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Home My WebLink About00-02596 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS Of. :+:;F. ''":If. . . OF CUMBERLAND COUNTY STATE OF PENNA. RAYMOND E. CLELAND, JR., Plaintiff No. 2000-2596 CIVIL TERM VERSUS DONNA L. CLELAND, Defendant DECREE IN DIVORCE AND NOW, /s" , IT IS ORDERED AND 2000 A)tt-ov RAYMOND E. CLELAND, JR. DECREED THAT , PLAINTIFF, AND DONNA L. CLELAND , DEFENDANT, 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; The attached Property Settlement Agreement dated April 17, 2000 is hereby incorporated into this Decree in Divorce. By THE cou4J J. ~~~~'OTHONOTA" . . .. . :f. '" 1F.;" "'if. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ ~ ,~~ - .. -, F<", ~~ ~'-.~~~~', - ,'~- ~.;. C,~, ;,> ~,~ - -~' ,-',1' ',- -c' "-"'I:.,..~':" '(Ilt-"'(j'" '?"nt>0:'-":c'~7mm'I~~:"'~d;~t~ jt;';":;~'f'->"'" ',' ""~frr':-'rr'~" I ~ I.' III -OJ"' ,. lJlif"nrtJTli' .. ", ~, ~ .,\ .:. \ , '"\"",; ':'.'(>> <'. . <f:Jd,,~t1 (i/~ ~ 7//~ ~ f/#?t7'71~ ~~~' . ,.~~-- '-' ,-!-.~,.,...,." n_~~" ,.,IL_~~~"'.-m" , ,;o_""""1!ll1!'!~ , q v,___~ ","" , ""~,,"^,e' '1' II:: . ,"" ~ ' . " , c PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this -it day of ~ ---- , 2000, by and between DONNA L. CLELAND, residing at 205 St. John's Church Road, Camp Hill. Cumberland County, Pennsylvania, hereinafter referred to as "WIFE," and RAYMOND E CLELAND, JR., residing at 3125 Old Trail Road. York Haven. York County, Pennsylvania, hereinafter referred to as "HUSBAND." WITNESSE TH: WHEREAS, the parties were lawfully married on ...ru-obev @l. ffiD Cumberland County. Pennsylvania; and in Bowmansdale, WHEREAS, in consequence of disputes and unhappy difficulties. the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution. assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980. and amendments thereto enacted into law on February 12,1988; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration. the parties, intending to be legally bound, agree as follows: 1 , Separation. The parties shall hereinafter live separate and apart, Each shall be free from interference, authority, and control, direct and indirect. by the other as if he or she were single and unmarried. 2. Control of Agreement. The provisions of this Property Settlement Agreement shall govern all past, present, and/or future claims for alimony, support, counsel fees and costs. alimony pendente lite. equitable distribution. or other property rights, and all other claims which the WIFE or HUSBAND has or might have against the other except as set forth hereinafter. ,-~ , . 'h ,~ '" _, < '~ , " " ~ 3, Divorce. Simultaneously with the execution of this Agreement, HUSBAND shall file a Complaint in Divorce in Cumberland County, Pennsylvania. under ~3301 (c) of the Divorce Code, Upon the expiration of ninety (90) days from WIFE'S Acceptance of Service of the Complaint. the parties agree to promptly sign any and all documents necessary to obtain a Divorce Decree under ~ 3301 (c) of the Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling. and Waivers of Notice of Intent to Seek Divorce under ~ 3301 (c) of the Divorce Code, The parties intend that this Agreement shall be incorporated into any forthcoming Decree in Divorce, 4, Real Property. The parties acknowledge that they are the owners as tenants by the entirety of real property, which is also considered marital property, located at 205 St John's Church Road, Camp Hill, Cumberland County, Pennsylvania. The home is presently encumbered by two (2) mortgages in joint name; the first in the approximate amount of Thirty Six Thousand ($36,000,00) Dollars; and the second in the approximate amount of Twenty Seven Thousand Eight Hundred ($27,800,00) Dollars. The parties agree that WIFE shall retain the marital home, including any equity therein. subject to any and all liens and/or encumbrances thereupon, as her sole and separate property, Within six (6) months of the execution of this Agreement, WIFE shall refinance the property into her name alone, thereby removing HUSBAND from any and all liability associated with the marital home, WIFE shall be solely responsible for payment in full of all costs, fees, taxes and/or expenses associated with the refinance process, HUSBAND agrees to cooperate fully with the execution of documents and provision of information necessary to accomplish the above, Upon the successful refinance of the property, HUSBAND shall convey all of his right. title, and interest in and to the marital home to WIFE, and HUSBAND agrees to cooperate with the signing of any deeds. documents or other papers necessary to effectuate this provision of the Agreement WIFE has had exclusive possession of the marital home since approximately January 7, 2000, WIFE shall be solely responsible for timely payment in full of all bills in connection with the marital home, including but not limited to the mortgages, taxes. insurance. utilities, repairs, and general maintenance, and WIFE shall indemnify HUSBAND and hold him harmless with respect to any past, present or future liability in connection with the marital home and/or with respect to her non-payment or non-performance of the above obligations, until such time as the refinance is complete. I'" /l/J u?iVV ~ {)J I r::e.. sfl ft} r.e..-frll (\ 1~ ~ HUS6AND f1&(Zu;5 'M ( ('e-:;;.l~ncg, unH l $.Mil-, fJCf'c. POS,[, f-Sf;'ON of +he.- rnf,n .s <:/'1,'01-. home- desrpd:.e- JW" f/J I r:-e, re -nrv;i nee.. J(.oVl ,/ h ~ 'h rn e.. , Ot 5 {r +h e ffi4 a~ -S.e. + r::v~ I n .(Jar * e.... Ii..) I #l.ol f2ttU a 0 -t' $r'~ {&,'J h e-('ein , ~~ ~ ~ ~ 10M ~ ~ -' ,.-" .(~ ", '~-,,'.'~ ,', ' ", '-j ! i I I , I I I I I , ' .. 5, Spousal SUDport / Alimony. There is a Spousal Support Order currently in effect through the Cumberland County Domestic Relations Office, PACSES Case No. 178101886. HUSBAND is currently paying WIFE the sum of Six Hundred ($600.00) Dollars per month per the Order, a portion of which is designated as contribution to the mortgages on the marital home, WIFE; 8ASII il'Rffl!lelialely \'JitA8Faw Mer sp6I:Jsal :'!I:JI'lI3SR 61stisR, HUSBAND shall continue to pay to WIFE, the sum of Six Hundred ($600,00) Dollars per month for a period of nine (9) months commencing on February 1, 2000, for a total payment to WIFE of Five Thousand Four Hundred ($5,400.00) Dollars, This spousal support / alimony award shall be non-modifiable. In no event shall HUSBAND'S support / alimony payments extend beyond October of 2000, HUSBAND'S wages are currently attached per the Domestic Relations Order, and such attachment shall remain in effect through October 2000, Both parties agree that the wage attachment shall terminate on October 31, 2000, The parties agree that this portion of their Agreement shall be shared with the Domestic Relations Office so as to facilitate the above. Except as inconsistent herewith, each party waives any other past, present and/or future claim for spousal support, alimony, or alimony pendente lite against the other. 6. Protection From Abuse Order. WIFE obtained a Protection From Abuse Order (PFA) against HUSBAND on or about January 27, 2000, The action is docketed to No. 2000-134, Cumberland County, WIFE agrees to withdraw the PFA against HUSBAND upon finalization of the divorce in its entirety, and specifically. as said PFA pertains to the marital home; however WIFE agrees to immediately upon the (..V~U:I?.:p ~e.. to""pICM',.,+ I A Pi '{'orne. Sl<13Ql,llieFl of IRis JI.!jmer+lsn1;, modify the current PFA to permit HUSBAND to be present at the Carriage House Farm only, Furthermore, HUSBAND shall be entitl~d to remove hisJLer150nal belongings from the ({L./efpi- of: Ct?n?plt:ll'7T'ln l?7 I"l?rc.e.., marital home within fourteen (14) days of tl:iis .^,gre.:.",e"l, as more particularly set forth in Paragraph 9 below, which action shall not be a violation of the PFA, 7, WIFE'S Inheritance. During the marriage, WIFE inherited approximately Eighty Thousand ($80,000,00) Dollars from her f;:lther. HUSBAND waives any right, title, interest or claim he may have in and to those funds, and they shall be designated as WIFE'S sole and separate property, 8, Employee. Pension and Retirement Benefits. Each party shall retain as his or her sole and separate property, any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401 (k) plans, employee savings and thrift plans, IRA's, or other similar benefits), whether vested or non-vested, The above shall specifically include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. Furthermore, each party shall be and remain the sole owner of any other asset in his or her --.. -^-\". "'~ , " " . . control not specifically covered by other provisions of this Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of the other party, ~ ~ 9. Personal Property. The parties have acquired certain personal property during the course of their marriage, the majority of which is located in the marital home. With the exception of HUSBAND'S tools, clothing, personal effects, and any other item the parties f1l~tually agree ut&n *w ich k1USBAND llhall . , , '" ~r o:eu;p 'eA.1J'!:>P..lalfYr I 'n remove from the mantal home within fourteen (14) days gf tho 9xes\,ItieR Q ..,pmonl tne' parties 'Pf..orc-& v ' agree that WIFE shall be entitled to retain as her sole and separate property, all household furnishings and other similar property. Specifically, the Percheron horse shall become the sole and separate property of WIFE, and HUSBAND shall execute all papers necessary to effectuate that transfer. Except as inconsistent with this Agreement, it is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under the control of the other. Furthermore, each party agrees to waive any right, title, and/or interest they may have to the property in the possession of the other. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 10, Automobiles. There are no jointly titled automobiles in existence, The parties shall each retain their respective vehicles as their sole and separate properly, subject to any liens and encumbrances, The parties agree to indemnify and hold the other harmless with respect to any encumbrance on their respective vehicles, Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and promptly sign any and all documents necessary to effectuate the provisions of this paragraph. 11. Bank Accounts. Any and all joint bank accounts in the parties' names which existed at separation have been previously divided to both parties' mutual satisfaction, Furthermore, each party agrees to waive any right, title or interest he or she may have in the bank account of the other. 12. Boat. The parties jointly own a pontoon boat that is in HUSBAND'S possession, There is approximately Fourteen Thousand ($14,000.00) Dollars owed on this obligation. The parties agree that HUSBAND shall retain the boat, specifically including any equity therein, as his sole and separate property subject to any encumbrance thereon and WIFE shall cooperate and sign any and all documents necessary to transfer title and/or registration into HUSBAND's name alone. Within six (6) months of the execution of .' ',. this Agreement, HUSBAND shall either sell the boat or refinance it into his name alone, thereby removing WIFE from any and all liability associated therewith, HUSBAND shall be solely responsible for payment in full of all costs, fees, taxes and/or expenses associated with the refinance process or the sale of the boat. WIFE agrees to cooperate fully with the execution of documents and provision of information necessary to accomplish the above, Upon the successful refinance or sale of the boat, WIFE shall convey all of her right, title, and interest to HUSBAND, and WIFE agrees to cooperate with the signing of any titles, documents or other papers necessary to effectuate this provision of the Agreement. 13. Credit Card Debt. There are no joint credit cards in existence and all marital credit card debt has been satisfied in full. Any other credit card debt in existence shall be the sole and separate responsibility of the person who incurred such debt, and that person shall indemnify and hold the other harmless with respect to any and all liability in connection with the same. I ., i .f ,t t , ~ 14, N.B. Liebman Furniture. The parties jointly financed household furniture, all of which is in the marital home, through N.B. Liebman Furniture in the approximate amount of Three Thousand Eight Hundred ($3,800.00) Dollars. Payment was due in January of 2000, however was not made, WIFE enjoys possession of the furniture and therefore shall be solely responsible for payment in full of this obligation, including penalties for late payment, if any. WIFE agrees to indemnify HUSBAND and hold him harmless with respect to any nonpayment or nonperformance of the repayment obligations. The parties agree to remove HUSBAND'S name from this obligation and transfer it into WIFE'S name alone, and further agree to cooperate fully with the signing of all documents necessary to accomplish the above. 15, Miscellaneous Debt. Any debt not specifically listed in this Agreement and/or incurred after the date of separation (January 7, 2000) shall be the sole and separate responsibility of the party who incurred it. 16, Agreement Executed Voluntarily and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A. If fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B. Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; ',~ ~~'-"!i .' \. C, Has given careful and mature thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; E, Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement 17, Release of All Claims. Each party releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred. Moreover, neither party is relieved or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement 18, Holding Other Partv Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereafter incur any liability or obligation on which she is or may be liable. If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and harmless therefrom, WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter incur any liability or obligation on which he is or may be liable. If any claim or action is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom, 19. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, and do or cause to be done, any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure, 20. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is satisfied with the financial disclosures made from the other, The parties acknowledge that although within their right to request, no formal discovery was done in this case, and that they are satisfied with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, and any further enumeration or statement thereof in this I ~ - ,-~.L-J"..' _^- ~_ __~ ~-~ij ,,. '., Agreement is hereby specifically waived, The parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full and proper disclosure, The parties specifically acknowledge that they have been advised by their individual counsel of their right to seek such discovery, however have elected to waive the same, Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto, and understand that this Agreement shall not be subject to modification by the Court, 21. Representation of the Parties. HUSBAND is represented by Johnson, Duffie, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement. WIFE is represented by Diane M, Rupich, Esquire, Each party has carefully read this Agreement and is completely aware not only of its contents but also of its legal effect. Each party acknowledges and accepts that this Agreement, in the circumstances, is fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal Agreement and/or Agreements, 22. Waiver of Rights to Other Party's Estate. Except as provided for herein, HUSBAND and WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B, To receive property from the estate of the other by bequest or devise except under a Will or Codicil dated subsequently to the effective date of this Agreement; C, To act as personal representative of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D. To act as the personal representative under the Will of the other unless so nominated by a Will or Codicil dated subsequently to the effective date of this Agreement; E, To claim a family allowance in the estate of the other. ,~- -, ~ ; ~"~.~"",-,--,c ii, ~ 'I I{ ,r '. . ] ,\ 23, Containment of Entire Agreement Herein. This Agreement supersedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage, This Agreement contains the entire agreement of the parties. 24, Partial Invalidity. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. 25, Effect of Reconciliation. Cohabitation or Divorce Decree. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to the parties. This Agreement shall survive any such final judgment or Decree of Divorce, Both parties shall have all rights and enforcement under applicable law including the Pennsylvania Divorce Code. This Agreement shall also remain in full force and effect even if the parties effect a reconciliation, cohabitate as Husband and Wife, or attempt to effect a reconciliation. 26, Modification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modify the Agreement 27. No Waiver of Default. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 2/l. Attorneys Fees and Expenses. Each party shall be responsible for their own attorneys fees and expenses, 29. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other, any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents and do or cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and purposes of this Agreement If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. . > , ',,-. I" . I ~~ 30, Bankruptcy. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under the provisions of this Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependents, Should either party file a Petition under Title XI of the United States Code, or should a petition be filed against either involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party. 31, Law of Pennsvlvania Applicable. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 32, Date of Agreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the Agreement on the same date, Otherwise, the effective date will be the date that both parties execute the Agreement if they execute on the same date, 33, Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding on and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties. IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written, WITNESS: jj /;-/7- OtJ Date ~:{ f2dOA oL DONNA L CLELAND Y!::r>~ (Al O~ Y-/o-oO . Date ~,~ (Jd.L"1-./ RAY ND E, CLELAND, JR. ' :132166 "' I.. " '... ~ ~~.M>_,_-, -I: I' I I, i COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss: On this, the I-l- day of ;j'~ ,2000, before me the undersigned officer, personally appeared DONNA L. CLELAND kncfwn to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. !> ('- - . ';-~'-,--"." ?'::~:,.:;";::,,~ ,.' - :~ ,/.- ~'i :t;-- ~.'-'"' . "'>,<~ NOrAi!lAl ~ DIANE II\. 1W~!CIl, I"*'Y Pub!lc 1tarrisI>uIt!, c..upMn Ownly, lOA "., ~Illlfilon E:lpl'" f<'ll>. ~5, 2002 COMMONWEALTH OF PENNSYLVANIA COUNTY OF (7 iL/'I./cdd d-lI..rl ss: , Yo, 11 'L On this, the /0 "'""day of UI ,2000, before me the undersigned officer, personally , appeared RA YMOND E. CLELAND, JR., known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~l~bl!il.lt'Hl~UII4, "" }/' <,". ...\.... <.: .~_r".,li'\.~- ~l "f", ...;:;.'~<<r-~n"'O"ll-h,,~~ J... .</ } 6" .<~!:i~Wj" " .(......r:..;' ? '-:'$I'":""'f.;, '.7 :: 1'>-~~~ " ~'::tf>.- * ;:::[!'+>",Of, : .~ /\~~~y"./!/ !.;.'. ,; ,..~, '. IJ.:J ~ ".... ..~.. .n~V', ..-:. '-<;; 7~ ~~~~,><"'~.. '<.\'V ,,,,5 . ,~1 '-'1<1' ..., '"-" ~.;;" "Jo.-~l i, ", ~\~"~" :fi.'mml~~l~~ Notarial Seal I{Jistee K Myers, NolaI)' Public LeltlOyne Bom, CumbMand County My CommissIon Expires Dec. 2, 2002 Member, Pennsylvania A~Oclatlon of Notaries ~""~"<^''' lMI." Illi:Ihiifli~ -II!, o~ "~ ,~ , ,~ - .......~~~... c~_ .~," , ~_ "J Biumti- - '" ~ - "'~"'" ~~-" , "'-,",,",,'" -~ < ,,' ~ "f (') Co c: a 0 s:: """ Tl ""067 mpl c- ::;:1 It ~"") i1;;;:o ,++ '.OiYt ,~ :.U? n -u --::::-tC} :ZCl :r:~ -,," -~~ -c' >-'(') j;:J c: ry C)C11 2: ,--j ~ c- .'" (.) :n -< l) ,/ -" ", '-'-, w , !], " -,''''-' . . Plaintiff IN THE COURT OF CCMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2596 CIVIL TERM RAYMOND E. CLELAND, JR., V5. DONNA L. CLELAND, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information; to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant's counsel on May 3, 2000 and filed with this Court on May 12, 2000. 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff August 7, 2000 by the defendant July 31, 2000 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section Waiver of Nbtice filed concurrently herewith and 3301 (d)(l)(i) of the Divorce Code signed by Plaintiff on August 7, 2000 and by Defendant on July 31, 2000. ~w.~ Attorney for' Plaintiff/~~ Keirsten W. Davidson Atty 10 #: 78243 :iillli!~~~I!l!liil~ibj;j~~n#t*,.li'-,,;!f-~"'l~""'''''''-''''-''- !I.l1iW~""-' d(j~~iliAAI...,;;d!;i~<~ loLoJ I. 1 [I,II'1lllll1 I ~~~.... ,_,_", ~"',_ ~,,__,"_"?:'" ~r__""",""'~_" ,,,,, r" '1__, ~" ~'!iblIllIlIi ~'''''!!IIII~liI!liI!lI!8Wli -.......1liiIIIIiIiIt . (') = 0 C 0 'Us:: "T] "" I.J:! C ,-, ~rn :tl 17) ()':j :-!) Z' r- C0~ .C- ~38 -<'7 r:~' (',I ;:::0 "'tJ :':::-t(::) ):> ,;~: =Ff zO ~ '0 ~?,('~ :l>c ry om ~ r:- 'j;! c,.) ;;0 -< ~ - , .' Johnson, Duffie, Stewart & Weidner By: Keirsten W, Davidson LD, No, 78243 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E, CLELAND, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 2000- ;l6'9~ CIVIL TERM v, CIVIL ACTION - LAW DONNA L. CLELAND, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case 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 pages by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 << ~ -,. , -" ~<;~'.. , Johnson, Duffie, Stewart & Weidner By: Keirsten W, Davidson LD, No, 78243 301 Market Street P. 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E, CLELAND, JR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO,2000, .2 :s9(, CIVIL TERM v. CIVIL ACTION - LAW DONNA L. CLELAND, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301(dl OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Raymond E. Cleland, Jr., by and through his attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Donna L. Cleland: 1. The Plaintiff is Raymond E, Cleland, Jr., an adult individual, residing at 3125 Old Trail Road, York Haven, York County, Pennsylvania, 2, The Defendant is Donna L. Cleland, an adult individual, residing at 205 St. John's Church Road, Camp Hill, Cumberland County, Pennsylvania. 3, The Plaintiff and Defendant were married on October 27, 1990 in Bowmansdale, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5, There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. .r: , , ~~~!J:;,':! , 6, The marriage is irretrievably broken. 7, The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301 (c) of the Divorce Code, JOHNSON, DUFFIE, STEWART & WEIDNER By:~LJ.~ Keirsten W, Davidson :131267 ,-- -"-~_1<i,j VERIFICA nON I verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.SA ~4904, relating to unsworn falsification to authorities. Date: 9" -/c? -Cl (J ~~~/~ dL_~ aymond E. Cleland, Jr, ~, - -II , , --"""',-: . , I I I I I I Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson Ln No, 78243 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff RAYMOND E, CLELAND, JR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 2000- :2 s-9(, CIVIL TERM v. CIVIL ACTION - LAW DONNA L CLELAND, IN DIVORCE Defendant AFFIDA vIr RA YMOND E CLELAND, JR., being duly sworn according to law, deposes and says: 1 , I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling, 2, I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3, Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court, 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. 94904, relating to unsworn falsification to authorities, Date: t/-/Cl-(},1 ~;;on::~:::!{J~ iili;0.(.,"O-",,~,~ '~_. ... "L_"'J1""-"~""'-~""'";";" . r& -.." "- ~\S ~~ ~ --~- JJmn,~, ,"~,"',,~_1Jl11!t_ ,"=, ~ ~c_"_,,,, .r-_" ~~ ~." .diL,[~~-.;.~ . _C-',," I' ,- -,,,, _~ , .....,..,....."'~""""..... ,,,"',-,- ."" ~, <~, "',,,--- J, .', S~:L~ .,::;--- ..-/ (.f) -< ~ ....."'- .~,-". '" z() )>.C" C 7 ,-i -< (') c .~ c:: ( :-r;-::-. ",:) ~.J f',,_) .~ .... -",(-) <-:.;i"-n ~~ -< IIiiiiiIIlii ~ .. '- ti7 --.I 6~~ t r - Ill: ~ - ~, ' _:-~" 1iA !; ~ '. f' , . Johnson, Duffie, Stewart & Weidner By: Keirsten W, Davidson I.D, No, 78243 301 Market Street p, O. Box 109 Lernoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff 'I- e Ii j,! I" I.: r! rt CIVIL ACTION - LAW ;" i-~ I I' Il ~ ti II i 1\ f~ r1 G ~ I I ~ ~~ , I,' I Ii " '1 RAYMOND E. CLELAND, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 2000-2596 CIVIL TERM v. IN DIVORCE i ~. DONNA L. CLELAND, Defendant ACCEPTANCE OF SERVICE I, Diane M. Rupich, Esquire, attorney for Defendant, Donna L. Cleland, hereby accept service and acknowledge receipt of the Complaint in Divorce filed by the Plaintiff in the above captioned divorce action, Date: May L, 2000 :131267,7 L~l~' , ~l7i1l1111ili1iliiiii1___llII'JoI~ . ~JJIT,~~,J))" ,_:" ,'1 ~~ _. ~"._ ""_,~,. c,~T,)"-'-'_,_ _,' r'ell ,1",- _, , O' , .~_ ~-","~~~ ," -'"-.,,, " ~' - . , -,,";;,.,, ,,~ '- () 0 ~ C CJ 5: :x ,-I -ofJ] :Do ~Lll nlrn -< nlr~ Z:TJ Z~ .-:,:!m en"", N :,~ry ~c5 '30 --0 -1- -r~ "- R-' <?o ~ :,,;('5 =0 ~ om Pc: ~ N ~ 0::> "' IW -,,- ~ " ,--. -~ -"" , . , . Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street p, 0, Box 109 Lernoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E CLELAND, JR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2596 CIVIL TERM v. CIVIL ACTION - LAW DONNA L CLELAND, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 27, 2000. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint 3, I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree, 4, I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Date: Z\"1 pcoC:> :136451 .' -0,. ,,~__",,"'""'__" . ;-itiI- i1i:JtlliLillD:~ l.~ll_( .rlJmL..~_" ,_I ~," ,~, .~ :-"'."'1: ,-" ' .. , '--~li =.':'_iri-r" ;"-..,.-- ~.. . '{,<O,-'",'''_' "--,-,-",,,,~<,,-,~ -~~~,,'- ,~,,~, " ..,--"-,, " "<,",,, ," ,'~> - ..,~ _co', ',.," '~ ,', ,. ,-", . 0 L":> 0 C a " <:: 1:>0 -~ "Ow c:: :~~iD Olrn G"") 2:~, ~ "~"rn ;;'::5? .;::- ';'il-""j C/) ~. (j6 =<-..:::. ~v " ~[, ='l1' ~c:; == ~o :;>0 ~ Om C j;! 2: r::- ~ :J;] C,o) -< I. ,__~,<, ffi ;' , , "'J',i . . , . Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E CLELAND, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 2000-2596 CIVIL TERM v. CIVIL ACTION - LAW DONNA L. CLELAND, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENT/ON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. 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 Waiver are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, ~4904 relating to unsworn falsification to authorities. Date:-tl2tatto ~~-/~~~r ymotid E lelan, lain :136451,2 i..;~l"~ 1lI!~.~ 10'00", ,','~" "'_ '("'(-'.lrr1inllli.n~- '~M ,,, "',"_ ,,"_ ~ '~iIll . ,,~ ,~,-,,,,. ~ " - . ~" ,,-", ,"~ .,~ . C) 0 '" ,~ ~ 0 " !>> -~ -Om ~ - -';1i"D r;pq; Ci:l f"i-n z5=' {iT (j)z .r,:- ~;'f(.J ;::>0 " .~-r, :;::: 5:0 :!€o :J: ~o >2 r;:;> orn --1 Z c- 53 ~ C41 -< " i,:i< lilii_ i ",. ,jP , _' -'-~"'- - <-"'-,.---~-- --'~.'''-^,,,,, '" ^. ;~~"a~,,---,-' -, ~. _ ..'<_~"..,~"~V"" <_'~",,",_, -0<' "'~' ""=' " '_ . . , . Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD, No, 78243 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E. CLELAND, JR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-2596 CIVIL TERM v, CIVIL ACTION - LAW DONNA L. CLELAND, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1, A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 27, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint 3, I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree, 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Date: 1-3/-j() flwuza X &.dfl--l4 Donna L. Cleland, Defendant :136451,3 ,{.<-:<, ; ''''tlf-^->-"''''-.'''- -J ,,[ J.IIJ_,Q., ,,_ "____,JQ-co""""",~ __~ ~~ ,~~ '''' ,,_~ '~ . .' lf~ , Y"'""",r_'.~. _~<" '-'~~~-";.-~ ~_... ,- ----,--,",', ~ ~, . ,-~'<' > ,'" '- ..1 .. o ~.; -of;"::. rn;::; Z" 7..::F (/).:- . -'< :" ~:::C; ~f;~ '-- ~~ ..,,' '~r~ll ~~; () " ~~ (r~) I Gj ;,.) (J1 I'" ~ .. . , ..,_.. Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff RAYMOND E CLELAND, JR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 2000-2596 CIVIL TERM v. CIVIL ACTION - LAW DONNA L CLELAND, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1 , 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. ~4904 relating to unsworn falsification to authorities, Date: 1- 3/-()() lQo/7flO ~ ~ Donna L. Cleland, Defendant :136451,4 liiIl' "';"'""""'--'~-""'~'''';""'''-'-' umL.J m' rlllMlnr HI 111I!!1lIlJ,I!If,~ - -'-Ai.' ..~" 'ill . ,'-- ~-' ~-" --~,,--". "'", ^ --'~ - " >,< ^', ,-~ - ~ ..-- J .-". . .' ., (j ~ "".Qf;-; It,,,, ~i:_" ~~~': ~~:~: >c:~ z -I -< c, C,') "'" c;') I -;:J I~,,) (e' " , - ~ ll,~,'" " . ,- " ,--,.""~,--:!';d ",-",o-,J,,"",,_h'<' - - .""'~ .; -" -- "-',. ,~ ~ 4 , ... AUG 1 8 20~ RAYMOND E CLELAND, JR, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000-2596 CIVIL TERM v, CIVIL ACTION - LAW DONNA L CLELAND, IN DIVORCE Defendant/Respondent ORDER OF COURT AND NOW, this c1//It: day of ~~~ ' 2000, upon consideration of the attached Petition for Special Relief for Con mpt of Property Settlement Agreement, IT IS HEREBY ORDERED that a hearing is scheduled for / ( , 2000, at !; J d o'clock ~M. in Courtroom No. 'f , Cumberland County Courthouse, Carlisle, Pennsylvania, BY THE COU~ J J. ~ LcrpLQD1'{JJ. 'iJ-cX)-() 0 RJ{!3 ~illii u '-"""'-0""" ,_-" "'ri ,-- HI,[lHFFICE O'r- ,-,,-~, "" 'nlARY !"'-,',J:r":\.)j\",-.l GO AUr; 2 I PH 2: I 0 CUMBERLi\I'1D COUN1Y PENNSYLVANIA II 1m I nlllll!lo IILJ!iiM!L ,,' ."",u,u" "'" _' ," ~ . .q~ . ' I, "..', . ,~---'-~ ~ . -~ , ",-,.. ... __c'''.""rh ,.- _~J' Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No, 78243 301 Market Street p, 0, Box 109 Lemoyne, Pennsylvania ] 7043-0] 09 (717)76]-4540 Attorneys for Plaintiff RAYMOND E, CLELAND, JR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner NO, 2000-2596 CIVIL TERM v, CIVIL ACTION - LAW DONNA L, CLELAND, IN DIVORCE Defendant/Respondent PETITION FOR SPECIAL RELIEF FOR CONTEMPT OF PROPERTY SETTLEMENT AGREEMENT Petitioner, Raymond E, Cleland, Jr., by and through his attomeys, Johnson, Duffie, Stewart & Weidner, hereby files this Petition for Special Relief and in support thereof avers as follows: 1, Petitioner is Raymond E. Cleland, Jr., who resides at 3125 Old Trail Road, York Haven, York County, Pennsylvania, hereinafter referred to as "HUSBAND." 2, Respondent is Donna L Cleland, who resides at 205 St John's Church Road, Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE." 3. On or about April 27, 2000, HUSBAND filed a Complaint in Divorce against WIFE, which action is docketed to No, 2000-2596, 4, On or about May 3, 2000, WIFE's counsel accepted service of the Complaint in Divorce, 5, On or about April 17, 2000, the parties entered into a comprehensive Property Settlement Agreement, a copy of which is attached hereto and marked as Exhibit "A." ~1.": I: I l: 6, Paragraph 4 of the above referenced Agreement provides that WIFE shall retain the marital residence located at 205 St John's Church Road, Camp Hill, Cumberland County, Pennsylvania, and that she shall be solely responsible for timely payment in full of all bills in connection with the marital home, including, but not limited to, the mortgages, taxes, insurance, utilities, repairs, and general maintenance. Paragraph 4 of the parties' Agreement further provides that within six (6) months of the execution of the Property Settlement Agreement, WIFE shall refinance the property into her name individually, thereby removing HUSBAND from any and all liability associated with the marital home, I' (, !J , '1 q " 1:; ;i r [,; 7. There are two (2) mortgages encumbering the marital residence, both of which are WIFE's responsibility pursuant to Paragraph 4 of the parties' Property Settlement Agreement p I: ii Ii ~! i. I-j ij Ii 8, HUSBAND recently learned that WIFE is at least two (2) months delinquent on the mortgage payments, in the approximate amount of $1,300.00. i i I, 1 ,f 9. The parties' mortgage company has threatened to withdraw funds from HUSBAND's individual bank account in order to cover the costs associated with the unpaid mortgages, 10, HUSBAND notified WIFE of the above immediately upon learning of the deficiency, however to date, WIFE has failed to pay the deficiency, Attached hereto and marked as Exhibit "B" is a copy of correspondence dated July 14, 2000 to WIFE's counsel. 11. The above obligations belong solely to WIFE, as she has agreed to indemnify HUSBAND and hold him harmless with respect to any and all liability in connection with the marital home and/or with respect to her nonpayment or nonperformance of the mortgage obligations. 12, The home is at risk of entering foreclosure which would severely prejudice not only HUSBAND's but both parties' credit 13. Paragraph 14 of the parties' Property Settlement Agreement provides that WIFE shall be solely responsible for payment in full of the outstanding obligation to N.B. Liebman Furniture, which approximates $2,500,00, ll:illijifll~,,\ Ii J 14, WIFE further agreed to remove HUSBAND's name from this obligation and transfer it into her name individually, and indemnify HUSBAND and hold him harmless with respect to any nonpayment or nonperformance of the repayment obligations in connection with this debt I r 15. HUSBAND continues to receive delinquent notices from N.B. Liebman Furniture regarding this account, evidencing WIFE's nonpayment 16, Payment of this debt in full, is WIFE's responsibility. 17. WIFE's nonpayment of this obligation severely prejudices HUSBAND's credit 18, Paragraph 15 of the parties' Property Settlement Agreement provides that any debt not specifically identified in their Agreement shall be the sole and separate responsibility of the party who incurred it Furthermore, Paragraph 18 of the parties' Agreement provides that WIFE warrants to HUSBAND that she has not incurred any liability or obligation on which HUSBAND is or may be liable, Paragraph 18 further provides that if any claim or action is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether founded or not founded, and she shall hold him free and harmless therefrom, 19, During the marriage, WIFE inherited approximately $80,000,00 from her father, which funds were designated as her sole and separate property under the terms of the parties' Agreement 20. After WIFE received the inheritance funds in 1998 in order to pay the inheritance tax, the parties assumed a second mortgage on the marital home in the approximate amount of $28,000,00. 21. The parties attended a spousal support conference on or about February 11, 2000, at which time WIFE represented that all inheritance taxes on the above referenced funds had been paid in full. 22. Subsequent to the entry of the parties' Property Settlement Agreement dated April 17, 2000, HUSBAND received notification from the Internal Revenue Service that such inheritances taxes had not been paid, and that in fact the parties still owed $33,560,25. A copy of the Notice from the Internal Revenue Service is attached hereto and marked as Exhibit "C," 23. Immediately upon receipt of this Notice, HUSBAND contacted WIFE in order to discuss this, Attached hereto and marked as Exhibit "D" is correspondence dated June 1, 2000 from HUSBAND's attorney to WIFE's attorney. 24, HUSBAND discovered that WIFE signed and mailed a check to the Internal Revenue Service in early 1999 for $28,444,00 in order to pay all inheritance taxes, When the Internal Revenue Service attempted to cash the check, there were insufficient funds in WIFE's Members' First Bank account to the tune of approximately $500,00, and therefore the check was returned to WIFE. 25, WIFE neglected to resubmit the payment of these inheritance taxes to the Internal Revenue Service, 26, On or about June 9, 2000, HUSBAND confirmed with WIFE that she indeed has sufficient funds to pay the inheritance tax and would do that within the next few weeks. Attached hereto and marked as Exhibit "E" is a copy of correspondence from HUSBAND's attorney to WIFE's attorney dated June 9, 2000, 27, On July 12, 2000, HUSBAND followed-up on his prior inquiry regarding the IRS debt, and also sought to confirm that WIFE had transferred the N.B. Liebman debt into her name individually, A copy of correspondence dated July 12, 2000 is attached hereto and marked as Exhibit "F." 28. Most recently, on or about July 24, 2000, HUSBAND received notification from the Internal Revenue Service that the parties owe $34,653,70 in unpaid inheritance taxes, which figure now includes additional penalties for non/late payment A copy of that Notice is attached hereto and marked as Exhibit "G," 29, HUSBAND has advised WIFE of all of the above, however WIFE refuses to satisfy the outstanding obligations which action is in direct violation of the parties' Property Settlement Agreement 30, WIFE has not complied with the terms of the parties' Property Settlement Agreement 31. WIFE's failure to comply has and continues to severely prejudice HUSBAND's financial condition. ~~ .......ailiilli..L j ri J J 1 , j,'i 'I I I I I '! i 32, Additionally, due solely to WIFE's breach of the Property Settlement Agreement, HUSBAND has been forced to incur attorney's fees in the amount of $438.00 thus far, in order to attempt to enforce the parties' Property Settlement Agreement Attached hereto and marked as Exhibit "H" is an itemized listing of HUSBAND's attorney's fees thus far in connection with this matter. 