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Home My WebLink About00-01146 !'.,- jO <. -. . . . ff. :tiff.:ti:ti:ti . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF . . RnNATn R f..IO(Hfl?U , No. ?()()A~1 :'L6.h' C""iTi 1 . Plaintiff VERSUS RARRARA A HOOVRR, . Defendant . DECREE IN DIVORCE . at~~tfofA : ~l. IT IS ORDERED AND : . . . . AND NOW'~ ~ DECREED THAT Ron.l" R Hhovpr , PLAINTIFF, AND Barbara A. , DEFENDANT, Hoover ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . 'l'hp p-,qrt-ipf::' ~p.p;:arA'tinn ;:anti Propprty ~p~tlpmpn~ Agrppmpn~ nAt-pt1 . . Apri 1 incoroorated berein~ but not mer~ed. . . . . .. " , -, ~ . -~ 1-1,'e ---,,-.-, 1 .,,'~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . , '" , ~;.' ,. ' - , T/ . .' ..5J/CJr' a4-C''*7_ M~-Z; 4-~ 53/-c;(' ~~ ~ ~ ~ ~~ . . . - . . > " SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this a y~ day of ~ ' 2001, by and between RONALD R. HOOVER, of 415~ Sunset Lane, Shippensburg, Franklin County, Pennsylvania, party of the first part, hereinafter referred to as "HusbtuUl', AND BARBARA A. HOOVER, of 50 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were married on June 13, 1970, in Patton, Cambria County, Pennsylvania; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for 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 Wtfe 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 Page 1 of 17 , ".'. _ '~~'_'n.~_. --'-,,^\,; "'-_'_'_",1"' ._ '~ _~_,,"': ,0._ '._, ' -,- T ". '..->-.""- - - ,~ ., 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 have had full and ample opportunity to consult with attorneys of their respective choice, the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto 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 legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: 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. ARTICLE II DWORCE 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 Page 2 of17 ""'<~,'-";:',>_,, 1-"",~"_ v, t"", ~~;<:'1'" " '--~"_!_'!'" ,,' '-1 " ", ._" ~< ,-,1-' ,'I the other that the execution and delivery of this Agreement is not predicated upon nor made . subject to any agreement 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 commencing, 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 defending any such action which has been, may, or shall be instituted by the other party, or from making 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. Husbll1lld and Wife do each hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from 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 provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, country, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be affected in any way by any such separation and divorce. Page 3 of1? , 'I" ',. ..""., ' co_ 'y" ,'--< '. .- - . , " . 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 DISTRIBUTION OF MARITAL 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 considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational skills, employability; estate, liabilities, 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, retirement, insurance or other benefits; the contribution or dissipation of each part 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 living of the parties established during their marriage; 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. Page 4 of17 ,~ , r -', J- .'f" -0 _ -' .'" ~- .. , '" ,-j' .-~ - 'p. ..-,~-",- -,-,",' \, ", ',.' , 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 constituting marital property. The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. 3.3 Personal PrOlJertv. The parties acknowledge that they have divided their personal property, tangible and intangible, to their mutual satisfaction. The parties acknowledge that they have the cash, accounts, and other tangible or intangible property in their possession that they wish to have and neither party will make any claim whatsoever against the other party for any items of personal property or assets that is in the other parties' possession. 3.4 Life Insurance. Husband shall maintain Wife as a partial beneficiary on any life insurance provided to him through his present employment with the United Stated Federal Government. Husband is obligated to maintain Wife as a beneficiary on his life insurance policy solely for payment, in the event of his untimely death, of the sum remaining due under the alimony provisions of this Agreement as set forth in paragraph 4.1 hereinafter. The parties intend that this is the sole obligation Husband shall have relative to naming Wife as beneficiary on his life insurance policies and that this amount shall be in the decreasing value based upon the ongoing payment by Husband of the alimony requirements as set forth in paragraph 4.1. It is not intended that Wife shall receive any additional benefits beyond the alimony payment she would have received had Husband not pre-deceased her. Effective with the final alimony payment made PageSofl7 ., 'I"" - -,'co -~- ,.", -, ",,'P- "_'-~_ 'o'_-_'"'. ;,.-'" - <"- "', w', ~~ -., __of',: - r~', ~~<:c-"j _'? ~"-:",--, - ~--- I - ~,-". ". '-'. '0-_ . ,~,---f-_I't' -If ,"_"", -. ,'~~" k'. _ ,_'I , pursuant to the provisions of paragraph 4.1, Husband shall have no obligation whatsoever to maintain Wife as the beneficiary on any of his life insurance policies. Except as otherwise set forth above, each party sha11 have the right to borrow against, cash in policies, change beneficiaries, and exercise any other incidents of ownership of their respective policies free of any right or claim by the other party. Each party shall sign any documents necessary to waive, relinquish, or transfer any rights on such policies to the respective party who presently owns such policies. 3.5 SubseJluentlv ACQuired PrODertv. 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 tangible personal property subsequently acquired by the other party. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 3.6 Reo.l Estate. The parties are the joint owners of real estate located at 50 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, which property is currently held in the parties' joint names. The is property is encumbered with a mortgage due and owing to the Standard Federal Bank, with an approximate balance of $63,000.00, requiring monthly payments of approximately $800.00. Husband waives, relinquishes and transfers any and all right, title and interest that he has in the aforesaid real estate and will execute a special warranty, fee simple Deed conveying his interest in such within fifteen (15) days of being presented with a Deed by Wife or her legal representative. The aforesaid Deed sha11 be held in escrow by counsel for Husband until such time as Wife sells the aforesaid real estate or refinances the mortgage on the property so as to Page 6 of17 r' -- - ",:,' ," .<" _ ,'-', - '", -' -, . - _~:" ~'o" ,n" p ,f_," _ ,;_, . ,;,F"._,:;_ ,,--.- 'I . remove Husband as a responsible party on that mortgage, whether this be through an assumption, refinancing or similar financial and legal procedure. From the date of execution of this Agreement forward, Wife is and shall be solely and exclusively obligated for repayment of the aforesaid mortgage and shall make payments on the mortgage in a timely fashion. to avoid any claims of delinquent payments or any procedures for default or in foreclosure. Wife shall indemnifY Husband and hold him harmless from any and all demands for payment or conection activity of any nature whatsoever on account of said mortgage. In the event Wife fails to make said payments, Husband shall be entitled to make such payments and immediately initiate an action for contempt, through which proceedings Husband shall be reimbursed any funds that he is required to pay to maintain the mortgage in current status, as wen as any and all costs or attorney's fees associated with pursuing the claim of contempt for Wife's failure to maintain the mortgage in current status. In the alternative, Husband may make such payments and deduct all amounts paid from his next alimony payment required hereunder in paragraph 4.1. Except as otherwise set forth herein, any real estate owned in each party's individual names shall remain their individual possession and neither party will make any claim of any nature whatsoever relative to any such real estate. Any encumbrances of any nature on any such real estate shall be the sole and exclusive obligation of the party retaining ownership of the aforesaid real estate. 3.7 Pension. Retirement. Profit-Sharinf!. Husband has a retirement account with the Civil Service Retirement System (CSRS), which has been earned through his employment with the Federal Government. Within thirty (30) days of finalization of the parties' divorce, Husband shall Page7of17 i-.; i-'" -'-""""~\ ',0,,'1'- , -' ., .,--, ,'- -"-"'-',- -"', ", <-. "~ ." - - ". "' -,~ ,~~ either provide Wife with a lump sum disbursement in the amount of TWENTY-THREE THOUSAND THREE HUNDRED TWENTY-FIVE AND 85/100 ($23,325.85) OOLLARS through a direct cash disbursement to her, or shaI1 provide a roll-over via a Qualified Domestic Relations Order (QDRO) from his CSRS pension or Thrift Savings retirement account into an appropriate retirement account for Wife, or shall provide a combination of lump sum disbursement and QDRO roll-over such that Wife shall receive the total sum through one of these forums or a mixed forum of these two disbursements in the amount of $23,325.85. Husband shaI1 have the exclusive right to determine how the sum is provided to Wife. Upon Husband providing Wife with this sum in the form described above, Wife waives, relinquishes or transfers any and all of her right, title and interest she has or may have in Husband's CSRS retirement account, as well as any other retirement accounts of any nature whatsoever maintained by Husband. Wife will execute any and all documents to so waive, relinquish and transfer her rights in any such retirement accounts. Husband waives, relinquishes and transfers 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 employers or past employers or which Wife has secured independently. Except as hereinbefore set forth, Wife waives, relinquishes and transfers any and all right, title and interest she has in Husband's pension through his past or present employment,including his CSRS funds, his Thrift Savings funds and any funds in the State Employees Retirement System, as well as any and all other pension, retirement, profit-sharing, stock options or similar accounts with Husband's present or past employers or which Husband has secured independently. Page8of17 '0 '" _"'-~_C_"__C'_' ,-^~, "~--- ,', -- .". . ~- ,- ", -'-'0_-0 3.8 Vehicles. Husband has and shall retain sole and exclusive ownership and possession of his 1979 Blazer and a 1986 Corvette (purchased post-separation). Wife has and shall retain sole and exclusive ownership and possession of the 1996 Jeep presently in her possession. Each party shall execute any and all necessary documents to so waive, transfer and relinquish any and all right, title and interest in the vehicles retained by the other parties within fifteen (15) days of being requested to do so by the other party or their legal representative. Each party shall retain sole and exclusive responsibility for the repayment of any debt or encumbrance of any nature on the vehicle that they have retained herein and will indemnify the other party and hold them harmless from and against any and all demands for payment or collection activity of any nature whatsoever on account of such encumbrance. 3.9 Intantlib1e Personal ProDerlv. The parties acknowledge that Wife shall retain the parties' account with Letterkenny Federal Credit Union. In the event it is necessary for Husband to execute any documents to remove his name from Wife's account, he will do so within fifteen (15) days of being requested to do so by Wife or her legal representative. Similarly, Wife shall retain sole and exclusive ownership and possession of a certain Certificate of Deposit (CD) presently held in the parties' joint names with Orrstown Bank. When the CD neld; comes due, Husband will execute any and all necessary documents to waive, relinquish and transfer any and all of his right, title and interest in the aforesaid CD to Wife. Except as hereinbefore set forth, the parties have otherwise divided their intangible personal property, including various bank accounts, Credit Union accounts, and the like and Page 9 ofl7 ,-' >,- -c<' , ~-, ,'-_~'-~C' "~"""__~,,,, -~ -" -~, e, , ^ -" ., " "_or =..H. ,~,," -- ~ , , . . neither party will make any claim of any nature whatsoever against the other relative to the financial accounts or other investments or intangible personal property that have already been retained by that party as described herein. ARTICLEW ALIMONY. ALIMONY PENDENTE LITE. SPOUSAL SUPPORT. CHILD SUPPORT AND MAINTENANCE 4.1 Wife is in need of financial support to assist her in the immediate future. With this in mind, Husband sha1I pay to Wife the sum of ONE THOUSAND FIVE HUNDRED AND XX/IOO ($1,500.00) DOLLARS per month, by the 15th of each month, until payment made on December 15,2001. Thereafter, he sha1I make payment in the amount of ONE THOUSAND AND XX/100 ($1,000.00) DOLLARS per month, by the 15th of each month, beginning on January 15, 2002 and ending on December 15, 2002. Thereafter, he sha1I pay the sum of FIVE HUNDRED AND XX/I00 ($500.00) DOLLARS per month, beginning on January 15, 2003 and continuing on a monthly basis on the 15th of each month until December 15, 2003. This alimony obligation shall be non-modifiable under any circumstances. This obligation shall continue for the exact time period set forth above, requiring payments in the exact amount described. 4.2 Except as otherwise hereinbefore set forth in paragraph 4.1, the parties have each secured and maintained a substantial and adequate fund from which to provide themselves sufficient resources to provide for their own comfort, maintenance and support in the station of life to Page 100fl7 \~ e,c" , "1'- , ."c , C , . which they were accustomed. Husband and Wile do hereby waive, release and give up any rights they may have, respectively against the other, for alimony, support or maintenance, except as provided in paragraph 4.1 above. 4.3 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. ARTIUE V DEBTS OF THE PARTIES 5.1 The parties acknowledge that they have an encumbrance due and oWIng to the Pennsylvania State Employee's Credit Union, which exists through a credit card account and a line of credit through the Letterkenny Federal Credit Union. From this time forward, Husband shall assume sole and exclusive responsibility for repayment of the aforesaid debts and shall indemnifY Wife and hold her harmless from and against any and all demand for payment or collection activity of any nature whatsoever. Husband sha11 at all times pay the aforesaid debts in a timely fashion and shall remove Wile's name from the aforesaid debts as soon as reasonably possible through the assumption of the debt in another form, or simply by removing Wile as an obligor on the aforesaid accounts. 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 neither party has contracted for any debts for which the other will be responsible, and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. Page 11 of17 ,., m; "?> ,'"'' .,,"~ ,'"~" " ,,':,'~':"1'f-"',':"7:"'7'!J'<:._''''''''!",''f'_.''':C_cW-- "eo":"' _" .'. ',--, Y',1.~ .',_;",~-. ~,- ~- - ',""--,'1-"- ARTICLE VI MISCELLANEOUS PROVISONS 6.1 Advice of Counsel. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, being Bradley L. Griffie, Esquire, for Husband and H. Anthony Adams, 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. 6.2 Counsel fees. Each party agrees to be responsible for his 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. 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 from any and all right, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof; Page 12 of17 ,.,-" -. '.',., -,'~' - - -, ~.- -~ '., - '. "!' ,- To" ~: -, '~', - "':'" - r' .= ":- -'! " ,'J_,__._ -,-- ~- I - . - p t 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 arise under this Agreement or for the breach of any thereof. It is the 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. 6.4 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 party harmless from and against any and all such debts, liabilities or obligations of every kind, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each wiI~ now and at all Page 13 ofl7 < -, ", ,"'~,,~'" -. .,' ~.(7' .". - "-,, -."-,, - ,-~, ,- "I "---I, -~~. - times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided for by the tenns of this Agreement and that neither of them hereafter incur any liability whatsoever for which the estate of the other may be liable. 6.5 No waiver or modification of any of the tenns of this Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 6.6 Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, 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 fully and effectively the tenns of this Agreement. 6.7 This Agreement sha1l be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date oftbe execution of this Agreement. 6.8 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. Page 14 ofl7 't~ l' -, "~. -''''-,~8'-,":~._~ ' "1 ,---, - ~_, - , - -, -"'If """ ~" - ~I ---~~ . 6.9 This 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 forth herein. 6.10 Severability. If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.11 It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and wife, or either of them, during the marriage as contemplated by the Divorce Code of the Commonwealth of Pennsylvania. 6.12 Disclosure. The parties each warrant and represent to the other that he or she has made a full 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. Page 15 of17 I"~ I"~~: --:';~"Oi'"",>,_-'~ ~C-'" ~:"=-'''~''i'-_'_ ~,,,~_,, ?,~-,'-"'-" "."" -,~ -r.':"'^I"'?Y' ."'0""""__'1"':"','" ~', ~-"-~"~_"."_'__d_,_"__'~__>"'_{~~_'_" 6.13 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 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 including equitable enforcement of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESSED BY: H. Anthony Adams, Esquire 4~~ RONALD R. HOOVER .sJ{/JDJ t?A.< (/1J.---.ct ~ ~ BARBARAA.HOOVER 7-)4-01 Date Page 16 of17 , ",- ~ ~"' ,,< ,,_ 't- "'., --" --'-,' .,,, --~ ..p - --'" ,.'-.,- .' COMMONWEALTH OF PENNSYLVANIA COUNTYOF &rvJwJ.