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Home My WebLink About03-1027 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBY G. WHITE, JR., Plaintiff - NO. 1/3. /tJ~7 ~ vs. LYDIAD. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other relief requested in these papers by the Plaintiff You may lose money or property or other rights important to you. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBY G. WHITE, JR., Plaintiff NO. vs. CIVIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE A VISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con prontitud. Se le avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted puede perder dinero, 0 propiedades y otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania I 70 13. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEV AR ESTE P APEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 Telefano: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBY G. WHITE, JR., Plaintiff NO. vs. CIVIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING BOBBY G. WHITE, JR., being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 10 r {)-3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBY G. WHITE, JR., Plaintiff NO. vs. LYDIAD. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 5th day of March, 2003, comes the Plaintiff, Bobby G. White Jf., by his attorney, G. Patrick O'Connor, Esquire, Office ofG. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: I. The Plaintiff, Bobby G. White, Jf., is an adult individual who currently resides at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. The Defendant, Lydia D. White, is an adult individual who currently resides at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. The Plaintiff and Defendant were married on or about September 26, 198 I, and separated on or about January 12,2003. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff request your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely. Respectfully submitted, )f!~~ /0. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 1701 I (71 7) 737-7760 ID No. 64720 Attorney for the Plaintiff VERIFICATION I, BOBBY G. WHITE, JR., state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. Date: 10 ~ 0.;9 ~(/(.k~, B6BBY G. HIT, JR. I ,~ '\ "'. " \Iv ~. ~ ~ ~ ~ ~ ~ ~H ~ tA <:>(\ n"'i . <s ,\0'. ;-~_. , ~,\ '\~ ~ ~ ~ . ~ ~ C) C:.' ~~ \-., () g) l. r~': j: - _~ :.J " rv ~ '- .. ..u "- ' :0 BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vi. NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION UNDER &3505 OF THE DIVORCE CODE AND PA.R.C.P. 1920.43(A) AND NOW, comes the Petitioner, Lydia D. White, by and through her counsel of record, Cara A. Boyanowski, Esquire, and petitions the Court as follows: 1. Petitioner/Defendant is Lydia D. White, an adult individual currently residing at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Respondent/Plaintiff is Bobby G. White, Jr., an adult individual with a current mailing address of P.O. Box 946, Warren, Michigan, 48090. Mr. White is represented by Gordon Patrick O'Connor, Esquire. 3. Petitioner and Respondent are Husband and Wife, having been married on September 26,1981, in New Castle, New Castle County, Delaware. They are the natural parents of six (6) minor children. 4. On or about January 12,2003, Petitioner and Respondent separated, with Respondent removing himself and his personal belongings from the Marital Residence. 5. During the marriage, Petitioner and Respondent contracted with Prudential Life Insurance Company of America to purchase two (2) separate whole life insurance policies, Policy No. 73-389-416 and Policy No. 63-013-629, which were insured through the life of Respondent. These policies were maintained throughout the parties' marriage and existed at the time of separation. 6. Since the parties' date of separation, Petitioner has been satisfying all of the premiums due on these two (2) life insurance policies. 7. It has recently come to the attention of Petitioner, through a letter dated December 21, 2004 from Prudential Insurance Company of America, that Respondent has filed the necessary documents to terminate his Prudential Life Insurance Policy No. 73-389-416 and has requested a payout of the cash surrender value of this policy. A copy of the letter, dated December 21,2004, from Prudential Insurance Company of America is attached hereto and incorporated herein as Exhibit "A." 8. It has recently come to the attention of Petitioner, through a letter dated December 2 I, 2004, from Prudential Insurance Company of America, that Respondent has filed the necessary documents to terminate his Prudential Life Insurance Policy No. 63-013-629 and has requested a payout of the cash surrender value ofthis policy. A copy of the letter, dated December 21, 2004, from Prudential Insurance Company of America is attached hereto and incorporated herein as Exhibit "B." 9. Petitioner, the sole beneficiary ofthese two life insurance policies, was never notified of Respondent's desire to cancel these policies or liquidate the cash value of same. 10. Petitioner is concerned about the canceling of these policies because all of the parties' children remain minors and the purpose ofthe life insurance policies was to provide benefits to them in the event of the death of Respondent. 11. Petitioner believes that Respondent does not have enough death benefits available for the children in the event of his demise. 