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Home My WebLink About96-00586 . ~ ~ I -E Q) 4: . 1 71 I ~ ....." /' ( f 'J , , ~ ()O' \ L.()' I .~ : 0- .' 0" "Z' d:\pn:II)'11lan\n:llcr.pcl file' .V]3-VS-01 . MICHAEL R. PRETTYMAN, PlaIntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO: 96-586 CIVIL TERM CIVIL ACTION - LAW CHRISTINA G. PRETTYMAN, Defendant AND NOW, this ~), da, Of-4l'vI' / the within Petition, a Rule Is Issued upon Respondent to show cause why the relief requested , 1996, upon consideration of should not be granted. RULE returnable at a hearing set for the ~C)tt:. day of 1996 in Court Room .s of the Courthouse at Carlisle, Pennsylvania, (l PENDING the hearing, Respondent is ordered not to spend, dissipate, or alienate any marital property including any payment received from any employment as severance pay without the express written permission of the Petitioner, and from canceling, borrowing against or changing the beneficiary of any life insurance policy in existence on the date of this Order. By the Court, J, " ....c.' !''''', ,..,...: ,~ , ': ., l I ( : ,'t..) " . - , / , j:" 'I} ; I.... i. '...I~ Il-""J' ", ,,; ,.,', ... " -', i......., :, ..~ " J/.~,ft/6J.(~ f::V!1\- t; (2,~ ~~~ \ ~ "J(.~ ~ 4 /~ff , d:\pRII)1lNIn\Rllcr,pcl m., 49J3.9~1I , MICHAEL R. PREnYMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 96.586 CIVIL TERM v. CHRISTINA G. PREnYMAN, Defendant CIVIL ACTION - LAW AND NOW, comes Christina G, Prettyman, Defendant above, by and through her counsel, Flower, Morgenthal, Flower & Undsay, and petitions this Honorable Court as follows: 1. Petitioner is Christina G. Prettyman who resides in the marital home at 546 Appalachian Avenue, Mechanicsburg, Pennsylvania with the parties' child. 2. Respondent is Michael R. Prettyman, who resides at 126 West Portland Street, Apartment 11, Mechanicsburg, Pennsylvania. 3. The parties are husband and wife, having been joined in marriage on June 7, 1975. 4. The parties separated on or about October 13, 1995 when Respondent left the marital home. 5, The parties are parents of a daughter, Megan Christine Prettyman, born March 8, 1990. Megan was adopted as an infant and since her adoption, Petitioner has not been employed outside the home. 6, Subsequent to separation on or about November 6, 1995, Respondent advised Petitioner that he was intending to liquidate the parties' Series EE Bonds to payoff certain marital debt. l':r:'. d:\p..II,....n\..ller,pcl nle I 49>>-95.01 . 7. In fact, without consulting or obtaining the permission 01 Petitioner, Respondent took control over all of the liquid assets or those assets that could easily be liquidated, approximately $38,000.00, and applied some of them to reduce debt. Included in the assets liquidated was a . New York Ute life Insurance policy which Petitioner believes Insured Respondent with Petitioner as beneficiary. 8. For 13 years prior to February 28, 1996, Respondent was the President and CEO of Members FIrst Credit Union from which Job he was terminated. 9. As part of a severance package, Respondent has demanded certain assets, A copy of his letter of demand Is attached hereto as Exhibit "A". Respondent demands the contents 01 the Thrift Savings Account, approximately $29,600,00 and severance in the amount of 4 weeks for every one of his 13 years of service or approximately one year's salary. In 1995, Respondent had a gross annual income of $166,572.00. 10. The parties are owners of other assets which are In the control of Petitioner or over which Petitioner could easily exercise control. These include a Certificate of Deposit which comes due soon and IRA accounts, 11. Petitioner does not seek to deprive Respondent of amounts reasonably necessary for the support of the parties and their child, but she objects to Respondent's exercising sole control over the disposition of these assets, 12. The parties have certain life in3urance policies, one of which, the New York Ufe Insurance Policy, was cashed in by Respondent in November, 1995. Petitioner seeks a court order 2 d:\rn:II)1l1..