~ On this Jtf!f; day of ~ , 2001, before me, the undersigned officer, personally appeared RONALD R. HOOVER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarial Seal Robin J. Goshom, Notary Public Canisle Bore, Cumberiand County My Commission Expll9s Apr. 17, 2003 ~a~~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cu.Jy\'bE-1c CI't'N ~ On this I t(VI day of /YYJu-( , 2001, before me, the undersigned officer, personally appeared BARBARA A. HOOVER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~'m~ S Dawn Meri~~~rial Seal f ~P~~!3oro~~u~o:,:r,,:~I/O Ion Expire. F.b, 1;, 28~" Page 17 of 17 ~" f"" -,-'-'",- ." ,'f""-,-';H,',,,'-~ _,J'. ,~.. . RONALD R. HOOVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARBARA A. HOOVER, Defendant : NO. 2000-1146 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under 9330l(c) 330l(a)(1) eithe Di'fer-ee Ceae. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery to Defendant, Barbara A. Hoover, on March 3, 2000. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code: by Plaintiff: May 22, 200 I by Defendant: May I I, 200 I (b) (I) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: May 23, 2001 Date defendant's Waiver of Notice III 93301 (c) Divorce was filed with the Prothonotary: May 23, 2001 ;'l"" , ~ ". "' """. . "." . ,. .,. ",,', ",' ,"'".'" 'C'- -,'",...~, ,"-""H". -~. ,"i-""-~",,- c ~~ ."""" ~,~ 'll;" C2 ~. -OF' 92S~: -71 ~:r:: --- ~'",-" G::C' ~t~ :Pc::: "2: ~ ,v".... ~- ~ '~.:: ( i, r....,j _C_:1 .I \~ C,,; ',s/ -::"' - '.- --r: ':-~~}~(l ~ 5:J '-< - ., ::,..'1 ,..D - '-~'-~-~"';"'?\ii ~"!, II I i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA RONALD R. HOOVER, Plaintiff, CML ACTION - LAW vs. NO. 02a$1 -lltl6. f4;/ BARBARA A. HOOVER, Defendant. IN DIVORCE 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 wl 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 judgement 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 grounds 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, PA 17013. IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 Avenue Carlisle, Pennsylvania 17013 717-249-3166 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPEN5BURG, PA 17257-1397 J ~: ,-"~ '-'I II ii " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD R. HOOVER, Plaintiff, CIVIL ACTION - LAW vs. - ~ NO. OLIrVV - II '/(, c;,;J, BARBARA A. HOOVER, Defendant. IN DIVORCE COMPLAINT IN DIVORCE COUNT I - IRRETRIEVABLE BREAKDOWN AND NOW, comes the above named Plaintiff, Ronald R. Hoover, by and through his attorneys, Weigle, Perkins and Associates, and David P. Perkins, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff: Ronald R. Hoover, is an !!dult individual presently residing at, 415 Yo Sunset Lane, P.O. Box 408, Shippensburg, Franklin County, Pennsylvania, since August 1998. 2. Defendant, Barbara A. Hoover, is an adult individual presently residing at, 50 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, since July 1980. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on June 13, 1970, in Patton, Cambria County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties or in any other jurisdiction. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since July 5,1998. MARK, WEIGLE AND PERKINS - ATTORNEYS AT L.AW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257.1397 , ~ ~,:",p ,-, ~v' d_. _, - ,1 _ <. ,~" ~, II WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of Plaintiff's Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage from June 13, 1970, until July 5, 1998, the date of separation, all of which property is "marital property" . 12. 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 the marriage and or subsequent to its acquisition during the marriage, which increase in value as marital property. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint and substantial portions of said property are in the exclusive control of Defendant. 14. Plaintiff requests the Court to equitably divide all marital property. WHEREFORE, Plaintiff requests the Court to equitably divide all marital property and to enjoin Plaintiff and Defendant from the removal, disposition, alienation, or encumbering of all real and personal property of the parties. WEIGLE, PERKINS AND ASSOCIATES Q~ 0- e2S<J By: David P. Perkins, Esquire Attorney for Plaintiff 126 East King Street Shippensburg, P A 17257 717-532-7388 MARK, WEIGl-E AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 --'\ ".,-, " "" , " _, F-,' , ' ~ II VERIFICATION I verify that the statements made in the furegoing Complaint in Divorce are true and correct. I understand that fulse statements herein are made subject to the penalties of l8 Pa C.S. ~ 4904, relating to unsworn falsification to authorities. ,~~~ Ronald R. Hoover, Plaintiff Dated: ).~11o 0 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257.1397 t ",._^, _ "", ~"_,:'" j - ,-['I'''' , .,", -~, . ,- I ,--I - II '. - IN TEI.E COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA RONALD IlL HOOVER. Plaintiff, CIVIL ACTION - LAW vs. . . NO. 2000-1146 CIVIL BARBARA A. HOOVER. Defendant. IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ~ COUNTY OF CUMBERLAND Rhonda R Wolford, being duly sworn according to law, deposes and says that on March 3, 2000, she served true and attested copies of Divorce Complaint upon the Defendant, Barbara A. Hoover, by mailing the same postage paid, certified maiL addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Barbara A. Hoover 50 Furnace Hollow Road Shippensburg, P A 17257 ~cfJ Rhonda R. Wolford Sworn to and subscribed before me this 10 day of March, 2000. =;;r1~ Notarial ,S~ Shl Rebecca L. HolIrv, Notary Public lIpensburg BolO, Cumberland County My CommISSIon Expires June 7; 2003 Member, PennsylVania Associallon of NOlan.. MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET' _ SHIPPENSBURG. PA 17257-1397 _H,.," " . - '. ,j', rr -,'- .r_;-,_~ ,- 'T " - :. , Ii ! ! ',.'1' I; Iii ;~j 'il ','I , ", !t1 I;i 1'1 1;:1 1;1 'I iii i:l 'H ~-i~ u._ . , . ' ;." 1':;:-,- - i e' "H' (j C" .---- ~!(~ --., - D~:;- rr::- ~-;: '~- .-:;;'~' - __,__c. .;;,:- l~? :n <::> CJ a o -'1 -~ -.....:.: :r:. ):::";0- . :;'\,7, , . :~'i;g 'In-; ;C'J .:) .1. -'-: !'''/ . " -:-'-;::c' _:sr:? - -'-~: - ::"0 -<; ,_ ~,,~'~~l~M~WlI'i.~~ ~~ !'!'ll'n"i~~~ 'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD R. HOOVER, Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-1146 CIVIL BARBARA A. HOOVER, Defendant; IN DIVORCE PROOF OF SERVICE "aOIAJas :td!a081::1 um'8:1:1 6ulSO JO. nOA lIUBl.f.l '" '0 '0 C. '" ! ~ ." '0; " ~ oj t 0 .'!l .;; 2 ~ 0 ~ " " ~ .~ " '" (]) -"", '0 .8 () .EO () a: ~ ~ <( Q; tloo 0- " 0 '" 0 ~ 'S"" -" 2 c '0 ~ ~ " '" " " '" :::J ",l'l '" u '" " -'" Qi ;;.