12. Respondent's actions of canceling his life insurance policies and liquidating the values associated with same are contrary to the interests of Petitioner and are in violation of the obligations owed by Husband to Wife under the Divorce Code. 13. Petitioner has a legal right and interest in Respondent's life insurance policies and their cash surrender values until a final decree in divorce is granted. WHEREFORE, Petitioner prays for equitable relief as follows: A. Issue an injunction enjoining Respondent from cashing the two (2) Prudential Life Insurance Company of American insurance proceed checks, numbered 01640184912 and 01640184931, absent a written agreement as to how same will be divided between the parties. Absent a written agreement between the parties, the parties are directed to deposit these two checks into an interest bearing escrow account, pending the entry of a final Decree in Divorce and the equitable division of their marital assets; B. Direct Respondent to purchase term life insurance, in an amount equal to the face values of the two (2) life insurance policies he cancelled, within ten (10) days of the date of the Order of Court; and C. Such other relief as your Honorable Court may deem appropriate. Respectfully submitted, SERRA TELL! SCHIFFMAN BROWN & GALHOON J~~~' Attorney No. 68736 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant/Petitioner VERIFICATION Due to the emergency nature of this Petition, Defendant Lydia D. White, was unavailable to sign a Verification. I hereby verify that the facts averred and statements made in the foregoing Petition for Special Relief are true and correct, as per information and statements I have received from my client. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: \~-~-oh\ 0!%~~~ Attorney for Defendant DEC-29-2004 01:30 AM P.02 Prudential. Financial PRUDENTIAL INSURANCE COMPANY OF AMERICA CUSTOMER SERVICE OFFICE POST OFFICE BOX 4579 JACKSONVILLE. FLORIDA 32231 BOBSY G WHITE JR 701 HILLTOP OR NEW CUMBERLND PA 17070 DECEMBER 21~ 2004 Policy # 73 389 416 Check # 01640184931 Insureds Name: B08BY G WHITE JR Your recent request for a cash surrender on this policy has been processed. A check in the amount of $8.475,82 payable to: BOBBY G WHITE JR* was issued on December 20, 2004 . As instructed. the cheek was mailed to the address shown below. PO BOX 946 WARREN 11\1 48090 If you have received or endorsed the above check and are satisfied with the transaction, please disregard this inquiry. However. If you have not received this check, or if you have any questions concernIng this transaction, a response to this letter would be greatly appreciated. Please se indicate in tne space provided below. Sign and date this letter and return to the 9ddress shown above. T~~nk yeu for your ~ooperatlon, SANDRA CLAYTON (904) )1)-3485 Comments : Signature Home phone humber Business phone number Oate Policy # 73 389 416 HARX, ADG EX~-tlB'T 1\ A \t _~A1O'TEl[~~Cl :~~ od. !l-01 =1+~.-~~55 DEC-29-2004 01:29 AM P.01 ....._._M _..__....~_ _. ~._ ___... . __. . ~__,.~. _M~_____..N _.. ___. - T _ lID Prudential. Financial PRUDENTIAL INSURANCE COMPANY OF AMERICA CUSTOMER SERVICE OFFICE POST OFFICE BOX 4579 JACKSONVILLE, FLORIDA 32231 BOBey G WHITE JR 701 HILLTOP DR NEW CUMBERLND PA 17070 DECEMBER 21, 2004 Policy # 63 013 629 Check # 01640184912 Insureds Name: BOBBY G WHITE JR Your recent request for a cash surrender on this pol icy-has been processed. A check in the amount of $3,915.40 payable to: BOBBY G WHITE JR* was Issued on December 20. 2004 . As instructed. the check was mailed to the address shown below. PO BOX 946 WARREN "'I 48090 If you have received or endorsed the above cheek and are satisfied with the transaction. please disregard this inquiry. However, if you have not received this check, or if you have any questions concerning this transaction, a response to this letter would be greatly appreciated. Please so indicate in the space provided below. $ign and date this letter and return to the address shown above. Thank you for your cooperation. SANDRA CL~YTON (904) 313-3485 Comments : Signature Home phone number Business phone number Date Polley # 63 013 629 HARX, ADG EX WI B\ T 11511 ~.!lJSA.\-Ol~J lOAD 70~~ ed. 1-01 CERTIFICATE OF SERVICE I, Cara A. Boyanowski, Esquire, hereby certify that on the date indicated below I served a true and correct copy of the foregoing Petition for Special Relief, on all interested parties, by depositing same from Harrisburg, Pennsylvania, first class mail, postage prepaid, addressed as follows: Gordon Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, P A 17011 SERRATELLI SCHIFFMAN BROWN & CALHOON Date: I;R.- ?o-Oh\ BY~~0W3~ Cara A. Boyanowski, Esq. Attorney No. 68736 2080 Linglestown Road Harrisburg, P A 17110 (717) 540-9170 Attorney for Defendant/Petitioner 0 ......., f-"; = 0 ,= W'1 11 <- :;:l ...';:.". --.. ..,., :L: r!1p: ..- ''v- I -o~ ~;~- (..:> "'J ()':J ...j' j;:~~i -:J ;J;~ ~.-,. -'- ;cJ C) N Om :::~ .-.1 (.n > ~..o f'v ""< BOBBY G. WHITE, JR., PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LYDIA D. WHITE, DEFENDANT/PETITIONER 03-1027 CIVIL TERM ORDER OF COURT AND NOW, this I~ day of January, 2005, upon receipt of the petition, a Rule to show cause is issued upon plaintiff/respondent to show cause, if any he has, why the relief requested therein should not be granted. Pending further order of court, plaintiff/responden~ is directed not to cash the two Prudential Life Insurance Company of America proceed checks, numbered 01640184912 and 01640184931. Rule returnable at a hearing to be conducted in Courtroom II, Cumberland County Courthouse, Carlisle, Pennsylvania at 11 :00 a~.Mood ,J uary 31, 2005. ,/' ~y the cout' '~ Edgar B. Bayley, J. J Gordon Patrick O'Connor, Esquire For Plaintiff/Respondent Cara A. Boyanowski, Esquire For Defendant/Petitioner .