPECTUS CAREFULLY 8EFORE YOU INVEST OR SEND KONEY.
Fu"d ldant. No.
13-371t7589
Your Poym.nt Optlo"
Dlvld.". Cap. Oaln.
REINVEST REINVEST
YTD Incom. Dlvld.".
YTD Capital Oaln, DI,lrlbutlo".
YTD Dlvld.nd. A"d Oth.r DI.lrlbullo".
GABELLI GL INTERACTIVE COUCH POTATO FD
MIClIAEL L RUPP
14 EAST OAlOOlOO DR
CARLISLE PA 17013-9385
TO MAKE A CHAHGI:: If the Iddr...
II Incorrlct. ,..... print .... GOf,eet
Information hw..
Shll."
In Cartlllcat. Form
+ Na,,-Certlllcat. Form
. Total Sh.... Hald
X Sh..a Prlc.
=a: Account V Ilue
11t.!18
lit. 18
SID. 2
SISIt.lto
IDlNT, NO. O~ SOC, SIC, NO, 'i6-46_SQ,
I ,..... N;;'21 A60i~2i;88 CM r'
THE GABELLI FUNDS
PO BOX 6306
BOSTON MA 022bb-6306
To In...t Iy Malt
'01 purch.... In'D thl. ..count.
"U.n thll stub ..-d yow c.......
In th. IMlo,.d eM'llope.
I'"",,,,. 01 lolnl own" Idl'I'
1II,"II.III,I,II".II"I"I,III,II,"lllll.I,1
AMOUNT 0' CHICK
"IM''''' Idl.,1
IIIIIIII
DC """_ lUJ .,... '"
DlALI" INf'O"MATION
1000 078
{} 0000 3b23'X40 000bO~424681 0000442
.
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, '"'' 'I' .". 'j ,~....
CUMULATIVE STATEMENI Fon
1994
c
SAFECO HIGH-YIELO BOND FUND
)
MICHAEL L RUPP
14 EAST OAKWOOD DR
CARLISLE PA 17013-9385
ACCOUNT NO,
2164850
lAX IDENT NO
ON FILE
our accounl. .as. call: Toll Fr.. I,Boo,B24,5711 or S.atll. 545,7319,
TYPE OF TRANSACTION
DOLLAR AMOUNT
TOTAL SHARES
BALANCE FORWARD
INVESTMENT - AUTO INVESTMENT
DIVIDEND- REINVEST
INVESTMENT - AUTO INVESTMENT
100.00
0.07
100.00
8.79
8.73
8.66
11.377
0.008
11.547
0.00
11.37
11. 38
22.93
Please review thIS slal.menl ClII.luPy and nolll, us 01 any Pfoc.ssmg "rOlS
within 30 clays 01 SAFECO WIll cons"'.. lho IransactiOn 10 be corrlCt.
ON 07/27/94 YOUR FUND VALUE WAS
.198.59 (
22.932 SHARES AT
$8.66
CURRENT YEAR'S ACTIVITY
0.07
0.00
ClAfIOICATa_
MELD" 'rOll
WITHHOlDINQ -.aRTlFlCATI
_s
0.00 TOTALSHARlS
0.00
22.93
22.9:!
INVES'RlENTS
200.00
REDEMPTIONS
0.00
DIVIDENDS STCAPGAINS LTCAPOAlNS
0.00
RG PUR AM
07/27/94
PLEASE DETACH AND RETURN THIS STUB WITH YOUR NEXT INVESTMENT
AKE CHECKS PAYABLE TO:
SAFECO HIGH-YIELD BOND FUND
P,O. Box 34890, Seatll., WA 98124,IB9O
ACCOUN1NO, 2164850-10
MICHAEL L RUPP
14 EAST OAKWOOD DR
CARLISLE PA 17013-9385
AMOUNT ENCLOSED ($100 HINIHUM) .
'-
O PLEASE CHECK THIS BDX AND COMPLETE REVERSE
SIDE IF REGISTRATION CHANGES ARE NECESSARY,
. ~.......,..~...,., O"""(COCO'DO',l'
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JhneJlUck & Co Inc
() L~tJlI Street. Nf!W t"rk. :VY /0003
~/2J 6rJ/,!I()()()
'emben uf AlIl+mc,pul E~,"unges
FAHNESTOCK
..rA.l""rD ""
Account Number
IA2S-0010830 - A20
Tax ID Number
1176-Q6-S988
Cop'(
For the Period
IOI/01/9Q Through
008211
Page 1
12!31/9Q
MIKE RUPP
14 EAST OAKWOOD DRIVE
CARLISLE PA 17913
Your Account Executive
KALINAK, LAURIE A
(1111 249-2811
OrCIce Serving Your Account
I 26 W, HIGH ST,
CARLISLE. PA 11013
noual Statement Summ
(Consolidated 1099)
lNCOME SUMMARY
INTEIlEIT
DMllUIl
T
4 OTHER DMIlEND
OTHER INTtREIT
CAPITAl. GAIN
DlSTRI8UT1ON
GRDSS
GRDSS DMDENll
24.60
24.10
0THEIl IT DID
0THEIl ACCIl\JEIl
IHItREST
TOTAl.
SALE PROCEEDS REPORTED
DATE
05/18/94
08/01194
08/01/94
UANTlTY
100
100
100
"
431353101
101589109
826409104
1
HlLlTE INDUSTllIES INC
MARKDOWN 1/2
PENN NAn. GAMING INC
SIERRA ON LINE INC
T TA
End ., 5_
13
198,25
813,15
1.189,82
2 ,82
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CllMMllh'l/!A1.TH 0' P!NN$YLVAHfA
STAT! !MPLOYES' R!TIREMENT SYSTEM
STAT!MENT 0' ACCOUNT AS OF OEC!MBER 31, 1114
Arnually the State bolo,.,' htt'-...."t S,st. CUI" provtdn each....tMr- .tth cur,.."t r.ttr~t ace.,...,t 'n'on.tton which should
be helpfUl In understanchnQ the benefits provided by tN ,..Ure.ont plan and 'n dotng financial plamtng. Thh stat..,t was
prepared USIng the data ,.,corded In 104.Jt' ,.,u,...nt accOlIIt IS 0' Dectll'ber 11. nu, and 11 Subject to ftnal audH b, the SUS In
Iccordane. with _"cabl. Ilw and r_lat'on., PLEA5r REFER TO TH! REVERSE SID! FOR IMPORTANT
INFDRMATIDN ABOUT YOUR STAT!MENT.
PlEP1RlD FOR: M L RUPP
081-180-26200
SEO-08643I
551: 176-48-5988 EMP .: 041355
Dat.o'lIrth. AUGUST 15, 1955
S._: MAI.E ..,ion Code: 7
~~tJ'll~=tuOa:':12_2ty,<<i~ST 15. 2015
Class Service
A 8,2836 VRS,
5612
ACCOUNT BALANCE
eo-allO 1)'pO
Contrlbutlon ~t.
Final........,. lab,..,
1". Retlr...nt CoY.red Earnings
551 R"'-CO.....d Earn,....
Jotnt CoY...... Convertlon Aaicu1t :
Matdator1 Debt
-----TAXABLE BREAKDOWN OF ACCOUNT-----
FULL
: 5.00"
: $32,865.78
$33.941,81
REGUllR
.ill
a.lane. a. of 12-11-93
1". Ac:ttvtt7
Contributions
LUIlII) SUI 'ar--ts
Arrears ,.~ts
AdJus~tt.
Credited Int.....t $564.25
Balanee U 0' 12-31-9. 115.517.00
lr,...... a.lanea itS 0' 12-31"'. -
.Adtus~ts reflect corrections to your account about wIItett ,ou No" bMn natUled.
I_'it e:nt_tls ara prepared for ..oars who haWl rMched ....., .ettr~t .1: and 'or .......s who have at least 10 ,urs of
credIted sarvtce 'or --oul... Ratlr.-.nt and at I..st 5 ,ears 0' credited sarvtca or Dt~lltt, _etlr..-nt (State Poltce and
En'or~t OfftC1lrJ have no .Inl... service ,....Ir-'t for dtsabflU7 ratlr..,.t).
H ,au t.,..,,.te prior to attaining e1tllbll It' for .onth" beneflU, that Is prior to ~Ing "IUed, 'OU -.ould be entlt'ed to
r.eetWl ,our aCCOU"lt balance .tnus an, debts to the ec-anw..lth as 0' ,our dlte 0' t.,..tnatton.
$13.255,40
$ I .697.35
.
Tal-De'erred Contrlbuttons
pr"lous', Tued Contributions
Credited Interest
ACCDU'\t a.lanee as of 12-31"'4
$2.221.18
$15,517.00
$13.295.82
.
.
BENEFIT ESTIMATES
Current itS 0'
12-31"".
Projected to No,...'
Rettr~t
FULL RETIREMENT - This optIon provIde. ttwo ..t... _thl,
beneftts to 'OU 'or II'.. If IOU die be'are recelvtng ,our
tota' acc..llattd deductions, the ba'ance wi" be p&1d to
'tout' beneficlar,lles).
OPTION 1 - This option provtde. roduced __"'I, _ftts to
70U for I"e. All ....tnl, Wnefits at. r~ 'r'* U-
Prasent V.l... An, ba'ance r_tnh" at 701Ul' death wt 11 be
patd to ,our beneffclar,. tesi.
PRESENT VALUE - Doath __fit under Optton 1 or a <Math
in state servlca.
OPTION 4 - You _, recatve aU or a portion 0' ,our
aco.a.Ilatect decb:Uons Icontrlbuttons and Int....U) In a '&alP
SJa or tnstal '-,t pa~ts ard receive r~td nwtthl,
,*,-flts ...,. one of the other retl,...."t options. Option"
IS available onl, at the tl.. of r.ttr~t and _, not
ezcMd ,our aCc:&a.Ilatad cM4Ictlons.
FULL RETIREMENT AD~USTED UNDER OPTION 4
OPTION 1 ~STED UNDER OPTION 4
~USTEO PRESENT VALUE UNDER OPTION I WITH OPTION 4
N/A
N/l
N/l
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MAXI_ DISABILITY - You -.st be _Icall, c...ttfled br SERS $912.94
Medica' E._tl'W'l to be phJSfcall, or -.ntall, Ircaoabl. 0'
_'"",I... ,_ CUM'oftt Job wtt... OPTION 4
WITHDRAWAL IS NOT AVAILABLE WITH A DISABILITY
RETIREMENT.
'REFER TO CODES A THROUGH R ON THE REVERSE SlOE OF THIS FORM FOR AN EXPLANATION OF THE FOLLOWING CODES
15 THE V lPPLY'fO YOUR BENEFIT ESTIMATES: L. 0
ADDITIONAL RETIREMENT OPTIONS ARE AVAILABLE, PLEASE TELEPHONE YDUR SERS REGIONAL RETIREMENT
TOLL-FREE (1-800-633-S4Bl) FOR QUESTION~ ~~l~~f ~p~~ B:NEFIT RIGHTS OR THIS STATEMENT OF
COUNSELOR
ACCOUNT .
,UR 0 II~ 1
1
IC T I VE
fPPR 18(1
.. I~E / lr<E~lE.I'H MASTEr.: r~EClll(1J ..
DATE FRIN/EO 02/24/9~
DEPT 081' SSII' 170 40 5988 NAME M L RUPP
ORG 5012 CO 202(11:1 EI'IP" (loll S::i:'i
[I/U ~\,;
TOTAL SERVICE CREDITS -
8.26::6 Al
D
E2
SI
T
BEFORE
Al
U
E2
SI
T
8/1/83 *
00 (1) 0(1
, STAT LIS ~)(I
SEX M CLS " " CUll '(n IIUURfl - ." 'HI,I IU sve ..
COV 1 eA r ... F:EH ~45.65 l>AIE / I
nil IE .'.50'.1 5S1 f'F'V
DUEl ~S/fJ81 t 5 F'F;: c.:LS PHE
ENlRV 80/09/22 PI', CHI slJe
EFr-EC 94/(17/26 PR HRS pr,E
-. GROSS
VTO
1 G l' PI,
2ND PR
PP 05
TX 015
PSERS
EARNINGS ....
o,ol20.57
:.3,91)6. a \
3:: t 26:3. '.12
_.**-
CUR
PR
um
FAS ***..
32,865.78
.32, 22'l. 59
3 YEAF: 94
NC C~IP
.. PRIOR VEAR HOURS **
1ST 1893.5(1 2ND '1950.00
3Rt) 1950. (1(1 4 TH 195'). 00
FOR CONTRIBUTION DATA, PRESS H\B, TRANSMIT
>RETRl(1 170405988/')81/A2 Z
tCTI VE
I
~***..* ACCUMULArEO DEDUCTIONS
REGULAR
AL PRE'I VR 15 , 517. ')0
CONTRIB VTO 321.04
~UMP SUM
~RR PMT VTO
rTD ADJUST
~UR VR INT
;RAND TOTAL
,
DEPT 081
SSII 170 46 ::;988
NA~IE 1-1 L Rur'p
rAGE 2
>
OED *....
PRE
.***'.....
S S I
...**
SPEC I AL CI.ASS ACCUI-'
I'll 1'1\1.
CLASS C
CLP,SS 0
ST SH(\RE
15,838.04
JOINT COV CONVERSION
>ICKUP CNTB
.OTAL INT
,~RR BAL
~CC OED PRE
INTEREST
l.25% AOD'L
INTEREST
'RE87 N-TXBL
13,010.80
2,221.18
2,577.73
427.34
PET043
EMP NUMBER: 041355
POS NUMBER: 110420
GROUP LIFE INSURANCE:
DED TVPE CD.......:
BEN PLAN CO.......: 001
CALC CD........... J 2
BEN NUM PMTS......:
BEN NOTIF EFF OT..:
BEN PNT START OT..:
BEN DIR BILLING...:
BEN ARREARS.......I
BEN STATE SH ANT..I
EMP BEN DATA - PT 3
MICHAEL L
CAL VR: 95
02/24/95
RUPP
BEN TVPE CD.......: 910 BEN ELIG CD.......I
BEN COV CD........: 1)30 BEN PRGM ADM CD... I 00
FREQ CD...........: BW
. ')1) GL I COVERAGE AMT.. I 37 , 000
BEN NOTIF TERN OT.:
BEN PMT STUP OT...I
BEN BILLED ro DT..I
.00 OED ARREARS.......: .00
3.22
- EXHIBIT "E" -
'I'
. . , ,
TrUltlt" 0' IIIUlrt Ham.. SI,... Idd,,". City, Sill', end Zip Codl
INVESTORS FIDUCIARY TR CO
FOUNDERS WORlDWIDE GROWTH
127 W 10TH STREET
KANSAS CITY MO 64105
~......... "'"I Addr... (~.... no J. euy....... MIl VpCode
1,,,111,,,111,,,,,,11,,11,1,1,,,,11,1,,1,,1,1,,,,11,1,,11,,1,1
INV FIDUCIARY TRUST CO CUST
IRA AIC MICHAEL LLOYD RUPP
14 E OAKWOOD DR
CARLISLE PA 17013-9385
"..... .......1........, ,Alln'l:PANr'I............... ."..,............................
373.09480020659
17l1.4e.51Nll1
43 .0995254
- EXfllBIT "F" -
D.part"',"t 0' U" Tre.,u,.,-Inlt,nl. A.venu. Slmel
IK_r.._.....d.' OY8NO,lU5.0147
.f I . .
TMIn'onunonIn BoI" t. ZIftd41.beI,.. hImI......o1M InlMM'
AIftftU. Sentel.
I __ IlIA ................In 181_ .IM.. ,...
50,00
2.......1AA c-...........
.
i
:
0,00
,'*.......... ......
!
~(.-l
o
U.'
,
:. '0 '
I' I
,
.".:-",.~
-,(,.l..~..'~"
;""-~...~
. ~!.I"" ' ~'.
'. .>",;",:,,~~.:-'~~
'.f.'!r.:i.'.~
.~:.-r'...~
.
. I."'.
. ,;,,".'~ .
_ ;:i':;
.' ~'~
Phone (7\71243.1032
FAX (7171243.6568
700 Walnut Bottom Road
Carlisle. PA 17013.3699
FOREST pARK
HEALTH CENTER
2/27/95
To Whom It May Concern:
Stephanie Rupp Is employed at Forest Park Health Center as a Part-time
Registered Nurse, with a guarantee of 30 hours every two week pay period.
There Is no guarantee that more than 30 hours will be available, however,
there are times when the employee works extra hours.
I f any more Information Is needed you may contact Forest Park Health Center,
Human Resources Department at 2113-1032.
Thank you,
";' ,
/- ~
~ 1oJ';,""-~
Pam Spence
Human Resources Bookkeeper
A ~l'rvk~ ..r rre~I'yll'ri~1I Il..nll'~, IlIe,
" N,,,,.I'..,,nlllr).:,.mi/,ltitllt
- EXHIBIT "G" -
. .. . .
,
"1
Label
U.. tho IRS Iobol.
Othlrwl..,
, pIeua prllll
01 Iypo,
PnoIdonIlol
EIoclIan ~
filing SlIItue
CI-.:k only
one box.
Enmptlona
Income
AIlIdI
!=oPY 8ol.Jlllll'
F_ w.2,
w.2G, ...
1.."......
II rou cId not
911 IW,2,_
...lIUcllonl,
.j"
W)'lIJ"
" II*'*'!II '
d"eck 01 flIlIWl'
anIIr. pulll on
top 01 ""y
Forms W,2,
W,2G... 01
to!l9-I<.
Adluetmente
to Income
"
LJ
~I,ol tho T,...~ - I'll.'" ~_ s.w:.
U.S. IncllvlduallncOlM Tax Rlturn
FOIIhe .lIn I ' Dee 31 1993 01 olher IIX
.
ItS _.. - 0..................__
1993 end 19 011I...._
~
..
't..._
II lool_
. .
-
1.6-46-5988
-.---
~09-'36-Z049
...
. ;~
For PrMcy Ad ...
"--".... .. lAd
Hollc8, _1nI1n1cl1an1.
Y. No -CIoooIloe-
......... ,..
....... ,..
-
} ..."'-
_.11
..... . .
, ,.....-
.L'l. =-
~
Adjueted !1 ........>> _.. Zl No ~ _ _ _ _ .... _ ~... ..'ZlIlO....
Grotllncome dlM........._.__........,.......ta.I....o.<<...,. . 0 . 0 . . . 0 .... !1
Dl ~_u,s"... ""lC AlMlIt 'Rill
EXHIBIT "I"
c D....\ta:
..... one. ..... ... .... __J
~40~sw AMIE E. RUPP
_insllUcbons, JUSTIN M. RUPP
1 ,allm does s a want 53 10 10 Ills IIrd 7 ,
Singla
Married n1inl,l JOIIlI ral..n (..... " only 01'1I hid incOme)
Married nllng __"Ia ,"11m. Enl. spouse's SSN above ond lUll nome herl. . ,.