~ '" E w ~ ~ .0 'B ~ a: 'in 'in c ~" '0 '" s;.1I) " '0 " 0 ~ '" " ~ "''' <( a: 0. " '" ~ ~" '5 co " ~ Cl .3: -; ~~ '" '" '" '0 (]) !f1O~ oj ~ '" " S2 ~ ~~ E \llo>< 0 0 () 0. '0; -~ '" -- " .-< ~ '0 '" .9- ,_ II) Q.. 0 .-< ~ ~ - -33,~ " '" . a: ...... l;g Q) m E N E o~ Q)~ N E . ail!! .a.& -01:1 '" , ;; Q) ctl "C t:: do ;;; ~. a: 0 <( ctl ,;, . E~ q> c . ,. r.: w 0 <Xi ~ ~ 0.0; m . ..~ w ~ u uc ~ . 'E(ll 1i ~ .~ . J " - .~ 0 ~ i~ . ~ ~ ~ o. -~ .E . 11m " . c ~. .; E . 0 .. u 0 " "5.13 ., 'ffi~ . . " '-3~ . " u E. ~ . .~ " :g. ~- ... c ~ -E 0 '. Bi! " '" ~ . E '" '" " " . '0. H '" ~ ~ ~ . c " -"0 Q) 0 Iii o.ci~ 0 .- :> ~~ " .c -v. C 0 " E C\J"'C~ .9 "c~ g w~ lJl " o.~ a:~ '0 on " :g,f~ .'9."3: " " . " H J5 " '" 0 . c " ~"9- '" Q) " ." .-('Ijl'll &'~ ~ <Ii u ..CJ ~ - ..w ~ oj " EEE . '0 - .. III III (ll 0 EO: '0 oj ., ., iri CXl a:::~'!::C::::I- .2E <( H H Q) ~ '" uJ**~g,~ ~2-g.9:! oj " p. 1ii E c-->oo..c:...... <11... 0 ..CJ I'< P. ~ i5 z g-g-CE o'g <11~.~ t H 'M >< ...88it ~i 8.~~~ cr: ojo.c u. "'''' '" C/) en... . .. (f) "- L9PIS 8SJaASJ 8LU uo pSJ8'dwoo mOA 51 Z 723 911 568 .......... Receipt for ~ Certified Mail ~ No Insurance Coverage Provided ~=a Do not use for International Mail (See Reverse) Sent to Barbara A. HOover Stre.@tandNo 5u Furnace Hollow Road p"o" State and ZIP Code Shippensburg; Postage PA 17257 $~--- Certified Fee ., -~ Speciel Delivery Fee Restricted Delivery Fee '" '" '" ~ .t: e .. ::;; o o CIO l') E o u. iJJ "- '1/' $ '..1 MARK. WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 1 26 EAST KING STREET SHIPPENSBURG. PA 17257_1397 "'~-"'i - "" ~~, .'1 "" I """"'~I"""~" .- ~ , I , \, . T~ ,~ . ~ ~ - ,-~,~I!II. ,_,_".T _!!bl~ , "."..~,,~ ill$Jlli~JI';llI~~~ Q g ~ ~ ~ ~-:I f ~ il;i~ ~} - :g~ s: (..n %:?~', (~~. ." ~c' ""0 :r-~ ~% .-"'. n -' .''T .. <Sf'f1 ~ cJ'I ~ 0' - ~~ T I PlIf!l~ .. . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD R. HOOVER, CIVIL ACTION - LAW Plaintiff, VS. NO. 2000-1146 CIVIL BARBARA A. HOOVER, Defendant. IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 5, 1998, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of p.J;'operty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ']i)ated: 7Jr!~O . L:L/ {~ / Ronald R. oover, Plaintiff WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 ",_ co_ _-"'-",7. _~' " "-1~ _ '.' ,. ,_" '1;- :1 ':1 ii "j ,~ ::J I;; i:!j :;;: i~t 1'1' 11 H~ ~ .. .... ,11 '" 1111!111!!Jl!!l!....", ~.~7 :;':.'"i-'C uS- 6 --.~ ',:.;:""' :.. i;~ () ~~. ,- '--..... (.::) ,- r....) '__1 ,.L._" cn co A(I ,_~~'Wi'IM,!I!!fl!flll~,,!~~,., J~.~_"",,-_~__n , ,. i~ '~--_" II !! , . , .1 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD R. HOOVER, CIVIL ACTION - LAW Plaintiff, vs. NO. 2000-1146 CIVIL BARBARA A. HOOVER, Defendant. IN DIVORCE COUNTER-AFFIDAVIT UNDER & 3301(d) OF THE DIVORCE CODE I. Check either (a) or (b): D rf (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry ofa divorce decree because (Check (i), (ii) or both): D (i) The parties to this action have not lived separate and apart for a period ~ at least two years. u;(" (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): D (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in ? not claim them before a divorce is granted. ~ (b) I wish to claim economic relief, which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. In fail to do so before the date set forth. on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW -- 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 "! ~ " II Ii . I verifY that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Dated: ~ I Lj ) {}-P f)~ /6nJ~ tA- ~ Barbara A. Hoover, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397 ~- ! !i II !I I!I,. ! iil II I:, !i !i "I ii' ,'! 1:1, !-'-',L.,.,,.,.,,..,.,,,,,, 1'1~,,. ~~~~__,,~_, ~ . _ 'c '" ~,. ,J,;.,Jt ~~ !!If____.. " - - . 0 <;:) 0 c 0 ,"1 ;;: "'" -0 t)J r-= :~~ n1rn s,,--, ZJ"} '- zr. " ~~: UI _, ~~ C) " ,:l, r;;O ::::"'\:-f:: ~. "r" " ~O :J'i: :_~,J~ 5>8 '2 c5rn -1 z N Jo- ~ :0 r" -< ,_J1I~_J!irl!(jMll'1~N","'w.>~'H!~~1W~~1m~~~~ RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA A. HOOVER, Defendant, : CIVIL ACTION - LAW : NO. 2000-1146 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was file on February 29, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a finaI Decree of Divorce after service of notice of intention to request entry of the decrees. 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 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: )!;;.1jo ( ~//L RONALD R. HOOVER .~_ -'_'-c'__-~,,_"~"_ n A- ,I!t!'! o ~ f~ ~!~: s::~ '::OJ -" ~. Ul ,.., , . > ~, ::::' j".) Lc:' " , , . '. 'ft .. RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA A. HOOVER, Defendant, : CIVIL ACTION -LAW : NO. 2000-1146 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was file on February 29, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service 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 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 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 5 ) J f J 0 I / ' ~_a~ BARBARA A. HOOVER . r, ",:-__,,_~ .''- ., ,p, ~. ", ~ '....-.".- -"" " - ~- I "r , ,_ -~-J-"', - ,._" , ,~"' "~~ < . i~ rI~""'F' . ,'..-r- .~ """" "" r,," ,'~, ^ .< ",. "11""~, "". ~!fl"IilIl"1P ~, "~. " C) c) C -;;:.s ~ ""'Or1,) !IW ,~~ ~~ f"",J (",,) ...-"~ ~I...-' ~-(] ~c; -- '-c J>c -'. z ~, ':i;: ::< __I :Q. - ~ " . , CJ .. ... <" .. RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA A. HOOVER, Defendant, : CIVIL ACTION -LAW : NO. 2000-1146 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301((.) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the , Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: p.,~ Cf ~ BARBARA A. HOOVER "'-,. ^ ~'-~/'_;___" _'~ '_-'_:'7"~"_,,"__,,",; ,,_,_~_, _" "",""0> _, ~L_ .~, ^ ~.;j . " - I~ ~ ~ , ' -"._, _',' ,.~ ,.~ ~"' ., ""'~ '" _ _ k a , .,:I, ~ . -o~:: rnF-, -?-, .<--', , zr'- g2'~-' <- ~~ z. -,~ > -.. o CD) ~ -:'7," -~ {'-...} c..",:-, _n .---J '" m~, """'~, , 0 I !! " ij , ! I , II , II> "' i I . ~ >'1' "L Ii ii I; :: ^"'~.,",., " !