~~ .~ /_/,(.(J~ ~ :sal I: 1"-" {; i .r' ! .C.... S l ~~'.}r S~:Jl BOBBY G. WHITE, JR., Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LYDIA D. WHITE, Defendant/Petitioner NO. 03-1027 CIVIL TERM ORDER OF COURT AND NOW, this 31st day of January, 2005, this matter having come before the Court this date, and upon representation that the insurance policies were cashed by plaintiff/respondent prior to this Court's order of January 13, 2005, and that approximately $12,000.00 in proceeds were obtained by plaintiff/respondent and spent by him, IT IS ORDERED that the petition for special relief is denied and order of January 13, 2005, is vac9L~d:- temporary Edgar ~don Patrick O'Connor, Esquire For Plaintiff/Respondent ~ra A. Boyanowski, Esquire For Defendant/Petitioner J 6fJ.;~~ 1~ 01-31-05 prs t- <<) c:} ~,.- .';"- u~ .- <;") ...~.. :;:;5* -, ~f::;> (,:::2\ !;.~ ---------- BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-1027 CIVIL CIVIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Cara A. Boyanowski, Esquire hereby accept service of Plaintiffs Complaint In Divorce. I hereby certify that I represent the above-captioned Defendant, Lydia D. White, and further certify that I am authorized to accept service on behalf of said Defendant. Date: 3-'1 -05 ()ffiM~oW;lu Cara A. Boyanowski, Esquire Pa. SUpf. Ct. J.D. # ~ SERRATELLI, SCHIFFMAN, BROWN AND CALHOON, P.c. 2080 Linglestown Road, Suite 201 Harrisburg, P A 1711 0-9670 Attorney for Defendant BOBBY G. WHITE, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL CNIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of the undersigned as counsel for the Plaintiff in the above-captioned matter. /1 :z:;g~cr< ,/-,if~ v' ("i'~ Gary J. Rothschild, Esquire Sup. Ct. LD. No. 62041 2215 Forest Hills Drive, Suite 35 Harrisburg, PA 17112 (717) 540-3510 Date:;! 4;' Cara A. Boyanowski, Esquire Supreme Court 1.0. No. 68736 2080 Linglestown Road Suite 20 I Harrisburg, PAl 71 10 (7] 7) 540-9170 BOBBY G. WHITE. JR.. PLAINTIFF IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1027 CIVIl. TERM DEFENDANT CIVIL ACTION - LAW IN DIVORO: LYDIA D. WHITE, NOTICE TO DEFEND AND CLAIM RIGHTS YOU lIA VE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY. LA WYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT [S GRANTED. YOU MAY LOSE THE RIGHT TO CLA[M ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted qui ere deienderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 pOl' abogado y archival' en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted puede perder dinero 0 sus propicdadcs () otms de;cchos imporlanatcc; para usted. LLEVE EST A DEMANDA A UN ABODAGO 1NMEDIA T AMENTE. Sl NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO. V A Y A EN PERSONA 0 LLAME POR TELFONO A LA OFlClNA CUY A DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGU1R ASlSTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Cara A. Boyanowski, Esquire Supreme Court l.O. No. 68736 2080 Linglestown Road Suite 20 I Harrisburg, PA 17110 (717) 540-9170 BOBBY G. WHITE, .JR., PLAINTIFF IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1027 CIVIL TERM LYDIA D. WHITE, DEFENDANT CIVIL ACTION - LAW IN DIVORCE ANSWER TO COMPLAINT IN DIVORCE WITH COUNTERCLAIMS AND NOW, comes the Defendant, Lydia D. White, by her attorney, Cara A. Boyanowski, Esquire, and files this Answer to Complaint in Divorce With Counterclaims, and sets forth the following: COUNT I DIVORCE 1. Denied. Since the filing of the divorce complaint, Plaintiff has relocated from the Marital Residence, located at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania. He now resides in Warren, Michigan. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Defendant has no knowledge as to truth of the averment set forth in Paragraph Six (6) of the Divorce Complaint. 7. Admitted. 8. The averment set forth in Paragraph Eight (8) is a conclusion of law \0 which no answer is deemed necessary. WHEREFORE, Defendant respectfully requests this Honorable Court to not enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant. COUNTERCLAIMS COUNT II EQUITABLE DISTRIBUTION 9. Paragraphs I through 8 of the Divorce Complaint, like on l\-1arch 7, 2003, are incorporated herein by reference as though set forth in full. 10. Plaintiff and Defendant have acquired property, both real and personal, from the date of their marriage. September 26, 198 l, until the date of their separation, January 12, 2003. 1]. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Defendant requests your Honorable Court to equitably divide all marital property. COUNT III ALIMONY 12. Paragraphs I through 8 of the Divorce Complaint, filed on March 7, 2003, are incorporated herein by reference as though set forth in full. 13. Defendant lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 14. Defendant requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Defendant requests your Honorable Court to enter an award of alimony in her favor. COUNT IV ALIMONY PENDENTE LITE, COlJNSEL fEES, COSTS AND EXPENSES 15. Paragraphs] through 8 of the Divorce Complaint, filed on March 7, 2003, are incorporated herein by reference as though set forth in full. 16. Plaintiff earns in excess of$94,000.00 dollars gross per year, and has assets that have not yet been ascertained. l7. Defendant has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. Defendant is unable to sustain herself during the course of this litigation. WHEREFORE, Defendant requests your Honorable Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. I verify that the statements made in this Answer to Complaint In Divorce With Counterclaims are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. By: LY~;~~, ~---~-- Date: Bs:-os;- By: Cara A. Boyanowski, Esquire Attorney No. 68736 2080 Linglestown Road Suite 20 I Harrisburg, PAl 7110 (717) 540-9170 Attorney for Defendant -0 " K-' A::, ('\ ~ --- ~ ,~ "^" ~' 'J> ~.\ ~ ,e-'~ J:. ;--\ w 0, i:) ~ ~ " (' 1<\ ~ -(:) '3 o ~ "<: ~ (il ., ~ ( ''--''~ " \ \ y -\ (') C :;::~ ~l~r' _/,1.:' ~. ;:~:' ~;; ~'~I'~- ~ ~.'~,,~ -'-~;' ::..:...j -< '" co, = """ o -," .-.\ :::J:"" :11:;:;;:.:. -r"!;-':! ;~):~? '::::~() :'>.'-l ~~:,\ ;-;:,:(j ;~'~:' i-~\ ~'l -~ ~~ -po -,::> "'" "" 0" :r::" =~:. CD U1 U1 - BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Bobby G. White, Jr., Plaintiff, moves the court to appoint a master with respect to the following claims: (X) Divorce () Annulment (X) Alimony (X) Alimony Pendente Lite (X) Distribution of Property () Support (X) Counsel Fees (X) Costs and Expenses and in support of said motion states: (I) Discovery is complete as to the c1aim(s) for which the appointment of a master is requested. (2) The non-moving party has appeared in the action by her attorney, Cara A. Boyanowski, Esquire. (3) The statutory ground for divorce is irretrievable breakdown. (4) (a) The divorce action is contested. (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: All. (5) The action does not involve complex issues oflaw or fact. (6) The hearing is expected to take approximately one day. (7) Additional information, if any, relevant to the motion: None. 9jt~ ~~ Date: Gary L oths hild, Esquire Sup. Ct. LD. No. 62041 2215 Forest Hills Drive, Suite 35 Harrisburg, PA 17112 (717) 540-3510 Attorney for Plaintiff o C~, .-' C-O <'^'":J. ""' (,I) C~i ", Cl ~I .-,-, -"~ t..'? -- Cf'l ~ECEIVED SEP 08 Z005 J J BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL CIVIL ACTION - LAW LYDIAD. WHITE, Defendant IN DIVORCE ORDER APPOINTING MASTER AND NOW. o.i~ 0,2005, master with respect to the following claims: .:- [ ~ ~squire, is appointed ~~ BY THE COURT: MOVING PARTY NON-MOVING PARTY Name: Bobbv G. White Name: Lvdia D. White Attornev's Name: Garv L. Rothschild Attornev's Name: Cara A. Boyanowski, Esquire Attornev's Address: 2215 Forest Hills Drive, Suite 35 Harrisburg,PA 17112 Attornev's Address: 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110-9670 Attornev's Telephone #: (17) 540-3510 Attornev's Telephone #: (717) 540-9170 Attorney's E-Mail: Glrothlawlalcomcast.net Attorney's E-Mail: cboyanowski@ssbc-Iaw.com 8~ , . . ~ :8 lId ~I ! . cr~7 ~~U~ :!() BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DIVORCE INVENTORY OF BOBBY G. WHITE. JR. Plaintiff, Bobby G. White, Jr., files the following inventory of all property owned or possessed by either party at the time this action was commence:d and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements, if any, herein are made subjeet to the penalties of 18 Pa. C. S. 9 4904 relating to unsworn falsification to authorities. Cf BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DIVORCE ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (x) 1. Real Property (x) 2. Motor Vehicles (x) 3. Stocks, bonds, securities and options (x) 4. Certificates of deposit (x) 5. Checking accounts, cash (x) 6. Savings accounts, money market and savings certificates ( ) 7. Contents ofsafe deposit boxes ( ) 8. Trusts (x) 9. Life insurance policies Husband's Fed'l Gov't Wife's Prudential Face value: $ 206,000 death benefit unknown Cash Surrender Value: none unknown Current beneficiaries: Lvdia D. White unknown ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business: Owners: ( ) 16. Employment termination benefits-severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans (x) 18. Pension plans (indicate employee contribution and date plan vests) (x) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/ VA benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-1027 CIVIL : CNIL ACTION - LAW LYDIAD. WHITE, Defendant : IN DNORCE MAIDT AL PROPERTY: Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any othf:r person as of the date this action was commenced. ITEM DESCRIPTION OF NAMES OF NUMBER PROPERTY ALL OWNERS 1. 701 Hilltop Dr. Bobby G. White, Jr. New Cumberland, PA Lydia D. White 2. 1998 Chevrolet Suburban Truck Bobby G. White, Jr. Lydia D. White 2. 1998 Ford Club Van Lydia D. White 3. CSFB brokerage account Bobby G. White, Jr. LydiaD. White 3. 