\n:u.r....' fiI. I .'IJ)'9$~J1 . which would prohibit him from failing to make the payments, canceling or withdrawing the cash value of any other life Insurance policy and prohibiting him, pending equitable distribution, from removing Petitioner as the beneficiary of any such policies, WHEREFORE, Petitioner prays this Honorable Court to Issue a temporary order of non. dissipation and, after a hearing, to enter an order prohibiting Respondent from spending, dissipating, or otherwise alienating any asset received as a part of his severance package, from liquidating or borrowing against any Insurance policy on his life or changing the beneficiary of any such policy, and from alienating, dissipating or liquidating any asset without the written consent of Petitioner. FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Defendant By: l , ~ ~>~ r'.."") , c'~ I . 1,l,I! C" ,~ I c.....; . [I' .'-" :~j (,:;,r , ':,J ;.) t:.~ ' ('" " u". ..... L:' t.-- '::J , I' . i) I t...' .... . '__J . ._~'..".,.:"".,'"' ~,.C>J . . , . ' EXHIBIT "A" , , ! l ~rom ~11'Sllr.VI~o 71~-637-e695 ~ No, : ~17 637 OG35 Mtr,a; 19% 12:Q6F'f1 PQ2 . , ' MICHUL a. nIl'H'YMM 1:UI-" Wut Pottlllna Btnet HechanicDbucg, ~A 170~~ Phone (717) fi97'6'~3 Hatch 4, 1996 Shawn D. Lochinger, Esquire Rhoael, (, Sinon One South Ha~k.e SQuate Hacci,burg, PA 17101 Dear Hr. LochinGer: r am in receipt of Herbert C. Fenotormachar'o termination lottcr ot FObruary 20. 1996. In ceeponee to that letter, and basad on tho rep....ntation. ..t forth therein. : am enc108ing herewith my letter of resignation as President and CEO of Members 1st ~ederal credit Union, This letter ot resignatIon is belng submitted under the condition that it will not affect any entitlement to unemployment compensation benefits and that there will not be any eontest by Hembers 1st to such benefits. except as may appropriately arise out of any severance package negotiated hereafter. As provided. this correspondenee, as requested. will also serve to inform you of the vested "entitlements. that I believe a:e due me. These would include the tOllowingl l. 1 week's salary from 2/24/96 to 2/29/96. 2. 415,5 hours of earned. accrued and unused vacation time. 3, 14' bonus for the period from 4/1/95 to 2/29/96. The 14' figure is the average bonus earned over the past 5 years, although currently I believe a 20\ bonua is appropriate. 4. All vested rights in retirement plans and other deferred eompensation plans. I have had a highly successful 13 1/2 year tenure with Members 1st Federal Credit Union. I am proud to say that I played a role in the many successes that ehe c.edit union has enjoyed over the years. resulting in it b~ing in Blteellent condition. uuring this time the Board et ~lrectorg has reeognized my achievements with above averag~ and out8tanding performance evaluations and has been more than tair in ~._ ..... I ~rco' 1ll1'Star'.\!ldr.> 717-6,7-E1S95 PtOlE No. 717 697 9695 I"~r. Ob 1996 IOl:0""l1 1'01 . , ' COlllptlllfoatior. illlues. In thio opidt r would like to ~n'nrm you that I would considllr Lhe following a "fair" sevorance pac:ka\llll 1, payment of the -entitlements" .et forth IIhlwlt. a. No conte.t to unemployment compenuation benefits exr.llpt IUI IIIAY be appropdau ill l.Ll/ht of receipt of! the RAverance packaqe. 3. Ono ~ntha .alary for each year of R9rvice. 