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Home My WebLink About00-04951 .. .. "" .-, '~C .. .. . .. IN THE COURT OF COMMON PLEAS .. . .. OF CUMBERLAND COUNTY STATE OF RICKY L. CRAMER VERSUS . BONITA J. CRAMER AND NOW, . DECREED THAT .. .. .. .. .. .. .. AND PENNA. No. 4951 2000 DECREE IN DIVORCE April z "1' 2005, IT IS ORDERED AND Ricky L. Cramer , PLAI NTI FF, Bonita J. Cramer , DEFENDANT, .. ARE DIVORCED FROM THE BONDS OF MATRIMONY. "' '.U11 .. .. . .. .. .. .. .. .. .. .. 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; .. .. .. None .. .. .... BY THE COURT: .. .. .. .. .. .. -~ .. PROTHONOTARY .. .... .. .. J. .. . .. .. /0 S'? '. .'., -'it_. '_;, ,'tIl .._ ""' - .,..' '.-~ . , . 5"' a< ,oS Iff' ~ -tJ,S M.'~ ~'t-1f ~~ /~ at'~- ~ ~ vfj-~ 'i~~'; ~J I I l I I I I ~ t t 1j ~' :1 L ,1 'I !, " il 1 I , -I 'I ;i 11 , ,I 11 'I I I [ I I . ,P,_ '_""'!l!!!IIIIJ"!'J"1 ~- , -,,"'__.. . .."~,,," ..,.. ,_ , ''''"^".......,...._~.,~r"I!!l1l!!~~ . ll~~~I....,...~~,."_I'!llIJl'l,;l.flll., ",~.,"'""'~...".,.. -,~. ~, , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY 1. CRAMER Plaintiff, No. 2000-4951 vs. BONITAJ. CRAMER Defendant 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: , 1. Ground for divorce: irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and manner of service of the complaint Julv 20. 2000. by nersonal service on Defendant's counsel - Acct(ptance of Service filed July 21. 2000. 3. Date of execution of the affidavit reqnired by ~3301(c) of the Divorce Code: By Plaintiff: 03/03/05 By Defendant: 03/03/05 4. Related claims pending; None. All issues settled bv agreement at time of Master's hearing and stipulation subseauentlv silmed bv the narties. 5. Date Plaintiff's Waver of Notice was filed with the Prothonotary: 03/07/05 Date Defendant's Waver of Notice was filed with the Prothonotary 03/ o . Baranski, Jr., Esqnire Attorney for Plaintiff .,< ~' < 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITAJ. CRAMER Defendant In Divorce DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTNE JANUARY 1,2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. DOCKET NUMBER: 4951 Civil PLAINTIFF'S NAME: Rickv L. Cramer PLAINTIFF'S ADDRESS: 370 Old State Road Gardners. P A 17324 DEFENDANT'S NAME: Bonita J. Cramer DEFENDANT'S ADDRESS: 19 Coral Drive Carlisle. P A 17013-9401 DATE OF MARRIAGE: Seotember 15.1990 DATE OF DECREE: . OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY One Court House Square Carlisle, PA 17013-3387 Curt Long Prothonotary Telephone (717) 240-6195 Bonita J. Cramer 19 Coral Drive Carlisle, P A 17013-9401 Date: Re: RICKY L. CRAMER, Plaintiff vs. BONITA J. CRAMER, Defendant DOCKET No. 2000-4951 NOTICE is given that a Decree in the above-captioned matter has been entered against you on Curt Long PROTHONOTARY OF CUMBERLAND COUNTY By If you have any questions concerning the above case, please contact: John J. Barnaski, Jr., Esqnire BLAKEY, YOST, BUPP & RAUSCH, LLP 17 East Market Street York,PA 17401 Telephone (717) 845-3674 ....1.:1~"'..."" ""tlmd'..w;" ~' ~. . - ,,':'; -~ " ~ ''-'' '..,d""""""" o s= iJH? .:.h,'" -~" ~--., r' <-:"' ~~~: rc ~, ~ "", , ,"'" I ,j 'I ij I '" il ~il ~1 I J 'I II IJ II , "'" = = c.n ". V :;el N N ;po :::l~ o -n 'l'! nl:a r- -om ~IJO Q,t, --;'-' .,......., ~~:~ ,:'5m o-l ,1> :n .< o -J ~' ~~ ~ , .~-~ , RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE THE MASTER: Today is Thursday, March 3, 2005. This is the date set for a hearing to take testimony on the factor of marital misconduct as that factor may have affected wife's alimony claim. Present are the Plaintiff, Ricky L. Cramer, and his counsel John J. Baranski, Jr., and the Defendant, Bonita J. Cramer, and her counsel Thomas J. Williams. ~ The parties were married on September 15, 1990, and separated April 2, 2000. There were no children born of this marriage. A complaint in divorce was filed on July 13, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. Counsel are going to have their clients sign affidavits of consent and waivers of notice of intention to request entry of divorce decree today before they leave the hearing room. The affidavits and waivers will be filed by the Master's office with the Prothonotary. The divorce will be able to be concluded under Section 3301(c) of the Domestic Relations Code. On August 30, 2000, economic claims were 1 0-'-' } ". ." ~~ filed by wife for equitable distribution, alimony, alimony pendente lite and counsel fees and expenses. The Master has been advised that after negotiations this morning the parties have reached an agreement with respect to the outstanding economic issues. Therefore, no hearing will be necessary on the factor of marital misconduct. An agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. After the agreement has been transcribed, it will be sent to counsel for review for typographical errors. Corrections, if necessary, will be made and then the agreement will be provided to counsel in a final draft for the parties to affix their signatures affirming the terms of settlement. In any event, the parties are bound by the terms of the agreement when they leave the hearing room today even though there is no subsequent signing of the agreement affirming the settlement terms. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel will then be in a position to file a praecipe transmitting the record to the Court requesting a 2 ~~ , ' . final decree in divorce. Mr. Williams. MR. WILLIAMS: The parties have agreed in full settlement of all economic claims that were made or could have been made in this divorce case to be resolved as follows: 1. Thirty thousand ($30,000.00) will be transferred from the husband's Daily Express, Inc., employment retirement and profit sharing plan to wife promptly upon the issuance of a final decree in divorce. Wife shall be responsible for obtaining a QDRO for the transfer of said $30,000.00. Husband shall cooperate fully as needed in order to obtain the information and process the necessary paperwork to effect this transfer. 2. All other claims which have been or could have been made in this case of an economic nature are deemed withdrawn. 3. Wife is currently in the possession of a handgun that is currently registered in the name of husband. Wife shall receive that handgun as part of this settlement; however, wife shall promptly re-register the gun in her name alone and husband shall cooperate in that re-registration if such cooperation is necessary. Wife is also in the possession of a .25 automatic handgun that is to become property of the husband as part of this divorce resolution and wife shall make that handgun available for pick up by husband at a mutually convenient time. 4. The parties acknowledge that they have satisfactorily divided all items of personal property, household contents, and the like between themselves. 5. There are no marital debts that either is aware of for which the other may be responsible. 6. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or 3 "-iI!' . ;-." ~ " the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. WILLIAMS: Mrs. Cramer, is the settlement of this case as I've just described satisfactory to you? MRS. CRAMER: Yes. MR. BARANSKI: Mr. Cramer, is the settlement as described by Mr. Williams today satisfactory to you? MR. CRAMER: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: . Ba~anski, Jr. Attorney for Plaintiff LI/~/6 S ? ~~""W"L Cramer ,/" 3h'los BO~~ ~~m~2tv~LVu V\J~-c- Thomas J. Williams Attorney for Defendant 4 " ~," " lilIIiilll"iilJitl:.titlJIU ~ ~ L;; ~~. ,,' []jj[i~~' -~~"~"'+'jj~ " iN e-:::5-' ~ ~,' .. ,. ..", '., ,- -~--.. :,;.,-;-" ./.>..,. " . ,", " .,:c' "." "~"",",., """"".1""'" , 1 ", -, . " '&~- _c" " ""~~..."" RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this /5(11 day of !l~ / into an agreement 2005, the parties and counsel having entered and stipulation resolving the economic issues on March 3, 2005, the date set for a Master's hearing, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, .J. cc: ~hn J. Baranski, Jr. Attorney for Plaintiff ~omas J. Williams Attorney for Defendant rt l~ ~"p"""",,,,,, "V",,,,,',,',,,,'',,' , .),"~--! ~,-- ,,' '" "' ,~ ..'>r,-,- _.~'. ,." _,~... ,~~~ /71N '?J FilED-OFfiCE OF THE PROTHCNOTAHY 2005 JIPR 13 t\fJ 10: 05 CI"'''''''' ", ",,-,,,'1'1 .J1\tC':..~-:Lf\:.;U :.....UUJ'III'1 PE}~NSYlW\I\)!t\ '. ""':",',"r",',"~"-!,_'",,,-~""'-IjIF1I!O .-.'.' ~ Pc" JrM,.[ " '",,, '0" llL"j' .' ~~ _, ,,~"'F~';;"_',-,'" ,;*/":i"'~c;, ---'" " :C,k~<;:,\S-.____'",_"'_""'-';':">>:~''''';'''''' '",I .JOHN .J. BARANSKI, .JR., ESQUIRE LAW OFFICE OF HAROLD S. IRWIN, III ATTORNEY ID NO. 82585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2000 - <./Q51 CIVIL TERM BONITA d. CRAMER, Defendant : IN DIVORCE NOTICE 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 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 AVE CARLISLE, PA 17013 (717) 249-3166 ~,~ " -- -^~ "~ '. ., '" . Lc._ '~,' '~. ' ~ ,"1 ,-' ',-', ",___".~ b--c., , .-- ~ "'~'"~ ,-, ,;,-~,:..::,-- ',:" RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2000 .L/f61 CIVIL TERM BONITA .J. CRAMER, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, Ricky L. Cramer, by his attorney, John J. Baranski, Jr., Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Ricky L. Cramer, an adult individual residing at 20 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Bonita J. Cramer, an adult individual residing 19 Coral Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 15, 1990, in Cumberland County, Pennsylvania. 5. The parties separated on or about April 2, 2000. ',- -, -, "",'I COUNT I - DIVORCE 6. Plaintiff hereby incorporates by reference averments 1 through 5 as if each averment were set forth fully hereunder. 7. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 8. Neither party is in the Armed Forces of the Untied States. 9. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 10. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties and such other additional relief as the Court deems necessary. Date: (, ~ctAJ JO J. BARANSKI, JR., ESQUIRE ID # 82585 Attorney For Plaintiff , " ;'-,,~, VERIFICATION I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. JUNE L 2000 ~/~ RIC . CRAMER ,.',;::..,..,., .-uc.> - "'~--,' ''^'" i,.' - 'Iii_' RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2000 -'195/ CIVIL TERM BONITA .I. CRAMER, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 may 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JUNE g, 2000 ~/~ RIC L. CRAMER - , "-""--~ ,~ ~ '.-"~-,"-" -- ~ '~ ia' <" w;;d~-"',,, ,:_',~' '_'-"'/',_,.,__o.,."~__'h_.~__. ""'" .' "''''~~ ",' """,N,,,. .. l:::J () ........ --- ~ rt- I:l() ~ ~ ~ ~ 0 () '8 --\) v::, 'd 0 (') C) 0 0() '1-J s:: C> -'n ~ , "~--1 ,-C;' ,..J ~ ..::0,.. ~ 00 Q I"){).) -..- ;'i~:JJ N n1ni ;- ~ -=1 2:IJ ' 'f'" b ~~., ~:~8 ~ += ("'" ,.-. : ~,.:;C) ..... "2 ~CJ ~ ,~'~;i~ ~ )C~~" -~~ -?l) -"-{-', )o-c ;'~-~. In u --i Z ,"'.) )> ::< ~ co -< r/5 ~ . ~ _," '_~'. L "~ WI" ""i;lW#W;r. 83/83/2885 18:29 71 72431 S8? MDWO PAGE 84/85 Thomas J. Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO In. 17512 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, DefendilIlt IN DIVORCE AFFJDA VIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(0) of the Divorce Code was filed on July 13,2000. 2. The marriage ofPla;,ntiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. J consent to the entry oia final decree of divorce after service of notice of intention to request entry of the decree. 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 .Fa. C,S. & 4904 relating to unsworn. falsification to authorities. Dale: ;3- 3-0 S " ,,,,,,."~ "~" '~""='~~'Iil!j@!~':Sg~~!!ll~~FJilIiMl~~~-l;_~_t-llrtlll;:-~ ~ ~ '-,,- - ." ,----~,,'" ,,' ., ",,'~ "-,~ 'rl'.'. ~5 /!;LL, .V', ,-, ,.~ '~"l_~lii 0 ...., 0 = ~~ = ,-- "Tl ",. """ 92ft-: :z ~::o :l> ;;0 ~~ ~~~,i I -.J ~ > =r=H z(:: :z 0-- -....( } i3~~ .>'<:: ':9 ~ d 0 .J> :;0 CJ'l -< !\l: ,.,..--.-- ~ - ",,~ 03/03/2005 10:29 7172431807 MDWO PAGE 05/05 Thomas J. Williams, Esquire MARTS ON DEARDORFF WilLIAMS & OTTO J.D. 17512 10 East High Street Carlisle, PA l70B (717) 243-3341 Attorneys for Defendant Bonita J. Cramer RlCKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CNIL ACTION - LAW BONlTAJ. CRAMER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6330Hc) AND 6 3301 (d) OF THE DlVOn.CE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or eXpenses ifI 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 ofthe 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: 3-3-0.5 ~ ~ J ;_-.'" , o .' , ^ -" l!lifill~~t'$~i!j!\!ID~~~!!'!~H~1~,I!!I~!l.M~' . ,"~~' --......lIilililliii'-llil ~ ~ ';$ ~ \ -l o ~~)~.i t\'"'.r:-,' ~;i:: ~;~:. !:::\ ~~ %v is .e;i-L ^ . ~ ~.." f\1f": -or!:' ?Jt;' 00 ---",c\""'f, ~..." Q<."i rsfn ':.0 7i :'9:: 9 ;:$ 'F! o IJ\ '" - ~ ~ ~';..,"", 03/03/2005 10:29 7172431807 MDWO PAGE 02/05 P;\FJL~S\IlATA1lUi\CtllOl{;aI\C\lII1:.nl\1 non. I ,cOlliall/ulc lQO?9.1 Thomas 1. Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO J.D. 17512 10 East High Street Carlisle,PA 17013 (717) 243-3341 Attorneys for Defendant Boni.ta 1. Cramer RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v, NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, Defendant IN DIVORCE Al':FIDA VIT OF CONSENT 1. A Complaint in Divorce lmder ~ 3301(C) of the Divorce Code was filed on July 13, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and servi.ce 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 decree. I verify that the statellJents made in this affidavit are tnle and COlTect. 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: J /. ~ /tJ5' I / B~t~efe0an~av . "- ",...".~~...4~_-i"~!i."HE$iBI11~~WWlIWi~~~*il1~~~_~~----" ~.' ~ W tiS' ,lZ?L """""..o!I ~-"--' '~~,~ ~ ", ^-- H]I!l "2- ~,'" .><\J 1~;:~. f"flr t_, 'W~ C::'\_' -- ":',F(-) ~~f~~, ""1 '::..:.. ~ 'iJ. ':S ~ I _J .- <;? ~~ -0 ' ~4' n:Q ~q, (')\ "" ~ ~ .p .' o ()'\ ~ ., .~~.-~" ~'~ . , '~",,,< 03/03/2005 10:29 71 72431807 MDWO PAGE 03/05 Thomas J. Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO I,D. 17512 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer RICKY 1. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, Defendant IN D.IVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) AND Ii 330Hd) OF THE DIVORCE CODE 1. I ,consent to the entry of a final decree of divorce without notice. 2. I understand that Imay 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 wil.1 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 ill 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: S / 'i a5 / ~fL/ l r ~JtM./ Bonita 1. Cram.\/, Defendant ;"j'.< ~~~!liiii~~~wern~~'~ll:i.i'~--"""'; . ,j, ~ W ;3' fC?L- -,.....- ,i>h-" (") ri~~. "-:"".7" .....-~~, -,,~ 2:r;'~,: (l,~ }',~ -</ ~8 >~; L_ -'" -< lh.r.~'<'<~ -_ '--"'--""Ij ..., ,"" = ..... :% P" ;:;0 I -.l ~ -I ~~ 'om ~~b :r.:-=H 0,- 6.0 . f(1 0-, ~ :P X <P. o U'l RICKY L. CRAMER Plaintiff v. BONITA .J. CRAMER, Defendant ~ ,;" J'. '," _, - 0" .'. H'~..