80 shares EPB common stock Lydia D. White 3. _ shares Ahold Corp stock Lydia D. White 3. various other shares of stock LydiaD. White 4. C.D. New Cumberland Fed'l Credit Bobby G. White, Jr Union Lydia D. White 5. IRS Refunds (2002 and 2003) Bobby G. White, Jr. Lydia D. White 5. New Cumberland Fed'l Credit Union Bobby G. White, Jr. checking account number 66429 Lydia D. White 5. Member's First Federal Credit Union Bobby G. White, Jr. checking account number 25604 Lydia D. White BOBBY G. WHITE, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-1027 CNIL CNIL ACTION - LAW LYDIA D. WHITE, Defendant IN DNORCE MARITAL PROPERTY (continued): 5. New Cumberland Federal Credit Union Lydia D. White checking account 5. Rock Island Arsenal Fed'l Credit Union Bobby G. White, Jr. checking account number 477186 5. Travel vouchers from government Bobby G. White, Jr. reimbursements 6. New Cumberland Fed'l Credit Union Bobby G. White, Jr. savings account number 66429 Lydia D. White 6. Member's First Federal Credit Union Bobby G. White, Jr. Savings, holiday and investment Lydia D. White account number 25604 6. New Cumberland Federal Credit Union Lydia D. White savings account 9. Life Insurance Policies-Prudential (2) Bobby G. White, Jr. 9. Life Insurance Policies-Prudential (I) Lydia D. White 9. Term life insurance-Federal Gov't Bobby G. White, Jr. 18. Federal Pension Bobby G. White, Jr. 19. Roth IRA account 0956-7034 Bobby G. White, Jr. 19. Roth IRA account 0956-7033 Lydia D. White 25. Household furnishings & personalty Bobby G. White, Jr. Lydia D. White BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CNIL ACTION - LAW LYDIAD. WHITE, Defendant : IN DNORCE NON-MARITAL PROPERTY: Plaintifflists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: ITEM NUMBER DESCRIPTION OF PROPERTY REASON FOR EXCLUSION s. Post separation travel vouchers Received post separation 6. Rock Island Arsenal Fed'l Credit Union savings account number 477186 Opened post separation 18. Portion of Federal Pension Post separation portion BOBBY G. WHITE, JR., Plaintiff : IN THE COLJRT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CNIL : CNIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DNORCE PROPERTY TRANSFERRED: Plaintifflists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred. ITEM NUMBER DESCRIPTION OF PROPERTY DATE OF CONSIDER. TRANSFER ATION PERSON TO WHOM TRANSFERRED 2. 1998 Chev. Suburban Truck 1-29-04 4. C.D. New Cumberland Fed'l unknown Credit Union 5. IRS Tax Refunds various 5. New Cumbo Fed'l C.U. 04-03 5. Cash withdrawal from 08-28-03 second mortgage 5. Cash withdrawals various 9. Life Insurance Policies- 01-03-05 Prudential (2) 19. Roth IRA account 0956-7034 11-04 25. Personal belongings various $ 8,000.00 traded in on new car unknown withdrawn by Wife $ 2,087.00 to Husband $ 7,539.00 to Wife $ 350.00 to Husband $ 3,500.00 to Wife unlmown to Wife $ 12,391.22 liquidated by Husband $ 4,454.89 used to payoff credit card debt- Wilm. Trust unknown Husband has some of his personal belongings BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : Cl.IMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DIVORCE LIABILITIES: Plaintifflists all liabilities of either or both spouses alone or with any person as of the date of separation. ITEM DESCRIPTION OF NAMES OF NAMES OF NUMBER PROPERTY ALL CREDITORS ALL DEBTORS l. I st mortgage Members First Fed'l Bobby G. White, Jr. Credit Union Lydia D. White l. 2nd mortgage New Cumberland Federal Bobby G. White, Jr. Credit Union Lydia D. White credit card balance Wilmington Trust Bobby G. White, Jr. LydiaD. White credit card balance Bank of America Bobby G. White, Jr. credit card balance Toys R Us Lydia D. White credit card balance L. L. Bean Lydia D. White telephone bill Cingular Bobby G. White, Jr. credit card balance various-details unknown Unknown Respectfully submitted: Date: U;:5 By: Gary . Rothschild, Esquire Sup. Ct. J.D. No. 62041 2215 Forest Hills DJive, Suite 35 Harrisburg, PAl 71 12 (717) 540-3510 Attorney for Plaintiff - . ~', . .. . ,; IN' H, re- VS. LV H, r,~ No. 03-/027 Date ~S"/l.JC- 0 S THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried llY a business of which you are owner in whole or in part, you must also fill out the Supplemental Income State- ment which appears On the last page of this Income and Expense Statement.) INCOME AND EXPENSE. STATE~IENT OF }30(38Y G. fA) H ( re. r f':.. . INCOME :::::~: -~~~; ~~1M~C~ Type of Work: /...0 J ('".) h c. S Payroll Number: 7--;"'- L/,)_.. ?-?-& 'f Pay Period (weekly, biweekly, etc.): 1;;1, ~lN lcly Gross Pay per Pay period: $ '3 ir L./4Jif'O ( Itemized Payroll Deductions per Pay Period: Way-....("l, 11-11 ti V-:::;C('T- S7JcJc) Federal Withholding................$ Social Security..................... Local Wage Tax ..................... State Income Tax ................... Retirement... ....,....... ........... Sa vings Bonds ...................... Credi t Union ....................... Life Insurance ..................... Health Insurance ................... Other (specify}..................... Mid' ell ,-t /43. <r1 --- -- 1')...4_(~ ]"'fL"1. (. - -:vX'. c.tI ( ~ 0 MIl"- -n-.tO--c ) ;,.L/S' i / y. ore, 0/. 0'1 Net Pay per Pay Period: $~. 3/8.0)( Other Income: Week Month Year (Fill in Appropriate Column) Interest.......................... .... $ Dividends............................ . Pension. . . . . .. .. . . . . . . . . . .. .. . . . .. . . . . . . . .. .. Annui ty .............................. Social Security...................... Rents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Royalties............................ . Expense Account.......................................... Gifts................................ . Unemploymer.t Comp..................... Workmen's Compo ............ ._,"........................... $ $ Total $ $ $ $ ~ / " Cj36BBY ,.. . 'i".. ~ ~., NAME: G, WIt/fC'. :TI'. . . EXPENSES Home $ Mortgage/rent . . . . . . . . . . . . . . . . . . . . . . . . t1aintenance .