Held 01 t1lusetIlkl (With qAllfying porson), lItho qAllfying por1Oll1. I c/lkI but nol 'JfU depIlldel ,I,
enler l/is c/lkI's name hera , , , , , , ..
0IaI1 wKlow. with I c/l1d _. 19
Younoll. W Y<U lBenl (01 ....... else) C8I\ dun rou IS I ..... do. .1 on tis 01 her
lox reI\m. iIII not c:twdc box 60. art be ....' to d"eck tho box on In 331 on pege 2-
S ,,'....,.. ,....,.. ...,.,.
-
-
STEPHANIE R\lf'F'
....1. ,.......
10 -........
4 EAST OAKWOOD DRIVE
. ,... .,... - ........
ARLISLE. PA 17013-9'385
00 rou Willi 53 10 go 10 Ills 1Ird7, , , , , ,
~ If.
1
l
3
4
(2)c""
-
I
1
2
(~':.:"
-
-64-6606 D
8-66-7203 5
(4)_
"'::-
GHr
N
d .,....,...,.....,..... ill.... -so-............ ....1_................ . . . . . . ....
I Tolal rum. 01 Ions cIeIma:I. . . . , . , , , . , . , . . , . , , . . ,
7 Weqa. _, lips, elc. A111c11 Form(s) W.2 ....,.,.....,...
I I TIDIlle II11.esl incOme. A111c11 Schoct.lte B II CMW $<<Xl , , . ,
b Ta.... Interesl. Don't _ on 1..80 , . , . , . '. I b
, 0_ 1nCIlme. A1tecl1 Schoct.lte B " CMW SCll , . , . , . ,
lD T_ rel\nls. credits, 01 oIIsels 0/ sllta end IoceI incOme laxes,
11 Alimonyrec:lll'lld, , . , , . , , , , . , , , , .
12 e..u- incane 01 (loss), A111c11 ScI'GJle C 01 C,EZ .
13 Caplel geln 01 (loss). A111c11 Schoct.lte 0 . , , , . ,
14 Caplel goo, clstnbullons not roported on In 13. , . .
15 0tIw goinI 01 (loues). A111c11 Fonm 4197 . , . , . . , . , , , , , , , . , , , . ,
'h ToIeI AAclslnbullons . , .W Ib T......IlIlOl.I1I. . , . . . .
170 ToleI ponslons & ......11es. ,ill!1 b T_ 1lIlOl.I11. . , , . , .
11 Renlal,eeI estola, royellles. pertners/lps, S COIpOIIllons. lrusls. alc, A111c11 Sct.uo E.
l' Farm '""""'" 01 (loss), A111c11 SchoclJIe F , , . , , , , , . , , , , , , . . . . ,
2lI UlIlO..pIo,meI.1 ccmponsallon, , , , . , , , , . , . , , , , , , , , , , . . , , , "
211 SodeI sacully benenls W Ib T_ 1lIlOl.I11. . . . . , . .
~ OtIwincane. _______________________________________
23 /ldd tho IlllOUlIs In tho lot .. caIum far IiIes 7 22. llis ts tolsIlncDIno.,. .
aea YOlI' AA datlcllon, , , , . , aea
b Spousa'. AA decU:IIon, , , , , , , , . :II b
25 Qne,rwll 01 ..."..........~.It.., , , , , , 25
:IS Sel1'IOIClIoJo._.1 IweIIh inI.....:e decU:IIon, :IS
'D I<ec91 rllnmenl plon end setl,ompIoyed seP decU:tlon 'D
21 Plnltyon_tywt_IloIlIVII1lII, , , , , , . , 21
2t Alimony peld. Reciplenl's SSN . 25
3D /ldd I... :!4I1t1
29, Tlwse.a
IlIIsI
........
, . , , , . . , . ,. 3D
, 2.
.~~.. 2.
.-...
-...-
,,--
_.
- . -
....-
-",.
--
&:-'..::. .... 4.
4 .
, 856 .
lD
11
12
13
14
15
lib
17b
11
l'
2lI
21b
~
23
." "
50.170.
onml (
_ ____C~py ~"DDNDrfll~~~___
FarmllMll
Tax
Computation
"
1
1I)'IlU wont
I/'e RS 10 I9n
)'IU tax, -
...trucllons.
Credlta
Other
T_
P8ymenta
AI'*'" Farms
W,2. W.2G,
andlO!l9-R
en pogo I.
Refund or
AmounlYou
OM
Sign
Here
~ . copy
-OIIIU r.l\m
.. fa' y<:u rlalllls,
P11ld
~m'.
UH Only
_....... us.. ....
II line J2 IS $81,350 ar less, multiply S2.35O by lht 10111 n..mber 01 ex_tions c_ en
line 61, II line J2 IS rNfJI $81,350, see IhI insl1uctians lar lhI......,llo antor , , , , .
11 T.....1nc:amL So.clttact line 36 ~om line 36, II lire 36 Is more tIwlllne 35, anlor ,(). . , .
31 TIX. ChIck il flamll"O Till TabI., bO Tex Ral. Sc:I1IWIes, cO Sch 0 Till Wlesl, 01
cl!J Farm 1lS15. Pmaull ~om Farm(s) 11I14, . , . . , , , , ... 31
31 1'ddI1Ien.1 taxes. Check II flam , , . , , , , ..0 Farm 4970 Farm If'I12 . . . 31
4lI JlcIdIInes:!land39 , , , , , , , . , . , , . , , , . , " . 4lI
C1 Ctldll fa' c:I1ld and dep .... expo AlllIch Farm 2441, , C1
Q CtIdIt fa' lhI_ly ar lhI_, AlIICh Sch R, , Q
4J Far. tax credil, AllIcI1 Farm 1116, . , . , , . , 4J
44 0lhIr crecllls. ChIck II 110m .0 Farm:mJ' b(J
Farm Il!l6 c[) Form IBII d[] Farm (spec) 44
45 JlcId lines 41 \1'1oo4144 , " ,."".
41 So.clllllct tine 45 flam In 40, II line 45 Is more tIwl In 40. anlor.(). , , , , , ,
o Sell'~lllll. AllIcI1 Sch SE. I'lsa, _11nI25
41 PlIImIIMI miniIlLm tax, oIItach Farm 6251, , , , , . , . . , , , . . , , , , . , .
45 RlCIph......., Check " ~om .0 Form 4Zi5 b(J Form IlSII c[] Farm lIl:/II
50 SS and Modlcor. tax en lip In: not raparted to ..... AI'*'" Farm 4137
51 Till en ~11Iod rolltoment plons, including RH. II ,""","", .tllcl1 Farm 5329 ,
52 /lclvance oornod IncanI credil ~ flam Farm W.2 . ,
53 JlcId lines 46 . 52. This IS 1aIII.....,
54 r_......IIl..I!told.II""is....rllll(l)lClIldlodl, ., .
55 1!BIlIlim1lld Ill........ n
__ildlnlnl!ll!...... , , , . , , , . , .
54 Eomod Incamo cndIl. AllIcI1 SchIcllIe EX:. , ,
57 Pmoull pal with Farm 4ll6lI (D1ension ,",,*1) ,
51. Excess sociIl SIlUlly, Modlc:or.. and RRTA IIll wl_
51 b Delorrll 01 _UcnII9!l3 ....., AI1Id1 Farm 11I41. . . . .
51 0lhIr Jl8YIIIInls. ChIck II flam ,.0 Fcrm ac39
b(J Farm 4136
sa JlcId lines 54 . 59, TI'ese.. tolll II. , ,.
S1 II In 60 Is more tIwlln 53, sublnlclln 53 flam In 60. 1l'is Is IhI ......,t you 0wtp0Id .
12 Pmoull olllne 61 you WIlli R.1IIndod 10 You , , . , , , , , , , . , , . . . , ,
13 Pmoull 0' In 61 you WIlli AppIIod I. Y_I"" Eel Tex , , ,. 13
54 1I1in1 53 II more tIwlllne 60, sublroc\ line 60 flam linI 53. This II lhI ~l You 11M.
FOI elIlIIls en mw to IlIY.jncludlng whit 10 wtll. en y<:u poymenl, _ Inslructlons. , ,
15 Estirreled till II , Plsa irdude en line 64, , , , , , , , 15
UnIIIr......... ......,. ....... _I.................... _ __........... 1M ~ .............. ........ MIl
...... ... ...... ..... ........... ~................ ~ it.... till II...................... ............
'-.J
MICHAEL, & STEPHANIE RUPP
3Z Pmoull flam line 31 (edlusled l1os1 orcama), , , , , , , , , , , , , , ,
.131 Chick il: 0 You wor. Ii/i ar older, 0 BIIld; 0 Spauao wu Ii/i ar alder, 0 Bind
JlcId IhI n..mber 01 boJes chocked abcMI and enter lhIlolll tw.. , . " . D .
b II y<:u I*anl (ar ___ ....) c:en clIim ~.. dip.. """,I, c:I-=k two. . Db
c II you .. m.med mlng _.llly and y<:u splUSI itemizes declJctions ar
you .. . duII,st.tus ahen, see Inslructions ard c:I-=k tw., , , , , " ," Dc
34 Enl. {lemIztd daducllont ~om Schedule A, lire 26, or }
~ Slendatddad ~n below far y<:u mtngslalus. Butll~c:hecIlad
al enr boI on ... Do or b, see Instructlcn to lIrd ~ Itandard clod,
JIll' II you c:heckId ball Dc:, y<:u standard clIWcUen il zero,
. Slrge - S3,700 . Had 01 _ - S5,4Sl . Married filong jointly ar
QualiFying widow!",) - S6,2W . Mawed filing s..,.ately - S3,I00
JI So.cllract line 34 ~om line 32, , , , , . , , , , , , , , , , , , , , , , , , , ,
.1l
54
55
51
57
51.
5Ib
51
v__
Dolo
;.'.......
;~'tl
34
JI
.1l
11
45
. 41
o
41
.
50
51
52
. 53
.
v__
A'COUNTANT
-
R GISTER NURSE
......... .... reIWtt.
--
.
Dolo
Old! ,
.._X
'-'
-.
"""~~r
~"'...... 1-
C
Ell
lP c.o.
1010121: n::WIIIU 13Z'ltt3
7,930.
42.240.
9.400.
4.924.
. .
5.023.
---....
1 6-46-5988
25-1666050
z
,
." ...
\
'.
STEPHANIE L. RUPP,
Plaintiff
IN 'l'HE COUR'l' OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
va.
-'
JaCHAEL L. RUPP,
Defendant
CIVIL ACTION - LAW
NO. 951sifCIVIL 1995
IN CUSTODY
. ,-
CUSTODY
8'1'IPULa'1'%O. UD AGUaIU5.-r
--.
'"',
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between Stephanie L. Rupp,
(hereinafter referred to as "Mother") and Michael L. Rupp,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Amie
Elizabeth Rupp, born July 25, 1983 and Justin Michael Rupp, born
April 27, 1987 (hereinafter the "children"): and
WHEREAS, the parties are presently separated and living in
separate residences: and
WHEREAS, the parties wish to enter into an agreement
relative to custody and partial custody of the children: and
NOW, THEREFORE, in consideration of the mutual covenants,
prOllises and agre_ents as hereinafter set forth, the partiea
agree as follows:
1. Mother shall have primary physical and legal custody of
the children.
2. Father shall have supervised visitation with the
children as agreed upon by the parties.
3. The parties will attempt to make arrangeJllents for both
parents to spend ti.e with the children on each holiday as they
~
may agree.
4. The parties will keep each other advised immediately in
the event of serious illness or .edical ..ergency concerning the
children and shall further take any necessary steps to ensure
that the health and well being of the children is protected.
During such illness or medical emergency, both parties shall have
the right to visit the children as often as he or she desires
consistent with the proper medical care of the children.
~. Neither parent shall do anything which may estrange the
children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
6. The parties desire that this Stipulation and Agre..ent
be made an Order of Court to the Court of COlIIIDon Pleas of
cumberland County, and further acknowledge that the Court of
Common Pleas of Cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor
children and shall retain such jurisdiction should circuaatancea
change and either party desire or require modification of said
Order.
9. The parties agree that in making this Agreement, there
has been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
10. The parties acknowledge that they have read and
understand the provisions of this Agreement. Bach party
acknowledges that the Agreement is fair and equitable and that it
"
i. not the re.u1t of any duress or undue influence.
IN WITNESS WHEREOF, the partie. hereto intending to be
legally bound by the teraa bereof, .et forth their banda and
.ea1. the day and year berein ..ntioned.
WITNESS:
Date: S/.;t-nr.- I~s'.eu; ./ d Cd-
" ~E~~1m
Dat.:.ilihL. ~ i,~
IaCHAEL L. P
I I I'
STEPHANIE L. RUPP,
Plaintiff
IN TIlE COORT OF CXXOlMCIN PLEAS OF
: CUHBERLAND c::outn'Y, PENNSYLVANIA
.
.
:
vs.
: NO. 95-1588
CIVIL TERM
:
MICHAEL L. RUPP,
Defendant
: CIVIL ACTION - LAW
IN cusrooY
.
.
CIUlI!R at CXXlRT
AND rDf, this IS-v... day of
upon consideration of the attached CUstody
ordered and directed as follows:
~lI..-v"t... , 1996,
Conclliation Report, it is
I. This COurt's prior order dated June 7, 1995, incorporating the
parties' CUstody Stipulation executed in May 1995, is hereby vacated.
2. The Mother, Stephanie L. Rupp, and the Father, Michael L. RUpp,
shall have shared legal custody of Arnie Elizabeth Rupp, born July 25, 1983,
and Justin Michael RUpp, born April 27, 1987.
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 5:00 p.m. until the following Sunday at
5:00 p.m. The Father shall also have partial custody of the Children every
Wednesday evening from 5:00 p.m. until 8:00 p.m. During weekends when the
Mother otherwise has custody of the Children, the Father shall have a period
of partial custody on Sunday evening from 5:00 p.m. until 8:00 p.m. Up to.
six times per year, the Mother may Preell'f;lt the Father's alternating Sunday
evening period of partial custody by providing at least one week prior
notice to the Father of other plans for the Children on the upcoming Sunday
evening.
5. The parties shall share or alternate custody of the Children on
holidays as follows:
A. Christmas/Easter/Thanksgiving: The party who otherwise has
custody of the Childk:eil during the night inmediately preceding
the holiday shall have custody of the Children until 2:00 p.m.
on the holiday. The other party shall have custody of the
Children from 2:00 p.m. until 8:00 p.m. on the holiday.
B. Memorial Day/July 4th/Labor Day: In even nUll'bered years, the
Mother shall have custody of the Children on Memorial Day and
Labor Day and the Father shall have custody of the Children on
July 4th. In odd nllllCered years, the Father shall have custody
of the Children on Memorial Day and Labor Day and the Mother
shall have custody on July 4th.
6. Each party shall have an opportunity to have a reasonable period of
custody with each Child on the Child's birthdays every year.
7. Each party shall be afforded at least two weeks of sUll1llllr vacation
- EXHIBIT "K" -
, .
,i
with the Children, which may be cOMecutive or non-COMecutive, upon
providing notice to the other party by May 1 of each year.
8. The parties ac:ltnowledge that the Children are currently
participating in counseling and agree that the Children shall remain in
their current counseling program, in which the parties may participate as
deemed appropriate by the Children's counselor.
9. The Father shall provide transportation for all exchanges of
custody under this Order.
10. The parties shall keep each other advised inmediately in the event
of serious illness or medical emergency concerning the Children and shall
further take any necessary steps to ensure that the health and well being of
the Children is protected. During such illness or medical emergency, both
parties shall have the right to visit the Children as often as he or she
desires consistent with the proper medical care of the Children.
11. Neither party shall do anything which may estrange the Children
fran the other party, injure the opinion of the Children as to the other
party, or hamper the free and natural develq:ment of the Children' s love or
affection for the other party.
12. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the terms of this
Order by autual. agreement. In the absence of mutual agreement, the
provisioM of this order shall control.
BY THE CXXlRT,
loSl ~ c. ,.p..O~
Hare d E. Sheely, P. .
cc: John B. Broujos, Esquire
Bradley L. Griffie, Esquire
TRUE COpy FROM RECORD' ,...
In T:st':n-,'/ ,..h. r:ol, I h,r~ unto set my h~n~ ",
and Ih~ "..: of SJ'd Ccurt at Carlisle. Pa.
This .".r~., day of .??7~..:.., 19~,(;r
_..._,...~"'~~~o~,.._";."'
,.~
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, ,
DR 2 3 . 65 3
Stephani.e L. Rupp , IN U{E COURT OF COMMON PLEAS OF
Pl.AlNtlFF 'CUMBERLAND COUNTY. PENNSYLVANIA
: DOMESnC RELATIONS SECTION
: CML Act10N . SUPPORT
DEFENDANT; NO. 227 SUPPORT 19"::""
ORDER OF COURT
rt..
AND NOW,ltUs Z-'" dayof'DeCember- . .,19 95 bascdupaalbcCcur\".
c!.cI.c::mia:aD lII:ar l'IuIri.lI'.lIIOlIIhIy 1lICl.""""-'camias aP"''''Y is S -r-;i 50 . alId n. ~ I ~:I'
cnarcII1y IllS ~ ~~ ia S 2 . 250 . ic is \oo:rd)y cnl=d l!l:l '.!!.., ~ I - ~ lIII
chcO"'. -.1manISo ..~.. C-rtOCG..._,_PIO:U.S 550 00 a....m~
.5'':;4 no n+_tJAA""r ~~ December 1. 1995
vs
Michael r.. Rupp
Anal'UIlllS 550.00 aoC December 29. 199irccb:iII6aII~"'T!LY.
r .(.... ....lCl8:iitb- ~-.,ca:rCmdo&ia'~1:. .Pt'''aIIIf~ _ora; .~
..,. bG bdll iII..be) -Iaac .. D - . .-;)'I S 25. 00 aumaa..dl jlI&i -....
FaiIz= m IIIabl adl Sl&) , c.-1iIDo ..t ill 8dl wiII_ all &I1'ClIa lit b ..bjecllllll . . -
............... by aD oClh: IDCIIIIS IisIId ea-
Fot1:bc 1Uppar'l at h;~ twn ehildren. Am"'~ 'F- Rtlp~. hnrn
7-25-83 and Justin M. RUop. bor-n 4-27-87.
.
.