-b' "'.e"':"i' ','. ,~;-~" .;, '," .,i" ,cc-';,.,' . " ., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 4951 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas J. Williams, Esquire, accept service of the Divorce Complaint. I certify that I am authorized to accept service on behalf of the defendant, Bonita J. Cramer. ~.2000 '/ l1v~~ THOMAS ILLIAMS, ESQUIRE Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 """" .~,,,~:.:- .X " . ""''- -,,,-C'I:''':''''~'''''':;;"'-'''~ ' . ',~, ~ C'S' ~ .~,~. Cd" " C" "" " n ~. .........JG-; rn:--,' ~IS'- 2c' ~~), >~;~ :-:.i -< c i ~-.,) ;~ "-!;'~ ",.-, __'''-r:; ":-:' '.' -, --r..">- :,g -, r;:- :' '. ,.,-',.-' :v" ,-,",_",--, ",;""",""., ___,i~., ".,;"'~ -~,--,_,~, ,I _""""", Albert G. Blakey Donald B. Hoyt Charles A. Rausch Bradley J. Leber Stacey R. MacNeal Penny V. Ayers John J. Baranski, Jr. Michael C. Anderson Wanda L. Snader 2gh Year Ii of counsel Donald H. Yost David Wm. Bupp Blakey, Yost, Bupp & Rausch. llP Attorneys at Law April 8, 2005 Office of Divorce Masters Attn: Traci Jo Colyer 9 North Hanover Street Carlisle, PA 17013 Re: Ricky L. Cramer v. Bonita J. Cramer No. 00-4951 Civil Dear Traci: Please fmd enclosed a fully executed original settlement agreement on the above- referenced matter. Please move forward with relinquishing jurisdiction in this case so that the parties can proceed with having the divorce finalized. If you have any questions or need any additional information, please call me. Jo J. anski, Jr. BLAKEY, YOST, BUPP & RAUSCH, LLP JJB:jbl Cc: Ricky Cramer Thomas J. Williams, Esquire 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 Celebrating 25 Years of Legal Excellence (1980 - 2005) -"= '~R , OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master West Shore 697-0371 Ex!. 6535 Traci Jo Colyer Office Manager/Reporter March 3, 2005 John J. Baranski, Jr. Attorney at Law BLAKEY, YOST, BUPP & RAUSCH, LLP 17 East Market Street York, PA 17401 Thomas J. Williams Attorney at Law MART SON , DEARDORFF, WILLIAMS & OTTO 10 East High Street Carlisle, PA 17013 RE: Ricky L. Cramer vs. Bonita J. Cramer No. 00 - 4951 Civil In Divorce Dear Mr. Baranski and Mr. Williams: Enclosed is a draft of the agreement which you put on the record on March 3, 2005. Please review the draft for any corrections with the understanding that no substantive changes can be made. After you have reviewed the draft, give us a call so we can make appropriate corrections. We will send the corrected original to the Plaintiff's attorney for signature who then can transmit the original to the Defendant's attorney for signature. When I receive a signed copy of the document, I will then obtain a Court order vacating my appointment. Thank you for your continuing cooperation in bringing this matter to settlement. Very truly yours, E. Robert Elicker, II Divorce Master ~'~ ~, F:\FILES\DA 1'AFILE\Gellera1\Current\1 0079_I_phs lItde 10079.1 Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS & OTTO !.D. 17512 10 East High Street Carlisle,PA 17013 (717) 243-3341 Attorneys for Defendant Bonita J, Cramer \ ~l ~D/Oit- RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CNIL ACTION - LAW BONITA J. CRAMER, Defendant IN DNORCE PRE-HEARING STATEMENT OF DEFENDANT I. MARITAL ASSETS: Description Title Date of Separation Value Present Value Trailer (marital residence) W $11,000.00 $8,000.00 1984 Chevrolet van' W $0.00 $0.00 Six guns @ $250 each H $1,500.00 $1,500.00 CTS Reeves Retirement account W $950.00 $950.002 Daily Express Profit Sharing Account H $80,000.003 Unknown During the marriage, Wife suffered kidney failure as a result of contaminated medicine and recovered $40,000.00 in a personal injury action. She used this money to buy a 1983 mobile home 'The van currently has 120,000+ miles, was purchased shortly before the separation and Wife paid it off after the separation, It has been broken down for some time and will need major repairs. tThis no longer exists as it was cashed in by Wife. 'This amount is the marital portion of$120,000.00 profit sharing account. ~" J:...M.. ~ -""""'",-,,- for $14,000.00, She also paid Husband's numerous bills and loaned $4,000.00 to Husband's brother, which has never been repaid. The household contents have already been divided. II. EXPERTS: Wife cannot afford any experts and they are probably not necessary. III. WITNESSES: 1. Bon~ta J. Cramer. She married Husband on September 15, 1990, at a time when both of them were alcoholics. She suffered life threatening health problems in 1993: kidney and liver failure and cardiac arrhythmia among others. As a result of which she quit drinking and smoking; however, Husband continued same. Husband abandoned her during these health problems and she recovered with the assistance of family and friends. Wife tried to maintain the marriage by going to the bars with Husband and being the designated driver, but this proved impossible. Wife suffered depression and considered suicide. Wife continues to be treated at Helen Stevens. Husband took up with another woman, Connie Jordan (with whom he is now living), and finally left April 2, 2000. At that time, Wife was employed at Reeves-Hoffman as an assembler, but withing a few months took a similar job at Corning Frequency to avoid a layoff, but was laid off anyway on June 6, 2001, with no severance. She received unemployment benefits until December 2001 when they expired. She worked at Kmart over Christmas, but was left go after Christmas with the rest of the seasonal employees. .She then worked for Rite Aid for about a year, but lost that job also and received unemployment for a short time. On February 6, 2003, she obtained employment at WaIMart on a part-time, 32 hour/week basis. Wife is currently earning $8.84 per hour, with no benefits. She applied for early Social Security when she turned 62 in November 2003, and is receiving $671.00/month in Social Security benefits. She is also receiving $373 .OO/month in support from Husband, plus health insurance. Wife has no other source of health insurance. She does receive some assistance from Helen Stevens MHC for some of her medications. In addition to the above noted health issue, Wife has asthma, which is occasionally disabling; (she cannot tolerate temperature extremes) for which she uses an inhaler. She has arthritis in her ~,-~" ~..... "t'lil knees and shoulders, and has been told a total knee replacement will be necessary at some point. Wife was hospitalized in 1996-7 when she underwent two surgeries on her knee; internal bracing was inserted and screwed in place when both tendons ruptured. There are no tendons holding her left knee together, instead rods that pivot at the knee are inserted in her leg bones. The recovery from this was six months during which Wife's knee was immobilized. Husband provided little assistance to her during this recovery period. For example, he did not make any food for her, nor help her in getting around to do daily activities. Wife even had to let the dog out. Fortunately she had family to occasionally help. 2. Bobbi Lytle This is Wife's daughter who will testif'y about having to take care of her mother during recovery from knee surgery when Husband did not do so. She will also be able to describe the limitation on her mother caused by her numerous ailments. 3. Peggy Hancock. Saw Husband in Midway Bar with Connie Jordan prior to separation. 4. Wife reserves the right to call other witnesses, if determined to be necessary upon fair notice, primarily to establish Husband's infidelity and essential abandonment during Wife's illnesses. III. EXHIBITS: 1. Payoff of Wife's CTS Reeves Retirement account. 2. Photographs of Husband's gun collection. 3. Husband's Daily Express Profit Sharing statement. 4. Cellular phone calls from Husband to his paramour. 5. Wife's FIT returns, 2000-2003. 6. 1999 purchase documents for the 1983 mobile home, This was purchased about six months before the separation with money borrowed by Wife and paid off by Wife primarily after the separation. TIIIlI ~ 7. Complaint and Settlement Agreement for Wife's lawsuit regarding contaminated drugs, Wife recovered about $40,000.00 in a personal injury action which was used for marital purposes: she has none left. 8. 1984 Chevrolet van value statement. 9. Wife's 40 I (k) statement from McCoy. During the marriage Wife cashed in a 40 I (k) plan in amount of approximately $3,000.00 and was used for moving expenses to Baltimore when Husband's job was relocated there. IV. GROSS INCOME: Wife's income is stated in Section III above. Income tax returns, pay stubs and Social Security statements will be provided, V. EXPENSES: Other than her medications, Wife has no unusual expenses. She does pay lot rent of $365.00/month and would like to buy a lot on which to put her trailer. VI. PENSION AND RETIREMENT BENEFITS: This information has been provided above. On the date of separation, Husband's Daily Express Profit Sharing Plan had a value of approximately $120,000.00. He had been working there 15 years, the last 10 of which he was married to Wife; therefore, two-thirds of the DOS profit sharing value is marital. $120,000 x 66 %% = $80,000.00. VII. COUNSEL FEES: Wife has been unable to pay her counsel fees and there is an outstanding balance of approximately $1,500.00, as of September 29, 2004. A copy of the attorney's billing will be provided. VIII. DISPUTE ON VALUE OF MARITAL PROPERTY: Wife does not believe there will be a dispute on the value of marital property. .' ~ ~"~~ , -,-, <~, IX. MARITAL DEBTS: There is one marital debt: prior to the marriage and during the engagement Wife agreed to cosign on one of Husband's debts in the approximate amount of $5,000.00. In 1989, Husband discharged the debt in a bankruptcy filing, The creditor is now claiming against Wife on the guaranty. Also, Wife did pay off the balance on the 1984 Chevrolet van that is titled in her name. She paid this off after separation. XI. PROPOSED RESOLUTION: Wife requests one-half of the marital component of Husband's Daily Express Profit Sharing account, the 1984 Chevrolet van, her 1983 mobile home, and alimony in the amount of 40% of the difference in the parties' net income, plus health insurance. Respectfully submitted, MARTSON DEARDORFF WILLIAMS & OTTO By I ~~ VvdL~~ Thomas J. Wi ams, EsqUIre Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: October 19,2004 Attorneys for Defendant -~ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certif'y that a copy of the foregoing Pre-Hearing Statement of Defendant was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John J. Baranski, Jr., Esquire 17 East Market Street York,PA 17401 MARTS ON DEARDORFF WILLIAMS & OTTO ~;~ fJ IJ~~/ la D. Eckenroad ( , Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: October 19, 2004 ,~,;w>]~~l!l<il "'~~ ~--~. .. " - ~ ". 'J , M"'. ,. ~" ~. - ~ ' - . -, , IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA RICKY L. CRAMER : . Plaintiff CIVIL ACTION LAW VS. NO. 00 _ 4951 IN DIVORCE CIVIL 19 BONITAJ. CRAMER DATE: 11 <).?// :J /"'ID 5' Defendant STATUS SHEET ACTIVITIES: ~~h&r IYn~, -, )1--'1)/)/; D .. tJ',ptll[l,fY}' ~ 7~~/~ q:60 ~c:,........ c.,l'h. c{1 ~ ~ lLv.. ~~ ~~c.,f--b~ ~.~tl.7:~~ , ~ ~6.. -vr~ . -"", , "" -..'~ -..,' ",-,'''"..', -.. ..-. .. . ,-,"'.'.-.' - . RICKY L. CRAMER, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE TO: John J. Baranski, Jr. , Attorney for Plaintiff Thomas J. Williams , Attorney for Defendant DATE: Tuesday, April 20, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. -- ~ :1 . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. -,.~' I ., ~'-,-~,' .~~ -"-'.,, RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: John J. Baranski, Jr. , Attorney for Plaintiff Thomas J. Williams , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 22nd day of December 2004, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 10/25/04 E. Robert Elicker, II Divorce Master ..<~ -. -~~-, -~ II " =~-~, ~ - ~ ,",'" ... - "-~~-, -~,- "II.--H-, OCT-14-2004 15:20 BLAKEY YOST BUPP RAUSCH 717 8S4 7839 P.01 Albert G. Blakey D~vid Wm. Bupp Donald B. Hoyt Charles A. Rausch Sara A. Austin Bradley J. Leber Stacey R. MacNeal Pepny V. Ayers John J. Baranski. Jr. Michael C. Anderson Wanda l. Snader of counsel Donald H. Y OSI Blakoy. VOlt Bupp' Rausch, UP DATE: FACSIMILE TRANSMITTAL COVER LETTER )()j,iJ )~4 , TO: TOTAL NUMBER OF PAGES: ~ (intluding this page) RE: , FROM: MESSAGE: L.u ( dluI!.tJ ,fdiM- If you have any problem receiving this, please call (717) 845-3674. THIS MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient. you are hereby notified that' any dissemiDati'on or copying of this communication is prohibited. If you have received this cOnuDunication in error, please notify us immediately by telephone (coiled), and return the original message to us at the above address via U.S. Postal Service. Thank you. 17 East Market Street, York. P A 17401 717-845-3674 Fax 717-854-7839 l D"rJ-I01t: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant In Divorce PLAINTIFF'S PRETRIAL STATEMENT I. Assets A. List of Marital Assets Description Valnation Date value Liens/Encumbrances Mobile Home 4/15/00 11,000.00 none 1986 Olds Calais 4/15/00 500.00 none Chevy Custom van 4/15/00 2,500.00 none Grumanjohn boat 4/15/00 7000.00 none Three wheeled bicycle 4/15/00 300.00 none Swing 4/15/00 150.00 none Guns 4/15/00 1,500.00 none Dailey's express 12/31/00 50,121.61 none Retirement account, marital portion CTS Reeves retirement 4/15/00 1,000.00 none Account Personal Injury Settlement after 4/15/00 22,000.00 none purchase of home and loan to Merlin Cramer Appliances/Stereo/Electronics 4/15/00 500.00 none 2000 income tax return 4/15/00 3,500.00 none Loan to Merlin Cramer 4/15/00 4,000.00 none . ~ , < ~. B. List of Non-Marital Assets Description: Camper 38 caliber revolver hand tools police monitor Luger .25 Auto Ford F150 4/15/00 4/15/00 4/15/00 4/15/00 4/15/00 4/15/00 4/14/00 3,500.00 145.00 1,000.00 89.00 6,000<00 500.0 2,500.00 none none none none none none none II. Expert Witnesses Dan McGeary - pension appraiser if necessary III< Fact Witnesses Ricky Cramer: Denies the characterization of him and the parties marriage by Defendant and the allegations of marital misconduct. On the contrary, wife was insufferable during the latter parts of the parties' marriage. Plaintiff is unaware of the specifies of Defendant employment history. Plaintiff is currently employed at Overnight Trucking, and has been since 10/02/2001. Plaintiff's current hourly rate is $19.80< Since July 20,2000, Plaintiff has paid defendant over $17,128.00 in spousal support. Bonnie Cramer - as on cross to question the allegations set forth in her Pre-trial Statement, which Plaintiff denies. Plaintiff reserves the right to list other witness if it is determined that they are necessary for the hearing. N. Exhibits Pension appraisal Plaintiff's FIT returns Plaintiff reserves the right to list other exhibits if it is determined that they are necessary for the hearing. V. Income/Expense Will be provided prior to Hearing, with a copy to Attorney Williams. '7,1 H;i VI. Counsel Fees Plaintiff has paid approximately $1,500.00 in counsel fees and anticipates another $3,000.00 in fees and costs should this matter go to a hearing. VII. Marital Debts $5,000.00 debt of Plaintiffs to which Defendant is a personal guarantor. IX. Personal property Items of Plaintiffs non-marital personal property remain with Defendant, specifically hunting items and firearms, which Plaintiff would like returned. X. Proposed Resolution The Marital estate is valued at approximately $103,071.61. Plaintiff requests that the marital estate be divided as follows: Plaintiff Defendant Daily's Pension - $50,121.61 marital portion Guns - $1,500.0 Boat - estimated at $7,000.00 Merlin Cramer Loan - $4,000.00 Mobile home - $11,000.00 Oldsmobile - $500.00 Chevy van - $2,500.00 Bicycle - $300.00 2000 income tax return - $3500.00 Appliances/stereo - $500.00 Swing - $150.00 Personal injury settlement proceeds - 22,000.000 CTS account $1,000.00 Payoff debt - (-5,000.00) $ 57,621.61 $ 41,450.00 Defendant has been paid $17,128.00 in support since separation, assiguing this to her share of the marital estate would result in the her share totaling $58,578.00. Plaintiff denies that Defendant would be entitled to alimony, in any amount, or to be maintained on Plaintiff s health insurance. October:J.L 2004 ,,,. . - , . Respectfully submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP By: o . Baranski, Jr., Esquire S. Ct. I.D. #82585 17 East Market Street York,PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff " ~', " IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITAJ. CRAMER Defendant In Divorce CERTIFICATE OF SERVICE I hereby certifY that I am this day causing a copy ofthe foregoing Petition to be served on the following person in the manner indicated: By First Class United States Mail on: Thomas J. Williams, III, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 BLAKEY, YOST, BUPP & RAUSCH By: J . aranski, Jr., Esquire . Ct. J.D. #82585 17 East Market Street York,PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff Dated: ICl-'J.1-of ~, ~ ',- 1'--, ;:"cc___~'~ .,,- ,-"",,--. ....'