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. Utilities... .......................... Electric. . . . . . . . . . . . ., . . . . . . . . ... . . Gas.................... ............ Oil............................... . Telephone ... . . . . . . . . . . . . . . . . . . . . . . . Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Sewer .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . Employment Public transportation ................ Lunch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Taxes Real estate . . . . . . . . . . . . . . . . . . . . . . . . . . Personal property.................... Income (other than payroll deductions) Insurance HomeoWIlers .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. Automobile. . . . . . . . . . . . . . . . . . . . . . . . . . . Life................................ . Accident. . . . . . . . . . . . . . . . . . . . . . . . . . . . . Health. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Other . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . Automobile Payments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . Fuel.......... ....... ..... ........... Repairs ................ . . . . . . . . . . . . . . Medical Doctor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Dentist.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. Orthodontist. . . . . . . . . . . . . . . . . . . . . . . . . Hospital.... ................. ........ Medicine.. .. .. .. ~ .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. Special needs (glasses, braces, orthopedic devices}................. Education Private school....................... Parochial school..................... College. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Religious. . . . . . . . . . . . . . . . . . . . . . . . . . . . Personal Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Food............................. .... Barber/h.airdresser .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. .. .. Credit payments ...................... Credi t card . . . . . . . . . . . . . . . . . . . . . . . . Cllarge account.......................................... Memberships . . . . . . . . . . . . . . . . . . . . . . . . . . Loans Weekly Monthly Yearly (Fill in appropriate column) $ 5 y). o() $ $TJ.O() 6i)'(lrl 1;;..1 .tfj 71kO:o 5'().{)o J )-0 .00 , . . . JiIl,ME : '/3013 BY G, WI-f-tTC', :Tte, , " Miscellaneous Household help .......................... $ Child care .............................. Papers/books/magazines .................. Entertainment .................................................. Pay TV .................................. Vacation.... ...... ............ ............ ..........................._ Gifts............................... ..... Legal fees .............................. Charitable contributions................ Other child support...................... . Alimony payments ........................ Other c V r~i SvtLPClr+ Total Expenses Weekly $ Monthly Yearly (Fill in appropriate column) $ $ q t!). ocJ ~ c'), of) ;/. .od ")17o?ofJU $ '-J,463.a> $ - " VERIFICATION I verify that the statements made in this Income and Expense statement 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 ~fS'- I$!LuP-r;, n ;-' ~!, ~ (/') I", .'''() I _.1 C) .::t, .-< -C-n Tn ~::::. "'T' "'1' _j ""'-r - :Ie' -..,,' C, ~'..::-'D ; ~') ::-'yn -;-' - - - c:? -(:? '~~ 0'\ - BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STATEMENT UNDER RULE 1920.31 I hereby file the Statement ofIncome and Expenses required under Rule 1920.31 and verify that the information therein contained is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904, relating to unsworn falsification to authorities. Date: tl, ::JD 0) /' By: {.~.. IJ/.L Lydi . White, Plaintiff INCOME AND EXPENSE STATEMENT Employer: Giant Food Stores OF LYDIA D. WHITE INCOME Address: 1149 Harrisburg Pike, Carlisle, P A 17013 Type of Work: Pharmacy Tech Payroll Number: 221-36-7819 Pay Period (Weekly, Bi-weekly, etc.): Weekly Gross Pay Per Pay Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Life Insurance Unemployment Other (specify) Net Pay Per Pay Period $ 191.10 $ 14.15 $ 11.85 $ 2.77 $ 5.87 $ 6.00 $ .18 $ 15.00 (stock options) $ 132.51 Weekly pay varies. I work a 12-14 hour week during the summer months, and a 18-21 hour week during the school year. The above was taken from a week pay of 19.5 hours. OTHER INCOME: Spousal and Child Support MONTHLY $2,571.00 TOTAL INCOME: $3,145.47 HOME: Mortgage Utilities: EMPLOYMENT: Lunch TAXES: Real Estate EXPENSES Electric Gas Oil Sewer Telephone Water Personal Property INSURANCE: Homeowners Automobile(s) Life Health MONTHLy' $ 724.00 $ 125.45 $ 85.00 (propane budget plan) $ 154.00 (budget plan) $ 46.66 $ 52.81 $ 82.75 $ 12.00 $ 207.84 $ 86.41 $ 80.85 $ 89.75 $ 21.65 Husband provides for Defendant and children AUTOMOBILES: Fuel $ 225.00 Repairs $ 30.00 MEDICAL: Doctor $ 315.00 Dentist $ 35.00 Medicine $ 100.00 Special needs (glasses, braces, orthopedic devices, etc.) $ 45.00 (contacts and glasses) EDUCATION: Parochial School $ 230.00 Religious $ 10.00 PERSONAL: Clothing $ 100.00 Food $ 600.00-800.00 Barber/Hairdresser $ 25.00 Credit Card $ 680.00 Charge Accounts $ 177.00 MISCELLANEOUS: Entertainment $ 275.00 (includes children's sports activity fees) Pay T.V. $ 25.00 Gifts $ 200.00 (averaging Christmas and birthdays) Legal Fees $ 100.00 TOTAL EXPENSES $5,041.17 CHECK NO' CHECK DATE: PERIOD ENDING D9904404 07/15/05 07/09/05 ~.~~'''''. ",dh" i~~:~: ,/r'.