Lee E. Seidel - Page 4

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          in the CWSC 401(k) plan began sometime between 1983 and 1985,               
          prior to his marriage to Ms. Seidel, and continued during the               
          marriage.  Petitioner’s CWSC 401(k) plan consisted of a separate            
          property interest for contributions made prior to his marriage to           
          Ms. Seidel and a community property interest for contributions              
          made during his marriage to Ms. Seidel.  The parties agree that             
          the community property interest in petitioner’s CWSC 401(k) plan            
          totals $77,000.                                                             
               Petitioner and Ms. Seidel each entered the marriage with               
          separate property interests.  Ms. Seidel had her own house, which           
          was encumbered by a first mortgage.  Petitioner had his own                 
          house, which he had purchased.  Petitioner’s house was encumbered           
          by a first and second mortgage.  After their marriage, petitioner           
          moved into Ms. Seidel’s house.                                              
               During the beginning years of their marriage, petitioner and           
          Ms. Seidel took out a second mortgage on Ms. Seidel’s house.  The           
          proceeds of this second mortgage were used to pay off the second            
          mortgage on petitioner’s house, to pay off some of Ms. Seidel’s             
          debts, and to purchase household assets.                                    
               Petitioner and Ms. Seidel separated on February 11, 1998.              
          During settlement negotiations to dissolve the marriage, Ms.                
          Seidel was represented by an attorney, Robert Fruitman (Mr.                 
          Fruitman).  Petitioner was represented by his attorney, Francis             
          L. Adams (Mr. Adams).  The marriage was dissolved by the Superior           

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