~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD R. HOOVER, CIVIL ACTION -LAW Plaintiff, vs. NO. 2000-1146 CIVIL BARBARA A. HOOVER, g Defendant. IN DIVORCE ,,;:;:: ~w Iltfrt 2:[1 :z:r;::: COUNTER-AFFIDAVIT UNDER !l3301(d) OF THE DIVORCE corje'5 ZO )>0 c :z: I. Check either (a) or (b): =< ".. :r 9 '" r" (a) I do not oppose the entry ofa divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): o (i) The parties to this action have not lived separate and apart for a period ~ at least two years. [{' (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! ~o not claim them before a divorce is granted. ~ (b) I wish to claim economic relief, which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 '" o a "'" c::: G') o "f'f :~;J !--;1;~ ,~~9 ~6 ::.!~=R ~o Om b! ~ (Jj .~1~ ""'T 11- ~ . " I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Dated: ~ / i. @..l' f) 1) . J {2, ,...,--1--. '&c/ a.- ?bn.-""""'" Barbara A. Hoover, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. WEIGLE. PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397 " I~ 333UG In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff Civil Action - In Law vs No. 99-1146 Michael E. Johns Defendant ARBITRATION \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilltles Inc. vs. Michael E. Johns Kindly enter default judgment in favor of Plaintiff, UGI Utilities Inc. and against Defendant, Michael E. Johns for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: TOTAL $ 849.66 $ 849.66 together with interest thereon from the date of judgment forward and all costs of this action. I hereby certify to the best of my knowledge and belief as follows: 1. The true and correct address of the Plaintiff, UGI Utilities Inc., is 225 Morgantown Road, Reading, PA 19612-3009. '~., , , 333UG 2. The true and correct address of the Defendant, Michael E. Johns, is 611 Lowther Street, Lemoyne, Dauphin County, PA 17043. Krzywicki d Associates DATED: April 26, 2000 By: Ant 0 1 Ne P.O New. pe, PA 18938 80 -296-2103 Attorney for Plaintiff Attorney I.D. 23754 '>;; ~- T - , '" " CASE NO: 1999-01146 P 3\.>vU:> ~"'0 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS JOHNS MICHAEL E KATHY CLARKE Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JOHNS MICHAEL E the DEFENDANT at 0017:30 HOURS, on the 23rd day of February, 2000 at 611 LOWTHER ST LEMOYNE, PA 17043 by handing to LEAH SEND! (ROOMATE) a true and attested copy of COMPLAINT & NOTICE together with IN ARBITRATION and at the same time directing Her attention to the contents thereof. i I, Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So Answers: rK~,,~~t R. Thomas Kline 02/25/2000 KRZYWICKI & Sworn and Subscribed to before By: ASSOCIATES I! rdh( CIaJu- Deputy Sheriff me this day of A.D. Prothonotary ~ 333UG In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff civil Action - In Law vs No. 99-1146 Michael E. Johns Defendant ARBITRATION """"""""""""""""'" , NOTICE TO: Michael E. Johns 611 Lowther Street Lemoyne, PA 17043 Date: April 5, 2000 You are in default because you have failed to enter a written appearance personally or by an attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/ (800) 990-9108 Krzywicki and Associates By: IS} Anthony P. KrzYWlckl 1 Neshaminy Interplex P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 .-'-'''-, .- , . _,^""",,~I 11 I! " , !:" , I I I !I~ ii, !I il 'I !I I II ! I I I I I 1 l. I,. I; I 1 , i ,/ --- -- ,/'- U.S. TALS VCE CER IFICATE OF MAILING MAY If USED FOR DOMESTIC AND lNTERNA T10NAL MAIL. DOES NO' PROVIDE FOR INSURANCE-POSTMASTER Reca tl/ !.nr"f-l.n (" L@ 1v->^'fM'; 3~ PS Form 3817. Mar. 1989 S-fr.e.o :f. rf'A IKJLf~ . ;',:. ~ i r :~; ~c ."; ~ ',~' ~~ ...!').'", , l '. .~~_:~~~:~,~ I co "i~",~""lI\l';:;>~"l w~.~;.,...,.:t.~"!\,, ~ ~'..'.J ~~~~,",~1;\'''' ~ i; g ;i~;'l:~~t ~'f~ o ~;'~:':;~~~~~j5, I, ;.~i'''::-;-~~iU' .. . ,-. ;!i -. -- ~, -~:. j ~, I~' ~,I,"'\ ~l ~ Uil i"nl di 1~> *~;rjo~..~.jl.!;-*.:; mp. and , of rent .;c:~~~~ ~""'1 333UG In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllltles Inc. Plaintiff Civil Action - In Law vs No. 99-1146 Michael E. Johns Defendant \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ ARBITRATION The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Michael E. Johns, in this matter was mailed to the defendant after the default occurred and at least ten days prior to the filing of the praecipe for entry of judgment pursuant to Pa. R.C.P. 237.1. True and correct copies of that notice is attached hereto and made a part of this certification. DATED: April 26, 2000 By: Antho 1 Ne P.O. New ope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 ,<~~".,~., ~.."' "M. --~,.' . ' 333UG In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilities Inc. Plaintiff civil Action - In Law vs No. 99-1146 Michael E. Johns Defendant ARBITRATION \ \ \ \ \ \'" \ \ \"" \ \ \ \'" \ \ \ \ \, \""" AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY ss. COUNTY OF HUNTERDON I, Anthony P. Krzywicki, being duly sworn according to law, deposes and state that I am a representative of UGI Utilities Inc., 225 Morgantown Road, Reading, PA 19612-3009, Plaintiff herein, and as such state the following: 1. The defendant, Michael E. Johns, is not, to my knowledge, in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940,as amended. 2. The defendant, Michael: E... johns, is more than 18 years of age and currently resides at 611 Lowther Street, Lemoyne, PA 17043. 3. I have ascertained the above information by personal investigation and make thJs affidavit with due authority. ,-.._>~ , ! I; I,~ m....-. . ~~ ' ~,PU ~ A> (J :a- ~ ft- i ~ ~ ~ ~ u (1l !j ~ ~ G' 6"- \U 0 r AA=. ~-"~,1'.!"~..,,..,..~1!l!II. (,") ~ ~s.. EJr?l ?"" id! ~,b. r-"~ ~c '>0 5!:O r:;. <- :;? .e;; . . & ~ ...." I .t:- >;:; :Jl ~ :;.:t Fi"if::J} '..'~ .,J e' :;:if .f?G J;! ~ ~-,',~ _f1f_I!Il~, , i '/1'I,"'l'.~'1"'U~1""''''ff';!'ql'''~''''"..