~ii; "t\~~: ";?" . Qualily. Seleetion. Savings. EveryDay. Giant Food Stores 1149 Harrisburg Pike Carlisle, PA 17013 LYDIA D WHITE 701 HILLTDP DRIVE NEW CUMBERLAND PA SSN: 221-36-7819 STOREIDEPT:0120 0170 400 17070 TAX STATUS: EXEMPTIONS: TAX ADJ: S FED: 00 FED: STATE: STATE: S 00 CURRENT Y- T ~Q CURRENT Y-T-Q DESCRIPTION HOURS EARNINGS HOURS EARNINGS DESCRIPTION AMOUNT AMOUNT REGULAR PAY 15.50 151,90 5.000,79 FICA-DASDI 11,B5 317,27 HDL IDA Y 4.00 39.20 116,40 FEDERAL 14,15 3B3,60 FICA-HI 2,77 74.20 STATE PA 5,87 157.10 PA UNEMPLOYMENT ,18 4.61 NEW CUMBRLND CU 2.77 74.20 TOTAL TAX 37,59 010.98 TAX 5TOCK DEDUCTION UNIVERSAL LIFE .00 15,00 6.00 52.00 420.00 168.00 TOTAL HOURS & EARNINGS 19.50 191.10 5,117.19 "" ":"','::'lIRE+TAj(DEbUCTiPN$'::' ITEMS BELOW DEDUCTED BEFORE FEDERAL TAXES MAY STILL BE SUBJECT TO STATElLoCAL TAXES .00 ,00 TOTAL TOTAL MISC. OED. 21.00 CURRENT 191.10 Y-T-D 5.117.19 "< "",' PAY' " '1':;\: 37.59 NEY::::P'AV:':; '--'.-.:::,::c 132.51 ;:::NET:: 132.51 1.010.98 640.00 3,466.21 QATE:'>,p7/ffiJi05,:'/'\':flECK <,;-:0; -\':L:> ~IIJ ';VOID -',,,' ',""/,, "':,'-'"",-- '" SdLcth E '\-'}hite d Total number of exemptions claimed 7 Wages, salaries, tips, etc. Attach Form(s) W.2 8a Taxable interest. Attach Schedule B if required b Tax-exempt !nterest. Do not include on line 8a I 8bj 9a Ordinary dividends. Attach Schedule 8 if required bQualf,ddivs I 9bl (seelnstrs). 10 Taxable refunds, credits, or offsets of state and local incometa:l:es (see instructions) . 11 Alimony received 12 Business income or (loss). Attach Schedule C or C-EZ 13 Capital gain or (loss). Att Sch 0 if reqd. If not reqd, ck here 14 Other gains or (losses). Attach Form 4797 158 IRA distributions .......... I 15al I bb Taxable amount (see instrs) 16a Pensions and annuities.... ~ Taxable amount (see instrs) 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E 18 Farm Income or (loss). Attach Schedule F 19 Unemployment compensation 20. SOCIal secuntybeneflts. I 20.1 21 Other Income 22 Add the am~u~t;- i~ u,; i~r--;i~ht c~I~~n fo-;:- iin;s -7 th-;:-o~ah 21 ~ This is ~our- ~talin~o-m-; -..: 23 Educator expenses (see instructions) 23 24 Certain bUSiness expenses of reservists, performing artists, and fee-basIs government officials. Attach Form 2106 or 2106-EZ. 25 IRA deduction (see instructions) 26 Student loan interest deduction (see instructions) 27 Tuition and fees deduction (see instructions) 28 Health savings account deduction. Attach Form 8889 29 Moving expenses. Attach Form 3903 30 One-half of self-employment tax. Attach Schedule SE 31 Self-employed health insurance deduction (see instrs) 32 Self-employed SEP, SIMPLE, and qualified plans 33 Penalty on early withdrawal of savings 34a Alimony paid b Recipient's SSN . ~ 35 Add lines 23 through 34a 36 Subtract line 35 from line 22. This is your adjusted gross income BAA For Disclosure, Privacy Ad, and Paperwork Reduction Ad Notice, see instructions, Form 1040 label (See instructions.) Use the IRS I.bel. Otherwise, please print or type. Presidential Election Campaign (See instructions.) Filing Status Check only one box. Exemptions If more than four dependents, see instructions. Income Attach Form(s) W-2 here. Also attach Forms W-1G and ID99-R if tax was withheld. If you did not getaW-1, see instructions. Enclose, but do notattach,any payment. Also, please use Form I04D-V. Adjusted Gross Income Department of the Treasury - Internal Revenue Service 1(99) IRS Use Only - Do not write or staple in this space. 2004 U.S. Individual Income Tax Return For the year Jan 1 - Dec 31, 2004, or other tax year beginning Your first name MI Last name ,1004, ending ,10 OMB No. 1545.0074 Your social security number L'dia If a joint return, spouse's first name Whit.-:o Last name .221-3,:~-7;.JICJ Spouse's social security number D MI Home address (number and street). If you have a P.O. box, see instructions. Ap.1rtmentno. ... Important! T (OU must entel- yOUI sodal security number(s) above. 701 HIlltoJ Drive City, town or post office. II you have a foreign address. see instructions. Stale ZIP code I-TeVl Cumber' land Pt.. 17U7u Itrr... Spouse ,.. Note: Checking 'Yes' will not change your tax or reduce your refund. Do you, or your spouse if filing a joint return, want $3 to go to this fund? ~ Yes 1 Single 4 Head of household (with qualifying person). (See 2 Married filing J"ointly (even If only one had Income) instructIons.) If the qualifying person is a child but not your dependent, enter this child's 3 Married filing separately. Enter spouse's SSN above & full name here ~ name here. ~ 5 0 Qualifying wldow(er) With dependent child (see instructlOns) 6: B ~o~~:~f.. I.f. ~~~~o~~. ~~.n. ~~~i.~. ~~~. ~~. ~. ~~:~.~d~~~,. .~~. ~~~ .c.~~~~ .~o~ .~~ . =~ ::~:;a;:~:~:: (2) Dependent's (3) Dependent's (4) if on 6c who: social security relationship qualifying. lived number to you child for child with you. tax credit . did not (see instrs) live with you due to divorce or separation (seelnstrs) .. Dependents on6c not entered above . No 1 c Dependents: {~ First name Last name Bobh U:?,-(,S-3198 G \'Thite, III S':Jn Erik H 1iJhite :i):-7f)-4:;':f',S .Son Annamarie K White 193-7':-SU43 Dauchter 1~3-74-314~ Dauqhter .SEE.'sTMT [Xl 71 Add numbers .1 on lines ~ above... . 7 8. 11), 1i':::::. :'7 9. C '-.<':J. .. 10 11 12 13 14 15b 16b 17 18 19 20b 21 22 19,(0,0.. C" 3,'34. ~D I b Taxable amount (see JOstrs) 24 25 26 27 28 29 30 31 32 33 34. 