SaidtlGlM:ffDbo...sOWl'b7d1cD _1'fII-~ I It. .S-... "U
. ~ 4.... be'" by cafa, cbldI: tIC...,.--.
Cub .-1 r IIIIIJt be.... iII,...- All dlac:b -1II:lDCf anIcn _ be.....-1 .~ 10 n. "r
11..1' s-w-...........4ar..u.!mD -' .1,' ., ......13Pb*P -sc...P.o.
Bc.na.c.disIQ,r .11.' 1'7'013. E8d1a-.t .mastbca')'lllIl'n. ., I~'... .,.
ClIda'lD be ~.
u..'. ''-'''1 & _"llapUI 60 "b7D -' .. 40 ~
br.l"lUaIif[ Defendant III r-.& ... --=- a::MZIlF as providea by
h], s emp .I.oyer . WIddD:JO"''' mUIIDY atdlis ClII5ar. dID
Defendant .lhabdCDtIlapcmm......-.A,.afdledtild(laI)wrilralpraa(t!IIt "'.
izta&nm:eCCMnp....bea:a... l'roalat--.plillllll '~.u' . .af CU"dID_atdID
bcaId1c:an>CDftI'IIOl'"~;.s...(.); (Z) ar,'1.-&'J.' L .~ I... (J) .."canke.w.. . _
~ (4) lbc 8ddRu to wtaiab daims IbaaJd be IMda; (S) a' ~oC Ill)' .......... -'" CIa asaF..
mc:haupriarappRlftllbrl I" 1..1...'-, ",aaddlo ar...........'~('> &aapfatdl-.
bcndir boakIIl CIl' =-wee .. ~: (7) . d.-.~ oC all <ir-a......1lId ~ '. - (1) &w
capia oC IZl)' daIm IbaIII.
- EXHIBIT "L" -
.
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IMPORTANT LEOAL NOTICE
pAJl,l1ES ~UST wrn-aN SEVeN DAYS INFORM nil:: DOMESTIC RELA nONS SECl10N AND
n<E OTHeR PARTlES. IN W1ln'tNO. OF I\HY MATEIUA1. CHANOE IN CIRCUMSTANCES
Ra.EV ANT TO mE LEVEL Of' SUPPORT OR. nm ADMlNlST'RA TlON OF TIiE SUPPORT
01lOER. INCt.UOINO. sur NOT LIMITED TO. LOSS OR CHANOE OF rNCOME OR
EMPl.OYMEHT AND CHNI06 OF PERSONAL ADDRESS OR CiANOE OF ADORESS OF ANY
om.o RJ:CEMNO SUPPORT, A PAIlTYWHO wt1.LPt1T...LY FAlLS TO REPORT A MA'tEUAL
, 0iANGE IN CDLCt1MSTAHCI! MAY BE AOItJOOED IN CONTEMPT Of COlJRT. AND MAY BE
FCNED OR IMPIlJSONEO,
~ENNsvt. v ANtA LAW PR.OVIDES lliA T ALL SUPPORT ORDERS SHALL BE IlEVtEWED AT
LEAST ONCE EValY THIlE6 (3) YEAJtS IF SUCH A R.EVtEW lS RSQtJ~ 1l:.U BY ONE OF lliE
I PAAnES, IF YOU WlSH TO REQUEST A R.EVtEW AND AD.l1JSi7wIEN1' OF YOUR. ORDER..
yOU MUST DO mE FOu.owlNCi: AN UN1U!PR.I!S~ PERsON WHO WANTS TO
MODIFY (ADJUS11 A SUPPORT Ol.Oa SHOULU 1'lL.C. ^ r'C n .-'011 ..-=n. MI:'Oa:rcA.nl'\N
I FORMS ARE A V ,tJlABLE AT neE DOMESTIC II.EU. noNS OFFtCE.
A. MAN'OATOr.Y tHCQME A1TAaIMENT W1LL ISSUE tlNLESS nm OEFemANI' IS MOT rN
.....1l.'tV RS IN PAYWEH'r rN ~ AMOUNt' EQUAL TO OR CiltEAlD. 'tHAN ONE MONrH'S
SUPPOI.T 08UtGA"0N AND (1) THE comtT FINDS l'HATTHEU IS 0000 CAUSE MOTTO
REQutRS lJAI1'I"IA TE INCOM& WIT14HOLDING; 01. (2) A WlUtTEN ...~=unrr IS
REAatED BEtWEENlliE p.u:rms WH!C< PI.OVIDes FOR AN AL~TE
,AJUV..~EMENT.
...
DELINQUENT ARJUWlAGE BAUNCES NAY BE REPORTED ro CREDrr A.CiEN~GIf .
AND AFTlm.lHl! DATE [t' IS DUP.. EAOI UNPAID SUPPORT PAnaJolt' SHALL ......-.IU~
A .1tJDOMENT AGAJNST YOU.
rr IS ftJKI'KEI. OlUJRI:n ..... . - . "'l. 6i1ara ~ ~ willi Ilia ordar. . - . -
m&y 1M .. '1IIll b. ~... bcia die c-t Ilr a "'- .'!..riac: .. .~ ..... ..,..
, "" 8ItIJI<< :.......- ~ be I . . ill........ . willa ..law. ... Old<< willie . .
...... --lIariac II) S 25 . 00 UKlG md all_. J _.... ill &IL D - . -II
.~, ~hlbrClllld_aadflauM.' '''''dlaD -'~p"'-'-s-w.
nil aaklr ...' &.1_.,. .... ~ _ oidia Dlllioc ftl"'a6r[ftldlc mdIr....
!*ticI.....IidMrI*!J'-.-. , ....wida..C " -'" " ~b-&' . .--
bcficR k c-.
0lpi0:I ddnwad CD JllftillCIR
r f.:., " . _/ ..,
\.. 1;:..... t,,-,<. X /td../7?:?--'
P\aiaD!{ , 'Stepha'l1ie L: Rupp
::TL~~;:!' R
Oc:li:nd&s, Mlchael L~
"
lstopher C. Houston, Esq.
1.
p\..n.. 4;'C
PSE(~
Pig.
VISA'St~tement of Account
1
PENNSYLVANIA
STATE EMPLOYEES
CREDIT UNION
',~~iir ~~MsiR'~f ~'m~1~'i '
0176465988
03/25/95
1...11111I11I......11..11,1,1",,11,1..1..1,1..,11.1
HICHAEL L RUPP
14 E OAKWOOD DR
CARLISLE PA 17013-9385
IF PAYING IlY MAlL PLEASE DETACH
ANO RETURN TOP POftTION WITH '/OUR PAYMENT
GMCE PERIOD: TO AVOIO ADDlTIOtW.
FINANCE CIWIGES ON PURCHASES, PAY THE
NEW IlALAHCE BY THE PAYMENT DUE DATE
0176465988 309 0627233 0012600 0000000 6
TO REPORT A LOST OR STOLEN CARD CALL: 234.84U OR '.800.237.7328 MONDAY THROUGH FRIDAY
8:00 AM . 4:00 PM: AfTER HOURS, HOLIDAYS AND WEEKENOS CALL: 1.800.558.5878
DETACH HERE t
CONVENIENT FOR WITHDRAWALS,
TRANSFERS AND DEPOSITS.
HAC DOES HORE.
. ~E .. '~,.,' it" . I': 1'!>"" 1 ~""I'f~~~
'!lA :~'::..',~';:1'~.;~,~ENCE.N~MIlEIII.;:.',:'_" ,:"}~" ,~
0207 0206 7429916143FKHDHQB5311 CPENNEY CD 11984 CARLISLE PA -107.86
0208 0207 2461044152LAFK77N5310 ILLS STORE 1107 CARLISLE PA 31. 27
0208 0208 2411600166W2Z3QJF5912 ITE AID CORP 3227 HARRISBURG PA 22.79
0209 0209 2427530176VTB5SL05912 VS 11646 CARLISLE PA 22.00
0209 0209 24610441707HNJ2365331 DOLWORTH 11566 CARLISLE PA 13.86
0209 0209 2461044172LAFENVN5310 ILLS STORE 1107 CARLISLE PA 60.0,
0213 0212 24275151901VKEQ4G7841 10-4 VIDEO MECHANISBURG PA 58.2e
0214 0213 24275301A6VTB705T5912 VS 11627 CARLISLE PA 26.50
0214 0213 24299161B3FKHB7AJ5311 CPENNEY CD 11984 CARLISLE PA 199.19
0215 0214 24275301Q6VTB7AXH5912 VS 11627 CARLISLE PA 24.53
0215 0214 24401401QOW8HT7LX5661 AYLESS SHOE SOURCE 117 CARLISLE PA 9.99
0216 0215 24610441D2LAFFZIE5310 ILLS STORE 1107 CARLISLE PA 65.17
0216 0216 24301721FWGN9V6BE5999 C WENTZEL & SONS CARLISLE PA 413.18
0221 0219 24401401GOA4QPSWS3510 AYS INNS - CARLISLE CARLISLE PA 470 . 95
0222 0221 24104001LFA6FHL5A5969 ONAIR CORPORATION EAST WINDSOR NJ 16.99
0222 0221 24301721LWGN9V4W85999 C WENTZEL & SONS CARLISLE PA 158.94
0223 0222 24399001LSERGBPAA5311 HART 00009208 CARLISLE PA 34.24
0223 0222 24610441L2LAFVYEE5310 ILLS STORE 1107 CARLISLE PA 36.28
0223 0223 VISA PAYHENT ISA PAYMENT - REF 1 001972 -200.00
0224 0223 24116001H6W435RTA5912 ITE AID CORP 3607 CARLISLE 23.26
0224 0224 24299161N3FKHE9395311 CPENNEY CD 11984 CARLISLE 92.97
-6,272.33
-(1,050.60
2.177.07
- EXHIBIT "0" -
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-1 J~-I" j(;:-lC.
-!
STEPHANIE L. RUPP,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95 - 1588
vs.
MICHAEL L. RUPP,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
"2 i( If I
J (,
of ...-t.. ,,'- :~-'-
day
1996, the economic claims raised in the proceedings having been
resolved in accordance with a separation and property settlement
agreement dated June 14, 1996, 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,
! !
\' ir(,1 ,.f I
Harold E. Sh ely, P.J.
cc: Bradley L. Griffie
Attorney for Plaintiff . j. I.
- ~ ~C!.A. ~ ~6/'ib.
Christopher C. Houston .04, f'.
Attorney for Defendant
,
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0,
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"
SEPARATION AIfD PROPERTY SBTTT,lnnP.1IT AGRBBMI!:BT
THIS AGREEMENT, made this 1'It!day of ~ ' 199;' by
and between STEPHANIE L. RUPP, of 14 East Oakwood Drive, Carlisle,
Cumberland County, Pennsylvania, party of the first part,
hereinafter referred to as "Wife",
AND
MICHAEL L. RUPP, of 201 Main Street, Apartment 1, P. o. Box
127, York Springs, Adams County, Pennsylvania, party of the second
part, hereinafter referred to as "Husband",
WITNESSETH:
WHEREAS, Husband and Wife were married on June 10, 1979, in
Mt. Holly Springs, Cumberland County, Pennsylvania; and
WHEREAS, Husband and Wife are residents of the Commonwealth of
Pennsylvania and have been so far at least the past six months;
WHEREAS, certain differences have arisen between the parties
hereto which have made them desirous of living separate and apart
from one another; and
WHEREAS, Husband and Wife desire to settle and determine
certain of their marital rights and obligations, and make an
equitable distribution of their marital property, determine their
rights to alimony and support and any other matters which may be
considered under the Divorce Code; and
WHEREAS, it is the intention and purpose of this Agreement to
set forth the respective rights and duties of the parties while
they continue to live apart from each other and to settle all
financial and property rights between them; and
,
.
.
"
WHEREAS, the parties hereto have mutually entered into an
agreement for the division of their jointly owned assets, the
provisions for the liabilities they owe, and provisions for the
resolution of their mutual differences, after both bave bad full
and ample opportunity to consult with attorneys of
their
respective choice, the parties now wish to bave that agreement
reduced to writing.
NOW, THEREPORE, the parties bereto in consideration of the
mutually made and to be kept promises set forth hereinafter and
for other good and valuable consideration, and intending to be
le9ally bound and to legally bind their beirs, successors,
assigns, and personal representatives, do bereby
promise and agree as follows:
covenant,
ARTICLE I
SEPARATION
1.1
It shall be lawful for Husband and Wife at all times
hereafter to live separate and apart from each other and to
reside from time to time at such place or places as they shall
respectively deem fit free from any control, restraint, or
interference, direct or indirect, by each other. Neither party
shall molest the other or compel or endeavor to compel the other
to cohabit or dwell with him or her by any legal or other
proceedings.
The foregoing provisions shall not be taken to be
an admission on the part of either Husband or Wife of the
lawfulness of the causes leading to them living separate and
apart.
2
,
.
. . "
,
ARTICLE II
DrvORCE
2.1
This Agreement is not predicated on divorce. It is
specifically understood and agreed by and between the parties
hereto that each of the said parties does hereby warrant and
represent to the other that the execution and delivery of this
Agreement is not predicated upon nor made subject to any
agre..ent for institution, prosecution, defense, or for the non-
prosecution or non-defense of any action for divorce: provided,
however, that nothing contained in this Agreement shall prevent
or preclude either of the parties hereto from commencinq,
instituting or prosecuting any action or actions for divorce,
either absolute or otherwise, upon just, legal and proper
grounds: not to prevent either party from defendinq any such
action which has been, may, or shall be instituted by the other
party, or from makinq any just or proper defense thereto. It is
warranted, covenanted, and represented by Husband and Wife, each
to the other, that this Agreement is lawful and enforceable and
this warranty, covenant, and representation is made for the
specific purpose of inducing Husband and Wife to execute the
Agreement.
Husband and Wife each knowingly and understandingly
hereby waive any and all possible claims that this Agreement is,
for any reason, illegal, or for any reason whatsoever of public
policy, unenforceable in whole or in part. Husband and Wife do
3
,
"
each hereby warrant, covenant and agree that, in any po..ible
event, he and she are and shall forever be estopped fro.
asserting any illegality or unenforceability as to all or any
part of this Agreement.
2.2
It is further specifically understood and agreed that the
provi.ion
of
this Agreement relating
to
the
equitable
distribution of property of the parties are accepted by each
party a. a final settleaent for all purposes whatsoever.
Should
either of the parties obtain a decree, judgaent or order of
separation
or
divorce in any other state,
country,
or
jurisdiction, each of the parties to this Agreement hereby
cons.nt. and agre.s that this Agreeaent and all it. covenant.
shall not be affected in any way by any such separation and
divorce.
2.3
This Agreement shall survive any decree in divorce and shall
be forever binding and conclusive on the parties.
It is
understood by and between the parties that this Agreement shall
be incorporated into any decree, divorce or separation, but it
shall not be deemed merged in such decree.
ARTICLE III
EOUITABLE OrSTRrBUTrON OF MARrTAL PROPERTY
3.1
The parties have attempted to divide their marital property
in a manner which conforms to the criteria set forth in the
Pennsylvania Divorce Code, and taking into account the following
4
.
considerations: the length of the marriage: the prior marriage.
of the partie.; the age, health, station, amount and sources of
income, vocational skills, employability: estate, liabilitios,
and needs for each of the parties: the contribution of one party
to the education, training or increased earning power to the
other party: the opportunity of each party for future acquisition
of capital assets and income: the sources of income of both
parties, including but not limited to medical, retire.ent,
insurance or other benefits: the contribution or dissipation of
each party in the acquisition, preservation, depreciation, or
appreciation of marital property, including the contribution of a
party as a homemaker: the value of the property set apart to each
party: the standard of livinc:J of the parties established during
their marriac:Je: the economic circumstances of each party,
including federal, state and local tax ramifications, at the time
of the division of the property is to become effective: and
whether the parties will be serving as the custodian of any
dependent minor children.
3.2
The division of existing marital property is not intended by
the parties to constitute in any way a sale or exchange of assets
and the division is being effected without the introduction of
outside funds or other property not constitutinc:J marital
property. The division of property under this Agreement shall be
in full satisfaction of all rights of equitable distribution of
the parties.
5
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3.3
Personal Procertv. The parties acknowledge that they have
divided their personal property, tangible and intangible, to
their mutual satistaction. Parties further acknowledge that they
have the cash, accounts, or other tangible and intangible
property in their possession that they wish to have and neither
will make any claim whatsoever against the other party tor any
other items of personal property or assets that in other party'8
possession.
3..
Life Insurance. Each party agrees that the other party
shall have sole ownership ot any life insurance policies owned by
the other party. This specifically includes but is not limited
to the AIG Lite Insurance Company policy number U86003814 which
is and shall remain the sole possession ot Wite and AIG Life
Insurance Company policy number U86003815 which is and shall
remain the sole possession ot Husband. Each party shall have the
right to borrow against, cash in policies, change beneficiaries,
and exercise any other incidents ot ownership of the respective
policies free of any right or claim by the other party. Each
party agrees to sign any documents necessary to waive, relinquish
or transfer any rights in such policies to the respective party
who presently owns such policies.
6
,
3.5
Subseauentlv Acauired ProDe~v. Husband and Wife agree to
waive and relinquish any and all right that he or she may now
have or hereafter acquire in any real or tanqible personal
property subsequently acquired by the other party. Husband and
Wife specifically agree to waive and relinquish any riqht in such
property that may arise as a result of the marriage relationShip.
3.'
Real Estate. The parties were previously the joint owners
of real estate located at 14 East Oakwood Drive, Carlisle,
CUmberland County, Pennsylvania which property has recently been
sold to a third party purchaser for value. The net funds fro.
this sale are presently held in escrow by counsel for Wife,
Bradley L. Griffie, Esquire. This sale has been conducted to the
parties' mutual satisfaction.
By execution of this Agreement, Husband acknowledges that he
shall make no claim whatsoever relative to any of the equitable
or legal interests in the aforesaid real estate. Husband further
hereby authorizes the release of all proceeds held in escrow by
Bradley L. Griffie, Esquire to Wife. Husband shall hereafter
make no claim or demand of any nature whatsoever of Wife or
counsel for Wife for any of the proceeds hereby released.
Husband shall make no claim of any nature whatsoever, legal
or equitable, in the interest in the aforesaid real estate or the
proceeds from the sale thereof, from the time of execution of
this Agreement forward.
7
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3.7
Pension. Retirement. Profit-Sharina. Wife agrees to waive,
transfer or relinquish any and all of her right, title and
interest in Husband's pension through his employment with the
Commonwealth of Pennsylvania. More specifically, Husband has a
pension available to him through the state Employees Retirement
system which account is docketed to Husband's social security
number of 176-46-5988. Wife hereby waives, relinquishes and
transfers any and all right, title and interest she has in this
retirement account, as well as any other accounts that Husband
may have in his individual name or may have secured through his
present or prior employment.