4. Continued health plan benefits for a IIIlIximllm IlRriod of 1 yea: ox until completo he.lth care eoverAO. ill olJLaillCld through other tlUlployment it that occur!! sooner. Should the new employment coverage not inc:lud6 coveragu rUt preoxisting conditiono. MemberR 1St coverage would continue until such preexisting conditions are covered or until the one year period has elapsed. s. Payout of 50\ of all aeeumulated sick leave. to whieh I would have been entitled but for this terminauon/resignation. in rec:uYllition of IllY superior attendance record and pruuellL use of sick leave over the 13 1/2 year period. 6. A program of !Xecutive Outplacement. 7. A letter of rehunce and expungmenc fu.nn my personnel file of any negative sCatement8 ~ertaining to my performance loading to the termination/resignation and assurances of confidentiality as to this termination/resignation lind Lh.. reasons theroforo. With respeet to the eomponent 7 of the proposed severance pac:l<&ge, plasse note thAt I dUll most concerned that the :eco~nendationB made by the supervisory committee to the Board ~! Directors may have included statements pertaining to my performance which were untrue, unwarxanted and perhaps defamatory, Provided that a xeasonable settlement package can be arrived at, I have no desire to oxeate any public relations ploblems for the credit union by defending my professional reputation through costly, protracted and negative litigation. therefore request that you submit my proposal fox a severance package to the Board of Directors for due eonsideration, In return fox a fnix package being agxeed upon. I will execute a release in favor of the credit union waiving all present and future tights chat may be present or may arise as a resu1t of my employment and to resign my seat on the Membor's 1st Board of Directors . - ... rrom : AII.s~r.Uld.o 717-6$7-9695 FHCtE tlo, 717 697 8695 ~r,06 19'* 1~:00'M PO. . , ' If you require any ~ddltional information or olarification o~ any of tilt! matteu set torth herein, pleaDe do not hellitate to COntact me dirtlctly by telephone at (717) 69"6'53 or by mail at tht 'C1llnwln;r H1chft.l R. Prettyman 12~'11 W. Poztland Street HechanicsbuT9' PA 17055 I will look forw~rd to a favorable and early reply to thi~ PIOPOSal IIU that this IMtter can be put bohind ue and have all pAIties moVtt tOlwucl, 1 wieh nothing but tho beat for Member '. lot Federal CrAdit Union. Very truly yours. t\..J~' "\L- ~J.V, MichAel R. PrAttyman - _.-'-r- .:) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL R. PRETTYMAN, Plaintiff V. CHRISTINA G. PRETTYMAN, Defendant . ; NO. 9&-586 CIVIL TERM . . : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WITHDRAW OF ECONOMIC CLAIMS AND TERMINATION OF ACTION TO THE PROTHONOTARY OF THE SAID COURT: Please withdraw any and all economic claims heretofore raised by either party in the above captioned matter and mark this action terminated and withdrawn. Respectfully submitted, t DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 1717} 737-ll1DD >- co ~ ~<;; . ~ .. ~5J-- UJ':-) - .r:');.!j '_"I ( - "..-.. r,: :,. A.": -'~. ~ t_ ' ' . j;::J ~~~- ,~ jL_ M :;', ~~~ LJ..!L- ,-. i}:ll W "i~ W f;:i v: u- ". OJ ;:; 0 0' U ~ :1 I ,J r-i ! .' ~" :: ~~~ t.; ~ . '-^ \/'t' ~ ......, ~.~ r- - 0.':" ('~ r. tIL . "I~ 1 u" r I'::! ." C):,. (" . U.l'." , r- r.~ l/'J .. , C' I , . < I -- , '. .' ....: . ~.I '. I . : : " 'i,j ~'... .~.. L._ :..5 ,.., V, U u;' ~ ,-- '<, '-' €) '- ,- \.- ~..! u ~3]~ ~ ~.1l~ (j~~~ ~~i! ~ MICHAEL R. PRETTYMAN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, . : NO. {}r., - .,'J" Ct~,:.f. ~-,- CHRISTINA G. PRETTYMAN Defendant : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT,lfyouwlshto defend against the claims set forth in the following pages, you must take prompt action. You are wamed that If you fall to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A Judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights Important to you, including custody or visitation of your children, When the ground for divorce is Indignities or Irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors Is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. DIANE G. RADCLIFF ATfORNEY.AT.LAW ,..1 TRINUI.f: ROAIJ CAMP 1111.1., fA nOli COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240.62~RUE COpy F OM RECORD In Testimony w here unto sat my hand 1 ",00 the seal of sat ourt at Carlisle, Pa. I hi!! day tl , 19 Prothonotary MICHAEL R. PRETTYMAN Pial ntlff vs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. tj(.. ~Tt, r2......J u-- CHRISTINA G. PRETTYMAN Defendant : CIVIL ACTION. LAW COMPLAINT AND NOW, thi6?t:c:L day of :t:l<:npnA~(, 1~, comes the Plaintiff, MICHAEL R. PRETTYMAN, by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following Is a statement: COUNT I: DIVORCE 1. The Plaintiff, MICHAEL R. PRETTYMAN, is an adult Individual residing at 126 West Portland Street, Apartment 11, Mechanicsburg, Pennsylvania, since December 1, 1995, 2. The Defendant, CHRISTINA G, PRETTYMAN, is an adult individual residing at 546 Appalachian Avenue, Mechanicsburg, Pennsylvania, since 19B7, 3, Plaintiff and/or Defendant have been bona fide residents of the Commonweelth for at leest six (6) months previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on June 7, 1975 In West Virginia. DIANE G. RADCLIFF ATTORNEY.AT.LAW "US TRINOLE ROAD CAMP 11I1.1., PA 17011 2 ,.,.~,~ ,~..^ .:.,....":',.",...,'.Q'\u.li"...^ DIANE G, RADCLIFF ATTORNEY-AT-LAW M.II TRINIJLE ROAI) CAMP 1111.". PA I7DII .'.".. ., 5, There have been no prior actions of divorce or annulment between the parties, 6, Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate In counseling, 7, The Defendant Is not a member of the Armed Services of the United States or any of Its Allies, 8, The Plaintiff avers that the grounds on which the action Is based are: (a) That the marriage Is Irretrievably broken. Or In the altematlve, (b) That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage Is Irretrievably broken, WHEREFORE, Plaintiff requests this Honorable Court to enter a decree In divorce, divorcing the Plaintiff and Defendant. COUNT II: EQUITABLE DISTRIBUTION 9, Paragraphs 1 through 8 are Incorporated by reference hereto as fully as though the same were set forth at length. 3 DIANE G. RADCLIFF ATTORNEY-AT-LAW SUI TRINDI.E ROAn CAMP 11I1.1.. I'^ 17011 10. Plaintiff and Defendant have legally acquired property, both real and personal, during their marriage from June 7, 1975 until October 13, 1995, the date of separation, all of which Is "marital property', 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has Increased in value since the date of marriage and/or subsequent to Its acquisition during the marriage, which Increase In value Is "marital property'. 12. Plaintiff and Defendant have been unable to agrea as to an equitable division of said property as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property of the parties, Respectfully submitted, 4 DIANE G. RADCLIFF ATfORNEY.AT.I.AW 'U. TRINIU.t ROAU (:AMP 11I1.1.. PA 17011 VERIFICATION MICHAEL R. PRETTYMAN verifies that the statements made In this Complaint are true and correct. MICHAEL R. PRETTYMAN understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities, ~~~~, MICHAEL R. PRETTYMAN MICHAEL R. PRETTYMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 96.586 CIVIL TERM v. CHRISTINA G. PRETTYMAN, Defendant CIVIL ACTION. LAW "" ORDER OF COURT ~ day of AND NOW this . 1996, upon request of counsel for the parties. the hearing set on a Petition for Special Relief filed by the Defendant herein on May 29, 1996 at 3:00 p.m, is hereby continued generally to be listed at the request of either party, The Temporary Order shall remain in full force and effect pending further Order of Court, By the Court, 'tIl"IIf,^".SNN:ltf . -,....,q'''''''J I II"', ......'-1 .-." . ," .,..', r...;, ~ . . . ... . . '. '. . .' , , - II J .. · "I' ", 6~:G t\' .,- .". ...U . ..