/ ~-""'--;;", - ,'~ .'~,' .~ ",,; ~ "-i Albert G. Blakey David Wm. Bupp Donald B. Hoyt Charles A, Rausch Sara A. Austin Bradley J. Leber Stacey R. MacNeal Penny V . Ayers John J. Baranski, Jr. Michael C. Anderson Wanda L. Snader of counsel Donald H. Yost Blakey, Yost, Bupp & Rausch, LLP October 21, 2004 E. Robert Elicker, II, Esquire Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ricky L. Cramer v. Bonita J. Cramer No. 00-4951- Cumberland County Dear Mr. Elicker: Please find enclosed Plaintiff's pre-trial statement. Cc Thomas J. Williams, w/encl. Ricky Cramer 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 -- ,,--. ",'" "."',-,,. _:.1' c~_._ -",-",,, "':""- .-: ", -" -y---" ~ -t:, " F Albert G. Blakey David Wm. Bupp Donald B. Hoyt Charles A. Rausch Bradley J. Leber Stacey R. MacNeal Penny V. Ayers John J. Baranski, Jr. Michael C. Anderson Wanda L. Snader BYB -.R of counsel , t 1 I ! I , Donald H. Yost i' I, " Blakey, Yost, Bupp & Rausch, llP Attorneys at law October 28, 2004 E. Robert Elicker, II, Esquire Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 i, I;, I' I~ ,. Ii: Re: Ricky L. Cramer v. Bonita J. Cramer No. 00-4951 Dear Mr. Elicker: Please find enclosed a copy of my client's Income and Expense Statement with attached signed Verification. i I Ii I I il I Jo anski, r. B AKEY, YOST, BUPP & RAUSCH, LLP JJB:jbl Cc: Thomas J. Williams, Esquire (w/encl.) Ricky Cramer 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 =~'-'''''--~"~~'''~.''I'''~-''''''c ., .~ ="' ......~-""'\I'..:""-~. ~"""'''''''.J''~^~'_' ..:'"'~~~~""''''.: ~'fO ~:'~:-' l,'.,;'~ '1 :~"""'~.., ~ ,,~" '-' ""'""_''''''''''"'''..,---.~"." M~~6 ATI'ORNEYS & COUNSELWRSAT LAW WILLIAMF. MARTSON CARL C. RISCH JOHN B. FOWLER III DAVID A. FrtplIMONS EDWARD L. SCllORPP DAVID R, GALLOWAY DANIEL. K DEARDGRFF ANTHONY T. LucIDo . THOMAS 1. WILLIAMS. CIIRlSTOPHBR E. R]('E Ivo V. OTI'O. ill JENNIFER L, SPEARS GEORGE B. FALLER JR.. HILLARY A. DEAN "'B,oARD CERTIFIED_CIVIL ThIAi, SPECIALIST IO,EAST HIGH STREET, CARLISLE,PENNSYLYANIA 17013 . TELEPHt:lNE (717)243,3341 FACSrMn.E (717)243-1850, 'INTE~T -www.rr~.dwo.com November 11, 2004 E. RobertE1i<:ker, II, Esquir(; , Offle(;()fpivorceMaster .' ' 9. North Hailoyer Street Car1ish~, PA 17013 RE:RickyLCramer v. ~onita J, Crainer No.OO~4951- Cumberland County C.C.P. Our File No, J0079.1 . Dear Mr. Eli~ker: '.. '" . ' , " ." ~ I*;mtedtolet youJrnowthat I hayebeen ordered toaPre- Trial Conference in the case of .' Ma{son.eftd.v.Btifclmr,02-3917(CumberlandCounty C.C.P.}onDecetnber 22,2004.' This is the date youhavesetfor fhepie.Hearing Conference in this matter. , , ' .' ' . . ' , , ' . - ' - ' , ' upoll;checkingWith the Court AdriIip.istrator; I find that the Pre- Trial Conference schedule has notyetb(;(;ll'P6sted, so it may. be tIi.ere will be nocdnflictwith .the 9:00 a.m. pre-Hearing " )'"."- ---, , " '-'-' . '- - -, ,. -. - . , Co,...n"., fi,Fl.t,en. .,c.,..,e, . in,.,' .this c",as,e,', ;how,ev"er;I v,rant.e,dto....let, YO,u.kn,..O.W, , 0, .,fthe"., possibility" ,as. soohaspossible.. TheiMatson.et al.v,ButchercasFlwasjustlisted for trial this week. ' Very tnlly Y(jurs, MARTSONPEARDORFF WILLIAMS&: OTTO 1i.~1,.-- . ~',~f/(,,,- ' Thomas J. Williams TJW/tde ',' cc: Johnt~aianski,k;.Esqu;re F::\FILES\DATAFJiE\Gellera1\C~enl\lg079.:1.re3' INFORMATION. ADVIC,E . ADVOCACysM , ' '- - ' -.' i4~~~t~~Sji~~,1~~~~4[;~;"~~*;';'->lJi~~,S'i;'iji":1'::~.'fk,~~~f~>;':i<i1's,;~''i:';~i.;#;r4j~i~~Il'/.~,;;,li''0l"l<._,,'c:-;,,~!:';.~;_~_;J:.~'.;"'~:~' ,,1<-:c':r;".M"!':~'r';""" dl-J""Y.~';1>'J;:_.,It"<,,,,,,:J;." '~';;;,,<,- ,..i.-;';;*""-,~",~,;":,,, ;'':'''.{,-,,,:,(~~,,~,.,,,..6 -~, ~_;.,. '--,:, '"" -",/." -'0- " ;- "~~-'_........ ~ _ 0'-' 0' - ""',,-, - 4. .. ~~~ : ' .:..1&i!ktl~,:" OCT-14-2004 16:21 BLAKEY YOST BUPP RAUSCH 717 854 7839 P.02 Albert G. Blakty David Wm. Bupp Donald B. Hoyt Charles A. Rausch Sara A. AUSlin Bradley J. Leba Sta<;ey R. MacNeal Penny V. Ayers John J. Baranski, Jr. Michael C. Anderson Wanda l. Snader BYB of counsel Donald H. Y OSI Blakey, Y.", Bupp & Rausch. llP Attorneys at law October 14,2004 VIA FACSIMILE (711) 240-7890 'Traci Jo Colyer Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ricky L. Cramer v. Bonita], Cramer No. 00-4951- Cumberland County Dear Traci: Tom Williams has no objections to an extension of one week to file my pre-trial statement. I will be filing it along with the income and expense statement by Friday, October 22, 2004. John J. Baranski, Jr. SLAKEY, YOST, BUPP & RAUSCH, LLP JJB:jbl Cc: Thomas J. Williams, Esquire 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 TOTAL P.02 HP Lased et 3330 County 7172407890 Oct-14-2004 15:38 Fax Call Report Job Date Time Type 455 10/14/2004 15:38:05 Receive - - ~~"~ .~ ~ -..' .~ ..... ~ ~~~ Identification Duration 717 854 7839 0:30 OCT-14-2004 16'20 7176547839 P.0t BLAKEYYOSTEIl.PPRAUSCH AlbertG.Blakey Da.ndWm.B\lJlP Dol1llldB.Hoyt ChllrleaA.Reu.ch Sara A.AlUlin B.sdleyl.Lcbcr SlaeeyR,MaeNcal PelUlyV.kft:ri Jobll J. Bamn!k.i,Jr. Miebael C, Anclerson WOIIdaL.Sned., ~ DonaldR,YOII ofCOllnsel Blol:4YaltBlfpliMdl,LlP DATE: FACSIMILE TRANSMITTAL COVER LETTER JoJ/4 )04 , TO';jv,...; ?-(1~./~~ TOTALNUMBEROFPAGES;~ ~NUMBER: r'f}tJ/J,.. 789/J (iadalmgthlspage) mOM, ~ eAt~ u, 'C . CA~- MESSAGE: W tI;/jj;jj,~ f.c/i;;:L. ( . Uyou bave auy problem re<<lv1Dg this, plellre can (717) 84$-3674. THIS MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WlllCH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDeR APPUCABLELAW. If the reader of tbls message II Dot the illteDded recipient, you are hereby notified that' :my dmemIDadoD or copyID& of this- Ilommmrleatiotro ill ,rohlblted. If )'ou have received this eommlllllir.ation kl error, please uotifY Us Iamaedblely by u1epbone (eolleet), and return the original message: to liS at the above address via U.s. Po.lal Serville. Think yOIl. 17 EastMarketSlreet,York,PA 17401 717.845.3674 Fu717.854-7839 Pages 2 - .~ > -,~~ ~',f" M@ i n v e n t Result OK . ~,,,,, '-",4'_-d " ",'. ~ .', OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master West Shore 697-0371 Ex!. 6535 Traci Jo Colyer Office Manager/Reporter September 22, 2004 John J. Baranski, Jr. Attorney at Law BLAKEY, YOST, BUPP & RAUSCH, LLP 17 East Market Street York, PA 17401 Thomas J. Williams Attorney at Law MARTS ON, DEARDORFF, WILLIAMS, & OTTO 10 East High Street Carlisle, PA 17013 RE: Ricky L. Cramer vs. Bonita J. Cramer No. 00 - 4951 Civil In Divorce Dear Mr. Baranski and Mr. Williams: Both counsel have certified that discovery is complete. A complaint in divorce was filed on July 13, 2000, raising grounds for divorce of irretrievable breakdown ofthe marriage, The complaint also averred that the parties separated on April 2, 2000. On August 30, 2000, the Defendant filed a petition raising claims for equitable distribution, alimony, alimony pendente lite and counsel fees and expenses. The Plaintiff filed a petition averring a separation in excess of two years which was previously averred in the complaint. In accordance with P.R.C.P. 1920.33(b) 1 am directing each counsel to file a pretrial statement on or before Friday, October 15, 2004. Upon receipt of the pretrial ";0-'1 < ~, [-,,-- '<-<j , Mr. Baranski and Mr. Williams, Attorneys at Law 22 September 2004 Page 2 statements, I will immediately schedule a pre-hearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) ofRu1e 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. "'>1. .~ ". =" ~" "lJ ~, w u ~~ ~ : jiOllit" , ~ ~ IN THE COURT OF CdMMON PLEAS OF CIlMBERLlliD COUNTY, PENNSYLVANIA RICKY L. CRAMER Plaintiff vs. BONITA J. CRAMER NO. 2000-4951 19 a master with respect to the (x) Divorce ( ) Annulment (x) Alilllony (x) Alimony Pendente MOTION FOR APPOINTIlENT OF MASTER (Plaintiff) (Defendant), following claims: moves the court to appoint Lite ( x) ( ) ( x) ( x) Distribution of Property Support Counsel Fees Cos ts and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) (has not) appeared in (by his attorney, Thomas J. vvi1liams (3) The staturory ground(s) for divorce (is) ~3301(cl and (dl of the FA Divorce Code (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the none (c) The action is contested with respect to the following all claims listed above (5) The action (~.) (does not involve) complex issues of law the action (personally) ,Esquire). (are) following claims: claims: or fact. Date: The hearing is expected to take 2 (hours) (Il:~. Additional information, if any. relevant to the motion: ~Y>' ~~or (Plaintiff) ~b"w~~) ~ ORDER APPOINTING MASTEwohn J. Barans~i, Jr., Esquire AND NOW .;:Po (9 ,~..:Jia!>,c( SL-IJ..If E" I,u'~ Esquire, is appointed mas er with respect to the following claims: tLl.J- ~-~ (6) (7) April 6. 2004 ;?J ~ , :""-" . ,_~~,~~<__._"J'lIl!l!!Ile't ryfICI 53'f 'F.> ,"" ~' FilED-CHiC::: ("C 'n.," fr: GorlT,1 '1-';-.,10'[,- ,6/:iV Vi :rlL I' ,-,j', LI.,J, ,,,< ..- . ?0ill. A ,\':>t.:) I 0 ,f.\,i,/,; Cj: 0,_9 t.t.J:J'1 H l\ I;) <"-' ~~~":'Lj;-{f"'l ,! ~ . im"iT~~~~!'il!Jt!~~I';;~""l%'-!~-~'"'''''''''';:''''!'''F'';=<;'""."~",,j"'''"",,,~","''ffiF;'''';T'_Plf'![.;Ri'lW';9'''''"'N;C;'~''-O:~~'l'i'i!ti~,';f~ RICKY L. CRAMER Plaintiff, No. 2000-4951 , ".-' ,I I tl ii I' I I' 11 Ii I, Ii 'I f~ Ii Ii u II ',I 1',1 'I I, !1 ij II IJ . IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CML ACTION - LAW vs. BONITA J. CRAMER Defendant In Divorce , , CERTIFICATE OF SERVICE I hereby certifY that I am this day causing a copy of the foregoing Petition to be served on the following person in the manner indicated: By First Class United States Mail on: Thomas J. Williams, III, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, P A 17013 BLAKEY, YOST, BUPP & RAUSCH, LLP By: ~...< ~ &-- rma M. D , Par~egal 17 East Market Street York,PA 17401 Dated: 4/ :>1eJ.~ . .,~.., .~ ll!\lI1':[Ua~l!!l,t"'~~~~O'.!~~~~-~'=~" ~.- M~" "'- -~' if fPV ,.<. ~_,;, ~", "-..;1,",-,"- ".~ "">-~,d.~--' '.'. C) "" c;) 0 C = ---;--"~ ""(1 ~T~ 'Or" "'" '-1 n~l ~ \ i V -r ""~" ;:;0 Rl:D 2~ t r- -orn ~/~ :00 -. en r' 06 :::: =;:1'1 ;:::: r'" " 13 -r, (<; -,,,, j;~ ._~loo 7C) ,';;:' ~::rn '~m~ ,j L ~ ::;I N ::'0 , CI'\ ~: . ""'" - RICKY L. CRAMER, PlaintifflRespondent v. BONITA J. CRAMER, DefendantlPetitioner , '. ... -~ , "",~,"-"-~,,, , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-4951 CIVIL ACTION - LAW IN DIVORCE RULE AND NOW, this Z'''"day of October, 2001, in consideration of the foregoing Motion for Protective Order to Preserve Marital Property, a Rule is hereby issued upon Plaintiff, Ricky L. Cramer, to show cause, if any there be, why the relief claimed should not be granted. Rule returnable IS days after service. Pending further Order of this Court, Husband is enjoined from taking distribution of all or any part of his share of the Daily Express, Inc. Employee Retirement & Profit Sharing Plan. A copy of this Order shall be promptly served on: Plan Administrator Daily Express, Inc. 1076 Harrisburg Pike Carlisle, P A 17013 BY THE COURT, / ~ .11~ , J. ~ '", ~-'~"" ""....., nl7~ ~ ) t,fl,_" "j'" -,' -~"., ! ~+~jTi\RY 0,' ['f'T 2 Q P,c'; '-',: I I I )'-.' ..... 'b' ,,-, . - <> D ") CUMBEkl.ANJ COUi~1Y PENNSYLVANIA tf '1 } " ~ .,' ,-\\,-;pl!I*.P_~ """,':ffl:1'ffl'!ll:l't'>il'*~~!'l:~WfJ~,:l!J_!DI!jiiiffllil!f I ~"'~""' ~<<'" , !lI! - - _I, h) F:\FILES\DATAFIL'E\Gendoc.cur\I0079-mot,lItde Created: 07/25/00 09:42:54 AM Revised: lOf17/011l:52:51AM 10079.1 RICKY L. CRAMER, PlaintifVRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-4951 CML ACTION - LAW BONITAJ. CRAMER, DefendantlPetitioner IN DIVORCE DEFENDANT'S MOTION FOR PROTECTIVE ORDER TO PRESERVE MARITAL PROPERTY AND NOW, comes Defendant, Bonita J. Cramer, by and through her attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, pursuant to 23 Pa. C.S. g3323 (f) and, in support thereof, avers as follows: 1. Petitioner is Bonita J. Cramer (hereinafter "Wife"), an adult individual residing at 19 Coral Road, Carlisle, Pennsylvania. 2. Respondent is Ricky L. Cramer (hereinafter "Husband"), an adult individual residing at 20 Trine Avenue, Mt. Holly, Pennsylvania. 