Husband agrees to waive, transfer or relinquish any and all
of his right, title and interest he has or may have in his
individual capacity or as Wife's Husband in any and all pension,
retirement, profit-sharing, stock options or similar accounts
with Wife's present or past employers or which Wife has secured
independently.
3..
Vehicles. The parties acknowledge that Wife has and shall
retain sole and exclusive possession of the parties' 1994 Ford
Aerostar XLT vehicle which is a leased vehicle. Wife shall
retain sole and exclusive responsibility for the re-payment of
the lease amounts due and owing on that vehicle. Husband shall
make no claim whatsoever relative to access for use of the
aforesaid vehicle and shall make no ownership claim of any nature
in the aforesaid vehicle.
8
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~
The parties further acknowledge that Husband has in hi.
possession and titled in his name alone a certain 1987 Beretta GT
which v.hicl. shall remain as Husband's sole and .xclusiv.
po.....ion. Wife hereby waives, relinquish.s and transfer any
and all right, title and interest that she has or may have in the
aforesaid vehicle. Husband shall be sol.ly and exclusiv.ly
responsible for any and all encumbrance of any nature whatsoever
in the afor.said vehicle and shall hold Wife ha~ess and .ave
her from and against any and all collection activity on account
of any such encumbrance.
3.t
Intanaible Personal ProDertv. The parties acknowledge that
they have a wide variety of stock investments that they have
secur.d during their marriage. The parties do not wish to list
all of their stock investments. Both are aware of the
investments and their approximate values. The parties agree that
these various stocks will be valued to the date of execution of
this Agreement by both parties. Those stocks shall then be
distributed so as to provide Wife with $14,000.00 worth of the
parties' stock investments. Any stocks that are in the parties'
joint names or in Husband's name, Husband will execute any and
all necessary documents to convey his interest in those stock
investment accounts.
Husband shall retain the balance of all stock accounts owned
by the parties. In the event Husband retains stock accounts that
are in joint names or in Wife's name, Wife will execute any and
all necessary documents to convey her interest in those stock
9
"
investment
accounts.
Upon the distribution of the
stock
investment as outlined above, each party shall then retain sole
and
exclusive
ownership and possession of
those
stocJcs
transferred into their respective individual name. Neither party
will malee any claim whatsoever relative to ownership interest or
rights to income from the stock accounts so transferred.
Upon
execution of this Agreement and transfer of ownership of any
stock investments required by this paragraph, each party shall
then
have
all right. attributable to ownership
of
the
aforementioned stocJcs without claim from the other party.
The parties have otherwise already transferred or waived
rights and interest in other intangible personal property,
includin9 their various bank accounts, credit union accounts and
the like.
Neither party will make any claim of any nature
whatsoever against the other relative to financial accounts or
other investments or intangible personal property that has
already been retained by the other party.
ARTICLE IV
ALIMONY. ALIMONY PENDENTE LITE. SPOUSAL SUPPORT.
CHILD SUPPORT AND MAINTENANCE
4.1
The parties agree that Wife is in need of financial
assistance in order to allow her to develop independent income
from Husband. As such Husband agrees that he will pay the sum of
SEVENTY-FIVE DOLLARS ($75.00) per month for a period of twenty-
four (24) months from the date of the parties' divorce decree.
Husband shall make the SEVENTY-FIVE DOLLARS ($75.00) per month
payment directly to Wife by the fifteenth (15th) of each month.
10
,
In the event Husband is in default of the monthly payment for a
period of ten (10) days, Wife shall be entitled, at her sole
discretion, to file a complaint for alimony with the cumberland
County Domestic Relations Office and have the alimony collected
by wag- attachment through the cumberland County Domestic
Relations Office. This sum of SEVENTY-FIVE DOLLAilS ($75.00) per
week for the period of the twenty-four (24) months shall be non-
modifiable under any circumstances.
...2
The parties herein acknowledge that expect for the
provisions set forth in Paragraph 4.1 above, the have each
secured and maintained a substantial and adequate fund with which
to provide themselves sufficient resources to provide for their
comfort, maintenance and support in the station of life in wbich
they are accustom. Husband and Wife do hereby waive, release and
give up any rights they may respectfully have against the other
for alimony, support or maintenance except as provided for in
Paragraph 4.1 above.
".3
Husband and Wife specifically waive, release and give up any
rights for alimony, alimony pendente lite and spousal support
pursuant to Chapter 37 of the Domestic Relations Code.
11
,
"
ARTICLE V
DEBTS OF THE PARTIES
5.1
The
parties
acknowledge that they
have
outstanding
encumbrances due and owing on their life insurance policies
referenced in Paragraph 3.4 above. Each party agrees to assume
responsibility for re-payment of the outstandinq loan obligation
due on their respective life insurance policies. Each party will
indemnify the other and hold them harmless from and aqainst any
and all collection activity or demand for payment of any nature
whatsoever relative to those outstandinq loans against the
parties respective life insurance policies.
In addition, the parties are jointly responsible for a
Pennsylvania State Employees Federal Credit union loan docketed
to account number 0176465988 L1-PSL loan. Wife agrees that upon
final settlement on the sale of real estate as described in
Paragraph 3.6 above, the sum of TWO THOUSAND SIX HUNDRED FORTY-
TWO
DOLLARS 93jXX ($2,642.93) shall be disbursed to
the
Pennsylvania State Employees Credit Union for purposes of
applyinq toward any and all outstandinq balance on the aforesaid
personal service loan. In the event that the total balance due
is
less than TWO THOUSAND SIX HUNDRED FORTY-TWO
DOLLARS
($2,642.93), Wife shall only be obligated to pay the final
balance due. In the event after payment of this sum a balance
remains, Husband agrees to be solely and exclusively responsible
for re-payment of that balance to the Pennsylvania
State
Employees Credit Union and will pay the balance due in a timely
fashion. Husband will indemnify Wife and hold her harmless from
12
,
and against any and all collection activity of any nature
whatsoever relative to the balance due on the aforesaid personal
service loan after Wife has made her payment as required herein.
In addition, the parties are obligated on a joint account
that the Pennsylvania state Employees Credit union being a Visa
account, account number 0176465988, Wife agrees that at the time
of final settlement on the sale of the parties' former marital
residence as provided for in Paragraph 3.6 above, she will
disburse a balance up to POOR THOUSAND THREE HUNDRED FORTY-SEVEN
DOLLARS and 90/XX ($4,347.90) to be applied toward the aforesaid
Visa account stat_ent. In the event that the balance due on the
aforesaid Visa account is less than that sum, Wife shall only be
obligated to pay the balance due. In the event there are any
aJlounts due over and above the sum of FOOR THOUSAND THREE HUNDRED
FORTY-SEVEN DOLLARS and 90/XX ($4,347.90) Husband shall be solely
obligated to make re-payment of any such outstanding balance.
Husband shall indemnify Wife and hold her harmless from and
against any and all demands for payment or collection activity of
any nature whatsoever for any amounts due on the Visa account
statement beyond FOOR THOUSAND THREE HUNDRED FORTY-SEVEN DOLLARS
and 90/XX ($4,347.90).
5.2
Each party represents to the other that except as otherwise
specifically set forth in this Agreement, and more particularly
as set forth in subparagraph 5.1 above, there are no major
outstanding obligations of the parties: that since the separation
13
,
"
neither party has contracted for any debts for which the other
will be responsible and each party indemnifies and holds harml...
the other for all obligations separately incurred or assumed
under this Agreement.
ARTICLE VI
MISCET~~NF.OUS PROVISIONS
'.1
Advice of Counsel. The provisions of this Agreement and
their legal effect have been fully explained to the parties by
their respective counsel, being Christopher C. Houston, Esquire
for Husband and Bradley L. Griffie, Esquire for Wife. The
parties acknowledge that they have either received independent
legal advice from counsel of their own selection, that they fully
understand the facts and have been fully informed as to their
legal rights and obligation or otherwise understand those legal
rights and Obligations. They acknowledge and accept that this
Agreement is, in the circumstances, fair and equitable, that it
is being entered into freely and voluntarily, after having
received such advice and with such knowledge that execution of
this Agreement is not the result of any duress or undue
influence, and further that it is not the result of any collusion
or improper or illegal agreement or agreements.
&.2
Counsel Fees. Each party agrees to be responsible for hi.
or her own legal fees and expenses, and each party hereby agrees
to waive any claim for alimony, alimony pendente lite, counsel
fees, expenses or costs.
14
"
6.3
Mutual Release. Husband and Wife each do hereby mutually
remise, release, quitclaim, and forever discharge the other and
the estate of such other, for all times to come and for all
purposes whatsoever, of and lrom any and all right, title and
int.r.st, or claims in or against the property (inclUding inco..
and gain from property hereafter accruing) of the other or
against the estate of such other, of whatever nature and
wher.soever situat., which he or she now has or at any tiae
hereafter may have against such other, the estate of such other,
or any part thereof, whether arising out of any former acts,
contracts, engagements, or liabilities of such other as by way of
dower or curtesy, or claims in the nature of dower or curtesy or
widow's or widower's rights, family exemption, or similar
allowance, or under the intestate laws, or the right to take
against the spouse's Will: or the right to treat a lifetime
conveyance by the other as testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any
state, commonwealth or territory of the United states, or (c) any
other country, or any rights which either party may have or at
any time hereafter have for past, present, or future support or
maintenance, alimony, alimony pendente lite, counsel fees, costs
or expenses, whether arising as a result of the marital relation
or otherwise, except and only except, all rights and agreements
and obligations of whatsoever nature arising or which may ari..
under this Agreement or for the breach of any thereof. It is the
15
,
~
intention of Husband and Wife to give to each other by execution
of this Agreement a full, complete, and general release with
respect to any and all property of any kind or nature, real or
personal, not mixed, which the other now owns or may hereafter
acquire, except and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any thereof.
c.e
BankruDtCV. The parties agree that any and all financial
obligations assumed herein shall not be subject to discharge
through bankruptcy proceedings. This includes, but i. not
limited to, all financial obligations assumed under Paragraph
3.6, 4.1, and 5.1 of this Agreement. In the event either party
attempts to avoid financial obligations described herein through
bankruptcy proceedings the other party shall have an independent
claim against the party claiming bankruptcy for any and all suas
that the other party assumes or is required to pay due to the
actions of the party Claiming bankruptcy. Further, all rights
available to the other party provided for in Paragraph 6.14
hereinafter shall be available to the party not filing
bankruptcy.
'.5
Warranties. Each party represents that they have not
heretofore incurred or contracted for any debt or liability or
obligation for which the estate of the other party may be
responsible or liable, except as may be provided for in this
Agreement. Each party agrees to indemnify or hold the other
16
. ,
party harmless rrom and against any and all such debts,
liabilities or obligations or every kind, including those ror
nece..itie., except ror the obligations arising out or this
Agreement. Husband and wire each warrant, covenant, represent
and agree that each will, now and at all times herearter, save
harmless and keep the other indemnified rrom all debts, charges,
and liabilities incurred by the other arter the execution date or
this Agreement, except as is otherwise specifically provided ror
by the teras of this Agreement and that neither of them hereafter
incur any liability whatsoever for which the estate or the other
may be liable.
,.,
No waiver or modification of any or the terms of this
Agreement shall be valid unless in writing and signed by both
parties and no waiver or any breach hereor or default hereunder
shall be deemed a waiver or any subsequent derault of the same or
similar nature.
'.7
Husband and Wire covenant and agree that they will forthwith
execute any and all written instruments, assignments, releases,
satisractions, deeds, notes or such other writings as may be
necessary or desirable for the proper implementation of this
Agreement, and as their respective counsel shall mutually agree
should be so executed in order to carry rully and effectively the
terms or this Agreement.
17
,
.
'.8
This Agreement shall be construed in accordance with the
laws of the Commonwealth or Pennsylvania which are in erfect as
or the date of execution of this Agreement.
,.,
This Agreement shall
benefit of the parties
be binding and shall inure
hereto and their respective
to the
heirs,
executors, administrators, succe..ors and a.signs.
'.10
Thi. Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agreements and
negotiations between them. There are no representations or
warranties other than those expressly set rorth herein.
'.11
Severabili~v.
Ir any term, condition, clause, section, or
provision or this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause, or provision shall be stricken rrom this
Agreement, and in all other respects, this Agreement shall be
valid and continue in full force, errect, and
operation.
Likewise, the railure of any party to meet his or her obligation
under anyone or more or the articles and sections herein shall
in no way void or alter the remaining obligations of the parties.
'.12
It is specirically understood and agreed that this Agreement
constitutes an equitable distribution or property, both real and
personal, which was legally and beneficially acquired by Husband
18
,
'.
i
and Wife, or either or them, during the marriage as contemplated
by the Divorce Code or the Commonwealth or Pennsylvania.
'.13
Disclosure. The parties each warrant and represent to the
other that he or she has made a rull and complete disclosure to
the other of all assets of any nature whatsoever in which party
has an interest, of the sources, and amount of the income of such
party of every type whatsoever, and all other facts relating to
the subject matter of this Agreement.
'.14
Enforceabilitv and Consideration. This Agreement shall
survive any action for divorce and decree of divorce and shall
forever be binding and conclusive on the parties; and any
independent action may be brought, either at law or in equity, to
enforce the terms of the Agreement by either Husband or Wife
until it shall have been fully satisfied and performed. The
consideration for this contract and agreement is the mutual
benefits to be obtained by both of the parties hereto and the
covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein
contained in stipulated, confessed, and admitted by the parties,
and the parties intend to be legally bound hereby. In the event
either party breaches the aforesaid Agreement and it is
determined through appropriate legal action that the alleged
party has so breached the Agreement, the breaching party shall be
responsible for any and all attorney's fees as well as costs and
expenses associated with litigation incurred by the non-breaching
19
..
o
,
.0
.
party to enforce this Agreement against the breaching party. In
the event of breach, the non-breaching party shall have the
right, at his or her election, to sue for damages for such breach
or to seek such other and additional remedies as may be available
to him or her includinq equitable enforcement of the Agreement.
IN WITNESS WHEREOF, the parties hereto have set their bands
and seals the day and year first above written.
WITNESSED BY:
~ii.ifR~~
20
,
-, .. ,
, .
..
.
COMMONWEALTH OF PENNSYLVANIA
COtm'l'Y OF c.. lA m bA.rl ~.." d.
6+
On this, the 31 day of
.
.
.
.
SS
.
.
Ih t<.. 'J--
V
the undersigned officer, personally appeared Michael L. Rupp, known
, 1996, before me,
to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Aqre_ent and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOI"al Seal
Katen F. By.... t10lalY Public
Carlisle Bora. Cum08rland County
My comrr.'..'. - ".e' \larch 18, 1999
~~~
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COMMONWEALTH OF PENNSYLVANIA
COUN'l'Y OF c.u. ~h.l' ,.. { /'l I A.
On this, the I~~ day of
.
.
.
.
SS
.
.
the
tju/U
undersigned officer, personally appeared
, 1996, before me,
Stephanie L. Rupp,
known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within Agreement and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~ Ju IL <I d..d..",~
"
, I
Notartal SUI ' I
Robin J. Gotham. Notary PubI1c . '
Cettlsle Iloto. Cumbelland County
My Commlsalon ExPres AprIl 17. 1999
2l
L, RUPP, : IN THE COURT OF COMMON PLEAS
Plaintiff . OF CUMBERLAND COUNTY,
.
: PENNSYLVANIA
vs, : CIVIL ACTION - LAW
. No, 95-1588 CIVIL TERM
.
MICHAEL L, RUPP, .
.
Defendant : IN DIVORCE
CBRTIPICATB OP SBRVICB
I, Bradley L. Griffie, Esquire, hereby certify that I did,
the 19th day of June, 1996, cause a true and correct copy of a
Notice of Intention to Request Entry of Divorce Decree to be
served upon the Defendant, Michael L. Rupp, by servinq his
attorney of record by first class mail, postage prepaid, at the
following address:
Christopher C. Houston, Esquire
Broujos, Gilroy & Houston
4 North Hanover street
Carlisle, PA 17103
DATE:
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Griffie, Esquire
E & ASSOCIATES
00 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Sworn and subscr~bed to
before me this 1'1-:::A day
of ,June, 1996,
(~ l-L' /
M J.... '" .J4.d..LN'I'--./
}:OTARY PUB C'
NOlllrial Saal
Robin J. Goshorn, Notary Public
CarlIsle Bora, Cum:>ortand County
My Commission e_f:.IJos Apnl17. 1999
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Plaintiff
IN THE COURT OP COMMON PLEAS OF
CtJMBERLAND COTJNTY, PENNSYLVANIA
CIVJ:L ACTION - LAW
vs.
!lIMn 1l;T. L. RDPP,
Defendant
NO. 95-1588 CIVJ:L TERM
IN DIVORCE
~C'JI a. .L~.lurli.O. m IUIODWS'f
DI'l'RT O. D:noIlCB DBCIUIJI
TO: Cbrist:apbar C. Houston, Esquire
Attorney for Defendant
Brauj oa, Gil.roy fr Houston
.. North BaIlover street
Carliale, PA 17013
PlainUff, steph_ftie L. Rupp, inteDda t:a fU. with the Cl...u;L
the attached Praecipe to '1"raI18mit Rac:ord on or a~ July 12,
1996, requesting the final decr.e in divorce be entered.
r t'fie,
or Plaintiff
fr ASSOCUTES
200 North Hanover street
carlisle, PA l7013
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STEPHANIE L. RUPP,
plaintiff
.
.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CIVIL TERM
IN DIVORCE It 9':1-- 'S~8CLt~LJ~t..-Jf'.-"
:
v,
.
.
.
.
MICHAEL L. RUPP,
Defendant
:
.
.
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case will
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at Cumberland County courthouse,
Carlisle, cumberland County, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
cumberland County Court Administrator
4th Floor
cumberland County Courthouse
carlisle, pennsylvania 17013
(717) 240-6200
STEPHANIE L. RUPP, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . CIVIL ACTION - LAW
.
. CIVIL TERM
.
MICHAEL L. RUPP, .
.
Defendant . IN DIVORCE
.
COMPLAIN'!' IN DIVORCB
COUNT I
1. Plaintiff is Stephanie L. Rupp, an adult individual whom
has been residing at 14 East Oakwood Drive, Carlisle, cumberland
County, Pennsylvania, since 1986.
2.
Defendant is Michael L. Rupp,
an adult individual
currently residing at Apartment #18, Winchester Gardens,
carlisle,
cumberland County, Pennsylvania, since February 15,
1995.