-_,''W,=~_"",!",~ , ,-- , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ronald R. Hoover, Plaintiff : No. 2000-1146 vs. : In Divorce a.v.m. Barbara A. Hoover, Defendant PETmON FOR ECONOMIC CLAIMS PURSUANT TO PA. R.C.P. 1920.15(b) Now comes the Defendant, Barbara A. Hoover, by her Attorney, H. Anthony Adams, and respectfully sets forth the following: Equitable Distribution of Property 1. During the course of their marriage, the Plaintiff and Defendant have acquired certain property, real, personal and mixed, some of which is owned by the Plaintiff, some of which is owned by Defendant, and some of which is jointly owned. WHEREFORE, the Defendant respectfully request your Honorable Court to enter an Order equitably dividing, distributing or assigning the marital property between the parties. Costs of Counsel Fees and Expenses 2. Defendant has retained an attorney to bring this action and has agreed to pay reasonable attorney's fees. Defendant has incurred certain costs in the filing of this Action and will incur further court costs and expenses in litigating the present action. The costs incurred are a direct result of the obduranteness of Plaintiff. WHEREFORE, the Defendant respectfully request your Honorable Court to enter an Order directing that Defendant's reasonable counsel fees, expenses and cost be paid by the Plaintiff. I,"""T ....,.,.....tloul...-'i"F.'... , , . Alimony and Alimony Pendente Lite 3. Defendant is employed by Trinity Day Care Center with a bi-weekly take home pay of $419.00. 4. Plaintiff is employed at Letterkenny Army Depot with a bi-weekly take home pay of $1,700.00. 5. The Defendant is without sufficient property to provide for her reasonable needs, and is unable to adequately support herself through her employment. 6. The Defendant cannot support and maintain herself in style she was maintaining prior to the separation of the Plaintiff and Defendant without continued financial assistance from the Plaintiff. 7, The Defendant is without sufficient means to adequately support herself and to meet the costs and expenses of this litigation and is unable to maintain herself during the pendency of this action. WHEREFORE, Defendant prays your Honorable Court enter an Order awarding Defendant alimony pendente lite and thereafter alimony. RespectfUlly submitted, H. Anthony Adams, quire Attorney for Defendant 128 E. King Street Shippensburg, PA 17257 (717)-532- 3270 -~ j ~ - -,~_.~;, '~ ~~ ~~~ -,=. -'" '.'i' 0_ "",,,~!D1I~~~;~Jlll<'1 ""':,'!.l'ili'r,''W ..".~.~~ " '- a C -b ~ ~ " S1.. ~ -r c' ::> p - ~ O' , (') ~ -om Q1-q.; 2__ ZC. ~,;; ~Z=' ~c -0 Pc Z =< -, o a ra (7-) ~~~ .~.J . ~cIF1 ~ or en "',: n :C:J _:"~; :-. ~,~~~; :-~~.\"Tl ~:::'i ...~~ ~ ~. ~, o 1'0 W "~.<j$~Y ';';;""1~'-S;'{"'0~,t;;q'""'l"I"'is;;J;"~f,m~~~ff~~~i!lI!J~j!j~._...,!~JMmr.r~ RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA A. HOOVER, Defendant, : CIVIL ACTION - LAW : NO. 2000-1146 CIVIL TERM : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance previously entered on behalf of the Plaintiff, Ronald R. Hoover, in the above captioned action. DATE: N I:l'i t-t4nL '").."&", '2..0aO , g:A 6=' ~ David P. Perkins, Esquire WEIGEL, PERKINS & ASSOCIATES Please enter my appearance on behalf of the above captioned Plaintiff, Ronald R. Hoover. DATE: iI/3oJ6/J fl lI'f ' u.~ I , I 1 I I I I l! i':<JriIlJII!!I!I .~.,r-'q T.I, ( ~~~!!I!!>,.lfI!~ .~ ~, ~ ~ ~ f'1 ~:il - '7 ~~ ~ ,~ ;':::;0 'P. (.,;) . G' .<;(, --1 ;~:iJ, ~3{B ti~ g~ ~ ~ ~JlII!I ~ rr[~~!WW"~'~~~1l"ll>"l)~_=.~,_._~I~~^.;~~_ ~~ '"VllIIlQI!, .,_ , ~ RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW BARBARA A. HOOVER, Defendant : NO. 2000-1146 CIVIL TERM : IN DIVORCE ORDER OF COURT AND NOW, this 0/" day of o/"~ , 2001, the attached Qualified Domestic Relations Order is approved by this, the Court of Common Pleas of Cumberland County, Carlisle, Pennsylvania, pursuant to the requests of the parties. Said Order is approved as pursuant to 5 V.S.C. S8435(c), S8467, and 5 C.F.R. part l653(A). It is hereby ordered and decreed that Barbara A. Hoover, social security number 174-38- 95 I 6, of 50 Furnace Hollow Road, Shippensburg, Pennsylvania 17257, is awarded the sum of TWENTY-THREE THOUSAND, THREE HUNDRED TWENTY-FIVE ($23,325.85) DOLLARS from the Thrift Savings Plan account of Ronald R. Hoover, social security number 189-38-5352, of 415 Y, Sunset Lane, Shippensburg, Pennsylvania, 17257, as of the date of acceptance and approval of the within Qualified Domestic Relations Order. No additional earnings shall be paid on this amount, but rather at the time of approval of this Qualified Domestic Relations Order, the exact amount stated above shall be transferred into the Alternate Payee's name. The Court retains jurisdiction over this Domestic Relations Order to amend, as necessary, and to establish or maintain its qualifications as a Qualified DOInestic Relations Order under ERISA, 5 V.S.C. S8435(c) and S8467, and 5 C.F.R. l653(A) BY THE COURT, cc: Bradley L. Griffie, Esquire Attorney for Plaintiff H. Anthony Adams, Esquire Attorney for Defendant ~d J. '~~ t? tf- OJ Cl-- , "1_,".h~'_iIIiIiIII-'~ ,- ~~ """....'Ii ~,~~ - " ^~~~j)j!1ilig~D"',[,',Hi,,~_jii.W'~'~ 'ill'" 01 StY- ii:SD CUMJ,.-,-,'L' /.:' ,-'.1..',; I'.'n' .::::,' , I "0 '-~,-j '-J~JUj \ Pi::J\ii\JSYLWINIA ld1ll' ~u - >~ " ~'1 ~. RONALD R. HOOVER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARBARA A. HOOVER, Defendant : NO. 2000-1146 CIVIL TERM : IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER WHEREAS, Ronald R. Hoover, (hereinafter referred to as "Participant") and Barbara A. Hoover, (hereinafter referred to as "Alternate Payee") have agreed to a division of marital property, which Agreement includes a provision for distribution from the Participant's account in the Thrift Savings Plan (hereinafter referred to as the "Plan"), through his employment with the United States Government; and WHEREAS, this Qualified Domestic Relations Order (hereinafter referred to as the "Order") provides for the division and disposition of the marital components of the Participant's account in the Plan, which is a benefit plan sponsored through Participant's current employment with the United States Government, Department of the Army; and WHEREAS, Participant intends to grant the Alternate Payee rights to such benefits in such amounts on the terms and conditions prescribed hereinafter as provided for in the Plan; and WHEREAS, this Order is intended to be a Qualified Domestic Relations Order (hereinafter referred to as "QDRO"), as that term is defined in Section 404(P) of the Internal Revenue Code and Section 206(d)(3) of ERISA. NOW THEREFORE, IT IS ORDERED AND DECREED AS FOLLOWS: I. This Order shall constitute a "Qualified Domestic Relations Order" as defIDed in Section "4l4(P) of the Internal Revenue Code of I 986, as amended. ,,~"'-~~. I , . - "~ ""-., . ~ 2. This Order applies to the following qualified retirement plan: Thrift Savings Plan ("Plan"). 