3. The principal item of marital property in this divorce is Husband's profit sharing plan from his employer, Daily Express, Inc" which has a value in excess of$1 00,000.00. A copy of the most recent statement in Wife's possession dated May 22, 2000 is attached hereto and marked as Exhibit "A." 4. Wife was recently advised that Husband left his employment at Daily Express, Inc. 5. The termination of Husband's employment at Daily Express, Inc. may allow him to withdraw, cash or otherwise dispose of the balance in the aforesaid profit sharing plan. 6. Wife believes, and therefore avers, that Husband will dispose of the balance in the aforesaid profit sharing plan in order to defeat the claim of Wife in the instant action. ._" WHEREFORE, Wife prays Your Honorable Court to enjoin Husband, Ricky 1. Cramer, from taking sole possession of the balance in the aforesaid profit sharing plan until an award of economic division of marital property can be made in this action. Date: October 23, 2001 Respectfully submitted, MARTSO, DEARDORFF WILLIAMS & OTTO By -~ ~~ Thomas J. W' Ii s, Esquire Ten East High treet Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer ,;Ii - - ~"~. .. Dear Plan Participant: I am pleased to report that our Profit Sharing and Retirement Fund had an overall return ofapproximately 4.24% for the year. The Fixed Income Fund returned (-)5.19%. Enclosed is your certificate showing your participation in the Fund for the year 1999, together with a "Statement of Account" which shows a financial summary of the transactions of the Equity and Fixed Income Funds. Your certificate shows the balance in your account as of January 1, 1999; the amount of the Company's contribution to be made to your account for 1999; your share of earnings on the investments during 1999; your share of forfeitures; the accumulated balance in your account on December 31, 1999; and the calculated amount of your vesting at year end. The net income of the Total Fund for 1999 was $615,112. This amount is composed of $663,502 of income from interest and dividends, less administrative costs of $28,202, plus net gain on securities sold of $5,216, and the decrease in market value of securities held at December 31, 1999, of $25,404. The contribution to be made for 1999 by Daily Express, Inc. totals $647,388 computed as 11 % of each participants 1999 wages. This is the fortieth year contributions have been made to the Plan. Each year the Company, by September 15, pays your computed contribution for the prior year to Dauphin Deposit Bank, as Trustee, which means the Fund is fully funded and you will receive all amounts to which your vesting entitles you. The funds are then invested from the Trust Fund once the contribution has been made. The Employees' Profit Sharing Fund Committee has the following members: R. F. Long, H. C. Smith, R. H. Wertz, K. F. Cummings, Dwayne A. Kepner and J. P. Mitchell. The attached Statement of Account reflects the transactions of the Fund for 1999 based on market values. Sincerely, e~~:7 for the Committee EXHIBIT "A" P. o. BOX 39' CARLISLE, PENNSYLVANIA 17013-0039' (717) 243-5757 DAIL Y EXPRESS, INC. EMPLOYEE RETIREMENT AND PROFIT SHARING PLAN Statement of Account __ January 1, 1999 to December 31, 1999 Fixed I~~,:e l{;i~~f~~~~E'f0.;;~~ $11'151736=\11 $647,388 ~7: .,.. '. MARKET VALUE OF FUND AT DECEMBER 31,1998 RECEIPTS: Employer's Contribution Transfers Between Funds Income from Investments Interest & Dividends- Net Galn/(Loss) on Investments Sold- TOTAL RECEIPTS DISBURSEMENTS: Distributions Fees TOTAL DISBURSEMENTS NET OF RECEIPTS\(DISBURSEMENTS) INCREASE\(DECREASE) MARKET VALUE' MARKET VALUE OF FUND AT DECEMBER 31,1999 Equity Fund $5,941 ,246 $14,000 $55,275 J';,:;, ($14,000)~5 %.~;~:::., '60.-1r4tll 'i:~''!!':Y.'".'i $38,912 $108,187 $1,207,918 ($15,950) $92,237 $1,048,080 ~7.'Yii~'~ ($1 073 484f":)'V;';',;"'-,::($25!40!'H , , s?~~1r#i~;~&;~~~r~ $9,460,889:::",0:$16',542,453; $7,081 ,564 ,.. ~ , , , , , DAILY EXPRESS; INC. EMPLOYEE RETIREMENT & PROFIT SHARING PLAN STATEMENT OF ACCOUNT AS OF 12/31/1999 FOR RI,CKY L CRAMER Profit Sharing Account 01/()111 999 Account $ 92,771.23 Contribution 3,855,86 Investment Results 3,934.83 Forfeitures 347.51 12/3111999 Account $ 100,909.43 Vesting Percent " 100% Vested Amount $ 100,909.43 . Every effort has been made to insure the accuracy of the information contained in this Statement of Account; however, in the event of a discrepancy, actual benefits will be determined according to the Plan provisions. ." lilIilllllid ,~ Daily Express, Inc. ' 1072 Harrisburg Pike Carlisle, PA 17013~1615 RICKY LCRAMER D285:A00025. DATE OF BiRTH: DATE OF EMPLOYMENT: SOCIAL SECURITY NO: - '-~~~. ~li<" 03/14/1957 07120/1981 209-60-7648 II Ii " , Ii Ii Ii !j ~-~' ,~,-' .. . j~ItWI"'~''''''''~..- ~..I ~.~ =-- "" ~ .~ . ~- ~ .~l!._"'11# , Daily Express, Inc. Employee Retirement & Profit Sharing Plan Summary Anliuar Report . . This is a summary of the annual report which has been filed with the Internal Revenue Service, as required under the Employee Retirement Income Security Act of 1974 (ERISA) for: Plan Name: Daily Express, Inc. Employee Retirement & Profit Sharing Plan Plan Number: 002 EIN: 23-1530123 Plan Year: January 1, 1999 to December 31, 1999 Basic Financial Statement Benefits under the Plan are provided from the trust fund. Plan expenses were $1,841,231. These expenses included $28,202 in administrative expenses, $1,813,029 in benefits paid to participants and beneficiaries, and $0 in other expenses. A total of 234 persons were participants in or beneficiaries of the Plan at the end of the plan year, although not all of these persons had yet earned the right to receive benefits. The value of plan assets, after subtracting liabilities of the Plan, was $16,542,453 as of December 31,1999, compared to $17,091,057 as of January 1, 1999. During the plan year the Plan experienced a decrease in its net assets of $548,604. This decrease included unrealized appreciation or depreciation in the value of plan assets; that is, the difference between the value of the plan's assets at the end of the year and the value of the assets at the beginning of the year or the cost of assets acquired during the year. The Plan had total income of $1,292,627', inciuding employer contributions of $649,313, employee contributions of $0, gains of $5.,216 from the s;3.le orassets, earnings from investments of $638,098, and $0 in other income. Your Rights to Additional Information You have the right to receive a copy of the full Form 5500 series annual report, or any part thereof, on request. The information listed below is Included in that report: . An accountant's report . Assets held for investment . Transactions in excess of 5 percent of plan assets To obtain a copy of the full annual report or any part thereof, write or call the office of the Plan Administrator: Daily Express, Inc. 1072 Harrisburg Pike Carlisle, PA 17013-1615 (717) 243-5757 The charge to cover copying costs will be $4.00 for the full annual report or $.25 per page for any part thereof. You also have the right to receive from the Plan Administrator, on request and at no charge, a statement of the assets and liabilities of the Plan and accompanying notes, or a statement of income and expensp~ of the Plan and accompanying notes, or both. If you request a copy of the full annual report from the Plan Administrator, these two statements and accompanying notes will be included as part of that report. The charge to cover copying costs given above does not include a charge for the copying of these portions of the report because these portions are furnished without charge. You also have the legally protected right to examine the annual report at the main office of the Plan shown above and at the U.S. Department of labor in Washington, DC, or to obtain a copy from the U.S. Department of labor upon payment of copying costs. Requests to the Department should be addressed to: Public Disclosure Room, N5638, Pension and Welfare Benefit Administration, Department of labor, 200 Constitution Avenue, N.W., Washington, DC 20210. 026S001.084:0El -. ""","," VERIFICATION The foregoing Motion for Protective Order is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ~To.-r'~ Bonita J. Cramer /ilili'", CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Motion for Protective Order to Preserve Marital Property was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John J. Baranski, Jr., Esquire Law Offices of Harold S. Irwin, III Hitner House Suites 20 I and 202 Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO ~. \ fJ y ~- . Tricia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 ~ Dated: October 23,2001 It''''~-'''~ '""-'\ ..,~ ~~~_~~~~.iilllir~-'"""""~~"'iiiil~"- ~.;..,' "'~~ ,N~' ~, - - . ,,-,," t!5 ~ l'1iU - - (') C:) 0 C 'T) "":- => 92ft ;:~~) --1 'Tj , zr'" N ~~~ [j (J)J'> -i= ~-:::L_~ ,.-., 1 r::O :::iC} ~- ::~ ::-:=:Ii --.l) -- ()c:'" Let 7 .I )O'C r:Y om ~ .-, '" ~ r" -< , ~~ RICKY 1. CRAMER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. BONITA J. CRAMER : NO. 00 - 4951 : IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Ricky 1. Cramer John J. Baranski, Jr. , Plaintiff , Counsel for Plaintiff Thomas J. Williams , Defendant , Counsel for Defendant Bonita J. Cramer * You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office ofthe Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 3rd day of March 2005 at 9'00 a,m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, George . Hoffer, President Judge Date of Order and Notice: 12!.22/()4 By: Divorce Master 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 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 * TESTIMONY WILL BE LIMITED TO THE FACTOR OF MARITAL MISCONDUCT AS THAT F ACTOR MAY AFFECT WIFE'S ALIMONY CLAIM. " ' , ,-, ~ _,C,'''__.'', ,', ~ ,-, ' Albert G. Blakey David Wm. Bupp Donald B. Hoyt Charles A. Rausch Sara A. Austin Bradley J. Leber Stacey R. MacNeal Penny V. Ayers John J. Baranski, k Michael C. Anderson Wanda L. Snader of counsel Donald H. Yost Blakey, Yost, Bupp & Rausch, t,t,p September 14, 2004 E. Robert Elicker, II, Esquire Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ricky L. Cramer v. Bonita J. Cramer No. 00-4951 - Cumberland County Dear Mr. Elicker: Please find enclosed Plaintiff's certification that Discovery is complete. Cc Thomas J. Williams, w/encl. 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 ,o~~,;~ii>~;;."i"..,:,;~:,;>l",>",,,,,,,,~,~ ~ ' ~" " ,', ~. < ........_~~ < - ....."""""""",'...."""""''''' ',-'-" --.. 'tf- .' ~"< i~ ii'iii",i;.ll!l;;j,i"W"'I..IiI""'''bll>>_'''-'''''i1,"",j,,--,,,,-,,~,,, MB\V&6 . - INFORMATION. ADVICE. AnvOcAC;" - ' ' ':-, " : May7,2004 ATTORNEYS' & COUNSELLORS AT LAW WILLIAM F. MARTSON JOHNB. FOWLER III EDWARD. L. -SCHORPP DANIEL K. DEARDORFF THOMAs J. WILLIAMS* Ivo V ,OTTO III GEORGE B. FALLERJR.* CARL C. RISCH DAVID A.' FITZSIMONS DAVID R. GALLOWAY ANTHONY T. LUCIDO CHRISTOPHER E. RICE STEVEN J. SHANAHAN *BOARD CERTIFIED CIVIL TRIAL SPECIALIST TEN EAST HIGH ST1'l-EET CAI{liSLE, PENNSYLVANIA 1701.3 , TELEPHONE FACSIMILE iNtER~ET (717) 243-3341 (717) 243-1850 WwW.mdwo.com ' E.RobertElicker; n, Esquire ,Office ofDivorceOMaster 9 NorthHanover Street 'Carlisle,PA 17013. RE: 'Ricky L,.Crll1TIery. Bonita J. Cramer - N\J.OO~4951 ~ CumberlandCountyC,C.P. our File No. 10079.1 ' Dear Mr. Elicker: . We enclose DefendanfsCertifiqatiol1 that discoveryis,complete. Veryttulyyours, MARTSON DEARDORFF WILLIAMS &- OTTO f~{ U-.,L(~ Thomas J, Willianis 'TJWM:: EnclosUre cc: John J. Baranski, Jr.,Eaqiiire (w/enc.) F:\FiL~\DATAflLE\~eraI\Curr~t\10079-L~1 _, IN.FORMATION . ADVICE' ADVOCACySM . , , ' - ;'".:t.. '.:d~,:.,.~..Eii_i,i,~",,,,,,,~.;j~~~:_~M..~.it,,,.i1~,,~il--4'Xri>:";"'m-:';;'''''''''l~'1>iil",-~i\'16"$..;,:"J.;",",~~."-~.,,,,'o;;.;'~v)-;-~';),.,o;, )''';'''''''''l<i:_~''';'~Wt'''~ .',o'--""i..."",,,,.o ,.-~;.,,;=,,~, ';'t/i;"f"'''-'' ,,,.,,,,>,<,.~~;,,.v~:,:.~;:..,,,-,,f;;";',,,,~,.'.,,~,<,.,;- <.--,,"~'- \ "'~ ' , . , ~- ,., F:\FILES\DATAFILE\Gendoc.cur\10079-equ.disltde Created: 07125/0009:42:54AM Revised: 08/28/0009:52:36AM 10079.1 RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, Defendant IN DIVORCE DEFENDANT'S CLAIM FOR ECONOMIGRELIEF AND NOW, comes the Defendant, Bonita J. Cramer, by and through her attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and makes the following claims for economic relief: I. Plaintiff and Defendant are the joint owners as tenants by the entireties of certain real estate which is subject to equitable distribution by this Court. 2, Plaintiff and Defendant are the owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this Court. 3. Plaintiff and Defendant are the owners of various motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. 4. Plaintiff requests your Honorable Court to allow alimony as it deems reasonable pursuant to Section 3701 of the Pennsylvania Divorce Code. 5. Plaintiff requests your Honorable Court to allow her alimony pendente lite, reasonable counsel fees and expenses pursuant to Section 3702 ofthe Pennsylvania Divorce Code. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; c. Awarding alimony as the Court deems just and reasonable; d. Ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; and e. For such further relief as the Court may determine equitable and just. MARTSON DEARDORFF WILLIAMS & OTTO ~~ IZA- ~ Jt ....::- Date: August 28, 2000 By Thomas J. Williams Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant J..WiIO " ~~. t VERIFICATION The foregoing Claim for Economic Reliefis based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ~P-- \.,. ~fV?) Bonita J. ~ramerQ' F:\FILES\DATAFlLE\Gendoc..cur\I0079..equ.dis ~ ~~ CERTIFICATE OF SERVICE I, Tricia D, Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Claim for Economic Reliefwas served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John 1. Baranski, Jr., Esquire 35 East High Street, Snite 20 I Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Y Trici D. Eckenroad n East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 28, 2000 ;;';k l~..J9i!trrm""j""i!t" -"~ lidilij.IJj!j!:i!ill1lllUMll:~~~~!if"rf--r.;~"....'i ..1 ,~"'~' I (~ >"~ ,', ,~;, >", . " '" 0 C:.::; C t.::J ~.; :;::0- V-C'j ::0. rflfT-, C=) - ~~' -, r== C'hl ,',.., <::) i=r5 ,-, ;_J ~"> C-"" ~? ~ ':':C >1 "-.J C 1;:) C) rn -, ~ /- =<! en 5:J -< . RICKY L. CRANER, Plaintiff vs. BONITA J. CRAMER, Defendant TO: John J. Baranski, Jr., Thomas J. Williams, Date: September 14, 2004 , .' C"o._ ". , 'i,) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNSYLVANIA NO. 00-4951 CIVIL IN DNORCE Attorney for Plaintiff Attorney for Defendant CERTIFICATION I certifY that discovery is complete as to the claims for which the Master has been appointed. BLAKEY, YOST, BUPP Jo . aranski, Jr., Esquire Supreme Ct. Id. No. 82585 17 East Market Street York, PA 17401 (717) 845-3674 <" Counsel for Plaintiff f ~ -<k ,'" _>0'. f'. VylOl b(f RICKY L. CRAMER, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE TO: John J. Baranski, Jr. , Attorney for Plaintiff Thomas J. Williams , Attorney for Defendant DATE: Tuesday, April 20, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. '~ ~.~f',""b- ,"---, 'L-o (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. I' I -r~ ;lwdt~ ATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT (X,) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ;- ~ -'m~!~iOOm~!;IiiI-~"~II:iilll:~J~~~~~;;:'.~oj,,'~w~~~OiIoil "_....'i"'1liJI:~ ",~ ",",--." ~ _ , _, ' ,J ......1Ii!lBnIl1lilii!iL.Al!' < '"'-'"~........-"~ '~~j "",",', --ow",," AECEIVEl APR 2 3 2004 I\IIDwr . ~ ~, '-~~=->O'-, . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY 1. CRAMER Plaintiff, No. 2000-4951 vs. BONITAJ. CRAMER Defendant In Divorce PETITION FOR RELATED CLAIM COMES NOW, the Plaintiff, Ricky 1. Cramer, and by her attorneys, Blakey, Yost, Bupp & Rausch, LLP, pursuant to Pa. R.C.P. 1920.13(b)(2), and Petitions the Court as follows: Section 3301(d) - No Fault The parties have been living separate and apart for a period in excess of two (2) years, to wit: since April 2, 2000. WHEREFORE, Plaintiff requests this Court to enter a Decree of Divorce under Section 3301(d) of the Pennsylvania Divorce Code, as amended. BLAKEY, YOST, BUPP & RAUSCH, LLP By: . aranski, Jr., Esquire S. Ct. J.D. #82585 17 East Market Street York,PA17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff , ~ . , . ~. " 'r _~' -, ..... VERIFICATION I, RICKY L. CRAMER, verify that the facts set forth in this instrument are true and correct to the best of my knowledge, information, and belief This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 94904) relating to unsworn falsification to authorities. ~ R . ... .~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant In Divorce CERTIFICATE OF SERVICE I hereby certifY that I am this day causing a copy of the foregoing Petition to be served on the following person in the manner indicated: By First Class United States Mail on: Thomas J. Williams, III, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, P A 17013 BLAKEY, YOST, BUPP & RAUSCH, LLP rma . oil, Paralegal 17 East Market Street York,PA 17401 Dated: .p%~ .' ,,~ -., ~'-'-"---i~r;; 'Ii U ''I !:! ''i :ii ;:) ii i~j ':-1 !d iIf'~~' .::~~ '~,~i}W.U,o&l_lliifu:m>!1';'C"I~~!ifj,;,lH~~~..~k;';'>WJI",m!,.",rn;'<i!dJ!I1....,~;l;ij!!~~- "'..< lliliiIIlii: 'lilJ'liS" . . .~ tIS I3/LL lr'~ltIl!iI!lfIii ~ - - 0 "-, c: =- ~ = s:: .zo- ~i"i] ~ :r'." ?!L;,! ;;:0 m51 ~.F-::'. '. iti" 3~~ w '~.~ ," -0 ~~s ::li:: a~ -~ .-e- N 'Orn :':'2: ):;' --, -< ::0 .j,,- -< . . .J' , ~, ~ 1 " ,"" ,,(, -'-,. -" ,- '" ' '"', - -;',~ ',", , . '_L". ,L"'-'",'1: RICKY L. CRAMER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000-4951 BONITA J. CRAMER Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF SUBMITTED BY: RICKY L. CRAMER, PLAINTIFF AGE:.!:LL. STATUS: SgPtiAA-7ED HEALTH: ::/4>11{ , EMPLOYER: {JUEI{ IJ IT E 7l<ft IV s f' L (J . LENGTH OF SERVICE: 3 i~ PRIOR EMPLOYER: D41iy eX;JIU~s ]l;/Jc.. I LENGTH OF SERVICE: Jo 'its EDUCATION, TRAINING, AND SKILLS: /.lIe- It Sq-j-C'o ( per rol'vlA , , t?tJ T(-f~ JC1B TMtlv'~ ".', ,~ ,'" , . Per Pay Weekly Monthly Yearly GROSS EARNED INCOME: 7;;':;, tIS DEDUCTIONS: Federal Income Tax /J-3,()' State Income Tax ;)3-03 F.I.C.A. l(6, 5 , Medicare Tax /()-If~ Local Tax ;-,]-00 P A Unemployment ,rc,q Life Insurance y. ;) <! Medical/HospitalJDental Insurance /S.oS i"[aHg..fi;ru-p~ I- 0"'''1 7d(Il/, ibis. (P.7! . v :L:J . 'Ih Voluntary Retrrement Savings Bonds , .9l7Jc.K c.. ;;'0- b:) .s:!o<.tSI4- ( -SC-{/J/bI(T r:st;-o fl' TOTAL DEDUCTIONS 37/."i1 NET EARNED INCOME 393.;)') OTHER INCOME: Child Support Spousal Support Interest " Dividends i Pension Other Retirement , Annuity '""'-'~~, ^- , ~ , '. -lG~ , ' Per Pay Weekly Monthly Yearly Social Security Rental Income Royalties Expense Account Gifts Unemployment Compensation . Workers Compensation TOTAL OTHER INCOME TOTAL NET INCOME CURRENT EXPENSES: Mortgage (Marital residence) Rent '),50, 'PO Maintenance UTILITIES: Electric 1.(0.' tJO Gas Oil (heating fuel) Telephone Io/f). (JD Trash Collection Water Sewer Cable Television .3 o. oV -, "'~ . "-~ "~ - ,~ ", ".~ Mil I I Per Pay I Weekly I Monthly I Yearly I EMPLOYMENT: Public Transportation Parking Lunch 30,00 Education Supplies/Equipment stJAl' ON 100 70,00 m,(lt 7<>01<, Memberships TAXES: Real Estate Income (not set forth above) Personal Tax INSURANCE: Homeowners (Not in Mortgage) Automobile /Joo,&C Life Accident Health (Not deducted from pay) Disability Renters . AUTOMOBILE: Payment Fuel 4500 MaintenancelRepairs . , . "-" , .- _ ~" ~_. ._",.' ~-,'~' _, C'" ,,0"< _-.~_~, :.'~_ .'"'." ,"__",,,~' '. ,. " " Per Pay Weekly Monthly Yearly MEDICAL (After insurance payment): Doctor JJ,o </<> Dentist ;200 c,o Orthodontist Hospital Prescription Medication 3000 , Over the Counter Medication 30,00 Special Needs EDUCATION: Private School Parochial School College Religious PERSONAL: Clothing .:);00 0 0 Food BarberlHairdresser tio,"o Laundry and dry cleaning (t;;..00 CREDIT CARDS: OAif11lL dAlE l/'/.llt- 300<" , C4f? ;Till- (77 Ie- 30 <>" OI\J€ . II /./ If it S e.c/r/l /J dehT /50<) ,.,-, -;- "'. ~- ,- - ~." ~, Per Pay Weekly Monthly Yearly CHARGE ACCOUNTS: . \ LOANS: C' , ~;NA/lJf;lllvL-- ,il'lOyO /17/ MEMBERSHIPS: /l1Jtt;(.J, (Cl/-IJ 1 ~G-I~/V :J~ ijO CJ /J-U {j.Fv-( /jo 7ftwi , ~!;tlD ~fj f B<wv MISCELLANEOUS: Household Help Child Care PaperslBookslMagazines Vacation Gifts Legal Fees Charitable Contributions Child Support Alimony , '~'. -,"-, ~ ~ '"" ,.-.!it, , , Per Pay Weekly Monthly Yearly OTHER: Tax preparation Lj.!Ji 00 Veterinarian TOTAL CURRENT EXPENSES NET CASH AVAILABLE ="-' " - ~ ,~.., -"J - ~ ~-,.. .:' ,,' '; , ~-n;::J '" ~. , VERIFICATION I verify that the foregoing facts are true, upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. ~a.- // Ric Cramer - Dated: /o-"lyt.ay^ , i!i~~~-'kri,"""""-"-'~~~"'-~"'~',"=-''''~"''"""" ~... '"", ~" ~'II\liliiIir"""-"- ."'~_.'~~'="""~'~~'~ 0, ~'~-, '-___~. ,." 1 ~'r "' ,'. ~''''',,'~...'""', " . -' , '.' MMARTSONIJD'EA~RDORFF .w~., ILLIAMS &oOTTCi .' '" ", < ' '.,' . . . ........ ...............<< > INFORMATION-ApVICE-MvOCACY- "'_ ,:.: :: , October 19,2004 ATTORNEYS & COUNSELLORS AT LAW WILLIAM F. MARTSON JOHN B. FOWLER 1II EDWARD L. SCHORPP DANIEL I<. DEARDORFF T~QMAS. J. WILLlAMS* Ivo V. Ono 1II GEORGE B: FALLER JR'. * CARL C. RISCH DA VII) A. FITZSIMONS DAVID R. GALLOWAY ANTHo'NY T. LUCIDO CHRISrOPH;ER E. RICE JENNIFER L. SPEARS . 10 EAST HIGH STREET , C;:ARLIS~E, PENNSYLVANIA -170'13 TEI:'EPi-IONE FAC~IMILE , INTERNET (717) 243~3341 (717) 243'1850 wWw.mdwo.com *BOARD CEE.T1FIE,D ,CIVIL TRIAL SPECiALIST . . . -, - E;R9bertE~icker, II, Esquire Oftice ofpivoi-<:,e Master 9 North lIanbver Street Cailisle,.PA 17013 RE:. RlckyL: Cramery.BonitaJ.Cramer No. 00.4951 : CumberlandCOIinty C.C.P. ()ur File No. 10079.1 . Dear Mr; Blicker; . . . . We encloie Defendant' sPre. Hearing Statement. . Very truly yours, , ' . , MARTSON DEARDORFF WILLIAMS & OTTO' ~~.~""'-u- . ThomasLWilliam& TJW/tde Enclosure cc: . John J.. Baranski, Jr.; Esquire (w/enc.) F:\Flr:.ES\DATAFiiE\Gen'?l"al\CU~t\J'dQ79-1.re'2 . INFORMATION. ADVICE. ADVOCACy.SM ',:-'. ,,:<,;>~-^~; ,:i!!I<::,-..J!f.~,!.rl;-i:J~\----d:~:;;.'r4';~fbI;m',\,,-"':\~&.c'u'~.;\ ,,:'t':l>":"rifN.c:'.: ,.-',.-!'A1\' :"'6:,t:tc:'~t<,,;, ,.: '.',j,:~}';;, ',q':.o ';;'~'''':-'''''''/:'' ,,,,:'1- ~'-<,~H. Ii ;,"'cc ,;''-.J'~.'\'"'''''' ,"",",-" ,,;,., "..",;", .~I?.,'u,;.~",~ ",-,: "'~P;'~;H;",.<;,~~,.,i--,.,k__"'" "00"" .,kI,.,,,,';c,' ,,,.,d,.,;. c',' '.", '-\;, ,,,.. ,"''f oj ~~ ~~ - ""''-<-;'''~'j: .. ~ RECEIVED FEB 212D~4 ," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY L. CRAMER Plaintiff DOCKET NO. 00-4951 vs. BONITA J. CRAMER Defendant ACTION IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER IT IS HEREBY ORDERED AS FOLLOWS: 1. Parties: The parties hereto were husband and wife, and a divorce action is in this Court at the above number. This Court has personal jurisdiction over the parties. The parties were married on September 15,1990. 2. Participant Information: The name, last known address, social security number, and date of birth of the plan Participant are: , Name: Ricky L. Cramer Address: 20 Trine Avenue, Mt. Holly Springs, Pennsylvania 17065 Social Security Number: #209-50-7648 Birth Date: March 14, 1957 3. Alternate Payee Information: The name, last known address, social security number, and date of birth of the Alternate Payee are: Name: Bonita J. Cramer Address: 19 Coral Drive, Carlisle, Pennsylvania 17013 Social Security Number: #195-32-2181 Birth Date: November 9, 1941 The Alternate Payee shall have the duty to notify the plan administrator in writing of any changes in her mailing address subsequent to the entry of this Order. 4. Plan Name: The name of the Plan to which this Order applies is the Daily Express Inc. Retirement Plan & Benefits Sharing Plan (hereinafter referred to as "Plan"). Further, any successor plan to the Plan or any other plan(s), to which liability for provision of the Participant's benefits described below is incurred, shall also be subject to the terms of this Order. Also, any benefits accrued by the Participant under a predecessor plan of the employer or any other defined contribution plan sponsored by the Participant's employer, whereby liability for benefits accrued under such predecessor plan or other defined contribution plan has been transferred to the Plan, shall also be subject to the terms of this Order. Any changes in Plan Administrator, Plan Sponsor, or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order. Drafted: 6/13/05 06-06-05-014.1434Q Ii ;, ," " ~,"" ...Jl!IlI, -- ~':~~== F1U:[;-C'?~F!CE U~~ Ti'E P~'"\~ll""-"" R Ii" .!~I:: '"i";i", \,--,j,',iU It\ IY 2006 FEB 22 PtJ '-""JQ II J. ...n,) C1 J~j:'i~":, " '.' I~ if I VI'. .pt(.j;~~':~:YLv't;'!~Ji~~:j\ f " . ,'""", liI9l'~~"'\!"iil~~IlI$~~~" ~",~c, ~ ,"',~ ' w=_ .~,_ "' ^-- "~ 'c. .~ 5. Effect of This Order as a Qualified Domestic Relations Order: This Order creates ~,:d re~ognizes .the existence of an Alternate Payee's right to re7eive a portion of the Participant s benefits payable under an employer-sponsored defined contribution pension plan that is qualified under Section 401 of the Internal Revenue Code, as amended, (the "Code") and the Employee Retirement Income Security Act of 1974, as amended, ("ERISA"). It is intended to constitute a Qualified Domestic Relations Order ("QDRO") under Section 414 (p) of the Code and Section 206(d)(3) of ERISA. 6. Pursuant to State Domestic Relations Law: This Order is entered pursuant to the authority granted in the applicable domestic relations laws of Pennsylvania. 7. For Provisions of Marital Property Rights: This Order relates to the provision of marital property rights as a result of the Order of Divorce between the Participant and the Alternate Payee. 8. Amount of Alternate Payee's Benefit: This Order assigns to the Alternate Payee an amount equal to Thirty Thousand Dollars ($30,000.00) of the Participant's account balance accumulated under the Plan. The Altemate Payee's portion of the benefits shall be allocated on a prorata basis from all of the accounts and/or investment funds maintained under the Plan on behalf of the Participant. The Alternate Payee shall receive a lump sum distribution of her interest in the Plan which shall be transferred, via a direct rollover, to her IRA account with Sovereign Bank, 269 Penrose Place, Carlisle, Pennsylvania 17013, Account No. 2891048059, Routing No. 231372691 in the name of Bonita J. Cramer. This transfer shall be made in accordance with Plan procedures as soon as administratively feasible following the qualification of this Order by the Plan Administrator. 9. Alternate Payee's Rights and Privileges: On and after the date that this Order is deemed to be a Qualified Domestic Relations Order, but before the Alternate Payee receives her total distribution under the Plan, the Altemate Payee shall be entitled to all of the rights and election privileges that are afforded to Plan beneficiaries, including, but not limited to, the rules regarding the right to designate a beneficiary for death benefit purposes and the right to direct Plan investments, only to the extent permitted under the provisions of the Plan. 10. Death of Alternate Payee: In the event of the Alternate Payee's death prior to her receiving the full amount of benefits called for under this Order and under the benefit option chosen by the Alternate Payee, such Alternate Payee's beneficiary(ies), as designated on the appropriate form provided by the Plan Administrator (or in the absence of a beneficiary designation, her estate), shall receive the remainder of any unpaid benefits under the terms of this Order. 11. Death of Participant: In the event that the Participant dies prior to the date the Alternate Payee receives a full distribution of her interest in the Plan, such Alternate Payee shall be treated as the surviving spouse of the Participant for any death benefits payable under the Plan to the extent of the full amount of her benefits as called for under Paragraph 8 of this Order. Should the Participant predecease the Alternate Payee after distribution has occurred, such Participant's death shall in no way affect the Alternate Payee's right to the portion of her benefits as stipulated herein. 12. Savings Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: Drafted: 6113/05 06-06-05-014-1434Q I'~ "~ J. ,- ~ .~ .-, - ~ ," ~ - -" ~, ~ " (a) (b) (c) to provide any type or form of benefit or any option not otherwise provided under the terms of the Plan; to provide increased benefits determined on the basis of actuarial value; to pay any benefits to the Alternate Payee which are required to be paid to another altemate payee under another order that was previously determined to be a QDRO; or to make any payment or take any action which is inconsistent with any federal or state law, rule, regulation or applicable judicial decision. (d) 13. Certification of Necessary Information: All payments made pursuant to this Order shall be conditioned on the certification by the Altemate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein. 14. Continued Qualified Status of Order: It is the intention of the parties that this QDRO continue to qualify as a QDRO under Section 414(p) of the Code, as it may be amended from time to time, and that the Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at the time benefits become payable hereunder. 15. Tax Treatment of Distributions Made Under This Order: For purposes of Sections 402(a) of ERISA and 72 of the Code, any Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the distributee of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate federal, state and local income taxes on such distribution. The tax basis of the assets awarded to each party by this Order shall be a proportionate share of the Participant's total tax basis in all the assets held in the Plan and allocated to his plan account. The Participant shall make such documents and records as are reasonably required by the Alternate Payee to determine such tax basis available to the Altemate Payee. 16. Constructive Receipt: In the event that the Plan Trustee inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall immediately reimburse the Alternate Payee to the extent that the Participant has received such benefit payments, and shall forthwith pay such amounts so received directly to the Alternate Payee within ten (10) days of receipt. In the event that the Plan Trustee inadvertently pays to the Alternate Payee any benefits that are to remain the sole property of the Participant pursuant to the terms of this Order, the Altemate Payee shall immediately reimburse the Participant to the extent that the Alternate Payee has received such benefit payments, and shall forthwith pay such amounts so received directly to the Participant within ten (10) days of receipt. 