3. Plaintiff is a bona fide resident of the Commonwealth
of Pennsylvania
and has been so for at least six months
immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on June lO, 1979,
in Mt. Holly Springs, cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the
United states of America or its Allies.
7. Plaintiff has been advised of the availability of
counseling and the right to request that the court require the
parties to participate in counseling.
Knowing this, Plaintiff
does not desire that the Court require the parties to participate
.~
in counseling.
8. Plaintiff and Defendant are citizens of the United
states of America.
9. The parties' marriage is irretrievably broken.
lO. Plaintiff desires a divorce and it is believed that
Defendant will after ninety (90) days from the date of the filing
of this Complaint consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter
a Decree in Divorce under Section 3301(c) of the Divorce Code of
1980, as amended.
COUN'l' II
11. Paragraphs 1 through 10 are incorporated herein by
reference as if set forth in their full text,
12. Plaintiff is unable to provide for or afford her counsel
fees, expenses, and costs during the pendency of this divorce
action and through its resolution.
13. Plaintiff is without sufficient property and otherwise
unable to financially support herself despite being employed.
14. Defendant is presently employed and receiving a
substantial income and benefits and is able to pay for counsel
fees, expenses, and costs as well as alimony and alimony pendente
lite for Plaintiff.
WHEREFORE, Plaintiff requests your Honorable Court to enter
an Order requiring Defendant to pay Plaintiff's counsel fees,
.'
.'
expenses, and costs as well as providing for payment of
appropriate alimony and alimony pendente lite to Plaintiff.
GRIFFIE , ASSOCIATES
By:
tV~.
Barbara J. , E~.
200 North Hanover Street
Carlisle, PA l70l3
(717) 243-555l
1-800-347-5552
Date: .qhJ/1)
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT
ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: 0.}''';3,/5
~~iA4t
~laintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
STEPHANIE L. RUPP,
Plaintiff
VS.
MICHAEL L, RUPP,
Defendant
COMPLAINT IN DIVORCE
GRIFFIE & ASSOCIATES
AnORNEVS..AT..LAW
200 NORTH HANOVER STREE.T
CARLISLE, PA 17013
Su ITE 307
14 NORTH MAIN STREET
CHAMBERSBURG. PA 17201
(3J
H~n 28 I \JG PH '95
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STEPHANIE L. RUPP, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . CIVIL ACTION - LAW
.
. CIVIL TERM
.
MICHAEL L. RUPP, . NO. 95-1588
.
Defendant . IN DIVORCE
.
ACCEPTANCE OF SERVICE
I hereby acknowledge that I have received a certified and
true copy of the Complaint in Divorce in the above-captioned case
and verify that I am authorized to do so on behalf of my client,
Michael L. Rupp.
~-
Christopher C, Houston, Esq.
4 North Hanover Street
CarliSle, PA l7013
Attorney for Defendant
DATE:
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Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-l588 CIVIL TERM
MICHAEL L, RUPP,
Defendant
: IN DIVORCE
APPIDAVIT OP CONSENT
1. A Complaint in Divorce under section 3301(c) of the
Divorce Code was filed on March 28, 1995,
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of the Complaint.
3, I consent to the entry of a final Decree of Divorce
after service of notice of intention to request entry of the
decrees.
I.
. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa, C,S. 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: .f/t . /~- fv
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.1ST HANI!:' L. R P
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plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
,
.
vs.
: CIVIL ACTION - LAW
95-1588 CIVIL TERM
IN DIVORCE
MICHAEL L, RUPP,
Defendant
UI'IDAVIT 01' CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce,Code was filed on March 28, 1995,
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of the Complaint,
3. I consent to the entry of a final Decree of Divorce.
'4. I have been advised of the availability of marriage
coun~eling, that I may request that the Court require that my
spouse and I participate in counseling, and that the Court
:~~intains a list of marriage counselors in the Prothonotary's
Office; which list is available to me upon request.
Being so
advised, I decline to request that the Court require that my
spouse and I participate in counseling.
5. I understand that I may lose rights concerning alimony,
division of property, lawyers' fees or expenses if I do not claim
them before a divorce is granted,
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C.S. 4904 RELATING
TO UNSWORN FALSIFICATION TO AUTHORITIES,
DATE:
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MICHAEL L.
Defendant
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STEPHANIE L, RUPP
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-1588 CIVIL TERM
IN DIVORCE
MICHAEL L. RUPP,
Defendant
ORDER OF COURT
AND NOW, this 4\'0 day of I:; ~("""LA .-_/ , 1996, in
consideration of the attached Petition, 1t is hereby directed that
the parties and their respective counsel appear before
, Es uire, the Conciliator, at
~ , on the
",r< h , 996, at ---10 . Dc) .M., for
a re-Hearing Custody Conference, At such conference, an effort
will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the
Court and to enter into a temporary order. All children age five
or older may also be present at the conference. Failure to appear
at this conference may provide grounds for entry of a temporary or
permanent order.
(c;r
__ the Court,
cus~~ni1t~;1:U-1 . f1- Be
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the Court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or business before
the Court. You must attend the scheduled conference or hearinq.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP,
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
717 - 240-6200
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: IN THE COURT OF COMMON PLEAS OF
, CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-l588 CIVIL TERM
IN DIVORCE
STEPHANIE L. RUPP
Plaintiff
MICHAEL L. RUPP,
Defendant
PETITION FOR MODIFICATION OF A PARTIAL CUSTODY ORDER
AND NOW, comes the Petitioner, Michael L, Rupp, the above-named
Defendant, who avers as follows:
1
The Petitioner, Michael L. Rupp, the above-named Defendant,
respectfully represents that on June 7, 1995, an Order of Court was
entered upon a Stipulation and Agreement of the Parties for custody
and partial custody of the minor children, Arnie Elizabeth Rupp,
born July 25, 1983, and Justin Michael Rupp, born April 27, 1987,
a true and correct copy of which is attached hereto and marked as
Exhibit A,
2
The Petitioner respectfully requests that this Order should be
modified as follows:
A. Petitioner desires to have shared legal custody of the
children.
B. Petitioner desires to have unsupervised periods of partial
custody with the children every Wednesday evening and alternating
weekends from 5:00 P,M, on Friday until 5:00 P,M, on Sunday, On
the remaining weekends, Petitioner desires to have partial custody
from 5:00 P,M. on Friday until 5:00 P.M, on Sunday durinq those
weekends that Mother works. If Mother does not work on the
remaining weekends, Petitioner desires to have partial custody on
Tuesday and Thursday evenings of the week prior.
C, Petitioner desires to arrange for a schedule to have
unsupervised periods of partial custody on alternating holidays and
to provide for a period of partial custody with the children during
their summer vacation.
3
The Petitioner believes that the current Order should be modified
so as to provide the Petitioner with more time with his children
which would be unsupervised.
WHEREFORE, Petitioner requests that the Court modify the existing
Order for partial custody because it will be in the best interest
of the children.
~OO.
Christophe C. Houston, Esquire
Attorney for Petitioner/Defendant
Broujos, Gilroy & Houston, P.C,
4 North Hanover Street
Carlisle, PA 17013
717 - 243-4574
I verify that the statements in the foreqoinq pleading are true and
correct,
I understand that false statements herein are made
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subject to the penalties of l8 PaCS 4904 relating to unsworn
falsification to authorities.
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STEPHANIE L, RUPP,
Plaintiff
IN THE COURT OF COMMON P~
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MICHAEL L. RUPP,
Defendant
CIVIL ACTION - LAW
NO, 9s-/5/t CIVIL 1995
IN CUSTODY
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CUSTODY
8TIPULATIO. AKD AORBBKBHT
THIS AGREEMENT AND STIPULATION entered into the day and
year hereinafter set forth, by and between stephanie L. RUPP,
(hereinafter referred to as "Mother") and Michael L. Rupp,
(hereinafter referred to as "Father").
WHEREAS, the parties are the natural parents of Amie
Elizabeth RUPP, born July 25, 1983 and Justin Michael Rupp, born
April 27, 1987 (hereinafter the "children"); and
WHEREAS, the parties are presently separated and living in
separate residences: and
.
WHEREAS, the parties wish to enter into an agreement
relative to custody and partial custody of the children: and
NOW, THEREFORE, in consideration of the mutual covenants,
promises and agreements as hereinafter set forth, the parties
agree as follows:
I. Mother shall have primary physical and legal custody of
the children.
2. Father shall have supervised visitation with the
children as agreed upon by the parties,
3. The parties will attempt to make arrangements for both
parents to spend time with the children on each holiday as they
may agree.
4. The parties will keep each other advised immediately in
the event of serious illness or medical emergency concerning the
children and shall further take any necessary steps to ensure
that the health and well beinq of the children is protected.
Durinq such illness or medical emergency, both parties shall have
the right to visit the children as often as he or she desires
consistent with the proper medical care of the children,
5, Neither parent shall do anything which may estranqe the
children from the other party, or injure the opinion of the
children as to the other party, or which may hamper the free and
natural development of the children's love or affection for the
other party.
6. The parties desire that this stipulation and Agreement
be made an Order of Court to the Court of Common Pleas of
CUmberland County, and further acknowledge that the Court of
Common Pleas of cumberland County does, in fact, have
jurisdiction over the issue of custody of the parties' minor
children and shall retain such jurisdiction should circumstances
change and either party desire or require modification of said
Order,
9. The parties agree that in making this Agreement, there
has been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other,
10. The parties acknowledge that they have read and
understand the provisions of this Agreement. Each party
acknowledges that the Agreement is fair and equitable and that it
is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto intendinq to be
leqally bound by the terms hereof, set forth their hands and
seals the day and year herein mentioned.
WITNESS:
Date: ~;J.~h5"
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MICHAEL L. PP
COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
me,
On this theda~ay of
the undersigned officer,
) flag-
personally
appeared stephanie L.
, 1995, before
RUpp, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
NoIat1aJ Seal
~o:~ J~s:;om. NOlary Public
My CommiSSIon E;::'~I~~~9
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COMMONWEALTH OF PENNSYLVANIA )
) SS
COUNTY OF CUMBERLAND )
On this the J./I-h day of fh ILt
, 1995, before
me, the undersigned officer, personally appeared Michael L. RUPP,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
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Notarial Seal
Karen F, B)1!IS, Notary Public
Carlisle Boro, Cumber1ai1d County
My Commission Explros March 18, 1999
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
STEPHANIE L. RUPP,
Plaintiff
MICHAEL L. RUPP,
Defendant
NO. 95-1588 CIVIL TERM
IN CUSTODY
AND NOW,
ORDER OF COURT
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.
, upon consideration of
the attached complaint, it is hereby directed that the parties
Do.wf\ $, S"'''.,(o~
and their respective counsel appear before lIululrt x. cilroy,
'2.,., Lu M..;.....:,t, MC'~k,";~~k.:/
Esquire, the conciliator, at the .e\1Illil~l::lQ..d eC.l;lll~Y Courthouse,
Fourth-Fl:oor, on the I ~ t .,
day of
Odg~IY
, 1996, at
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a,m" for a pre-Hearing custody Conference.
At such
conference, an effort will be made to resolve the issues in
dispute; or if this cannot be accomplished, to define and narrow
the issues to be heard by the court, and to enter into a
temporary order.
All children age five or older may also be
present at the conference. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
BY:cD'I..'-oI1
CUSTODY
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Courthouse, 4th Floor
Carlisle, PA 17013
(717) 240-6200
_ FILED-OrrtCE
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STEPHANIE L. RUPP, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA
,
,
.
vs, . NO. 95-1588 CIVIL TERM
.
: CIVIL ACTION - LAW
MICHAEL L, RUPP,
Defendant . IN CUSTODY
.
PETITION POR MODIPICATION OP CUSTODY
AND NOW, comes Petitioner Stephanie L. Rupp, by and through
her counsel of record, Bradley L. Griffie, Esquire, and petitions
the Court as follows:
1, Your Petitioner, Stephanie L. RUpp, the above-named
Plaintiff and an adult individual currently residing at 211-A
Chestnut
Street,
Mt. Holly
springs,
Cumberland
County,
Pennsylvania.
2. Your Respondent is the above-named Defendant, an adult
individual currently residing at Apartment 12, Evergreen street,
Thompsontown, Juniata County, Pennsylvania.
3, The parties are the natural parents of Amie Elizabeth
Rupp, born July 25, 1983 and Justin Michael Rupp, born April 27,
1987,
4. The parties are subject to an Order of Court dated March
15, 1996 which is attached hereto and incorporated herein by
reference as Exhibit "A" relative to the custody arrangements for
the children.
5. Petitioner has made arrangements to move from the
jurisdiction of Cumberland County, Pennsylvania which move would
necessitate the modification of the instant custody order as the
1
terms would not be able to be met due to the distance between the
future residence of the Petitioner and her children and the
Respondent's residence.
6. The Petitioner and the children will be moving to Lake
oswego, oregon upon confirmation of the court of a new custody
order either by agreement or following a hearing in this matter.
7. The move of the Petitioner and the children to Lake
oswego, Oregon will dramatically improve the quality of life for
the children for a wide variety of reasons which will therefore
be in the best interest of the children.
8, The move by petitioner is not done in any fashion to any
way inhibit or damage the relationship between the Respondent and
the children.
9, Appropriate accommodations can be made for contact
between the Respondent and the children following the Petitioner
and the children's move to Oregon.
WHEREFORE, Petitioner requests your Honorable Court to
schedule a conciliation at which time an agreement can be entered
to provide for a modification of the Court's Order of March 15,
1996 in this matter.
Respectfully submitted,
GRIFFIE & ASSOCIATES
Attorneys for Petitioner
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: IN THE COURT OF CCXoIMOO PLEAS OF
: ClIMBERLAND <XXJN'l'Y, PENNSlCLV1\NIA
STEPHANIE L. RUPP,
plaintiff
.
.
CIVIL TERM
vs.
: NO. 95-l5BB
.
.
MICHAEL L. RUPP,
Defendant
: CIVIL ACTIOO - LAW
IN CUSTODY
.
.
CJU)I!R ~ CXlRr
J\ND tDf, this IS-v... day of
upon consideration of the attached CUstody
ordered and directed as follows:
"-f):) IIM'~ ' 1996,
conclliation Report, it is
l. This COurt I S prior Order dated June 7, 1995, incorporating the
parties' CUstody stipulation executed in May 1995, is hereby vacated.
2. The Mother, Stephanie L. Rupp, and tile Father, Michael L. Rupp,
shall have shared legal custody of Arnie Elizabeth Rupp, born July 25, 19B3,
and Justin Michael Rupp, born April 27, 19B7.
3. The Mother shall have primary physical custody of the Children.
4. The Father shall have partial physical custody of the Children on
alternating weekends fran Friday at 5:00 p.m. until the following Sunday at
5,00 p.m. The Father shall also have partial custody of the Children every
Wednesday evening fran 5:00 p.m. until 8:00 p.m. During weekends when the
Mother otherwise has custody of the Children, the Father shall have a period
of partial custody on sunday evening fran 5:00 p.m. until B:oo p.m. Up to
six times per year, the Mother may preempt the Father's alternating Sunday
evening period of partial custody by providing at least one week prior
notice to the Father of other plans for the Children on the upcan!ng Sunday
evening.
5. The parties shall share or alternate custody of the Children on
holidays as follows:
A. Chrisbnas/Easter~ivi~: The party who otherwise has
custody of the Chlldren dunng the night i.IlInediately preceding
the holiday shall have custody of the Children until 2:00 p.m.
on the holiday. The other party shall have custody of the
Children fran 2:00 p.m. until 8:00 p.m. on the holiday.
B. Memorial Day/July 4th/Labor Day: In even nurrbered years, the
Mother shall have custody of the Children on MemCJrial Day and
Labor Day and the Father shall have custody of the Children on
July 4th. In odd nurrbered years, the Father shall have custody
of the Children on Memorial Day and Labor Day and the Mother
shall have custody on July 4th.
6. Each party shall have an opportunity to have a reasonable period of
custody with each Child on the Child's birthdays every year.
7. Each party shall be afforded at least two weeks of sunmer vacation
EXHIBIT "A"
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with the O1ildren, which may be consecutive or non-con.secutive, upon
providing notice to the other party by May 1 of each year.
8. The parties acknowledge that the Children are currently
participating in counseling and agree that the Children shall remain in
their current counseling program, in which the parties may participate as
de,rood aw~.....d.ate by the Children's counselor.
9. The Father shall provide transportation for all exchanges of
custody under this Order.
lO. The parties shall keep each other advised illlllediately in the event
of serious illness or medical emergency concerning the Children and shall
further take any necessary steps to ensure that the health and well being of
the Children is protected, During such illness or medical emergency, both
parties shall have the right to visit the Children as often as he or she
desires consistent with the proper medical care of the Children.
11. Neither party shall do anything which may estrange the Children
fran the other party, injure the opinion of the Children as to the other
party, or hamper the free and natural development of the Children's love or
affection for the other party.
12. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the terms of this
Order by IllUtual, agreement. In the absence of mutual agreetudlt, the
provisions of this Order shall control.
BY THE CXXlRT,
cc: John H. Broujos, Esquire
Bradley L. Griffie, Esquire
I I ~ c!' ..J/~.IJf.
S Baro d E. Sh~y, P. .
TRUE COpy FROM RECORD
In T;s:":;;"" \,'1-. ~~nf. ! It.rr unto S;1 my hand
and lh~ ~c.:' :.' s::r;' C~J': c: Carlisle, Pa,
This J.f.:rL. day of d7n~..:.., 19.9..6.
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Prothonotary
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STEPHANIE L. RUPP,
Plaintiff
IN 1'BE CClllR1' OF calMCN PLEAS OF
: aJmERLl\ND CXlUNTY, PENNSn.VANIA
.
.
:
VB.
: NO. 95-1588
CIVIL TERM
:
MICHAEL L. RUPP,
Defendant
PRICE JDDGE: Kerin A. Bess
: CIVIL ACTIOO - LAW
:INCUS'l'ClDY
UJ:>:J.UJX ~ ~ REPCRl'
IN ACXXImI\NCE wr:m aJmBRLAlm CXXN.rY RIlLE (R CIVIL PJl(lo"" "IKIS
19l5.3-8, the undersigned CUstody Conciliator sul:lnits the following report:
l. The relevant information pertaining to the Children who are the
subjects of this litigation is as follows:
NAME
BIRTHDATE
CllRRENTLY IN CUSTODY OF
1Imie Elizabeth Rupp
Justin Michael Rupp
July 25, 1983
April 27, 1987
Plaintiff/Mother
Plaintiff/Mother
2. A Ccnciliation Conference was held on March 5, 1996, with the
following individuals in attendance: The Father, Michael L. Rupp, with his
counsel, John .B. Broujos, Esquire, and the Mother, Stephanie L. Rupp, with
. her counsel, Bradley L. Griffie, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
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Date
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Dawn S. SWlday ,y
CUstody Conciliator
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Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL L, RUPP,
DefendantlPetitioner
CIVIL ACTION - LAW
NO, 95-1588 CIVIL TERM
IN RE:
CONTEMPT
ORDER OF COURT
AND NOW, this 22nd day of November, 1999,
after hearing the Court finds that the Respondent is in
contempt of our prior order, and she is so adjudicated.