33, Paragraphs 18, 19 and 29 of the parties' Property Settlement Agreement provide that if either party fails to comply with the terms of the Property Settlement Agreement, the breaching party shall pay all attorney's fees, costs and other expenses reasonably incurred by the non breaching party, '1 'I i I I 1 WHEREFORE, HUSBAND respectfully requests that the Court enter an Order: ,1 J I I iJ A, Finding WIFE in contempt of the parties' Property Settlement Agreement; B, Directing WIFE to pay in full any and all outstanding mortgage payments for the property located at 205 St John's Church Road, Camp Hill, Pennsylvania, and directing WIFE to maintain current payments with respect to the same; in the alternative, WIFE should place the home on the market for sale immediately and be solely responsible for any and all costs, fees, taxes, penalties and other settlement charges in connection with the sale. All proceeds should be used to pay the outstanding obligations under the parties' Property Settlement Agreement C. Directing WIFE to either pay in full the N.B. Liebman furniture debt, or execute whatever documents necessary so as to remove HUSBAND from any and all liability in connection therewith; D, Directing WIFE to immediately pay the inheritance taxes owed to the Internal Revenue Service, or execute whatever documents necessary to remove HUSBAND from any and all liability in connection therewith; E. Directing WIFE to be solely responsible for payment in full of HUSBAND'S attorney's fees in connection with enforcing the parties' Property Settlement Agreement which total $438.00 as of the date of this Petition; - ~ + ~ , ~" F. Directing any other relief this Court deems appropriate, Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: ~lJ.~ Keirsten W. Davidson : 136960 -= ~., 0 ,','-' ,,' --",-,', . "',"~~"~_~ ~-"_~ ~"-<-,- 'ro-' ''''''''''''. VERIFlCA TlON I, Raymond E. Cleland, Jr., do verify that the statements made in the foregoing Petition for Special Relief are true and correct to the best of my knowledge, information and beliet I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. 4- ./~~L4 ' Raymond E Cle an ,Jr.' ' Dated: <i? \ IlOl~ - "" -~ ~-~~ 1 , PROPERTY SET.TLEMENT AGREEMENT THIS AGREEMENT, made this -1.1- day of ~~ , 2000, by and between DONNA L. CLELAND, residing at 205 SI- John's Church Road, Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE," and RAYMOND E. CLELAND, JR., residing at 3125 Old Trail Road, York Haven, York County, Pennsylvania, hereinafter referred to as "HUSBAND." WI TNESSETH: WHEREAS, the parties were lawfully married on C1:'h)bev;ll f BSD Cumberland County, Pennsylvania; and in Bowmansdale, I ,I \ WHEREAS, in consequence of disputes and unhappy difficulties, the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution, assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980, and amendments thereto enacted into law on February 12, 1988; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration, the parties, intending to be legally bound, agree as follows: 1. Separation. The parties shall hereinafter live separate and apart, Each shall be free from interference, authority, and control, direct and indirect, by the other as if he or she were single and unmarried, 2, Control of Agreement. The provisions of this Property Settlement Agreement shall govern all past, present, and/or future claims for alimony, support, counsel fees and costs, alimony pendente lite, equitable distribution, or ?ther property rights, and all other claims which the WIFE or HUSBAND has or might have against the other except as set forth hereinafter. -~1 " I """"-, 3, Divorce. Simultaneously with the execution of this Agreement, HUSBAND shall file a Complaint in Divorce in Cumberland County, Pennsylvania, under g3301(c) of the Divorce Code, Upon the expiration of ninety (90) days from WIFE'S Acceptance of Service of the Complaint, the parties agree to promptly sign any and all documents necessary to obtain a Divorce Decree under 9 3301 (c) of the Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice of Intent to Seek Divorce under 9 3301 (c) of the Divorce Code, The parties intend that this Agreement shall be incorporated into any forthcoming Decree in Divorce. 4, Real Property. The parties acknowledge that they are the owners as tenants by the entirety of real property, which is also considered marital property, located at 205 St John's Church Road, Camp Hill, Cumberland County, Pennsylvania. The home is presently encumbered by two (2) mortgages in joint name; the first in the approximate amount of Thirty Six Thousand ($36,000,00) Dollars; and the second in the approximate amount of Twenty Seven Thousand Eight Hundred ($27,800.00) Dollars, The parties agree that WIFE shall retain the marital home, including any equity therein, subject to any and all liens and/or encumbrances thereupon, as her sole and separate property, Within six (6) months of the execution of this Agreement, WIFE shall refinance the property into her name alone, thereby removing HUSBAND from any and all liability associated with the marital home. WIFE shall be solely responsible for payment in full of all costs, fees, taxes and/or expenses associated with the refinance process. HUSBAND agrees to cooperate fully with the execution of documents and provision of information necessary to accomplish the above. Upon the successful refinance of the property, HUSBAND shall convey all of his right, tille, and interest in and to the marital home to WIFE, and HUSBAND agrees to cooperate with the signing of any deeds, documents or other papers necessary to effectuate this provision of the Agreement WIFE has had exclusive possession of the marital home since approximately January 7,2000, WIFE shall be solely responsible for timely payment in full of all bills in connection with the marital home, including but not limited to the mortgages, taxes, insurance, utilities, repairs, and general maintenance, and WIFE shall indemnify HUSBAND and hold him harmless with respect to any past, present or future liability in connection with the marital home and/or with respect to her non-payment or non-performance of the above obligations, until such time as the refinance is complete. . _ ,,-/If! ,d)'VS- , r.' . Ire- s1J~)1 rLffl/(\ .f~kJ otc.-. HuSd;8;\JD f16iZ~ '+ ~~ reof;,le1eflL.€- l.mH l ~6h DE.G pOS56SS/0N Df +he- VY\f,rt ' s ,setA'v./.. hOfTle- oU..spif...e- nfc!: / , 11 (e- (e it /Iii r,c!,e. ' J f) h 8.g- +-/m e- C( 5 vv. +h e. fffI' 6(5 se + fbr-tt. ;'n -rarar;('ap -rh e.... tJJ /~ol r~'a I o.f St'y., {lo~ h e-(V2t n .. . , - , , , ""~o_~. ~0 ~ ~ 5. Spousal SUpDort I Alimony. There is a Spousal Support Order currently in effect through the Cumberland County Domestic Relations Office, PACSES Case No, 178101886, HUSBAND is currently paying WIFE the sum of Six Hundred ($600,00) Dollars per month per the Order, a portion of which is designated as contribution to the mortgages on the marital home. W1F5 SAslI ifl9F1'1eaistely 't:ithaFaw Mer spel:lssl :;1:l~~6Ft astiQR, HUSBAND shall continue to pay to WIFE, the sum of Six Hundred ($600,00) Dollars per month for a period of nine (9) months commencing on February 1, 2000, for a total payment to WIFE of Five Thousand Four Hundred ($5,400,00) Dollars, This spousal support / alimony award shall be non-modifiable, In no event shall HUSBAND'S support / alimony payments extend beyond October of 2000, HUSBAND'S wages are currently attached per the Domestic Relations Order, and such attachment shall remain in effect through October 2000, Both parties agree that the wage attachment shall terminate on October 31, 2000, The parties agree that this portion of their Agreement shall be shared with the Domestic Relations Office so as to facilitate the above. Except as inconsistent herewith, each party waives any other past, present and/or future claim for spousal support, alimony, or alimony pendente lite against the other, ~ IW 6. Protection From Abuse Order. WIFE obtained a Protection From Abuse Order (PFA) against HUSBAND on or about January 27, 2000, The action is docketed to No. 2000-134, Cumberland County. WIFE agrees to withdraw the PFA against HUSBAND upon finalization of the divorce in its entirety, and specifically. as said PFA pertains to the marital home; however WIFE agrees to immediately upon the {.l<!!U'p+-- ~e. to".,plCAA'"i- If"\ Piv'urce.. SJEsQ\,JtieR of tRis Agr8gI+lQn~, modify