~ ^~';lC~b~~O-G31;.1'- ;. J. MMIlS I). I'LOWI!R ROOI!R M. MOROI!NI1IAI, MMJl.~ D, 11,OWI!R. lR. CAROl. l, UNI>!i.\ Y LAW OFFICES FLOWER, MORGENTHAL. FLOWER & LINDSAY ^ 1'NllIl.\\IIINAI.I'IIlI"UtAIIIIS II EAST HIGH STREET CARLISLE, PENNSYLVANIA 17013-3016 (717l2H.l'l~ I'^": (717124~4,\Il1 1II1:1);C:1I '" MllIUlI!NI1IAI. (l'm.I'ItI5) I'LOWI!R. KIII\MI!R MlIROI!NIlIAL'" I'LOWI!R (I'ItI5.1'1l2) May 28. 1996 The Honorable George E. Hofler CUMBERLAND COUNTY COURT HOUSE One Courthouse Square Carlisle. PA 17013 RE: Prettyman v. Prettyman No. 96-586 Civil Term Dear Judge Hoffer: Diane Radcliff represents Mr. Prettyman. She and I have agreed that the matter which was a subject of my Petition for Special Relief can be resolved. We request a general continuance to permit us time to work out a Stipulation. I encloss a proposed Order for your consideration. Thank you for your help, Very truly yours. '?;;~/'O::"wm · UN'SAY, 'C Carol J. Lin.d~ CJLltjb cc: Diane Radcliff Christina Prallyman c.. ,.~. '0 ...~-" J - ~1lC: j~'" ~~~ tliS~~ ~~!J ~ ,. " ' ;. - .. MICHAEL R. PRETTYMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 96-586 CIVIL TERM CIVIL ACTION - LAW v. CHRISTINA G. PRETTYMAN, DEFENDANT RESPONSE TO PETITION FOR SPECIAL RELIEF AND NOW, this ~ day of rY\l.uJ . , 1996, comes the Plaintiff, Michael R. Prettyman, by and through his attorney, Diane G. Radcliff, Esquire, and files the above captioned response as follows: 1. It is admitted that the Petitioner is Christina G. Prettyman who resides in the martial residence located at 546 Appalachian Avenue, Mechanicsburg, Pennsylvania with the parties' child. 2. It is admitted that the Respondent is Michael R. Prettyman, who resides at 126 West Portland Street, Apartment 11, Mechanicsburg, pennsylvania. 3. It is admitted that the parties are husband and wife, having been jointed in marriage on June 7, 1975. 4. It is admitted that the parties separated on or about October 13, 1995 when the Respondent left the marital residence. DIANE G. RADCLIFF ATTORNEY.AT.LAW Sf.. TIUNnL[ ROAD CAMP lULL. PA 17011 5. It is admitted that the parties are the parents of a minor daughter, Megan Christine Prettyman, born March 8, 1990, which daughter was adopted as an infant and since that adoption the petitioner has not been employed outside the home. . ... .." _ 10 .....;.. 6. It is admitted that the subsequent to the parties' separation on or about November 6, 1995, the Respondent advised the Petitioner that he was intending to liquidate the parties' Series EE Bonds to payoff certain marital debts. It is further averred, however, that he also told her at said time that he was going to cash in Life Insurance Policies, as well as other specified marital assets in order to payoff specified marital debts. 7. Denied. It is denied that the Respondent did not consult with the Petitioner for obtaining her permission and taking over control of liquidate assets or at these assets had a value of $38,000.00. On the contrary the Respondent believes and therefore avers that a discussion was held between the parties' pertaining to the actions that the Respondent intended to take by liquidating the marital assets set forth in the preceding paragraph 6 as due the parties separation there was not sufficient income with which to meet all of the parties' marital obligations and run two separate households. After having informed the Petitioner of these intentions, the Petitioner did not inform or indicate to the Respondent that he could not take this action and the Respondent right fully assumed her agreement thereto. It is further averred that assets liquidated by the Respondent did not equal $38,000.00, but rather $30,034.00 which were DIANE G. RADCLIFF ATTORNEY.AT.LAW S.wl TRINDL[ ROAD CAMP lULL. PA 17011 itemized and set forth in a letter to the petitioner from the Respondent's counsel dated November 20, 1995, a true and I I correct copy of which is attached hereto marked Exhibit "A" and made a part hereof. 