Sentence of the Court is that she undergo a period of
incarceration in the Cumberland County Prison for 30 days.
Conditions of purge are as follows:
1. That she allow the children to visit with their
father from immediately after this hearing until three hours
---
before their flight leaves tomorrow,
2. That she post the amount of $5,000.00 with the
Prothonotary to secure compliance with this order, the
current custody, and any future order of court entered by
any court of competent jurisdiction.
3. That she pay the sum of $1,000.00 to Petitioner
within 30 days to cover his attorney's fees in connection
with these proceedings.
4. That she arrange for the children, at her expense,
to visit with their father over Christmas vacation from
December 18, 1999, through December 30, 1999.
Upon the posting of said $5,000.00 with the
Prothonotary, the R~spondent shall be discharged from
custody on the condition that she comply with the other
conditions of purge.
Edward E. Guido, J.
Emily Long Hoffman, Esquire
For the Petitioner
~('J.., 11/:13/'1'1'
- ~~ ,,&.1":
Bradley L. Griffie, Esquire
For the Respondent
:lfh
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
NO, 95-1588
STEPHANIE L. RUPP,
Plaintiff/Respondent
MICHAEL L, RUPP.
Defendant/Petitioner :
CIVIL ACTION - LAW
IN DIVORCE
ORDER
, 1999, it is hereby Ordered
and Decreed that Michael L. Rupp is penniUed to conduct discovery,
AND NOW, this I f it-- day of
ocXtGc.,
BY THE COURT:
Edward E, Guido, Judge
_.
STEPHANIE L. RUPP (CORNWALL)
Plaintiff/Respondent
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
:NO, 95-1588
MICHAEL L, RUPP,
Defendant/Petitioner
:CIVIL ACTION - LAW
:IN DIVORCE
DEFENDANT'S MOTION REOUESTING DISCOVERY
AND NOW, comes Petitioner, Michael L, Rupp, by and through his attorney Emily Long
HotTman and in support of his Motion Requesting Discovery avers as follows:
1, Petitioner, Michael L. Rupp (hereinafter "Father") filed a Contempt Petition on July
20, 1999, and a hearing is scheduled for November 22, 1999 with The Honorable Edward E,
Guido,
2, Petitioner requires infonnation from the airline in order to detennine when or if the
airline tickets were canceled,
3. Petitioner desires to serve the airline with a subpoena in order to obtain the
infonnation,
4, Respondent, Stephanie L, Rupp aka Stephanie Cornwall (hereinafter "Mother") has
been contacted through her counsel Bradley L, Griffie, Esquire and they do not object to our
pursuit of discovery.
WHEREFORE, Father requests that this Honorable Court allow Father to conduct
discovery,
Date: \0 J '6ICI~
Respectfully submitted,
lrW\ % 1-\-1J\-
Emily Long Hoffinan, Esquire
Sup, Ct. ID # 66307
10S North Front Street
Harrisburg, PA 17108
(717)233-1112
Attorney for Petitioner
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CARUSL.I!:,'PIENNSVLVANIA 17013
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STEPHANIE L. (RUPP) CORJ'l/W ALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAN'D COUNTY, PENNSYL V ANlA
vs,
: CIVIL ACTION. LAW
MICHAEL L. RUPP,
Defendant
NO, 95-1588
IN DIVORCE
PLAINTIFF'S PRE-TRIAL MEMORANDUM
1. PLAINTIFF'S POSITIONI HISTORY OF CASE,
The Mother's position in this case is that both of these teenage children have had
difficulties in their extended summer time visits with their Father here in Pennsylvania. Prior to
the summer of 1998, both children attempted to reach an accommodation with their Father that
would have allowed them to reduce the period of time that they would spend in Pennsylvania,
but Father would not accommodate their request and the children were extremely displeased and
despondent over the bulk of their time spent in Pennsylvania, While Father apparently attempted
to spend periods of his vacation time with the children over the summer, this was extremely
limited when one considers the extended period of time they were here, They spent most of their
time with a babysitter,
Of course, the children are also involved in extracurricular activities at their home in
Oregon, which were atTected by their inability to take part in pre.season practices, camps, and
similar aspects of their routine life,
Then, even though the Court Order provided for the children to spend their 1999 spring
break in Pennsylvania. Father never followed up on that and the spring break simply went by
without any request on his part for the children to be here. Shortly after the spring break period,
however. the children began contacting their Father again. asking if the summer of 1999 could
include a reduced period of time rather than what is required on the Court Order, Again, Father
responded indicating that he was extremely hurt by their request and refused to accommodate in
any fashion, In fact. Father had no contact whatsoever with the children for three months in the
spring, Father simply insisted that the children would come and that was the end of the story
from his perspective,
Mother has attempted to do what she can to develop a better relationship between the
children and their Father, even though their relationship was always strained, The relationship
between the children and their Father was very limited when the children moved to Oregon with
their Mother approximately three years ago,
Mother has tried various angles to get the children to accept the current situation and visit
without the ongoing request for a reduction in their time with their Father, This has included
telling them that she could be in trouble for contempt if they did not go, suggesting that they
could be in trouble for contempt if they did not go and indicating she would accommodate their
requests by attempting to change the arrangements between now and next year and facilitating
their contact with their father in an attempt to maturely discuss some reduced period of
visitation. Despite her many attempts, nothing seems to work going into the begiMing of the
summer of 1999,
In the late spring of 1999, Mother initiated proceedings in Oregon to modify the Custody
Order as that Court now has jurisdiction of the issue of custody of the children, She advised the
children that she had done this and, by doing so, should be in a position to help them secure a
more acceptable visitation schedule for the year 2000, Unfortunately, even this effort did not
assist her in securing any cooperation from the children,
The children have expressed fear of their Father, The children have been distraught over
being forced into a totally unacceptable situation from their perspective and have been upset
over their Father's unwillingness to maturely discuss this type of issue with them and understand
their side of the story,
Mother's present husband has substantial frequent flyer miles available to him so Mother
intended to redeem some of those miles for the tickets to fly back to Pennsylvania, Beginning
approltimately one or two weeks prior to the children's leave, they indicated that they were flatly
refusing to go despite Mother and Mother's husband talking to the children about the need to go,
the fact they should maintain a relationship with their Father and similar arguments to support
their position that the children should visit, The children continued in this position until the day
when they were to leave, On that day, the parties' 16 year old daughter went to her bedroom
crying and sobbing, refusing to go to the airport with her Mother, The parties' son similarly was
sobbing and crying, begging his Mother not to literally drag him out to the car to go to the
airport, Mother's husband was not present at the time so she was unable to get his physical
assistance in somehow trying to physica\1y force the children into the car, into an airport and
onto an airplane. Under those circumstances, the children did not come to Pennsylvania which
resulted in the filing of the Petition for Contempt.
In the meantime, Father has retained legal counsel in Oregon and their ongoing
negotiations relative to a modification of the present Order, which includes a proposal that
appears to be close to being accepted where the children's time in the summer would be reduced
to one month, If that agreement is reached. then some of the issues that have been creating the
problems over the past two (2) years in the summer vacation period will have been resolved,
It is the Mother's position that she did everything within her power to force the children
to come to Pennsylvania, but, at their ages, her ability to physically force them to come is
obviously limited and, therefore, she did not take any willful action that should cause the Court
to find her in contempt. In addition. she is bringing the children to Pennsylvania for the
contempt hearing in order for them to express their position to the judge. if necessary, even
though they are already involved in the litigation in Oregon, :'vlother has advised the children
that they should expect to spend some time with their Father while they are here in Pennsylvania
over the weekdays before Thanksgiving, although the Court may need to intervene to discuss
with the children what periods of time they are willing to spend with their Father, While Mother
docs not believe the children should simply dictate when they will and will not see their Father,
she is keenly aware that essentially shoving the custody and visitation Order down their throat
over the past three (3) years has done nothing more than push them further away from their
Father in that relationship,
II. DEFENDANT WITNESSES.
A, Stephanie Cornwall will testify to the circumstances surrounding the prior visits
and the prospective visits in this case, as well as the ongoing negotiations in the pending case in
Oregon,
8, George Cornwall, who is Ms, Cornwall's husband, may be requested to testify by
telephone as to Ms, Cornwall's ongoing efforts to have the children visit with their Father, as
well as any issues related to the allegation that Mother did not take appropriate actions to secure
airline tickets for the children to come to Pennsylvania,
C, Thomas Deschler, Ph,O, is the children's counselor with whom they have
counseled relative to these issues, The counselor was secured by Mother in an effort to have
some independent voice in trying to develop some accommodation with the children for them to
be agreeable to visiting their Father,
D, Arnie Elizabeth Rupp and Justin Michael Rupp are the parties' children, Mother
will request the opportunity for the children to presenltheir position 10 the Court,
Respectfully submitted,
("
8 ad L. rim. uire
Attorney for De endant
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
l:!ID1
VALUE
(4) 22.l02 shares of
RPM, Inc. 342.58
(5) 37.717 shares of
AT&T 2,305.45
(6) ll2.476 shares of
Central Maine Power 1,630.90
(7) 2l.8l5 shares of
Templeton World Fund 343.59
(8) 32.68 shares of
Michiqan Gas 547.39
(9) l.l902 shares of
Motorola Inc. 63.08
(lO) l32.5320 shares
of Berger 10l Fund l,797.13
(ll) 222.6520 shares
of Berger Small Co.
Fund 899.5l
(l2) 8.866 shares of
of Invesco - Select
Income Fund 57.63
(l3) 8.426 shares of
Invesco - High Yield
Fund 57.72
(l4) 276.448
of Invesco -
Income Fund
shares
Industrial
3,621.47
(l5) 662.62 shares
of Invesco - Cash
Reserves
662.62
NON-MARITAL LIENS OR
DATE OF PORTION OF ENCUM-
VALUATION VALUE BRANCES
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
1DH
VALUE
(l6) ll8,607 shares
of Atmos Enerqy
Corp. 2,727.96
(l7) 52,009 shares
of Allied Group 2,067.36
(l8) l.234 shares of
Phoenix Growth Fund 3l.26
(l9) l.426 shares of
Phoenix Capital
Appreciation Fund 2l,63
(20) 2.075 shares of
Phoenix International
Fund 27.52
(2l) 2.795 shares of
Phoenix Worldwide
Opportunities Fund 26.83
(22) 32.607 shares of
AFLAC 1,018.97
(23) l.5690 shares
of Founders World-
wide Growth Fund
33.29
TOTAL VALUE -
26,052.81
B. Liquidated by
Defendant
(l) Hasland's Stock 1,6l0.63
(2) Invesco Ind.Inc, 2,954.19
4. H's 1989
Chevrolet Beretta
3,000.00
5, W's Household
Furnishings
3,000.00
NON-MARITAL LIENS OR
DATE OF PORTION OF ENCUH-
VALUATION VALUE BRANCES
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
3/29/96
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
current
N/A
N/A
current
N/A
N/A
llID1
VALUE
DATE OF
VALUATION
NON-MARITAL
PORTION OF
VALUE
LIENS OR
ENCUM-
BRANCES
6. B's AIG Life
Insurance Policy
flU860038l4
unknown
N/A
N/A
N/A
7. W's AIG Life
Insurance Policy
flU860038lS
unknown
N/A
N/A
N/A
(1) (ii) NON-MARITAL ASSETS
LIENS OR
DATE OF ENCUM-
ITEM VALUE VALUATION BRANCES
l. H's Household $3,000 Current N/A
Furnishings
(2) EXPERT WITNESSES
The Defendant has a diagnosis of Bipolar Affective Disorder. Dr.
Richard Fonte, a psychiatrist, and Cheryl Shope, a licensed
psychologist, may be called as a witnesses to testify concerning:
(1) the Defendant's diagnosis and the condition's relationship to
the Defendant's past behavioral problems and spending habits, and
(2) the proqnosis,
(3) TESTIMONY OF OTBER PERSONS
Karen Cumberledge, supervisor at LeB Comptroller's Office, may be
called as a witness. Defendant reserves the right to call others
that may be identified as being necessary at the Pre-Trial
Conference.
- -.,.......... .~-.,-..._.
~o Wife - Net proceeds from the sale of the marital residence,
household furnishings currently in wife's possession, and the sum
of $lO,BOO of the investments, which Husband will select.
~o Husband - Chevrolet Beretta automobile, investments already
liquidated by Husband, Husband's pension, and the balance of the
investments.
The above distribution scheme provides for a distribution of
approximately 55 per cent of the marital assets to Wife.
with
respect to marital debt, the only remaining marital debt is that
portion of the PSECU personal service loan and VISA account which
are still outstanding. Husband's proposal is that Wife assume 55
per cent of that debt. It is Husband's responsibility to satisfy
the remaining balance on the two outstanding PSECU accounts.
Husband also seeks claiming one of the parties' two children as an
exemption for income tax purposes.
~
Chn,st
Attorney
Broujos, Gilroy & Houston, P.C.
4 North Hanover Street
Carlisle, PA 17013
717 - 243-4574
Date:
~1t1/f~
INCOME AND EXPENSB STATEMENT OF
MICHAEL L, RUPP
SSN 176 - 46 - 5988 DR' 23,653 DATE 4/1/96
THIS STATEMENT MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of
which you are owner in whole or in part, you must also fill out
the supplemental Income Statement which appears on the last page
of this Income and Expense Statement,
INCOME
(a) Wages/Salary Commonwealth of PA
Employer & Address PLCB Comptroller's Office, HarrisburR, PA
Job Title/Description Accountant - Inventory Control Section Chief
Pay Period (weekly, bi-weekly, monthly) Bi-weekly
Gross Pay per Pay Period...........................$ 1.484.25
Payroll Deductions:
Federal Withholding,.. ,$ 224,93
Social Security"."" ,$ 113,54
Local Wage Tax, , , , , , . , ,$ 14,84
State Income Tax,..,., ,$ 41.56
Retirement."".,.".. ,$ 74,21
Health Insurance,."",$
Other (specify).,.".,,$
Unempl. Camp. ........$ .45
....... .$
Net Pay per Pay Period.............................$1.014.72
(b) other Income Week Month Year
Interest/Dividends,. ".,,$ $ $
Pension/Annuity., ,."",,$ $ $
Social Security,.".".,,$ $ $
Rents/Royalties"".",..$ $ $
Expense Account".""",$ $ $
Gifts. . . . . . . . . . . . . . . . . . . . $ $ $
Unemployment Compensation$ $ $
Workmen's compensation, ,,$ $ $
Total, Other Income. . . . . . . . . . . $ $ $
I verify that the statements in the foregoing pleading are
true and correct, I understand that false statements herein
are made subject to the penalties of 18 Pa,C,S, Section 4904
relating to unsworn falsification to authorities,
$ 80,00
$ 250.00
$ 80,00 $
$ 100.00 - BantruDtev
*to be determined-PSECU loan aeets
$ $
Total Expenses................$
*The Defendant agrees that approximately $4,400 of the PSECU debts are his
responsibility.
EXPENSES
Home Week
Mortgage/Rent...............$
Maintenance.................$
Utilities (telephone,
heating, electric, etc,),,$
Employment (transportation,
lunches) . . . . . . . . . . . . . . . . . . $
Taxes
Real Estate.................$
Personal Property.,.""",.$
Income. . . ., . . . . .. . . . . . . . . . . . $
Month
$ 300.00
$
$ 131.00
$ 155.00
Insurance
$
$
$
$
$ 65,00
$
$
56,00
Homeowners..................$
Automobile. . . . . . . . . . . . . . . . . . $
Life/Accident/Health.""",$
Other. . . . . . . . . . . . . . . . . . . . . . . $
Automobile (payments, fuel,
repairs) . . . . . . . . . . . . . . . . . . . . $
Medical
Doctor, Dentist, Ortho."..,$
Haspi tal. . . . . . . . . . . . . . . . . . . . $
Special (glasses, braces,
etc.).................... .$
$ 330,00
$ 50,00
$
$ 75.00
Education
Private, Parochial School,. ,$
College. . . . . . . . . . . . . . . . . . . . . $
Personal
Clothing. . . . . . . . . . . . . . . . . . . . $
Food. . . . . . . . . . . . . . . . . . . . . . . . $
$
$
Other (household supplies,
barber, etc.).............$
Credit payments and loans",$
Miscellaneous
Household help/child care".$
Entertainment (inc, papers,
books, vacation, pay TV,
etc.).................... .$
$ 100.00 $
$ 25,00 $
$ 150.00 $
$ 550.00 $
$ $
$2,497.00 $
Gifts/Charitable Contrib".,$
Legal Fees.................. $
Other child support/alimony
payments. . . . . . . . . . . . . . . . . . $
Other (specify),.,.."",.,.,.$
2
Year
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
fi.
..
COMMONIIEAL TH OF PENNSYLVANIA
STATE EMPLOYCS' RETIREMENT SYSTEM
STATEMENT OF ACCOUNT AS OF OECEMSER 31. 1884
(S)
Amually the Stat. ~10)"" Rellr....", Syst.. CSERSI proYtdes e.ch"..oe,. with current rettrement account '"fOrNlion whtch should
be helpful tn lItderstlndtng the benefits proyjcSed by the r.ttrll'lOnt plan and In doing financial plamtng. this statlfllent WlS
prepared using the data rlcorded In Jour rettr_nt account as 0' Ole.....,. 'I. ltt~. and is Subject to 'tnal audH br the SERS In
occ.rdanco .tth lljlpllcablo 10. ond roqulotlons, PLEASr REFER TO THE REVERSE SlOE FOR IMPORTANT
INFORMATION ABOUT YOUR STATEMENT,
PREPARED FORI M L RUPP
081-180-26200
SEO-086431
55', 176-48-5988 EMP N: 041355
Ooto .r Blrthl AUGUST 15, 1955
s..: MALE Region Code. 7
N.....l Rollr...nt Oot" AUGUST 15. 2015
Credited Service as of 12.31"-'~;
Clan Service
A 8,2636 YRS,
5612
REGUlAR
..ill
Coverage l,P4I
Contribution Kate
Final Average S.I.r1
1"4 R.ttr~t Cov.red Earntngs
551 Non-Covlred Earntngs
Jotnt Coy,rage Conversion AMount
Manda tor7 Debt
FULL
ACCOUNT BALANCE
15,00"
I $32,865.78
$33,946,81
ealance IS of 12-31-'3
I.", Acttvtt)'
Contributions
L~ SLIft P.,...,..U
Arrear, P.~ts
Adjustments.