the current PFA to permit HUSBAND to be present at the Carriage House Farm only. Furthermore, HUSBAND shall be entitled to remove hisJLersonal belongings from the reoeip f- '" f- &7/??p/aI'7r /n bh'V'iJrce.. ' marital home within fourteen (14) days of thii: J\!jFeeIIlI!lIJt, as more particularly set forth in Paragraph 9 below, which action shall not be a violation of the PFA Q1S( ~ 7, WIFE'S Inheritance. During the marriage, WIFE inherited approximately Eighty Thousand ($80,000,00) Dollars from her father. HUSBAND waives any right, title, interest or claim he may have in and to those funds, and they shall be designated as WIFE'S sole and separate property, 8. Employee. Pension and Retirement Benefits. Each party shall retain as his or her sole and separate property, any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401 (k) plans, employee savings and thrift plans, IRA's, or other similar benefits), whether vested or non,vested, The above shall specificaily include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder, Furthermore, each party shail be and remain the sole owner of any other asset in his or her . ~ , ~ ~' ~- ~,: control not specifically covered by other provisions of this Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of the other party, )Jl; ~ 9. Personal Property. The parties have acquired certain personal property during the course of their marriage, the majority of which is located in the marital home, With the exception of HUSBAND'S tools, clothing, personal effects, and any other item the parties lJ'liJtually agree. u on w ich /~USBAND shqll V\,~T-e- r (D!.u P eA.>> l'hp"ta.t"n t' 01 remove from the marital home within fourteen (14) days ' , the parties 'Pf"OrCe-- . agree that WIFE shall be entitled to retain as her sole and separate property, all household furnishings and other similar property, Specifically, the Percheron horse shall become the sole and separate property of WIFE, and HUSBAND shall execute all papers necessary to effectuate that transfer- Except as inconsistent with this Agreement, it is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under the control of the other- Furthermore, each party agrees to waive any right, title, and/or interest they may have to the property in the possession of the other. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph, 10, Automobiles. There are no jointly titled automobiles in existence, The parties shall each retain their respective vehicles as their sole and separate property, subject to any liens and encumbrances, The parties agree to indemnify and hold the other harmless with respect to any encumbrance on their respective vehicles. Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and promptly sign any and all documents necessary to effectuate the provisions of this paragraph, 11, Bank Accounts. Any and all joint bank accounts in the parties' names which existed at separation have been previously divided to both parties' mutual satisfaction. Furthermore, each party agrees to waive any right, title or interest he or she may have in the bank account of the other- 12, Boat. The parties jointly own a pontoon boat that is in HUSBAND'S possession, There is approximately Fourteen Thousand ($14,000.00) Dollars owed on this obligation. The parties agree that HUSBAND shall retain the boat, specifically including any equity therein, as his sole and separate property subject to any encumbrance thereon and WIFE shall cooperate and sign any and all documents necessary to transfer title and/or registration into HUSBAND's name alone, Within six (6) months of the execution of ~I , ~ ~ "-. '~M' this Agreement, HUSBAND shall either sell the boat or refinance it into his name alone, thereby removing WIFE from any and all liability associated therewith, HUSBAND shall be solely responsible for payment in full of all costs, fees, taxes and/or expenses associated with the refinance process or the sale of the boat WIFE agrees to cooperate fully with the execution of documents and provision of information necessary to accomplish the above, Upon the successful refinance or sale of the boat, WIFE shall convey all of her right, title, and interest to HUSBAND, and WIFE agrees to cooperate with the signing of any titles, documents or other papers necessary to effectuate this provision of the Agreement 13, Credit Card Debt. There are no joint credit cards in existence and all marital credit card debt has been satisfied in full. Any other credit card debt in existence shall be the sole and separate responsibility of the person who incurred such debt, and that person shall indemnify and hold the other .harmless with respect to any and all liability in connection with the same. 14, N.B. Liebman Furniture. The parties jointiy financed household furniture, all of which is in the maritai home, through N,B, Liebman Furniture in the approximate amount of Three Thousand Eight Hundred ($3,800,00) Dollars, Payment was due in January of 2000, however was not made, WIFE enjoys possession of the furniture and therefore shall be solely responsible for payment in full of this obligation, including penalties for late payment, if any. WIFE agrees to indemnify HUSBAND and hold him harmless with respect to any nonpayment or nonperformance of the repayment obligations. The parties agree to remove HUSBAND'S name from this obligation and transfer it into WIFE'S name alone, and further agree to cooperate fully with the signing of all documents necessary to accomplish the above, 15, Miscellaneous Debt. Any debt not specifically listed in this Agreement and/or incurred after the date of separation (January 7, 2000) shall be the sole and separate responsibility of the party who incurred it 16, Agreement Executed Voluntarilv and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A, If fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B, Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; , , -'=~,~ .:, C, Has given careful and mature thought to the making of this Agreement; D, Has carefully read each provision of this Agreement; E. Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement 17, Release of All Claims. Each party releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred, Moreover, neither party is relieved or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement 18, Holding Other Party Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereafter incur any liability or obligation on which she is or may be liable, If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and harmless therefrom WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter incur any liability or obligation on which he is or may be liable, If any claim or action is brought attempting to hold HUSBAND liabie for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom. 19. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, anq do or cause to be done, any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 20, Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is satisfied with the financial disclosures made from the other. The parties acknowledge that although within their right to request, no formal discovery was done in this case, and that they are satisfied with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, and any further enumeration or statement thereof in this .~,~, II~ , <l.~ , ~ . ' ~ 0 Agreement is hereby specifically waived, The parties do not wish to make or append hereto any further enumeration or statement Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full and proper disclosure, The parties specifically acknowledge that they have been advised by their individual counsel of their right to seek such discovery, however have elected to waive the same, Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto, and understand that this Agreement shall not be subject to modification by the Court. 21, Representation of the Parties. HUSBAND is represented by Johnson, Duffie, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement WIFE is represented by Diane M. Rupich, Esquire, Each party has carefully read this Agreement and is completely aware not only of its contents but also of its legal effect Each party acknowledges and accepts that this Agreement, in the circumstances, is fair and equitabie, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal Agreement and/or Agreements, 22. Waiver of Rights to Other Party's Estate. Except as provided for herein, HUSBAND and WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B , To receive property from the estate of the other by bequest or devise except under a Will or Codicil dated subsequently to the effective date of this Agreement; C, To act as personal representative of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D, To act as the personal representative under the Will of the other unless so nominated by a Will or Codicil dated subsequently to the effective date of this Agreement; E, To claim a family allowance in the estate of the other, " ' , . ~ '1 ~1i\ll1 23. Containment of Entire Agreement Herein. This Agreement supersedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage, This Agreement contains the entire agreement of the parties, 24, Partial Invalidity. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. 