17. Continued Jurisdiction: The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as are necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein, including, but not limited to, the recharacterization thereof as a division of benefits under another plan, as applicable, or to make an award of alimony, if applicable, in the event that the Participant or the Plan Administrator fail to comply with the provisions contained in this Order requiring said payments to the Altemate Payee. Drafted: 6/13/05 06-06-05-014-1434Q , - ^" ""' ."j -," ", . " ~, ,~, I I' I I .". . '" 18. Effect of Plan Termination: In the event of a Plan termination, the Alternate Payee shall be entitled to receive her portion of the Participant's benefits as stipulated herein in accordance with the Plan's tennination provisions for participants and beneficiaries. 19. Actions by Participant: The Participant shall not take any actions, affirmative or otherwise, that circumvent the terms and provisions of this Qualified Domestic Relations Order, or that diminish or extinguish the rights and entitlements of the Altemate Payee as set forth herein. Should the Participant take any action or inaction to the detriment of the Alternate Payee, the Participant shall be required to make sufficient payments directly to the Altemate Payee to the extent necessary to neutralize the effects of the Participant's actions or inactions, and to the extent of the Alternate Payee's full entitlements hereunder. 20. Notice of Pending Retirement: In the event that the Plan Administrator requires the Alternate Payee to wait until the Participant's actual date of termination of employment or retirement before becoming eligible to receive her distribution, then the Participant shall be required to notify the Alternate Payee, in writing, within ten (10) days following his termination of employment or retirement. The notice shall be sent via regular first-class mail. For this purpose, the Alternate Payee shall notify the Participant of any changes in her mailing address. " u i i: ,; Ii t I, , i; '. l:~ (. i~ 'Ii :~ {ifi/~ 'Ricky . Cfamer tJ+r~ ~ ,(h,a/f'VVliQ Bonita J. Cramer IT IS SO ORDERED on this t-z'" day of f -.t-...., 20 oC- , BY THE COURT: 1 - J-s--vt.., ~ ~ ,Jld> 4J Drafted: 6/13/05 06-06-05-014-1434Q .JOHN .J. BARANSKI, .JR., ESQUIRE LAW OFFICE OF HAROLD S. IRWIN, III ATTORNEY ID NO. 82585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2000 . <.JCi5J CIVIL TERM BONITA .I. CRAMER, Defendant : IN DIVORCE NOTICE 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 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 AVE CARLISLE, PA 17013 (717) 249-3166 RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2000 - '17"51 CIVIL TERM BONITA ... CRAMER, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, Ricky L. Cramer, by his attorney, John J. Baranski, Jr., Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Ricky L. Cramer, an adult individual residing at 20 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Bonita J. Cramer, an adult individual residing 19 Coral Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 15, 1990, in Cumberland County, Pennsylvania. 5. The parties separated on or about April 2, 2000. COUNT I - DIVORCE 6. Plaintiff hereby incorporates by reference averments 1 through 5 as if each averment were set forth fully hereunder. 7. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 8. Neither party is in the Armed Forces of the Untied States. 9. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 10. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties and such other additional relief as the Court deems necessary. Date: ~/;~ RESPECT /' , ~//~ -~~ JO J. BARANSKI, JR., ESQUIRE ID # 82585 Attorney For Plaintiff VERIFICATION I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. JUNE L 2000 ~/~ RICK . CRAMER RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2000 ."'ll>' CIVIL TERM BONITA .I. CRAMER, Defendant : IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 may 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. JUNE E, 2000 ~7~ RIC L. CRAMER - -r:> 'l -...\. y f\:" '.>(1 v\ Qi\ , ~ ~. 0 C) \1' V' Q 2- .. """"I I...>:> \ c.', 0(\ 'I.J C' -0 A .,..l '-'1 o(l "\) ~ :s;.. 1'J " ~. - D h +- ~ '" ~ RICKY L. CRAMER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2000 - 4951 CIVIL TERM BONITA d. CRAMER, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas J. Williams, Esquire, accept service of the Divorce Complaint. I certify that I am authorized to accept service on behalf of the defendant, Bonita J. Cramer. 7/2-0 ,2000 -r {!v~6-VV THOMAS ILLlAMS, ESQUIRE Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 . I~ THE COURT OF COMMON PLEAS OF CL~ERLAND COUNTY, PENNSYLVANIA RICKY L. CRAMER Plaintiff vs. BONITA J. CRAMER ~O. 2000-4951 19 a master wich respect to the (x) Divorce ( ) Annulment (x) Alimony (x) Alilllony Pendente :10TION FOR APPO I~TI1ENT OF :!ASTER (Plaintiff) (Defendant), moves the court to appoint folloving claillls: Lite ( x) ( ) ( x) ( x) Distribuc10n of Property Support Counsel Fees Costs and ~~penses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) (has not) appeared in Thomas J. Williams (3) The staturory ground(s) for divorce (is) ~3301(c) and (d) of the FA Divorce Code (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the none (c) The action is contested with respect :0 the rolloving all claims listed above (5) The action (i~a) (does not involve) complex issues of 1av (by his attorney, the action (personally) ,Esquire) . (are) following claims: claims : or fact. (6) (7) Date: April 6. The hearing is e..--q>ected to take 2 (hours) (Il:~. Additional informacion, if any. relevant to the motion: C:~oK~~~~ ~. ~f~~) ~ ORDER APPOINTING :'lASTEwohn J. Ba=a~sJ.<i. Jr.. Esquire ~~ /9 ,:&.:1J;bt.( E', ~cP -If ~ jl././kb.~ Esquire, mas er with respect to tl1e rolloving claims: t1..-lL " '"f!JU1r1 2004 AND ~OW is appointed ;?J Cf':: c . . IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant In Divorce CERTIFICATE OF SERVICE I hereby certify that I am this day causing a copy of the foregoing Petition to be served on the following person in the manner indicated: By First Class United States Mail on: Thomas J. Williams, III, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 BLAKEY, YOST, BUPP & RAUSCH, LLP By: ~. ~ &--- rma M. D ,Paralegal 17 East Market Street York, PA 17401 Dated: 4/f::.rj"f RICKY L. CRAMER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITAJ. CRAMER, Defendant/Petitioner IN DIVORCE RULE .. AND NOW, this 21 day of October, 2001, in consideration of the foregoing Motion for Protective Order to Preserve Marital Property, a Rule is hereby issued upon Plaintiff, Ricky L. Cramer, to show cause, if any there be, why the relief claimed should not be granted. Rule returnable ~ days after service. Pending further Order of this Court, Husband is enjoined from taking distribution of all or any part of his share ofthe Daily Express, Inc. Employee Retirement & Profit Sharing Plan. A copy of this Order shall be promptly served on: Plan Administrator Daily Express, Inc. 1076 Harrisburg Pike Carlisle, P A 17013 BY THE COURT, / ~ . /l i>/t-. , J. i l {Jt; \-(I\~\,lt:l), Srlr-.J3J Al.>,w:b:.: (-;' '~.,' r-':<,'Jr\O '" G o ." (- (; ~_,.;.J : r., F\Fll.ES\DA T AFlL'E\Gcndoccur\l 0079-mol.l/lde Crealed 07/25i0009.4254AM Revised: lOi17!Olll:525l AM 10079.1 RICKY L. CRAMER, PlaintifflRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITAJ. CRAMER, Defendant/Petitioner IN DIVORCE DEFENDANT'S MOTION FOR PROTECTIVE ORDER TO PRESERVE MARITAL PROPERTY AND NOW, comes Defendant, BonitaJ. Cramer, by and through her attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, pursuant to 23 Pa. C.S. 93323 (f) and, in support thereof, avers as follows: I. Petitioner is Bonita J. Cramer (hereinafter "Wife"), an adult individual residing at 19 Coral Road, Carlisle, Pennsylvania. 2. Respondent is Ricky L. Cramer (hereinafter "Husband"), an adult individual residing at 20 Trine Avenue, Mt. Holly, Pennsylvania. 3. The principal item of marital property in this divorce is Husband's profit sharing plan from his employer, Daily Express, Inc., which has a value in excess of$100,000.OO. A copy of the most recent statement in Wife's possession dated May 22, 2000 is attached hereto and marked as Exhibit "A." 4. Wife was recently advised that Husband left his employment at Daily Express, Inc. 5. The termination of Husband's employment at Daily Express, Inc. may allow him to withdraw, cash or otherwise dispose of the balance in the aforesaid profit sharing plan. 6. Wife believes, and therefore avers, that Husband will dispose of the balance in the aforesaid profit sharing plan in order to defeat the claim of Wife in the instant action. WHEREFORE, Wife prays Your Honorable Court to enjoin Husband, Ricky L. Cramer, from taking sole possession of the balance in the aforesaid profit sharing plan until an award of economic division of marital property can be made in this action. Date: October 23, 2001 Respectfully submitted, MARTSO~DEARDORFF WILLIAMS & OTTO By l~ ~ ~ Thomas J. Wi lia s, Esquire Ten East High treet Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Defendant Bonita 1. Cramer .. .''''\<''')''.''''. "" ",,,,,,,,,, lI."illl.fa'!!!!"'!'!:l!!!!: May 22, 2000 Dear Plan Participant: I am pleased to report that our Profit Sharing and Retirement Fund had an overall return of approximately 4.24% for the year. The Fixed Income Fund returned (-)5.19%., Enclosed is your certificate showing your participation in the Fund for the year 1999, together with a "Statement of Account" which shows a financial summary of the transactions of the Equity and Fixed Income Funds. Your certificate shows the balance in your account as of January 1, 1999; the amount of the Company's contribution to be made to your account for 1999; your share of eamings on the investments during 1999; your share of forfeitures; the accumulated balance in your account on December 31, 1999; and the calculated amount of your vesting at year end. The net income of the Total Fund for 1999 was $615,112. This amount is composed of $663,502 of income from interest and dividends, less administrative costs of $28,202, plus net gain on securities sold of $5,216, and the decrease in market value of securities held at December 31, 1999, of $25,404. The contribution to be made for 1999 by Daily Express, Inc. totals $647,388 computed as 11 % of each participants 1999 wages. This is the fortieth year contributions have been made to the Plan. Each year the Company, by September 15, pays your computed contribution for the prior year to Dauphin Deposit Bank, as Trustee, which means the Fund is fully funded and you will receive all amounts to which your vesting entitles you. The funds are then invested from the Trust Fund once the contribution has been made. The Employees' Profit Sharing Fund Committee has the following rnembers: R. F. Long, H. C. Smith, R. H. Wertz, K. F. Cummings, Dwayne A. Kepner and J. P. Mitchell. The attached Statement of Account reflects the transactions of the Fund for 1999 based on market values. Sincerely, Py? v?~'? Robert F. Long , for the Committee EXHIBIT "A" f' O. BOX 39. CARLISLE, PENNSYLVANIA 17013-0039. (717) 243-5757 DAIL Y EXPRESS, INC. EMPLOYEE RETIREMENT AND PROFIT SHARING PLAN Statement of Account January 1, 1999 to December 31, 1999 Fixed Equity Income Fund Fund Transfers Between Funds $14,000 $9,460,889 MARKET VALUE OF FUND AT DECEMBER 31, 1998 $5,941 ,246 RECEIPTS: Employer's Contribution Income from Investments Interest & Dlvidends- $55,275 Net Gain/(Loss) on Investments Sold- $38,912 TOTAL RECEIPTS $108,187 DISBURSEMENTS: Distributions Fees $15,950) ($15,950) TOTAL DISBURSEMENTS NET OF RECEIPTS\(DISBURSEMENTS) INCREASE\(DECREASE) MARKET VALUE $92,237 $1,048,080 MARKET VALUE OF FUND AT DECEMBER 31,1999 $7,081 ,564 DAILY EXPRESS, INC. EMPLOYEE RETIREMENT & PROFIT SHARING PLAN STATEMENT OF ACCOUNT AS OF 12/31/1999 FOR RICKY L CRAMER Profit Sharing Account 01/01/1999 Account $ 92,771.23 Contribution 3,855.86 Investment Results 3,934.83 Forfeitures 347.51 12/31/1999 Account $ 1 00,909.43 Vesting Percent 100% Vested Amount $ 100,909.43 Every effort has been made to insure the accuracy of the in1ormation contained in this Statement of Account: however, in the event of a discrepancy, actual benefits will be determined according to the Plan provisions. Daily Express, Inc. . 1072 Harrisburg Pike Carlisle, PA 17013-1615 RICKY L CRAMER D265- A00025 DATE OF BIRTH: DATE OF EMPLOYMENT: SOCIAL SECURITY NO: 03/14/1957 07120/1981 209-50-7648 Daily Express, Inc. Employee Retirement & Profit Sharing ~Ian Summary Annual Report This is a summary of the annual report which has been filed with the Internal Revenue Service, as required under the Employee Retirement Income Security Act of 1974 (ERISA) for: Plan Name: Daily Express, Inc. Employee Retirement & Profit Sharing Plan Plan Number: 002 EIN: 23-1530123 Plan Year: January 1, 1999 to December 31, 1999 Basic Financial Statement Benefits under the Plan are provided trom the trust tund. Plan expenses were $1,841,231. These expenses included $28,202 in administrative expenses, $1,813,029 in benefits paid to participants and beneficiaries, and $0 in other expenses. A total of 234 persons were participants in or beneficiaries of the Plan at the end of the plan year, although not all of these persons had yet earned the right to receive benefits. The value of plan assets, after subtracting liabilities of the Plan, was $16,542.453 as of December 31, 1999, compared to $17,091,057 as of January 1, 1999. During the plan year the Plan experienced a decrease in its net assets of $548,604. This decrease included unrealized appreciation or depreciation in the value of plan assets; that is, the difference between the value of the plan's assets at the end of the year and the value of the assets at the beginning of the year or the cost of assets acquired during the year. The Plan had total income of $1,292,627, including employer contributions of $649,313, employee contributions of $0, gains of $5',216 from the sale a/assets, earnings from investments of $638,098, and $0 in other income. Your Rights to Additional InformatIon You have the right to receive a copy of the full Form 5500 series annual report, or any part thereat, on request. The information listed below is included in that report: . An accountant's report . Assets held for investment . Transactions in excess of 5 percent of plan assets To obtain a copy of the full annual report or any part thereof, write or call the office of the Plan Administrator: Daily Express, Inc. 1072 Harrisburg Pike Carlisle, PA 17013-1615 (717) 243-5757 The charge to cover copying costs will be $4.00 for the full annual report or $.25 per page for any part thereof. You also have the right to receive from the Plan Administrator, on request and at no charge, a statement of the assets and liabilities of the Plan and accompanying notes, or a statement of income and expensl" of the Plan and accompanying notes, or both. If you request a copy of the full annual report from the Plan Administrator, these two statemenls and accompanying notes will be included as part of that report. The charge to cover copying costs given above does not include a charge for the copying of these portions of the report because these portions are furnished without charge. You also have the legally protected right to examine the annual report at the main office of the Plan shown above and at the U.S. Department of Labor in Washington, DC, or to obtain a copy from the U.S. Department of labor upon payment of copying costs. Requests to the Department should be addressed to: Public Disclosure Room, N5638, Pension and Welfare Benefit Administration, Department of Labor, 200 Constitulion Avenue, NW., Washington, DC 20210. 