3. Participant's social security number is 189-38-5352 and is a participant in the Plan. Participant's date of birth is January 31,1947, and his current and last known mailing address is 415 Y, Sunset Lane, Shippensburg, PAl 7257. 4. Alternate Payee's social security number is 174-38-9516 is the Participant's spouse. Alternate Payee's date of birth is August 7, 1946, and her current and last known mailing address is 50 Furnace Hollow Road, Shippensburg, P A 17257. 5. Participant's account in the Plan is marital property subject to the distribution by the Court of Common Pleas of Cumberland County, Pennsylvania. Effective immediately upon receipt of this QDRO, and honoring as such by the Plan Administrator, the exact lump sum of TWENTY-THREE THOUSAND THREE HUNDRED TWENTY-FIVE AND 85/100 ($23,325.85) DOLLARS, shall be separately designated in the Plan as Alternate Payee's sole benefit or account. This amount to be rolled over from the Participant's account to an account designated for Alternate Payee is non-taxable as an authorized rollover from Participant's name to Alternate Payee's name. Within the sixty (60) days of such rollover, Alternate Payee shall designate for the Plan Administrator the shelter plan or account into which she wishes to place or rollover these funds, at which time the funds shall be transferred or rolled- over as requested. If the Alternate Payee fails to elect the distribution within sixty (60) days of the date of the acceptance letter, the amount assigned under this Order shall be paid, as soon . ,~ ~", as practicable, ta the Alternate Payee. Such distribution shall be made in cash with applicable withholding for federal income taxes. 6. This Order does not require the Plan to provide any type of form of benefit, or option not otherwise pravided under the Plan; nor require the payment of any benefits for the Alternate Payee which are required to be paid to another Alternate Payee under another Order previously determined to be a Qualified Domestic Relations Order; nor require the Plan to provide increased benefits which result from future contributions to the Plan. Any provision of this Order, which appears to be otherwise shall be null and void and have no effect. 7. In no event shall the Alternate Payee have a greater right than those which are available to the Participant. 8. Upon the death of either the Participant or the Alternate Payee, following implementation of this QDRO, neither party shall be entitled to any benefit or rights in the other parties' share or portion of the Plan or benefits received therefrom. 9. To the extent permitted by the Plan and Section 4l4(p) of the Code, the Alternate Payee may designate a beneficiary to receive payment of the Alternate Payee's remaining interest in the Plan, if any, upon the Alternate Payee's death. Any such beneficiary designation shall be made without regard to any designation by the Participant of a beneficiary with respect to the Participant's interest under the Plan. In the absence of an effective beneficiary designation by the Alternate Payee, or if the named beneficiary predeceases the Alternate Payee, the amount assigned under this Order shall be paid to the Alternate Payee's estate 10. The parties shall promptly submit this Order to the Plan Administrator for determination as a Qualified Domestic Relations Order. The Plan Administrator is the Federal Retirement Thrift Investment Board to whom communications should be sent to: Thrift Savings Plan Service Office, National Finance Center, P.O. Box 61500, New Orleans, Louisiana 70101-1500. 1 I. A copy of this Order shall be mailed promptly, return receipt requested, to the Plan Administrator. If this Order has been predetermined by the Plan Administrator to constitute a Qualified Domestic Relations Order, the Plan Administrator shall promptly carry out its provisions. If this Order has not been predetermined by the Plan Administrator as a Qualified Domestic Relations Order, then the Plan Administrator shall, within a reasonable time after the receipt of this Order, determine whether this Order is a Qualified Domestic Relations Order and notify both the Participant and Alternate Payee of such a determination. Until such time as a determination has been made, the Plan Administrator shall comply with all requirements imposed upon it by Section 414(P)(7) of the Code and Section 206( d)(3)(h) of ERISA. If the Plan Administrator determines that this Order is not a Qualified Domestic Relations Order, then he shall notify the Participant and Alternate Payee of such a determination and reason therefore. 12. The Court of Common Pleas of Cumberland County, Pennsylvania shall retain jurisdiction for enforcement purposes and to make any changes in this Order to the extent required to carry out the intent of the parties as evidenced by their affirmations in their Separation and Property Settlement Agreement, and to establish or maintain '~ ~1lI'll('~-"""-~ ~~ ~m its qualification as a Qualified Domestic Relations Order under ERISA and Title 5 of the Code of Federal Regulations. IT IS INTENDED THAT THIS ORDER SHALL QUALIFY AS A QUALIFIED DOMESTIC RELATIONS ORDER AS SUCH AS DEFINED UNDER SECTION 4l4(P) INTERNAL REVENUE CODE OF 1986, AS AMENDED. WITNESS: -&~ H. Anthony A ams, Esquire )'i I I -~ -^<-, - , '-~'.~" .'..-"- ~&.t)/ Date /~~ RONALD R. ~VER, Participant 13~ a J.h.r7?J-'0- BARBARA A. HOOVER, Alternate Payee "-1 '-, COMMONWEALTH OF PENNSYL VANIA COUNTY OF C \A VV\ \:).ev'[ vliV'-d On this tt'.t'- day of Jv,,- V\..L , 2001, before me, the undersigned officer, personally appeared RONALD R. HOOVER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. .-- , NoIariaI Seal Kerisa J. Lehman, Notary Public Carlisle 80m, Cumberland County My Commission Explres Aug. 25, 2003 t~J~ COMMONWEALTH OF PENNSYLVANIA COUNTYOF c.um.f:,~ i2..L~ Onthis l~daYOf ~ , 2001, before me, the undersigned officer, personally appeared BARBARA A. HOOVER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarlal Seal Dawn Maria Shoop, Nplafy Publio Shlppansburg Boro. Cumb8IIind ~ My Commission Expires Feb. 6, 2004 Owu~ Notary Public >< . '- ."'. - .,' () a (,~ c " ,"r:::.. =-~f V W 2c.:; Q..J p'" c c..:; 0 .. c) , r' 1_'1 ~ O:'} i~E; ..::'~. ''0 ~'q :;;i , 0, ~, ~~-'~~-: .,. . <" ?,,""~~,' " " ' ,,',",