25. Effect of Reconciliation. Cohabitation or Divorce Decree. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to the parties. This Agreement shall survive any such final judgment or Decree of Divorce, Both parties shall have all rights and enforcement under applicable law including the Pennsylvania Divorce Code. This Agreement shall also remain in full force and effect even if the parties effect a reconciliation, cohabitate as Husband and Wife, or attempt to effect a reconciliation, 26, Modification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modify the Agreement. 27, No Waiver of Default. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, 28. Attorneys Fees and Expenses. Each party shall be responsible for their own attorneys fees and expenses, 29, Mutual Cooperation Each of the parties shall, on demand, execute and deliver to the other, any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents and do or cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shaH pay to the other all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. - ' L ~ -" - "'-~~f. 30. Bankruptcy. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under the provisions of this Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependents, Should either party file a Petition under Title XI of the United States Code, or should a petition be filed against either involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party, 31, Law of Pennsylvania Applicable. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 32, Date of Agreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the Agreement on the same date. Otherwise, the effective date will be the date that both parties execute the Agreement if they execute on the same date, ji , 'I I :1 :1 i 'I :1 !I :1 I 33, Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding on and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties, IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written. WITNESS: /;-/1- 00 ~xt!hLQ^ oL DONNA L CLELAND < Date Y6J~~ (/j O&l. 'y-/o-oo Date ~~,b {?/!!1-/ RAY NO E. CLELAND, JR :132166 , ~'H I' , COMMONWEALTH OF PENNSYLVANIA ss: IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,." ,," c ~ ,:::? .,'.. '. ~... ' - COMMONWEALTH OF PENNSYLVANIA ~ . COUNTYOF C 1l/1tb:klttl{tl 1"----~O';~;;f~~,:::f:.Z~;~;:""w.~~...=l ~.^f-- 'I"~, ,.":,':n;',, ,:' "," -,,- ",,,,,,,,-,.-,~ 1,1, ~~"~ ~",;.~, ,'"},,-,,, ,'~"', ,-e.:.. ,.,. ,I , ,~'o"'" ;i :,..~?:o~o""~.,~".,~"',.:;:~,....:;~:;~d ss: On this, the 10 {!, day of d tk i L , 2000, before me the undersigned officer, personally , appeared RA YMOND E. CLELAND, JR., known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,'."'" ,i~~ . 0.1-- 'e:1:>;;, '\. ; ...,J-: ~:d" ,i:-:- ~' ,(: , '-". Notarial Seal Kri'stee K. Myers. Notary Public Lemoyne Bora, Cumberland County My Commission Expires Dec. 2, 2002 Member, Pennsylvania ASSOciation of Notanes . ~ ~-'.'n EXHIBIT "B" ~!.. IERR Y R, DUFFIE RICHARD W, STEWART C ROY WEIDNER. IR. EDMUND G, MYERS DAVID W, DELUCE RALPH H, WRIGHT, JR, DAVID L LANZA MARK C DUFFIE KEJRSTEN WALSH DAVIDSON MICHAEL /, CASSIDY LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET p, O. BOX 109 LEMOYNE. PENNSYLVANIA 17043-0109 WEBSITE: www.jdsw.com HORACE A JOHNSON OF COUNSEL TILEPHONE 717-761,4540 FACSIMILE 717,761,3015 E~MAIL mail@jdsw.com July 14, 2000 WRITER'S EXT, NO, 18 E,MAIL kwd@jdsw,com FAX AND REGULAR MAIL 233-2567 Diane M, Rupich, Esquire 1017 N, Front Street Harrisburg, PA 17102 Re: Raymond E. Cleland, Jr. v. Donna L. Cleland No. 2000-2596 Civil Term In Divorce Dear Diane: This will confirm my telephone conversation with your secretary of Friday, July 14, 2000, regarding the above referenced matter. Donna has agreed to permit Ray to come to the marital home tomorrow, Saturday, July 15, 2000 at 7:00 a.m. in order to retrieve the remainder of his personal belongings. Ray also learned that Donna is approximately two (2) months behind in mortgage payments on the marital home. When Ray spoke with the mortgage company, they advised him that they would be pulling funds from his individual savings account in order to cover the deficiency, While I am not convinced they have any authority whatsoever to take that course of action, we would appreciate it if Donna would take care ofthis immediately. Finally, I am enclosing herewith the final divorce documents that I need Donna to execute and return to my office at your earliest convenience. Also, please complete Wife's portion of the Vital Statistics form and return that to my office, If you have any questions, please do not hesitate to contact me. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER ~~W~ Keirsten W, Davidson KWD:kkm:136450 Enciosures cc: Raymond E, Cleland, Jr. ~U- , ~ " " -"-'~ ~ lli:;~'t'" JUN- I-GO THU 10:04 ~l' .'\\1:1....'. q'\I~; . .,I,Iil"l , " , ' ~ .p.artm1nt~f.lheT:reasury ~ 't,rnal M.qJle,'nUll Service lAoelPH'IlI, PA U255 P,OI "(,,.\~!' I iL~,\"\:' , ~I, ~ l'.~ '.' ' ~", , ~>k,:'r:: ~r":;l ~Il' "'1,>, ~';I;l .'1 : , Iff ~~'" ~', ~,: {I ,1.,11'1 " ~ ~~\ ~:d' ,', "~' <a!,I\',:":;" ~ h;]!l.i:l, " I. j,J"llo.'l ,1 . r:\i~~lil~~I:i\ ,~iiM'(MOf.lD ~1'1i"j)dN,NA L CLELAND JR 'il'lit:!it"~~'"XJ' '11~US O!,.D tRAIl: ~D ;1!1i~~~!K:t1:~;:f::: ,'I(tiRK HAVE!t 'PA 17370-9069251 ~li\l\'::tl: :,'H~L~; " lll' 1'1' ,/'", . I: ; :I;!E;, '~:~. " , 'I,j,~, ,1,-' ' I' '"rl."" " , tl~h~, .~ '!Jv,' ~ '" ':ll"I"~" 'I"i'. ,~\.. ~ ,I!J' ~'i \!" iJ:"Ir,' h ':';1 ~f, <' l' " : 1,1il,:""~;.'L 't ?:~'" ~i\~'tH~i~J"'1 ',',' fl!1111l l'i...::.JJ'l.;~' .: ' 1f:j~~ l(t...1,1,'I'\' .l ~'f' iI"~'!!:';;:.,\ W,'ii""HflV~~~:tl;D ALL OR PART Of AN OVC.RI'~VJIIi\!&1:,Il:IU:!M OTHER l'EOERAL TAXES UNDER if (;:&ECU:RI.p; :t!1l'M)l,ER 209-50-9310 Tll THE' Al4qO~:r"'iElU;',fJW't; FOR'THE FORM AND TAX II' '"IDENnP'!'l~li :'A!OVE. : ~' ,',: : ,. , 'II: '~r;JER FEDI1RAl, I.A~, All TAXPAYERS WH\l F, lLie',;.)~~~r.a,liE:rU,RtI~ ARE RESPONsIBl.E FOR 1 '1:HE TAl(. iIlQt;; llK THEIR ORIGINAL fAX l/e;rtl~sHtNil'JPllR ANV LATER TAX ,INCREAses 'i ,~Jl RSTIJR~S'1" IJKTtL YOU PAV THE llAI;ANCS: ,:'tIt(,:,~E W'Iu CONTI/WE T'O CHARGE ",liT, THlls :i:i!C)('EASING THE TOTAL AMOUNT Vo,.:(lIilE;" LISTElD BELOW THE AMOUNT YoU STILL ,owe. \ 'r~ '. ,,' , . i.i~'i~':/':i: OVERPAYMENT AMOUNf' APPlll'liL,.... $1,214.00 .' ",,,, AMOUNT VOU STIll OWE."...,..... $33,560.25 .. "~l ' , rr;, ~, ' ! , ", '1F.,~ you Sl'"!,;!,, OWE AN, AMOUNT. PLEAS!': seND ,U!, ~:I\~~I.t.~, TEN, DAYS. IF YOU PAY THE t;1 ',;>MWN AltllV,lt> '~y ~UNE 8, 2000 "&OU IOU ~\rll~~~:.\Il1iU IONAL INTEI<EST CHARGES, " ';.1' f,/:YOU' M~Ilj; <~, .PAYMENT WITHIti THr!; LASJ. ff9.U!ll"jf.Iii~:1l T.HAT IS NOT SHOWN AllOVE, ~,I' tl:ll;::, ~MOUHI 'OF THE PAYMENT YoU; MAI)E.."$!i1ifl,~~~"J~~S,560 .2S. IF tHIS RESULTS :I.I.I~Ml'CE OU~I,';HEASE PAY IT. NO FUR'rH'l;~ Mltlli'ti,,'J iUS REQIJIREO OF YOU IF YOU :, , IH'!' ENTI ~E'AMaUNi DUE. ';: ',j'r '!\" ",,:,:,-::,',tF YOU "'Mi; A.,PAYMENT MORE THAN, f.DUR W~Jlii :IiIIAT IS NOT SHOilN ABqVE. SEND A 1" 'P,f,'i'(OIJR gAfilCI;j,.ED CHECK (BOTH SIDE~), ,N ,~i'" Ilh,l1.TUa- OR,:CASHIER'S ~eCEIPT, " ; '" ';i,TH rHE, :~:tU)' t\T THE END OF THU NQU ' ::;'" 'Al' 'i;HE AMOUKT OF THE PAYMENT , " '!!' FROM ":'3''5.560.25. IF THIS RESU!TlS"'Ji , ' !:ANCE Ou!L P.LEASE PAY IT. ~ ,., , ' it' il:\': EAsE \iI"~!il& :VOU,R SOCIAL SECUR.Ili<t, NUM,Bl;fft ~NL_' t' ,1'CHECK OR MONEY Q.ROER AND MAKE '~LE TO ,r.~E ,U~lTEO STATES TREA~URY. ~~ ~a ~ HE'~fUB At THE END' OF THrS ,~ND' ,SENIl n' WITH yOUR PAYMENT It!' Tl:liH,N '~ii :tI'\E>>VE(OPE. 'i~:I'fill ':::j :1i~:~OU 1lE;,!:;IE!V6 OUR RECORDS ARE NOT Cr,J.R~"f:~';: ~:L~m; YOU A REFUNP., OR YOU NEED ,~~l ! :N:F~RMAIrcIN.: l:I!:u THE TELEPHONE !l\l'MB!;'IH$, 'tUifep ABOVE. IF VOU PREFER, YOU MAY 1:: ,', ;',~'tl TH.:"'t\Dll'gI?~S LISTED ABOVE, ' 'I: I'. A'," i~~IJi~{'J;~~: ': r'HANK YOU POR YOUR COOPERATI ON. "I',ii1i:~J'I'.":,, . I(&~lljll:' !: ( " '\ . 'II l;p.Hll;":;,'i::.~": , :,'.}.ije:"/l'! ':~". " ' i~;;';~111.' ,I'~:, ' 1 J\\-!'~ 1'.,\".\, '::, r:,~J';'f;'~ l:~:i,j:,r '1:"~i~i;~lil.;':h'" :1;?:'\:'I'!:,:li;,I:.,:,. il "1.11'0' T .,' ,;, I! .M~;_'l::,~,,~",:',', U~~:h'}:h:'~~:", ' 'II ;~~..\~,.t ,j.; u.. :~,!, , 1'~'I,.ti' "",. ,. . :"$i,t~" 11)1:'i!.'~~" : It, ,'l\~ : . i:!:,[,. : :", Ji; ~l'l~~ ~l;.' i1 '~'.:' , . ;t..., ~~. ~~,,,., t ." ~'Wf!.;j~'~",JI": , ~"!;I:!~j~~:;~':';:'1 ~ " i""i~j'" ',"" I', ~'J;~1\r":i~:,r;:,,:~ : ~::r'fP\:;':.'" J' :,i!,,;V;:.r::, ' ' ;!l ;~~r:;1:;:<::l i\:,!m ~1!":\,,I,~,I'" , , '''Qa\IT:ill:~hl~Mti<:e; MAY 29, 2000 , ':tI!~Y<!t,["denlifyin9 Number 170-~4.72~2 Fprm:!t'll4e Tax Period: DEC. 31, 1998 I"OT assistance you may eall US at; ~llllo--a29-aa15 " 1.:"1jJ..\III'I"II,I.,. 1,11",1. .,,1, ,1111,11.11". !"Il""lllhl CALLER ID. l52166 WE APPLIED A~ OVERP~V.Me~T 1~ YOUR BALANCE DUE J,iJ-j t L ,J2,jJ PAGE 1 , ~~,' .1. -" ~ IEI<I<Y I<- DUFFIE I<ICHAI<D W. STEWART C I<OY WEIDNEI<, II<- EDMUND G, MYERS DAVID W, DELUCE iV\LPH H, WI<IGHT, II<- DAVID J, LANZA MAI<K C DUFFIE KtlRSTEN WALSH DAVIDSON MICHAEL J, CASSIDY LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE, www.jdsw.com . i; HOiV\CE A JOHNSON OF COUNSEL TELEPHONE 717,761,4540 FACSIMILE 717-761,3015 E~MAIL mail@jdsw.com WRITER'S EXT, NO, 18 E-MAIL kwd@jdsw.com June 1, 2000 Diane M. Rupich, EsqUire 1017 N. Front Street Harrisburg, PA 17102 Re: Raymond E. Cleland, Jr. v. Donna L. Cleland No. 2000-2596 Civil Term In Divorce Dear Diane: Enclosed herewith please find a document that Ray Cleland delivered to me on Thursday, June 1, 2000. I assume this notice pertains to the inheritance Donna received from her mother. Please recall that at the support conference we attended, Donna represented that these taxes were paid in full. If these taxes are not yet paid, we will assume that Donna will be taking care of them per the parties' Property Settlement Agreement. Please also confirm that the PFA has been amended per the parties' Agreement. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Keirsten W. Davidson KWD:kkm:135118 Enclosure cc: Raymond E, Cleland, Jr. - . ~ , ~~~-, - = "':~ IERR Y R. DUFFIE RICHARD W, STEWART C ROY WEIDNER. JR. EDMUND G, MYERS DAVID W, DELUCE RALPH H, WRIGHT, JR. DAVID L LANZA MARK C DUFFIE KEIRSTEN WALSH DAVIDSON MICHAEL L CASSIDY LAW OFFJCES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET p, 0, BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE: www.jdsw.com HORACE A JOHNSON OF COUNSEL TELEPHOl<E 717-761,4540 FACSIMILE 717 -761-3015 E-MAIL mail@jdsw.com WRITER'S EXT. NO, 18 E,MAIL kwd@jdsw,com June 9, 2000 FAX AND REGULAR MAIL 233-2567 Diane M, Rupich, Esquire 1017 N. Front Street Harrisburg, PA 17102 Re: Raymond E. Cleland, Jr. v. Donna L. Cleland No. 2000-2596 Civil Term In Divorce Dear Diane: Thank you for your voicemail messagetomeofJune8.2000.This will confirm our understanding that Ray Cleland will be at the marital home on Sunday, June 11, 2000 at 8:00 a.m. in order to retrieve the remainder of his personal belongings, Aithough the parties' Property Settlement Agreement calls for him to remove such items within 14 days of the Agreement's execution, Ray was unable to do so because of inclement weather and scheduling conflicts between both parties. In any event, he will be there this Sunday at 8:00 a.m. in order to retrieve the remainder of his belongings which I believe include his tools, his stereo, his clock, and his saddle, Next, you will revise the Protection from Abuse Order as per the parties' Property Settlement Agreement You indicated that Legal Services was unable to do so, Finally, enclosed herewith please find the notification from the Internal Revenue Service regarding the inheritance tax. You indicated that Donna has sufficient funds to pay this debt and will take care of that within the next few weeks, Thank you for your cooperation in this matter. If you have any questions, please do not hesitate to contact me. Very truiy yours, JOHNSON, DUFFIE, STEWART & WEIDNER Keirsten W, Davidson KWD:kkm: 135372 Enclosure cc: Raymond E- Cleland, Jr. _IL ,g /-,1:' i- r ":.-,.1 I IERRY R, DUFFIE RICHARD W, STEWART C ROY WEIDNER, JR, EDMUND G, MYERS DAVID W, DELUCE RALPH H, WRIGHT, JR, DAVID L LANZA MARK C DUFFIE KElRSTEN WALSH DAVIDSON MICHAEL L CASSIDY LAW OFFICES JOHNSON, DUFFIE" STEWART & WEIDNER A Professional Corporation 301 MARKET STREET p, O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE: www.jdsw.com HORACE A JOHNSON OF COUNSEL TELEPHONE 717,761.4540 FACSIMILE 717,761-3015 E~MAIL mail@jdsw.com July 12, 2000 WRITER'S EXT, NO, 18 E,MAIL kwd@jdsw,com Diane M. Rupich, Esquire 1017 N, Front Street Harrisburg, PA 17102 Re: Raymond E. Cleland, Jr. v. Donna L. Cleland No. 2000-2596 Civil Term In Divorce Dear Diane: At your convenience, would you please confirm that Donna Cleland has taken care of the IRS debt approximating $35,000,00, Would you please also confirm that Donna has transferred the N B Liebman Furniture debt into her name individually, On an unrelated matter, is Donna available either Saturday the 15th or Sunday the 16th to meet Ray so that he may retrieve the remainder of his personal belongings from the marital home? I look forward to hearing from you, Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Keirsten W. Davidson KWD:kkm:136324 cc: Raymond E. Cleland, Jr. , ,~ ,'--^~ . " "~-" ~ ~ ^ --- --,"w-;t' :~"~I:~iiJ' ID.\~I:rl~'~I'I';.' '~' 1m~I1~Q~~T.!~~ury " ~"+'" "',' ., r f!l~~r\f~:\,,;,";t;le .; \1> 'i:~ "~< 'Q;1o , .,:.-i9Jl't."""f<?' ',' :;, 'i., "X5 :' '" !t ':" ,f.' ~<~ ~ " I' , G;jjif ~1~i' f" ~ ,. I" " AlE;i\II.,f1~f1,1lI?g9 ,,;I.'!I1:1. 'I I '\ ' ~i\I~,~,~"~I'\'" ", " ' "';fir,/1 \0' ;' 1 r i" "'~f'il'I""~' ': " " l'n, 7 ;>"1" ::'" '. '1 ",. "' '.. " ~11 11,f.~~: ::f;,,:' 1,),,1, r ;;j'" I :~ ' f '., ,"' ,1'"'1, <, ~i.'" -'l" f,~' "i t ,~' f ~" , ~;F':rt~YMD,~P,:~ ,~i !lPNfo/A L CLELAND jR ~:" '*l5 ,G,L'~:~1:~rl RD , ::,:',XqRI<-;~~~~t;,I'A 17370-9069251 ~~ln::" " .'~r~':': . ).('1 , . " "~I~v ~l;:, , ' ?i1 ,~,~. \!I" , l'~:ll~ "f.:r; I,: :. , ,," : ,::': ~I!:@ Call uSA.!?out Your O\(IiI!I'~~''''.a:ke.s Qf,Tax Datutn" , ,,", ' " "\4f7T7"""'~'Jj":~,- \" ',~?!~"P,,{"' r .; '~,~~~;"Tn~~~:'d.I\ti:~,::]ll,,' , '~~t1.Jj~t' .::r,~ITI;t.~~ -"'''''l,~r,::;r~'''~:-'"":~!TI,:-;':':''"ff:t:f;' ~;d'~rr.~!':r: I' , . 1,""111, "IiI i?'f.\/"," , ,I', ,*,tiril1~:?'If'><: '( ~. ..lli; l:t:ll' r-. f' '-~.", . '\' \, ""I' ',(, '. ':\1' '\: ",\ ':;VI, 'i"'.,' .' :~'" "';~I ~.,.~.~~, 'I~V ;ft;l\:" \,"I'Y ,I' " ',,:""':", '.:'...., , 'lhn,~~:,'" ' ~q,tl1nl,youre~pon(lelft~}~I~~~! 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Forall uldivjd\Ul~iffiijJrir"tl\!' ,", ,!l~ YpllI fn.<;om~, flti.llli ~!;ntl1~1 Rl,\d, ,d%J'~~ ';~elct FQt a bl1s~e!ls ~t'Ill~~ t1lls 'S~~li,td:, ' sge~,llhid, lllUll6Jr of eillployees, SIlIA,,,:' "':""'''l'QU. , " ,lili!~~ !,I'O;1~; , ! :JtJ/.Y'24, 200D i ' 1:r~~l!',f"'~ntJfyi~g N~"'i>"r. l' 'l'10"f44"7Z02 1\ 00 , : 'C~hllo~t T,r~"ho... Nll~~~r: , ;, :rlll!: iF~FE, l-ebil,~~2,~-765il i' :ll,~S'l'''I!T!ME, T\1. CALL, ' I :$,.Qo JAM 'Tl,1 <ji30 PM i ~UES~AY, WE~NESDAV AND THURSDAV ; , , ,':" , I ; " ; ! "", , . ".~ ' 11~'~r ~., ," .;: '"i'" f;" ;', :'t .' , ; l"'!':::",,:",'[' ~"i~.D~ ;: rl' l:lmm' C~!~~~Pl,ell,:CPIleCIiOll aIs!\cb i , i '- "11":>', . " :' ~etlst 26~p (R~~ ~g'1'9g2;(l+:~'~):: :' l~) I~+ . ''','' , '. " , "~.!. .' '. ' l' jlA:":I\:il'~'/ f " ,; " , r.",,, ",,, "1"1' ''1,1,,,,': ..' "'j ,,' ",,! ,h ~ ~ :... ~I)li" ' ~~ ~::i', ~rr(~~ ; 'I, :.r'l'l;1",l:' ~:; ; '. I \:,.~ '. H ~ I: t;,~fe~~i~~ ,~~~:~ I \1i~ ~1f I~ ~'~;"J :'"i",~ -'II 'l"~"'''' !' 'll.I~J.lkl' j\ I I'" . t, "l.~i~J:Ii" .t'fi',: " .. flo;,ilIl'~ l".I. "ll'l' '~':". ;'11'1"1 Wi, <""""", , " ~ 1,.',1" ". , I;, .;t~ ~ l' >~, 1'-11 (, f(~"~~~~~I~' ~,t:~ ,;1,' ~tP;"'li,n~~i'I":' ' 'Uil.~ '11'/I,j,: :fg::'IP( J\Io~!.)..~ '; I ')~f<<~,ri .':,~1:"": ii' I'~'il ~~/', I( ;" ,: 1 ~"Ji~". l;~ I ~. '1~ '1l!'il. I~ ,,\' :'i"'I.~~i!: ,}:'-, .. f'f-{' ~'" '-i.., ' I >, ~+<l" 'll ., 'I, . \ 7 ~!J:i~~~'~'~ ~'!~;: ~ : 1?n<1:h.....1. ~'~~~.,,~ : ;.1': IJ~l :,i;' ''!J~"l " :1; '\J.'r~]" ~~!~\\ .~ ',1';:; '-l !{.',';;' 1 , . 'C' h' \~ '\~' , ,', . l " ,.<<. , " ", ~,~'. '.,f.: ~,',l :j&:,:i> , ,\ ~;~' I' i ,', '" l~" r<, 'I r~~,,"'\ :'~ (.rt}i',~f. r .'}~!{f::~, "1."l,:: ~,;ty:, llffl"-: ' ):1 ~ , :'1'''' i I"i,', l:'>lk ,~J.I' .'t. {~i~:';<:: . ~':'\; ,".' \r~:; f'.; {1'~' ,.,." " ,~,:tk{} : ::!.~I,'.~, . ".11' ",} ." ,~ ' i~~,:::~~1 . , , ,~~': Per'l<>!i: ~"!ilng - . RIIVMDND F. & D~N' ^ss~s$":d 13"'''"0'' $ 28.973.~B '. \.' '(i:l;~~\I\N~t(' I ' ~il.l!1;li4~~~l,!fl)" ns u l , $' r>:; ~~IJ ,52 " t',. . ----~";1;;i~~~tlnl Q\lo ...."......,.-.......------.....r'-......-'"'..;~ , ~~~""lillllilurll ~,..,.~"lIf""--..-.,...--- $ 17D-4r,~7202 Tol", 34,653.70 $ ..,...........--- 34,653.1D ~~:D!l<trfiel1l'oflhe,rre8slltV" Intetl1nl Revenue S<l'rvlc' .-. t. ' I .. .~ ,,-. " ~-~,I, , ~ ~'"" "' ~-"""""-r$1 STATEMENT OF ACCOUNT LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET p, 0, BOX 109 LEMOYNE, PENNSYLVANIA 17043,0109 TELEPHONE 717,761,4540 FACSIMILE 717,761,3015 E-MAIL: mai1@jdsw.com to, NO, 25,1802360 Raymond E. Cleland, Jr. c/o Geraldine Cleland 325 Old Trail Road York Haven, PA 17370 Re: Donna Cleland / Domestic Relations File No. 9478-3 FOR PROFESSIONAL SERVICES RENDERED: 06/01/00 06/06/00 06/08/00 07111/00 07/14/00 07117/00 07/27/00 07/31/00 ,Il7390 Review of fax from client re IRS unpaid taxes; Letter to Attorney Rupich re same Telephone conference with client and Rick Cleland re unpaid inheritance tax; Fax to Attorney Rupich re same Telephone conference with Attorney Rupich re unpaid inheritance tax, 'modification of PFA, and return of Ray's personal property; Telephone conference with client re same Telephone conference with client re unpaid bills under Property Settlement Agreement; Letter to Attorney Rupich re same Telephone conference with client re Donna's failure to pay mortgage, furniture debt and taxes; Fax to Attorney Rupich re same Telephone conference with client re unpaid bills and Properly Settlement Agreement; Letter to Attorney Rupich re same Telephone conference with Rick Cleland re Donna's failure to adhere to terms of Property Settlement Agreement and possible recourse; Draft Petition for Special Relief re enforcement of Property Settlement Agreement Review and revise Petition for Contempt "Balance Due" $438.00 PLEASE INCLUDE THE ABOVE STATEMENT NUMBER ON YOUR CHECK AND RE1lJRN A COPY OF THIS STATEMENT WITH YOUR REMmANCE, THANK YOU KWD :iiil!i........~"liliilij(~..~'..ti:.....,..iIil;w!ri~lt.iliil~_,.~,.;, ""l-~ill,~~-'~'- 'll\illi!oll;j~~""""'~'.~'" JW~t. . 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