0265oo1.0B4:DEl ........ VERIFICATION The foregoing Motion for Protective Order is based upon information which has been gathered by my counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. ~j-a- . O-ta-mh~ Bonita 1. Cramer 1 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Motion for Protective Order to Preserve Marital Property was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John 1. Baranski, Jr., Esquire Law Offices of Harold S. Irwin, III Hitner House Suites 201 and 202 Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO c5J:, - 'fJ y~ . Tricia D. Eckenroad Ten East High Street Carlisle, P A 17013 (717) 243-3341 ~ Dated: October 23,2001 "") , r,~' - RICKY L. CRAMER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. BONlT A 1. CRAMER : NO. 00 - 4951 : IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Ricky L. Cramer John J. Baranski, Jr. , Plaintiff , Counsel for Plaintiff Bonita J. Cramer Thomas J. Williams , Defendant , Counsel for Defendant * You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 3rd day of a.m., at which place March 2005 at 9'00 and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, Date of Order and Notice: 12/22/04 By: Divorce Master 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 ASSOCIA nON 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 * TESTIMONY WILL BE LIMITED TO THE FACTOR OF MARITAL MISCONDUCT AS THAT FACTOR MAY AFFECT WIFE'S ALIMONY CLAIM. F:\FILES\DA T AFILEIGendoc_curl I 0079-equ,disltde Created; 01/25/000942:54 AM Revised 08J28/0009:S2:36AM 100791 RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, Defendant IN DIVORCE DEFENDANT'S CLAIM FOR ECONOMIC RELIEF AND NOW, comes the Defendant, Bonita J. Cramer, by and through her attorneys, MARTS ON DEARDORFF WILLIAMS & OTTO, and makes the following claims for economic relief: I. Plaintiff and Defendant are the joint owners as tenants by the entireties of certain real estate which is subject to equitable distribution by this Court. 2. Plaintiff and Defendant are the owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this Court. 3. Plaintiff and Defendant are the owners of various motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. 4. Plaintiff requests your Honorable Court to allow alimony as it deems reasonable pursuant to Section 3701 of the Pennsylvania Divorce Code. 5. Plaintiff requests your Honorable Court to allow her alimony pendente lite, reasonable counsel fees and expenses pursuant to Section 3702 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; c. Awarding alimony as the Court deems just and reasonable; d. Ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; and e. For such further relief as the Court may determine equitable and just. MARTSON DEARDORFF WILLIAMS & OTTO r~a-. ~ J.i, ....:-. Date: August 28, 2000 By Thomas J. Williams Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant , VERIFICATION The foregoing Claim for Economic Reliefis based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. l{&1 uJ-;...... ~. tlil/\/'H [II) Bonita J. Cramer F:\FILHS\DA T At'ILE\Gendoe.cur\ l0079_equ,diJ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Claim for Economic Relief was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John J. Baranski, Jr., Esquire 35 East High Street, Suite 201 Carlisle,PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Y Trici D. Eckenroad n East High Street Carlisle, P A 17013 (717) 243-3341 Dated: August 28, 2000 RICKY L. CRANER, Plaintiff vs. BONITA J. CRAMER, Defendant TO: John J. Baranski, Jr., Thomas J. Williams, Date: September 14, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNY, PENNSYLV ANlA NO. 00 - 4951 CIVIL IN DIVORCE Attorney for Plaintiff Attorney for Defendant CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. Jo . aranski, Jr., Esquire Supreme Ct. Id. No. 82585 17 East Market Street York, PA 17401 (717) 845-3674 <' Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant In Divorce PETITION FOR RELATED CLAIM COMES NOW, the Plaintiff, Ricky L. Cramer, and by her attorneys, Blakey, Yost, Bupp & Rausch, LLP, pursuant to Pa. R.C.P. 1920.13(b)(2), and Petitions the Court as follows: Section 3301 (d) - No Fault The parties have been living separate and apart for a period in excess of two (2) years, to wit: since April 2, 2000. WHEREFORE, Plaintiff requests this Court to enter a Decree of Divorce under Section 3301(d) of the Pennsylvania Divorce Code, as amended. BLAKEY, YOST, BUPP & RAUSCH, LLP By: . aranski, Jr., Esquire S. Ct. I.D. #82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff .... .... VERIFICA nON I, RICKY L. CRAMER, verify that the facts set forth in this instrument are true and correct to the best of my knowledge, information, and belief This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. CS. (4904) relating to unsworn falsification to authorities. ~~ , . . . IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant In Divorce CERTIFICATE OF SERVICE I hereby certify that I am this day causing a copy of the foregoing Petition to be served on the following person in the manner indicated: By First Class United States Mail on: Thomas J. Williams, Ill, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, P A 17013 BLAKEY, YOST, BUPP & RAUSCH, LLP .,4-, ~>A2~- ~orma . oil, Paralegal 17 East Market Street York, PA 17401 Dated: ~%c/ -'. ~~, C.":-, {~'~:::> .r- (:) -n ..... :1: -T, r-ni;<"~ --\~,G) :-:;)Z;J -~~J, )..<J -~ ,; ) " ::~ 0) C~) -.-'- r.) . ,) ------ ,~ .. I " RICKY L. CRAMER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000-4951 BONIT~ J. CRAMER Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF SUBMITTED BY: RICKY L. CRAMER, PL~INTIFF AGE:!LL HEALTH: :-/1 If STATUS: SZ::PEi!,A (Ef) EMPLOYER: (1)1...1 A;1 ,( If ",.,F'; . (), LENGTH OF SERVICE: 'Iii': PRIOR EMPLOYER: lHJ! l,/ p /;'~ P'-; 7 /,( LENGTH OF SERVICE: ./-, " "//' c ( EDUCATION, TRAINING, AND SKILLS: fJ/(,. fI. S<-I~PU ( 11, fio" , OfJ '{ (il ,jo(J, 7i1' ,.u'j~ I I Per Pay I Weekly I Month!; I Yearly I GROSS EARNED INCOME: ?tc;. If? DEDUCTIONS: Federal Income Tax /;).3. (<" State Income Tax ::13 (j~, F.LC.A. I ~) f Medicare Tax /0, c'? Local Tax I ~ 00 co' P A Unemployment . (; (~l Life Insurance 'I /S' Medical/Hospital/DentalInsurance 1<:".05 H:m~llgrv Pew.ri:on L ON'j 7 MI/' D i "i (, "" .0' / ! Voluntary Retirement Ii Jd.. '/10 Savings Bonds (.,ioc I" C ;/0 (] SfoCfSf4 ( c:; ,,- '?Sf:J () P , '-{II.I! / TOTAL DEDUCTIONS 37/.'11 NET EARNED INCOME ~Q? ' . " OTHER INCOME: Child Support Spousal Support Interest Dividends Pension Other Retirement Annuity Per Pay Weekly Monthly Yearly Social Security Rental Income Royalties Expense Account Gifts Unemployment Compensation Workers Compensation TOTAL OTHER INCOME TOTAL NET INCOME CURRENT EXPENSES: Mortgage (Marital residence) Rent )_~o, cO Maintenance UTILITIES: Electric '-!o. f)() Gas Oil (heating fuel) Telephone / ,-!O. ,";' Trash Collection Water Sewer Cable Television ~\ 0 OD I I Per Pay I Weekly I MonthtLl Yearly I EMPLOYMENT: Public Transportation Parking Lunch 30,00' Education Supplies/Equipment S;JA(J ON 10,", I/O. 0 0 mAt 7ocl'~ Memberships TAXES: Real Estate Income (not set forth above) Personal Tax INSURANCE: Homeowners (Not in Mortgage) Automobile / J 00. CJC Life Accident Health (Not deducted from pay) Disability Renters AUTOMOBILE: Payment Fuel "'lS 0' 0 Maintenance/Repairs Per Pay Weekly MonthIy Yearly MEDICAL (After insurance payment): Doctor '" /J, <:0 , Dentist ;JOG 00 Orthodontist Hospital Prescription Medication 3q (}O Over the Counter Medication 30. (() Special Needs EDUCATION: - Private School Parochial School College Religious PERSONAL: Clothing :loo 0 0 Food BarberlHairdresser ;"0 cO tR . Laundry and dry cleaning .,... :jO / '-.., - CREDIT CARDS: Cf-I p; rill dIvE !//~' 11 36. C '. C' If' -: .. Iii Ie 30 ('.0 _" _._1 ',' --,' ONt . . ~ J/t1<< J 1/{7/ ) (-k;'~/.''/ :- I r e:l) ~ , , I I Per Pay I Weekly I Monthl~ Yearly I CHARGE ACCOUNTS: LOANS: C,'T/ -:?' ;. NA /v tA L- ,i}'10( u - MEMBERSHIPS: /J If!! (~ j I ( '0"/ JtJ ,,(1) (1),1) C",' flU ( /Jur' bo I/c'p / Rll>tJ, b<WA/ J5:W - MISCELLANEOUS: Household Help Child Care P apers/BookslMagazines Vacation Gifts Legal Fees Charitable Contributions Child Support Alimony . . I I Per Pay ! Weekly ! Monthl:J Yearly I OTHER: Tax preparation LjtJ 00 Veterinarian TOTAL CURRENT EXPENSES NET CASH AVAILABLE r .' . VERIFICATION I verify that the foregoing facts are true, upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. ..7L ~~ ~4 . .... Ric Cramer Dated: /C102Y~V , 03/03/2005 10:29 7172431807 MDWO PAGE 04/05 Thomas J. Williams, Esquire MARTS ON DEARDORFF WU,LlAMS & OTTO I.D.17512 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA RlCKY L. CRAMER, Plaintiff v, NO. 2000-4951 CIVIL ACTION - LAW BONITA 1. CRAMER, Defendant IN DIVORCE AFFJDA VIT OF CONSENT 1. A Complaint in Divorce under g 3301(c) of the Divorce Code was fiI(~d on July 13,2000. 2, The marriage ofPIai.ntiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 decree. 1 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, e.S. g 4904 relating to unsworn. falsification to authorities. Date: ;3-3-0'5 ~~,~~ :;'>::l <<ry ~) .,- (:'i -_r":_I " \." _l '_:'".' '-:':' (J" 03/03/2005 10:29 7172431807 MDWD PAGE 05/05 Thomas J, Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO I,D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RlCKY L CRAMER, Plain tiff v. NO. 2000-4951 CIVIL ACTION - LA W BONITAJ. CRAMER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330lic) AND G 3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or ex.penses ifI 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 oCthe decree will be sent to me irrunediately 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: 3-3 -05' '- ~Q/ ~--- - 03/03/2005 10:29 7172431807 MDWO PAGE 02/05 F;\flU: SItu.., A11UiI,C~nar..J\ClII'Trnl\ I CC7'.I,COlll'o;tIVUle 10079,1 Thomas 1. Williams, Esquire MARTSON DEARDORFF WiLLIAMS & OTTO J.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Bonita J. Cramer RlCKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-4951 CIVIL ACTION - LAW BONIT A J. CRAMER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Ii 3301 (c) of the Divorce Code was fi.led on July 13, 2000 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 decree. I verify that the statelDents made in this affidavit are !TIle and COITect. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Ii 4904 relating to unsworn falsification to authorities. Date: J A, '3 / t:25 I / M~ to & ~;tt>>V Bonita J. Cram ,Defendant , ~~ 03/03/2005 10:29 7172431807 MDWO PAGE 03/05 Thomas 1. Williams, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO 1.0.17512 10 East High Street Carlisle, PAl 7013 (717) 243-3341 Attorneys for Defendant Bonita 1. Cramer RlCKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA v. NO. 2000-4951 CIVIL ACTION - LAW BONITA J. CRAMER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 9330l(c) AND & 330](d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 authorihes, Date: S/5//25 I / ~~{J../ 1 ' (!/l?l/J Jt.M/ Bonita 1. CramM; Defendant <iy .-"" ~~ \ -^ .. '"::; '.. RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 1-5 t'h day of ;J Wt~ f 2005, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on March 3, 2005, the date set for a Master's hearing, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: ~hn J. Baranski, Jr. Attorney for Plaintiff ~omas J. Williams Attorney for Defendant ~~~ ~~~ .~~ .,,~ t;X"" ( '. '\ . .{J\:f O~\ ~/ ~/ SO :[)\ I!'] [,1 Hd\j souz ). RICKY L. CRAMER, Plaintiff IN THE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 4951 CIVIL BONITA J. CRAMER, Defendant IN DIVORCE THE MASTER: Today is Thursday, March 3, 2005. This is the date set for a hearing to take testimony on the factor of marital misconduct as that factor may have affected wife's alimony claim. Present are the Plaintiff, Ricky L. Cramer, and his counsel John J. Baranski, Jr., and the Defendant, Bonita J. Cramer, and her counsel Thomas J. Williams. The parties were married on September 15, 1990, and separated April 2, 2000. There were DO children born of this marriage. A complaint in divorce was filed on July 13, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. Counsel are going to have their clients sign affidavits of consent and waivers of notice of intention to request entry of divorce decree today before they leave the hearing room. The affidavits and waivers will be filed by the Master's office with the Prothonotary. The divorce will be able to be concluded under Section 3301(c) of the Domestic Relations Code. On August 30, 2000, economic claims were 1 ... filed by wife for equitable distribution, alimony, alimony pendente lite and counsel fees and expenses. The Master has been advised that after negotiations this morning the parties have reached an agreement with respect to the outstanding economic issues. Therefore, no hearing will be necessary on the factor of marital misconduct. An agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. After the agreement has been transcribed, it will be sent to counsel for review for typographical errors. Corrections, if necessary, will be made and then the agreement will be provided to counsel in a final draft for the parties to affix their signatures affirming the terms of settlement. In any event, the parties are bound by the terms of the agreement when they leave the hearing room today even though there is no subsequent signing of the agreement affirming the settlement terms. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel will then be in a position to file a praecipe transmitting the record to the Court requesting a 2 , final decree in divorce. Mr. Williams. MR. WILLIAMS: The parties have agreed in full settlement of all economic claims that were made or could have been made in this divorce case to be resolved as follows: 1. Thirty thousand ($30,000.00) will be transferred from the husband's Daily Express, Inc., employment retirement and profit sharing plan to wife promptly upon the issuance of a final decree in divorce. Wife shall be responsible for obtaining a QDRO for the transfer of said $30,000.00. Husband shall cooperate fully as needed in order to obtain the information and process the necessary paperwork to effect this transfer. 