8. It is admitted that for approximately 13 years prior to February 28, 1996, the Respondent was the President and CEO of Members First Federal Credit Union. It is denied that he was terminated from said job as he resigned therefrom based on mutual agreement of the Board of Directors and himself. 9. Is admitted that as a part of a severance package the Respondent requested the payment of certain assets which were set forth in his letter to Members First Federal Credit Union attached as Exhibit "A" to the Petition for Relief ~ including, but not limited the Thrift Saving Account, accrued and unused vacation time, 14% bonus pay, certain rights under the retirement plan and a contribution of pay for a period of 14 months. It is averred, however, that the bonus pay, a portion of unused vacation time, a earned post separation portion of his retirement plan and deferred compensation plan and earned post separation and any severance pay to which he had no entitlement prior to separation are non.marital property and therefore are not subject to any injunctive relief. 10. It is admitted that the Petitioner is in control of certain other marital assets including, but not limited to a DIANE G. RADCLIFF ATTORNEY.AT.LAW ,... TRINOLE ROAD CAMP lULL. PA 17011 Certificate of Deposit which comes due soon and IRA accounts which the Petitioner and avers an approximate value of about $20,000.00. It is further averred that the Petitioner has t DIANE G. RADCLIFF ATTORNEY.AT.LAW Uti TRINDLF. ROAn CAMP lULL. PA 17011 " .~ : control and possession of the parties marital residence which has an estimated value of approximately $200,000.00. 11. The Respondent believes and therefore avers that the averment set forth in paragraph 11 of Petitioners, petition for Special does not require an Answer or Response. 12. The Petitioner admits that there are certain life insurance policies that were acquired during the course of the marriage, one of which was the New York Life insurance policy cashed in by the Respondent in November, 1995, so as to pay the marital obligations set forth above, which policy had a cash value of approximately $2,400.00. It is further averred that there are two other policies, one being a universal policy with State Farm with the Respondent as the owner having a cash value of approximately $2,000.00 and one owned by the petitioner with New York Life having a cash value of approximately $3,000.00. The Respondent has not withdrawn any of the cash value from any of those remaining policies and has no intention of doing so and is not opposed to any injunction being entered prohibiting either party from cashing in said policies. The Respondent, however, does protest and deny any requirement requiring him to continue to make payments on the aforementioned policies or to keep them in full and effect, as his ability to do so is dependent upon the income level that he maintains. WHEREFORE, the petitioner respectfully request this Honorable Court to deny the Petitioner's request for , . 4 "- . .' '.J'V injunctive relief pertaining to the non.marital portion of his, unused vacation pay, bonus pay and severance pay and to deny the petitioner's request for him to continue to make the payment on his life insurance policies. Respectfully Submitted, DIANE G. RADCLIFF ATTORNEY.AT.LAW .... TRINDLE ROAD CAMP IIILL. PA nOli . . . I ... ~T_ ....~ VERIFICATION Michael R. Prettyman, verifies that the statements made in this Response to petition for Special Relief are true and correct. Michael R. Prettyman, understands that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorities. \'u,-~~. qjt - ~ MICHAEL R. PRETTYMAN DIANE G. RADCLIFF ATTORr-:EY.AT.LAW .... TRINDLE ROAD CAMP IIILL. PA 17011