C,.edl ted Interest $564.25
Balance as of 12-31-94 515.517.00
Ar,..ars Balance as of 12-31-9. -
.ldjustments ,.eflect ca,.,..ctlons to YOU" account about whtch YOU have been notified.
$13.255.40
$1.697.35
-----TAXABLE SREAKDOW'I OF ACCOUNT-----
.
Ta.-Deferred Contributions
Previous I, Ta.ed Contributions
Credtted 1nterest
Account aalance as of 12-31-'.
$13,295,82
$2,221.18
$15.517,00
.
Benefit esttmates are p,..~red fo" ..mbers who haYe ,..a~ Na,.mal Retirement Ave and for members who haYe at le.st 10 ,ears of
credtttd serviCe for Regullr ReUr...,.,t and at I.ast , ,ears or credtted service for Dtsabtl tt, RoU,....nt (State PoHce and
Enforcament Offlcen have no ..lni...... service requln...nt for dlsabt1tt, rettr_nt).
tr ,ou temtnate p,.ior to attatnlng e1tglbl I it, for monthl, benefits. that is prlar to beCOMing vested, you would be entitled to
recetve Jour account balanc. ..tnus any debts to the Commonwealth as of ,our date of ter.tnatlon.
BENEFIT ESTIMATES
FULL RETIREMENT - This optton pr..tdes the "'ut.... ",nthl,
benefits to 'au foro life. If ,ou dte befo,.e recetvtng ,ou,.
tatal aCCU'I'IJlated deductions, the balance will be patd to
lour beneflcl.,.,tlest.
OPTION 1 .. This option providn reduced fnOnthl)" benefits to
IOU far l,fe. .,11 IIlOf'\lnl, Uenefit. .,. ,..duced fr"lI tn.
Present Value. Art)" balance ,._inlng at )"our death wtl1 be
paid to ,our ~flclar)"(lesJ.
PRESENT VALUE - Death hneftt \n:Ier Option 1 or . death
in state ,.rvlce.
OPTION 4 - You .)" rKeive all or a portion of ,.our
accUl'lllated deductions (contrtbutions and tnterest) In . I~
SU'll ar inUal1llef\t pa)'lMl'lts Ind recetve reduced monthl,.
benefits lrde,. one of the other rettrement options. Option 4
is avattable onl, at the tillt of retirement and mar not
e.ceed ,our acc\JIIJlated deductions.
FULL RETIREMENT AD~USTED UNDER OPTION 4
OPTION 1 AD~USTED UNDER OPTION 4
AD~USTED PRESENT VALUE UNDER OPTION I WITH OPTION 4
Current as of
12-31-"
N/A
Projected to Nonnal
ReUr"""t
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
MAXIMUM DISABILITY - You IIlUst bo _tcol1, corttFlod b, SER5 $912.94
Hedical Eramtners ta be ph,stcal1, or MentallJ' incapable or
performtng J'our current Job duties. OPTION 4
WITHDRAWAL IS NOT AVAILABLE WITH A DISASILITY
RETIREMENT ,
'REFER TO CODES A THROUGH R ON THE REVERSE SIDE OF THIS FORM FOR AN EXPLANATION OF THE FOLLOWING CODES
AS THEY APPLY ~O YOUR 8ENEFIT ESTIMATES: L. 0
ADDITIONAL RETIREMENT OPTIONS ARE AVAILASLE, PLEASE TELEPHONE YOUR SERS REGIONAL RETIREMENT COUNSELOR
TOLL-FREE 11-800-633-5481) FOR QUESTIONS CONCERNING YOUR BENEFIT RIGHTS OR THIS STATEMENT OF ACCOUNT,
IMPORTANT INFORMATION ABOUT YOUR STATEMENT
KEY TO BENEFIT ESTIMATE CODES - Due to one or more of the followIng reasons, specIal condItIone appiy to yOl
bene'lt 81tlmates or the eltlmates have not been calculated:
A . You nave more than 1 active account.
B Your account has not been audited by SERS.
e You have a frozen prelont valuo.
D You have Class 0 lervlce.
E . Our records Indicate you wore compensated
F The FOP Arbitration Award Is not Included
G . Your benoflt estimates may be understated
last 5 year..
H Your retirement and death benefit estimates shown assume you will eloct to convert to full coverage.
I . Your benoflt estimates InclUde an additional benefit derived 'rom your Clals C Regular Accumulated
Deductions.
~ - Your projected estimates may be lower this year than last because your Retlremont Covered Earnings were
lower thlS year than last.
K . Your benefit estimates were calculated without tho use of any early retirement "WindoW" plans.
L . You nave inSUffiCient servtce credits to quallfv for a regular retirement benefit.
M Y~u have inSUffiCient service credits to qualify for a disabtl tty retirement benefit.
N - Yo~ have InsuffiCient earnings quarters to be used to calculate a disability retirement benefit.
o . More than ten years remain to normal retirement date.
p . You have alre~dy reached normal retirement age.
Q - This statementexcludesall P5ER5 contributions: therefo,.., the monthly ann....ttj. benoftta Dft.r an Qption
4 wlthdr'awal are overstated. In addition. State service may be overstated If In any calendar year you
have concurrent employment (contributing to P5ER5 while acttvely contributing to SERS). IF EITHER
SITUATIDN APPLIES TO YDU, CONTACT YDUR RETIREMENT CDUNSELOR PRIDR TD RETIREMENT TO RECEIVE A MDRE
ACCURATE BENEFIT ESTIMATE,
R - Your current and/or prOjected estimates are based on Age 60 retirement. since you must have 20 years of
credtted servtce as a Capitol Pol Ice Officer or Airport Poltce Officer to qualtfy for Age SO retirement.
for leSE than 1,650
in your estimates.
because you did not
hours In at least 3 or the last 5 years.
receive fUll-time credit durtng each of tho
Retirement Covered Earntnas - Includes all salary and wages (e)(cludes bonuses and cash awards) on whicl
contrlbuttons were made to your account.
Ftnal Average Salary (FAS) -The 'Inal average salary assumes: i) you contributed at least 1:! quarters: and 2
you are a full-tIme employe, IF YDU DO NDT MEET SOTH OF THESE CONDITIDNS, YDUR CORRECT FAS WILL BE CALCULATEI
_HEN YOU RETIRE,
Arrear!!: R.l!Ilznee - The balance owing to your account for which you are maktng payroll deductions for th.
purchase of service.
Mandatory Debt - The amount owing to your rettrement account about which you have been notified previously.
This debt ts to be satisfied at the ttme of your rettrement through an actuarial reduction to your pres en
value.
S51 Non-Covered Earntnqs
coverage since 01"01"56.
beneflt esttmates.
.. Earnings which exceeded the Federal Social Security base for all years of 55
These earnings were used to determine your 551 benef It and are included In you
Credited Class. of Service: A - Normal Retirement Age of 60; A.SO . Normal Rettrement Age of 50; C _ Norma
Rettrement Age of 50 as a State Police Officer or Enforcement Officer whose servtce began prior to,03.01-74
0,,3 .. Normal Retirement Age of 50 as a member of the General Assembly whose servtce began prtor to 03-01-74
E-1 .. Normal Retirement Age of 60 for members of the uUdlctary: E-2 .. Normal Retirement Age of 60 as a dtstric
justice: PSERS .. Serv1ce with the PUbliC School Employes' Retirement System: 551-60 - Normal Retirement Age o.
60: 551-50 - Normal Retirement Age of 50.
I' ~'Oll "Hive any creditable Stat9 or
information on purchasing such credit.
STATUS,
non3tate service not InclUded, SEE YOUR RETIREMEhi COUNSELOR fa'
ALL REQUESTS TO PURCHASE SERVICE MUST BE FILED WHILE IN AN ACTIVE PA'
Normal Retirement Aqe CNRA) - If you wtll achteve 35 years of credtted servtce prior to the age tndlcated abov
under Class of SerVice. your NRA becomes your age on the date you achteve 35 years of credtted service.
Normal Retirement Date - The date at whtch you will achieve NRA.
BENEFIT ESTIMATES - Assumptions used to project estimates: 1) future earnings will be the same as 1994; 2) yc
will continue 1n your present class as a full-ttme employe; 3) retirement tables and factors will remain tt
same as those tn use on 12"31.94: 4) any arrears balance wtll be paid (EXCEPTION: those members who ar
currently vestees or tn a furlough status): 5) your earnings wtll not e)(ceed the Federal Social Securi1
taxable wage base after 1994; 6) you are a full coverage member: and 7J your mandatory aebt. wtth appropria1
interest. has been actuarlally reduced from your present value.
DISABILITY RETIREMENT .. To be eltgible for a diSability retirement. you must have at least 5 years 0' credlte
serVlce (State Pollce and Enforcement Officers have no mtnlmum servtce requirement) and be medically certtfl(
by SERS Medical Examtners to be phystcally or mentally incapable of performing your current Job duttes.
Meeting these eliglbiltty requirements does not guarantee you a benefit. In order to apply for a dtsabtli'
retirement. you must be an actlve contr1buttng member of SERS or be a member in an Inactive leave without pi
status. See your Rettrement Counselor for further details.
Keep thts statement In a safe place. There ts . $5,00 charge for dupltcate statements,
In the event of y6ur death. any benefits due wtll be paid to your named beneftctarY(lcs). If you are unsuro (
whom you have deslgnated, you should update your beneflctary(1es). See your Retlroment Counselor for the
proper form.
10/11/1994 11:00
717-2495755
OBRIEII BARIC SCHEPER
RAGE 04
IT IS ORDERED THAT
1. The debtor's plan, as modified, is confirmed,
2, That as of October 1, 1995, and each month
thereafter until further order of the court, the debtor shall pay
to the trustee, Charles 3. DeHart, III, P.O, Box 410,
Hummel.town, Pennsylvania, 17036 the sum of $9,000.00 broken down
as fOllows I
A) First 12 monthly payments of $50,00 each,
B) 13-24 months payments of $100.00 each,
C) 25-36 months payments of $150.00 each;
D) 37-48 months payments of $200.00 each; and
E) 49-60 monht. payments of $250.00 each.
BY THE COURT
Dated I
.Pl1t.
~ldi
Bankruptcy Judqe
11:00
717-2495755
OBRIEtl BARIC SCHERER
PAGE 01
UNITED STATES BANKRUPTcY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
MICHAEL L. RUPP
BCY #
~
~:
CLASS 1: Priority Claims and Taxes - 100% in Plan.
CLASS 2: All Other Secured Claims. Liens to be retained, regular payments to
be made outside PIBn.
CLASS 3: Allowed Unsecured Claims - Pro rata of those filing proofs of claim.
L
First 12 monthly payments of 550,00 each
13-24 months payments of 5100.00 each
25-36 months payments of 5150.00 each
37-48 months payments of 5200.00 each
49-60 months payments of $250,00 each
Total of $9,000,00,
PLAN
PROPERTIES AND FUTURE EAR.....IINGS SVD.JECT TO THE
SUPERVISION AND CONTROL OF THE TRUSTEE;
Amount & Duration:
1. The Debtor submits to the supervision and control of the Trustee Bll
or such portion of the Debtors' future earnings or other future income
as is necessary for the execution of the Plan. including:
A. The monthly amountS which shall be paid to the Trustee from future
earnings,
B. Other property: Additional sums as necessary to fund the Plan;
10/11/1994 11:00
717-2495755
OBRIEU BARIC SCHERER
PAGE 02
DURATION: It Is proposed that payments shall be made over a period of 60
months.
CLASSIFICATION A.."iD TREAntENT OF CLAIMS:
1. Qass One. Claims Entitled to Priority under Section 507, Title 11,
United States Code, Unless other provision is made. the creditors in
Class One shall be paid prior 10 distributions to other classes, The
payments to the Trustee shall be made by deduction from each
payment made by the Debtor to the Trustee.
The Debtor will pay Class One claims in full in deferred casb
payments as follows:
A. Allowed Administrative Expenses
(1) Charles J. DeHan. Esquire standing Trustee (10% or
applicable percentage of amounts paid by debtors).
(2) Attorney's Fees. Robert L. O'Brien. Esquire, 5700.00 for
preparation of original petition and 341 hearing, and reasonable
compensation for legBl services subsequent to filing of
Statement of Financial Affairs, Schedules, and Chapter 13 Plan.
2, Class Two. Allowed Secured Claims of Creditors shall be dealt with
as follows: First and Second mortgage on residence.
PAID OUTSIDE OF PLAN
3, Class Three - Allowed Unsecured Claims not otherwise referred to in
the Plan:
Distribution to be determined after amount of priorities and creditors
to receive a pro rata share of those filing proofs of claim.
!y. EXECUTORY CONTRACTS:
1. The following executory contracts and unexpired leases are rejected:
NONE.
2. The effective date of this Plan shall be the date of entry of the order
confirming this Plan,
'1934 11:00
OBPIEII BARIC SCHERER
C' I
PAGE 1)3
:/"'. ,(, f:,
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of r"Y'P '1/.)(,/91
717<~49'57'5'5
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Hl:lrrlr;burQt"~ '
UPTCY" OURT
~So~V IA
!EP 2 1199.5
IN REI
MICHAEL LLOYD RUPP
Debtors Per
.^ Merfl'l'l'4'! A. r'n~;' . .
Cieri< cf II>Il CQr::(f~'j>>..~~NO.
De u aerlr
1-95-00772
(Chapter 13)
Social Seourity Numberl l76-46-5988
ORDER CONFIRMING PLAN
The debtor's plan filed on April 20, 1995, as modified
by an Answer to oDjection to Chapter 13 Plan filed August 9,
1995r and
It havinq been determined after hearinq on notice:
l. That the plan complies with the provisions of
Chapter l3 and with other applicable provisions of the Bankruptcy
Code r
2. That the filing fee and any other amount required
to be paid before confirmation have been paidr
3. That the plan has been proposed in qood faith and
not by any means forbidden by law,
4. That the value, as of the effective date of the
plan, of property to be distributed under the plan on account of
each unsecured claim is not less than the amount that would be
paid on such claim if the estate of the debtor were liquidated
under Chapter 7 on such date;
5. That each holder of an allowed secured claim
provided for by the plan and the holder of each secured claim
retain the lien securing such claim, and the value on the
effective date of the plan, or property to be distributed under
the plan on account of such claim is not less than the allowed
amount of such claim, and
6. The debtor will be able to make all payments under
the plan and to comply with the plan,
Ihdl<y (. (Jollie
MkheUe R. Cal\'c11
Anne M. Shcp.vd
Tbamu S. Diehl
GRIFFIE & ASSOCIATES
Attorneys Ilnd Counselors At Lllw
200 North llano\'<!' SlICd
Clfliale, PA 17013
(717) 243.''''
1(100) 347."'2
FAX 717.243.'063
Robin J. ooohom
om<< Mana....
January 7, 1997
Clwnhcnbura Tnulllulldinl
Suite "0, 14 North Main SlICd
Ch.vnbcnbutJ, PA 17201
(717) 267.13'0
Reply 10: CatliaI.
The Honorable Harold E, Sheely
Judges' Chambers
One Courthouse Square
Carlisle
Dear Judge Shee y:
This will confirm the telephone message I left with your office indicating that the
Rupp matter which was scheduled for a custody hearing with you on Wednesday morning,
January 8, 1997 has been settled. In fact a Custody Stipulation and Agreement has
already been signed by both the parties, witnessed by counsel, and submitted to the Court.
Therefore, the hearing can be canceled accordingly.
Your attention and consideration in this matter is appreciated.
Very truly yours,
GRIFFIE & ASSOCIATES
\ "~I I . /
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Bradley L. Griffie
BLG/lam
J:>/A C~
cc: Christopher C. Houston, Esquire
Stephanie L. Rupp
.
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'I'1r' '!!lfjtY
STEPHANIE L. RUPP, . IN THE COURT OF CXX>IMOO PLEAS OF
.
Plaintiff . CUMBERLAND CXlUNTl/', PENNSYLVANIA
.
.
.
vs. . NO. 95-l588 CIVIL TERM
.
.
.
MICHAEL L. RUPP, .
.
Defendant . IN CUSTODY
.
aIDER OI!' CXlURT
AND lDf, this 4th day of Decel!tler, 1996, the COnciliator being
advised by counsel for both parties that all custody matters have been
resolved by agreement of the parties, hereby relinquishes jurisdiction in
this case.
~"i..~
CUstody Conciliator
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I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C,S.
Section 4904, relating to unsworn fBlsificalion to authorities.
DATE: ? PIIi'5'
I
I'. . ~ /J . /J
~L{fZj4~/.' /(m~~e-
STE ANIE ~ ORNW ALL
.: ;00.
STEPHANIE L. RUPP,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL L. RUPP,
Defendant/Petitioner
CIVIL ACTION - LAW
NO, 95-1588 CIVIL TERM
IN'RE:
CONTEMPT
ORDER OF COURT
AND NOW, this 22nd day of November, 1999,
after hearing the Court finds that the Respondent is in
contempt of our prior order, and she is so adjudi~ated.
Sentence of the Court is that she undergo a period of
incarceration in the Cumberland County Prison for 30 days.
Conditions of purge are as follows:
1. That she allow the children to visit with their
father from immediately after this hearing until three hours
before their flight leaves tomorrow.
2. That she post the amount of $5,000,00 with the
Prothonotary to secure compliance with this order, the
current custody, and any future order of court entered by
any court of competent jurisdiction,
3, That she pay the sum of $1,000.00 to Petitioner
within 30 days to cover his attorney's fees in connection
with these proceedings,
4. That she arrange for the children, at her expense,
to visit with their father over Christmas vacation from
December 18, 1999, through December 30, 1999.
Exhibit "A"
~.
Upon the posting of said $5,000.00 with the
Prothonotary, the Respondent shall be discharged from
custody on the condition that she comply with the other
conditions of purge.
Edward E. Guido, J.