2. All other claims which have been or could have been made in this case of an economic nature are deemed withdrawn. 3. Wife is currently in the possession of a handgun that is currently registered in the name of husband. Wife shall receive that handgun as part of this settlement; however, wife shall promptly re-register the gun in her name alone and husband shall cooperate in that re-registration if such cooperation is necessary. Wife is also in the possession of a .25 automatic handgun that is to become property of the husband as part of this divorce resolution and wife shall make that handgun available for pick up by husband at a mutually convenient time. 4. The parties acknowledge that they have satisfactorily divided all items of personal property, household contents, and the like between themselves. 5. There are no marital debts that either is aware of for which the other may be responsible. 6. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or 3 ;,.' . ,,. the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. WILLIAMS: Mrs. Cramer, is the settlement of this case as I've just described satisfactory to you? MRS. CRAMER: Ye,3. MR. BARANSKI: Mr. Cramer, is the settlement as described by Mr. Williams today satisfactory to you? MR. CRAMER: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: '- ~l/t~1t ~- ;() ; /i I~: ~/J'- -.=_ (t ,;;: 'j,.!-1.. Ricky L. Cramer . Baranski, Jr. Attorney for Plaintiff ~ Ji ~"" Thomas J. Williams Attorney for Defendant l~\v,JI.v \ 0ilGytlQ/l/ Bonita J~mer 3h'/os 4 v V ~l-7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITA J. CRAMER Defendant 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: 1. Ground for divorce: irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and manner of service ofthe complaint Julv 20. 2000. by Dersonal service on Defendant's counsel - Acceptance of Service filed Julv 21. 2000. 3. Date of execution of the affidavit required by ~3301(c) of the Divorce Code: By Plaintiff: 03/03/05 By Defendant: 03/03/05 4. Related claims pending: None. All issues settled by agreement at time of Master's hearing and stiDulation subseauentlv siJpled bv the parties. 5. Date Plaintiff's Waver of Notice was filed with the Prothonotary: 03/07/05 Date Defendant's Waver of Notice was filed with the Prothonotary 03/ ~ ) .~ ------ --- o . Baranski, Jr., Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CIVIL ACTION - LAW RICKY L. CRAMER Plaintiff, No. 2000-4951 vs. BONITAJ. CRAMER Defendant In Divorce DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1,2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. DOCKET NUMBER: 4951 Civil PLAINTIFF'S NAME: Ricky L. Cramer PLAINTIFF'S ADDRESS: 370 Old State Road Gardners. PA 17324 DEFENDANT'S NAME: Bonita J. Cramer DEFENDANT'S ADDRESS: 19 Coral Drive Carlisle. PA 17013-9401 DATE OF MARRIAGE: SeDtember 15. 1990 DATE OF DECREE: OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY One Court House Square Carlisle, P A 17013-3387 Curt Long Prothonotary Telephone (717) 240-6195 Bonita J. Cramer 19 Coral Drive Carlisle, PA 17013-9401 Date: Re: RICKY L. CRAMER, Plaintiff vs. BONITA J. CRAMER, Defendant DOCKET No. 2000-4951 NOTICE is given that a Decree in the above-captioned matter has been entered against you on Curt Long PROTHONOTARY OF CUMBERLAND COUNTY By If you have any questions concerning the above case, please contact: John J. Barnaski, Jr., Esquire BLAKEY, YOST, BUPP & RAUSCH, LLP 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Ci :-.., ('- (,":.~ ( ) C ~J ~ , -1'1 , :'-;.! - (-; ._,.r i;~ :".:' '''' - c::: -, ......, .' . . . . . + ++ .. . . . Of. :f.:f.:+;:f'+':+.:f'+. :t: '+: :f.:+''f''+':+':+',., + + , . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY , + . . . + + . PEN NA. STATE OF . + . . + , No. 4951 2000 RICKY L. CRAMER + + + . + + VERSUS + + + + + + + . + . + + + + + + + + + + + + + + BONITA J. CRAMER DECREE IN DIVORCE . z"" Aprl1 r AND NOW, 2005, IT IS ORDERED AN D Ricky L. Cramer DECREED THAT , PLAI NTI FF, + + + + + + + + AND Bonita J. Cramer , 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 EeNTERED; + + + + + + + + + + + + + + + + + + None BY THE COURT: + + + + + + + + J. PROTHONOTARY + + :+"'''':f + + + , + + + + + + + :+. :+. :+:f. ~:+. :+.:+. :+.:+.~+:+.+.++:+. + + + + . + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + :+:+.:+.:+-'+- (/~ ~~'4rr7f/'~' J;{~ #? #7.?r' ''PH'' :i':?7:J.~ 7// . ?ff r(/ '7.0:-",< {~ . . ~ ~?e/ 2~/~'r{l . . . . . (,...cI..vp.r'''Ji V ,l'/ .)r? C -if ,?v' ,'-:".Ji .' ~ RECEIVED FEB 21 ZO~4 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICKY L. CRAMER Plaintiff DOCKET NO. 00-4951 vs. BONITA J. CRAMER Defendant ACTION IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER IT IS HEREBY ORDERED AS FOllOWS: 1. Parties: The parties hereto were husband and wife, and a divorce action is in this Court at the above number. This Court has personal jurisdiction over the parties. The parties were married on September 15,1990. 2. Participant Information: The name, last known address, social security number, and date of birth of the plan Participant are: Name: Ricky L. Cramer Address: 20 Trine Avenue, MI. Holly Springs, Pennsylvania 17065 Social Security Number: #209-50-7648 Birth Date: March 14, 1957 3. Alternate Payee Information: The name, last known address, social security number, and date of birth of the Alternate Payee are: Name: Bonita J. Cramer Address: 19 Coral Drive, Carlisle, Pennsylvania 17013 Social Security Number: #195-32-2181 Birth Date: November 9, 1941 The Alternate Payee shall have the duty to notify the plan administrator in writing of any changes in her mailing address subsequent to the entry of this Order. 4. Plan Name: The name of the Plan to which this Order applies is the Daily Express Inc. Retirement Plan & Benefits Sharing Plan (hereinafter referred to as "Plan"). Further, any successor plan to the Plan or any other plan(s), to which liability for provision of the Participant's benefits described below is incurred, shall also be subject to the terms of this Order. Also, any benefits accrued by the Participant under a predecessor plan of the employer or any other defined contribution plan sponsored by the Participant's employer, whereby liability for benefits accrued under such predecessor plan or other defined contribution plan has been transferred to the Plan, shall also be subject to the terms of this Order. Any changes in Plan Administrator, Plan Sponsor, or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order. Drafted: 6113/05 06-06-05-014-1434Q 11'-" ':::"" -,.-i , ;,,':.! T? (1'1. l (J ~--" L .:~.J V'I""'" :,) SOGZ .' 5. Effect of This Order as a Qualified Domestic Relations Order: This Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of the Participant's benefits payable under an employer-sponsored defined contribution pension plan that is qualified under Section 401 of the Internal Revenue Code, as amended, (the "Code") and the Employee Retirement Income Security Act of 1974, as amended, ("ERISA"). It is intended to constitute a Qualified Domestic Relations Order ("QDRO") under Section 414 (p) of the Code and Section 206(d)(3) of ERISA. 6. Pursuant to State Domestic Relations Law: This Order is entered pursuant to the authority granted in the applicable domestic relations laws of Pennsylvania. 7. For Provisions of Marital Property Rights: This Order relates to the provision of marital property rights as a result of the Order of Divorce between the Participant and the Altemate Payee. 8. Amount of Alternate Payee's Benefit: This Order assigns to the Alternate Payee an amount equal to Thirty Thousand Dollars ($30,000.00) of the Participant's account balance accumulated under the Plan. The Alternate Payee's portion of the benefits shall be allocated on a prorata basis from all of the accounts and/or investment funds maintained under the Plan on behalf of the Participant. The Alternate Payee shall receive a lump sum distribution of her interest in the Plan which shall be transferred, via a direct rollover, to her IRA account with Sovereign Bank, 269 Penrose Place, Carlisle, Pennsylvania 17013, Account No. 2891048059, Routing No. 231372691 in the name of Bonita J. Cramer. This transfer shall be made in accordance with Plan procedures as soon as administratively feasible following the qualification of this Order by the Plan Administrator. 9. Alternate Payee's Rights and Privileges: On and after the date that this Order is deemed to be a Qualified Domestic Relations Order, but before the Alternate Payee receives her total distribution under the Plan, the Altemate Payee shall be entilled to all of the rights and election privileges that are afforded to Plan beneficiaries, including, but not limited to, the rules regarding the right to designate a beneficiary for death benefit purposes and the right to direct Plan investments, only to the extent permitted under the provisions of the Plan. 10. Death of Alternate Payee: In the event of the Alternate Payee's death prior to her receiving the full amount of benefits called for under this Order and under the benefit option chosen by the Alternate Payee, such Alternate Payee's beneficiary(ies), as designated on the appropriate form provided by the Plan Administrator (or in the absence of a beneficiary designation, her estate), shall receive the remainder of any unpaid benefits under the terms of this Order. 11. Death of Participant: In the event that the Participant dies prior to the date the Alternate Payee receives a full distribution of her interest in the Plan, such Alternate Payee shall be treated as the surviving spouse of the Participant for any death benefits payable under the Plan to the extent of the full amount of her benefits as called for under Paragraph 8 of this Order. Should the Participant predecease the Alternate Payee after distribution has occurred, such Participant's death shall in no way affect the Alternate Payee's right to the portion of her benefits as stipulated herein. 12. Savings Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: Drafted: 6/13/05 06-06-05-014-1434Q (d) to provide any type or form of benefit or any option not otherwise provided under the terms of the Plan; to provide increased benefits determined on the basis of actuarial value; to pay any benefits to the Alternate Payee which are required to be paid to another alternate payee under another order that was previously determined to be a QDRO; or to make any payment or take any action which is inconsistent with any federal or state law, rule, regulation or applicable judicial decision. (a) (b) (c) 13. Certification of Necessary Information: All payments made pursuant to this Order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein. 14. Continued Qualified Status of Order: It is the intention of the parties that this QDRO continue to qualify as a QDRO under Section 414(p) of the Code, as it may be amended from time to time, and that the Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at the time benefits become payable hereunder. 15. Tax Treatment of Distributions Made Under This Order: For purposes of Sections 402(a) of ERISA and 72 of the Code, any Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the distributee of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate federal, state and local income taxes on such distribution. The tax basis of the assets awarded to each party by this Order shall be a proportionate share of the Participant's total tax basis in all the assets held in the Plan and allocated to his plan account. The Participant shall make such documents and records as are reasonably required by the Alternate Payee to determine such tax basis available to the Altemate Payee. 16. Constructive Receipt: In the event that the Plan Trustee inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall immediately reimburse the Alternate Payee to the extent that the Participant has received such benefit payments, and shall forthwith pay such amounts so received directly to the Alternate Payee within ten (10) days of receipt. In the event that the Plan Trustee inadvertently pays to the Alternate Payee any benefits that are to remain the sole property of the Participant pursuant to the terms of this Order, the Alternate Payee shall immediately reimburse the Participant to the extent that the Alternate Payee has received such benefit payments, and shall forthwith pay such amounts so received directly to the Participant within ten (10) days of receipt. 17. Continued Jurisdiction: The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as are necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein, including, but not limited to, the recharacterization thereof as a division of benefits under another plan, as applicable, or to make an award of alimony, if applicable, in the event that the Participant or the Plan Administrator fail to comply with the provisions contained in this Order requiring said payments to the Altemate Payee. Drafted: 6/13105 06-06-05-014-1434Q . 18. Effect of Plan Termination: In the event of a Plan termination, the Alternate Payee shall be entitled to receive her portion of the Participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries. 19. Actions by Participant: The Participant shall not take any actions, affirmative or otherwise, that circumvent the terms and provisions of this Qualified Domestic Relations Order, or that diminish or extinguish the rights and entitlements of the Alternate Payee as set forth herein. Should the Participant take any action or inaction to the detriment of the Altemate Payee, the Participant shall be required to make sufficient payments directly to the Altemate Payee to the extent necessary to neutralize the effects of the Participant's actions or inactions, and to the extent of the Alternate Payee's full entitlements hereunder. 20. Notice of Pending Retirement: In the event that the Plan Administrator requires the Alternate Payee to wait until the Participant's actual date of termination of employment or retirement before becoming eligible to receive her distribution, then the Participant shall be required to notify the Alternate Payee, in writing, within ten (10) days following his termination of employment or retirement. The notice shall be sent via regular first-class mail. For this purpose, the Alternate Payee shall notify the Participant of any changes in her mailing address. , /" ~ /' ~~7~~"//~( J. [1 tJ t<-11A.j;-~ } . 1C(rYl~t. Bonita J. Cramer IT IS SO ORDERED on this .I :/..'1. day of f'-t.........., ,200c.. BY THE COURT: 4J ) - Jf-lJlt {J~.~ ~ Drafled: 6/13/05 06-06-05-014-1434Q