Emily Long Hoffman, Esquire
For the Petitioner
adley L. Griffie, Esquire
Fo the Respondent
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,
STEPHANIE L. (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
: NO, 95-1588 CIVIL TERM
: IN CONTEMPT
ORDER OF COURT
AND NOW, this ~}" dBY of N ~
, 2005, upon
presentation and consideration of the within Petition, the Rule previously entered in this
matter is hereby made absolute. The Prothonotary's Office of Cumberland County is
ordered and directed to release the sum of FIVE THOUSAND AND XX1100 ($5,000.00)
DOLLARS that was posted by Petitioner, Stephanie L. 0 her
B THE COURT,
~
EDWARD E, GUIDO, Judge
"
STEPHANIE L, (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
"
1:
MICHAEL L. RUPP,
Defendant
: NO, 95-1588 CIVIL TERM
: IN CONTEMPT
I.
i,
PETITION TO MAKE RULE ABSOLUTE
,
,
I
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AND NOW, comes Petitioner, Stephanie L. (Rupp) Cornwall, by and through her
counsel of record, Bradley L, Griffie, Esquire, and the law finn of Griffie & Associates
and petitions the Court as follows:
1. Your Petitioner filed B Petition for the Release of Posted Funds on or about
September 22, 2005, which resulted in the issuance of an Order of Court and Rule
to Show Cause dated September 27, 2005, a copy of said Order and Rule to Show
Cause, as well as the Petition for the Release of Funds being attached hereto and
incorporated herein by reference as Exhibit "A",
2. Service was made on the Respondent, Michael L. Rupp, by certified mail on
October 12, 2005 as per the certified mail receipt card attached hereto and
incorporated herein by reference as Exhibit "B",
3, Twenty dBYS have passed since service of the Order of Court and Rule to Show
Cause.
4, Respondent has not filed an Answer to the Rule,
5, Pursuant to the tenns of the Order of Court and Rule, as an Answer was not filed,
an Order will be issued releasing the posted funds in this matter to Petitioner,
WHEREFORE, Petitioner requests your Honorable Court to enter an Order
making the prior Rule absolute and, further, ordering the Cumberland County
. ~ .1 ...
Prothonotary's Office to release the sum of $5,000.00 previously posted by Petitioner in
this matter to the Petitioner.
Respectfully submitted,
Y L,9 Ie, Esquire
ttomey for Petitioner
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa,C.S.
Section 4904, relating to unsworn falsification to authorities,
DATE:-1 ( I, ~I ()~
I .
STEPHANIE L, (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY , PENNSYLVANIA
vs,
: CIVIL ACTION - LAW
MICHAEL 1. RUPP,
DefendWlt
: NO, 95-1588 CIVIL TERM
: IN CONTEMPT
ORDER OF COURT AND RULE TO SHOW CAUSE
AND NOW, this ~ day of ~ fk 41' ~. r ,2005, upon presentation
Wld consideration of the within Petition, a Rule is hereby issued upon DefendWlt, Michael
L, Rupp, to show cause, if Wly he has, as to why the relief requested should not be
granted, The Rule is returnable by DefendWlt filing Wl Answer within twenty (20) days
of service by fIrst class mail, postage prepaid upon DefendWlt at his last known address,
If Wl Answer is not fIled, the Court will issue Wl Order releasing the $5,000,00 sum thBt
was posted 'With the Prothonotary's office to secure compliWlce with the prior Orders in
this case,
BY THE COURT,
/5> {f;j<.t-"J C 8(,: J ~
Edward E, Guido, Judge v .
I RUE COpy FROM RECORD
'n T llIt>>ItOny wnereot, I hare unto set "'Y hIn<l
c'md the seal 01 said Coo IlL (
Thi .:J ,~
Exhibit "A"
6. At the time of entry of the Order, the parties' children visited with their
father from after the hearing until three (3) hours before their flight left for
them to return to their former home state of Oregon.
7. Petitioner paid the sum of $1,000.00 toward the Respondent's attorney's
fees.
8. The children visited Respondent from December 18, 1999 through December
30, 1999 at Petitioner's expense.
9. The children are now over 18 years of age and have graduated from high
school such that the parties and the children are no longer subject to the
Order of Court on custody at issue in this case.
10. Both children maintain a relationship with both parties.
II. There is no basis or reason to retain the $5,000.00 deposited with the
Cumberland County Prothonotary's Office by Petitioner in this matter.
12. Petitioner is in contact v.ith Respondent and has made him aware of filing
this Petition, to which he has indicated he has no opposition.
WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the
Respondent to show cause, if any he has, as to why the relief requested in the return of
the $5,000.00 deposited to the Cumberland County Prothonotary's Office should not be
ordered.
L. . ffie, Esquire
ttorney for Petitioner
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
Upon che posting of said $5,000.00 with the
?rothonocary, che Respondenc shall be discharged from
custody on the condicion that she comply with the other
conditions of purge.
Edward E. Guido, J.
Emily Long Hoffman, Esqui=e
For the Petitioner
L. Grif=ie, Esqui=e
Responde~t
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Distribution
Cumberland County Prothonotary's Office
Manual Release Check Reg~ster
Escrow
Case No Accounting Amount
Pag~ 1
11/30/2005
Tran Date
Date Release
09272811302005
PYS405
--------------------------------------------------------------------------------
3884
BOND
BOND
BOND
BOND
CORNWALL STEPHANIE L
1995- 01588
1995- 01588
1995- 01588
1995- 01588
Check Date:
PYMT/CHECK
TRNS ESC OUT
TRNS ESC IN
TRNS ESC OUT
Payee total:
11/30/2005
5000.00
4920.30-
4920.30
79.70-
4920.30
Check No. :
ll/.22/.Z1999
llZ29 2005
llZ29Z2005
lln9n005
1559
--------------------------------------------------------------------------------
Grand total:
4,920.30
STEPHANffi 1. (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
MICHAEL 1. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
PETITION FOR RELEASE OF POSTED FUNDS
AND NOW, comes Petitioner, Stephanie 1. (Rupp) Cornwall, by and through her
counsel, Bradley 1. Griffie, Esquire and the law fInn of Griffie & Associates, and
petitions the Court as follows:
1. Your Petitioner, Stephanie 1. (Rupp) Cornwall, is the above named Plaintiff
and an adult individual currently residing at 4236 Carlisle Road, Gardners,
Cumberland County, Pennsylvania.
2. Your Respondent, Michael L. Rupp, is the above named Defendant, and an
adult individual currently residing at RR 2, Box 184A-8, Thompsontown,
Pennsylvania
3. The parties are subject to an Order of Court dated November 22, 1999, a
copy of which is attached hereto and incorporated herein by reference as
Exhibit "A".
4. Petitioner, who was the Respondent in the reference contempt action, has
complied with each and every provision of the Court's Order of November
22,1999.
5. At the time of the entry of the Order, Petitioner posted the sum of $5,000.00
with the Cumberland County Prothonotary's Office pursuant to the direction
of the Court in the aforesaid Order.
6. At the time of entry of the Order, the parties' children visited with their
father from after the hearing until three (3) hours before their flight left for
them to return to their former home state of Oregon.
7. Petitioner paid the sum of $1,000.00 toward the Respondent's attorney's
fees.
8. The children visited Respondent from December 18, 1999 through December
30, 1999 at Petitioner's expense.
9. The children are now over 18 years of age and have graduated from high
school such that the parties and the children are no longer subject to the
Order of Court on custody at issue in this case.
10. Both children maintain a relationship with both parties.
11. There is no basis or reason to retain the $5,000.00 deposited with the
Cumberland County Prothonotary's Office by Petitioner in this matter.
12. Petitioner is in contact with Respondent and has made him aware of filing
this Petition, to which he has indicated he has no opposition.
WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the
Respondent to show cause, if any he has, as to why the relief requested in the return of
the $5,000.00 deposited to the Cumberland County Prothonotary's Office should not be
ordered.
r;
1. <;Jrlffie, Esquire
ttorney for Petitioner
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE: 9/clI/l;s
I J
~,~
. E IE t: ORNWALL .
.., ~ ~
STEPHANIE L. RUPP,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL L. RUPP,
Defendant/Petitioner
CIVIL ACTION - LAW
NO. 95-1588 CIVIL TERM
IN RE:
CONTEMPT
ORDER OF COURT
AND NOW, this 22nd day of November, 1999,
after hearing the Court finds that the Respondent is in
contempt of our prior order, and she is so adjudicated.
Sentence of the Court is that she undergo a period of
incarceration in the Cumberland County Prison for 30 days.
Conditions of purge are as follows:
1. That she allow the children to visit with their
father from immediately after this hearing until three hours
before their flight leaves tomorrow.
2. That she post the amount of $5,000.00 with the
Prothonotary to secure compliance with this order, the
current custody, and any future order of court entered by
any court of competent jurisdiction.
3. That she pay the sum of $1,000.00 to petitioner
within 30 days to cover his attorney's fees in connection
with these proceedings.
4. That she arrange for the children, at her expense,
to visit with their father over Christmas vacation from
December 18, 1999, through December 30, 1999.
Exhibit "A"
Upon the posting of said $5,000.00 with the
Prothonotary, the Respondent shall be discharged from
custody on the condition that she comply with the other
conditions of purge.
Edward E. Guido, J.
Emily Long Hoffman, Esquire
For the Petitioner
L. Griffie, Esquire
Respondent
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STEPHANIE L. (RUPP)
CORNWALL,
Plaintiff
RECEIVED 5EP 26 ZOOS ~f
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
ORDER OF COURT AND RULE TO SHOW CAUSE
AND NOW, this ~ 7'" day of ~ ' 2005, upon presentation
and consideration of the within Petition, a Rule is hereby issued upon Defendant, Michael
L. Rupp, to show cause, if any he has, as to why the relief requested should not be
granted. The Ru1e is returnable by Defendant filing an Answer within twenty (20) days
of service by first class mail, postage prepaid upon Defendant at his last known address.
If an Answer is not filed, the Court will issue an Order releasing the $5,000.00 sum that
was posted with the Prothonotary's office to secure compliance with the prior Orders in
this case.
Edward E. Guido, Judge
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STEPHANIE 1. (RUPP)
CORNWALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
MICHAEL 1. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes Petitioner, Stephanie 1. (Rupp) Cornwall, by and through her
counsel of record, Bradley 1. Griffie, Esquire, and the law firm of Griffie & Associates
and petitions the Court as follows:
I. Your Petitioner filed a Petition for the Release of Posted Funds on or about
September 22, 2005, which resulted in the issuance of an Order of Court and Rule
to Show Cause dated September 27,2005, a copy of said Order and Rule to Show
Cause, as well as the Petition for the Release of Funds being attached hereto and
incorporated herein by reference as Exhibit "A".
2. Service was made on the Respondent, Michael 1. Rupp, by certified mail on
October 12, 2005 as per the certified mail receipt card attached hereto and
incorporated herein by reference as Exhibit "B".
3. Twenty days have passed since service of the Order of Court and Rule to Show
Cause.
4. Respondent has not filed an Answer to the RuIe.
5. Pursuant to the terms of the Order of Court and Rule, as an Answer was not filed,
an Order will be issued releasing the posted funds in this matter to Petitioner.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order
making the prior Rule absolute and, further, ordering the Cumberland County
Prothonotary's Office to release the sum of $5,000.00 previously posted by Petitioner in
this matter to the Petitioner.
Respectfully submitted,
y L. ffie, Esquire
ttorney or Petitioner
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE: II I, ~ I ():)
I '
STEPHANIE 1. (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: CIVIL ACTION - LA W
MICHAEL 1. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
ORDER OF COURT AND RULE TO SHOW CAUSE
AND NOW, this ;. 7 .~ day of ~ f~ 41'~' r ,2005, upon presentation
and consideration of the within Petition, a Rule is hereby issued upon Defendant, Michael
1. Rupp, to show cause, if any he has, as to why the relief requested should not be
granted. The Rule is returnable by Defendant filing an Answer within twenty (20) days
of service by first class mail, postage prepaid upon Defendant at his last known address.
If an Answer is not filed, the Court will issue an Order releasing the $5,000.00 sum that
was posted with the Prothonotary's office to secure compliance with the prior Orders in
this case.
BY THE COURT,
(~I L/A-t;.J C8{~ ~
Edward E. Guido, Judge ~ ,
r RUE COpy FROM RECORD
10 T estiPIony wnereof, I rtsre unto set "'Y iIaI",o
<100 the seal of said Coo Fa.
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Exhibit "A"
STEPHANIE L. (RUPP)
CORNWALL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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vs.
CIVIL ACTION - LAW
L
'.
M]CHAEL L. RUPP,
Defendant
: NO. 95-]588 CIVIL TERM
: IN CONTEMPT
PETITION FOR RELEASE OF POSTED FUNDS
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AND NOW, comes Petitioner, Stephanie L. (Rupp) Cornwall, by and through her
counsel, Bradley L. Griffie, Esquire and the law firm of Griffie & Associates, and
petitions the Court as follows:
]. Your Petitioner, Stephanie L. (Rupp) Cornwall, is the above named Plaintiff
and an adult individual currently residing at 4236 Carlisle Road, Gardners,
Cumberland County, Pennsylvania.
2. Your Respondent, Michael L. Rupp, is the above named Defendant, and an
adult individual currently residing at RR 2, Box 184A-8, Thompsontown,
Pennsylvania.
3. The parties are subject to an Order of Court dated November 22, 1999, a
copy of which is attached hereto and incorporated herein by reference as
Exhibit "A".
4. Petitioner, who was the Respondent in the reference contempt action, has
complied with each and every provision of the Court's Order of November
22,1999.
5. At the time of the entry of the Order, Petitioner posted the sum of $5,000.00
with the Cumberland County Prothonotary's Office pursuant to the direction
of the Court in the aforesaid Order.
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6. At the time of entry of the Order, the parties' children visited with their
father from after the hearing until three (3) hours before their flight left for
them to return to their former home state of Oregon.
7. Petitioner paid the sum of $1,000.00 toward the Respondent's attorney's
fees.
8. The children visited Respondent from December 18, 1999 through December
30,1999 at Petitioner's expense.
9. The children are now over 18 years of age and have graduated from high
school such that the parties and the children are no longer subj ect to the
Order of Court on custody at issue in this case.
10. Both children maintain a relationship with both parties.
11. There is no basis or reason to retain the $5,000.00 deposited with the
Cumberland County Prothonotary's Office by Petitioner in this matter.
12. Petitioner is in contact with Respondent and has made him aware of filing
this Petition, to which he has indicated he has no opposition.
WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the
Respondent to show cause, if any he has, as to why the relief requested in the return of
the $5,000.00 deposited to the Cumberland County Prothonotary's Office should not be
ordered.
s ctfully submitted,
L. ffie,Esqurre
ttorney for Petitioner
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE:
'7 /~ /
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NIE E. CORNWALL
.'
STEPF~IE L. RUPP,
Plaintiff/Respondent
IN THE COURT OF CO~ON PLEAS OF
CUMBERLP_~ COUNTY, PENNSYLVANIA
V.
MICILIillL L. RUPP,
Defendant/Petitioner
CIVIL ACTION - L~W
NO. 95-1588 CIVIL TEP~
IN RE:
CONTEMPT
ORDER OF COURT
.l\ND NOW, this 22nd day of November, 1999,
a=ter hearing the Court finds that the Respondent is in
c:mtempt of our prior order, and she is so adj u.dicated.
Sentence of the Cou.rt is that she undergo a period of
incarceration in the Cumberland County Frison for 30 days.
Conditions of purge are as follows:
1. That she allow the chi.ldren to v"isi t with their
father from immediatelyaf~er this hearing until three hours
before their flight leaves tomorrow.
2. That she post the amoun~ of $5,000.00 with the
Prothonotary to secure compliance with this orde~f the
current custody, and a~y future order of court entered bv
any court of competent jurisdiction.
3. That she pay the sum of $1,000.00 to petitioner
within 30 days to cover his attorney's fees in coru,ection
with these proceedings.
4. That she arrange for the children, at her expense,
to visit with their father over Christmas vacation from
December 18, 1999, through December 30, 1999.
Exhibit "A"
Upon the pos~ing of said $5,000.00 with the
?rothonotary, the Respondent shall be discharged from
custody on the condition that she comply with the other
conditions of purge.
By
Edward E. Guido, J.
Emily Long Hoffman, Esquire
For the Petit~oner
L. Griffie, Esquire
Respondent
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. prtnt your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
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STEPHANIE L. (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
MICHAEL L. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
AND NOW,
ORDER OF COURT
this ; 3&4 day of N ~
, 2005, upon
presentation and consideration of the within Petition, the Rule previously entered in this
matter is hereby made absolute. The Prothonotary's Office of Cumberland County is
ordered and directed to release the sum of FIVE THOUSAND AND XX/100 ($5,000,00)
DOLLARS that was posted by Petitioner, Stephanie L.~o her
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Distribution
Cumberland County prothonotary's Office
Manual Release Check Reglster
Escrow
Amount
Page 1
11/30/2005
09272811302005
PYS405
Case No
Accounting
Tran
Date
Date
Release
3884 CORNWALL STEPHANIE L Check Date: 11/30/2005 Check No. : 1559
BOND 1995- 01588 PYMT/CHECK 5000,00 11/22/1999
BOND 1995- 01588 TRNS ESC OUT 4920.30- 11/29/2005
BOND 1995- 01588 TRNS ESC IN 4920,30 11/29/2005
BOND 1995, 01588 TRNS ESC OUT 79.70- 11/29/2005
Payee total: 4920.30
--------------------------------------------------------------------------------
Grand total:
4,920.30
RECEIPT FOR TRANSFER
--------------------
--------------------
Cumberland County Prothonotary's Office
Carlisle, Pa 17013
RUPP STEPHANIE L
14 EAST OAKWOOD DRIVE
CARLISLE, PA 17013
Case Number 1995-01588
Remarks
POUNDAGE BOND SPLIT
Receipt
Receipt
Receipt
Date 11/29/2005
Time
No.
14:04:08
171395
Transaction
",,------------------ Distribution Of Adjustment ,-----,,-------,"'-----'--
BOND
BOND
BOND
BOND
Payee
CORNWALL STEPHANIE L
CORNWALL STEPHANIE L
CORNWALL STEPHANIE L
CUMBERLAND CO GENERAL FUND
This Adj
4,920.30'
4,920.30
79,70-
79.70
NOV 222005 ,!,,'
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STEPHANIE 1. (RUPP)
CORNWALL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
MICHAEL 1. RUPP,
Defendant
: NO. 95-1588 CIVIL TERM
: IN CONTEMPT
AND NOW,
ORDER OF COURT
this ') )&4 day of N ~
, 2005, upon
presentation and consideration of the within Petition, the Rule previously entered in this
matter is hereby made absolute, The Prothonotary's Office of Cumberland County is
ordered and directed to release the sum of FIVE THOUSAND AND XX/lOO ($5,000,00)
DOLLARS that was posted by Petitioner, StePhan, ie 1.~(,o her
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B(TH~C~URT:/r
-~~~
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EDWARD E, GUIDO, Judge
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