35 ~ 36 1 ~J, (, 8. FDIA0112 11/10/04 Form 1040 (2004) Form 1040 (2004) Lvdia, D V,Thi t e ';'21-?,(-7(~lc) Paqe 2 37 Amount from line 36 (adjusted gross income) 37 1 :) , t",~ n Tax and Credits 38_ Check -I B You were born before January 2, 1940, B Blind. Total boxes 38_L If: Spouse was born before January 2, 1940, Blind. checked ... Standard I b If your sp-ouse Itemizes on a separate return, or you were a dual-status Deduction .. 38bD for - _ allen, see Instructions and check here . People who -~~ Itemized deductions (from Schedule A) or your standard deduction (see left margin) 39 11), .:.~) 7 . checked any box 40 Subtract line 39 from line 37 40 ::1, :2::) 1. on line 38a or 41 If line 37 is $107,025. or less, mUltip~ $3,100 by the total number of exemptions claimed 38b or who can be claimed as a on line 6d. If line 37 IS over $107,02 , see the worksheet in the Instructions ...... .. . . 41 21, 70(J. dependent, see 42 Taxable income. Subtract line 41 from line 40. instructions. If line41 IS more than line 40, enter -0- 42 I). 43 Tax (see mstrs). Check if any tax is from: a DForm(s) 8814 b D Form 4972 43 u . All others: 44 Alternative minimum tax (see instructions). Attach Form 6251 44 Single or Married 45 Add lines 43 and 44 .. 45 " filing separately, 46 Foreign tax credit. Attach Form 1116 If required 46 $4, 50 47 Credit for chIld and dependent care expenses. Attach Form 2441 47 Marned filing 48 Credit for the elderly or the disabled. Attach Schedule R 48 jointly or Qualifying 49 Education credits. Attach Form 8863 . 49 widow(er), 50 Retirement savings contributions credit. Attach Form 8880 50 $9,700 51 Child tax credit (see instructions) 51 U Head of 52 Adoption credit. Attach Form 8839 . 52 household, $7,150 53 Credits from: a D Form 8396 b D Form 8859 53 54 Other credits. Check applicable box(es): . Dform3800 b Dform c DSpeclfy 54 8801 55 Add lines 46 through 54. These are your total credits. 55 u. 56 Subtract line 55 from line 45. If line 55 is more than line 45, enter .0- .. 56 1.1. 57 Self. employment tax. Attach Schedule SE . 57 Other 58 SOCial security and Medicare tax on tip Income not reported to employer. Attach Form 4137 58 Taxes 59 AdditIOnal tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required 59 60 Advance earned income credit payments from Form(s) W-2 60 61 Household employment taxes. Attach Schedule H 61 62 Add lines 56.61. ThiS is your total tax. .. 62 IJ. Payments 63 Federal income tax withheld from Forms W-2 and 1099 63 f: U ~J . If you have a L 64 2004 estimated tax payments and amount applied from 2003 return . 64 qualifying 65a Earned income credit (EIC) . 65. 3, 113. child, attach I b Nontaxable combat pay election. "I 65bl Schedule EIC. 66 Excess SOCial security and tier 1 RRTA tax withheld (see instructions) 66 67 Additional child tax credit. Attach Form 8812 67 u. 68 Amount paid with request for extension to file (see Instructions) . 68 69 Other pmts from: a Dform1439 b D form 4136 c D form 8885 69 70 Add lines 63, 64, 55a, and 65 through 59 .. 70 3,9:: . These are your total payments. Refund 71 If line 70 is more than line 62, subtract line 62 from line 70. This IS the amount you overpaid 71 ) c,,--,,- ~, '}" Direct deposit? 72a Amount of line 71 you want refunded to you .. 72_ 3, CI;' See instructions : : :~~~:~t ~~:bbe:r ::::::: I~~~~~~~~~~~~~~~~,~~~~~~~~~,~L, .. c Type: n Checkin9 o Savings and fill in 72b, -,,"\- ':; ~-< 1 72c, and 72d. " 73 Amount of line 71 you want applied to your 2005 estimated tax . "173 I Amount 74 Amount you owe. Subtract line 70 from line 62. For details on how to pay, see instructions .. 74 You Owe 75 Estimated tax penalty (see instructions) 175 I Third Pa Do you want to allow another person to discuss thiS return with the IRS (see Instructions)? . U Yes. Complete the following, UNo . rly Deslqnee Sign Here Joint return? See instructions. Deslgnee's Phone Personal Identification name .. no. .. number (PIN) ... Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements. and to the best of my knowledge and belief, they are true. correct, and complete. Declaration 01 preparer (other than taxpayer) is based on alllnform;~tlon of which preparer has any knowledge. Your signature Date Your occupation Daytime phone number ~ Keep a copy Spouse's signature II a joint return, both must sign for your records. .. Date Pharmdcv Tech Spouse's occupatioll Date Preparer's SSN or PTIN Paid Preparer's Use Only Preparer's Iil.. signature r Firm's name (or yours if Irrrr.. s~lf."'lllpI0\,~d}_r address,and ZIP code Self-Prepared Checkilself.employed 0 ~EIN Phone no. Form 1040 (2004) FDIA0112 11110104 SCHEDULE A Itemized Deductions OMS No. 1545.0074 (Form 1040) 2004 Department of Irle Trea~ury . Attach to Form 1040. Internal Revenue Service (99) ... See Instructions for Schedule A (Form 1040). 07 Name(s) shown on Form 1040 l~ourSOCialsecuritynumber Ludia D I'Thite ':'>1-3c-7::'~1~) Medical Caution. Do not include expenses reimbursed or paid by others. and 1 Medical and dental expenses (see Instructions) 1 ';' , Ij ~j 5 . Denial 2 Enter amount from Form 1040, line 37 . . . . . I 2 I 19, (E,o,. Expenses 3 Multiply line 2 by 7.5% (.075) 3 1,475. 4 Subtract line 3 from line 1. If line 3 is more than line 1, enter .0. 4 i::1U. 5 State and local (check only one box): a ~ Income taxes, or J 5 459. Taxes You b General sales taxes (see Instructions) Paid 6 Real estate taxes (see instructions) 6 3,:'1)7. (See 7 Personal property taxes 7 Instructions.) 8 Other taxes. list type and amount . --~-~-------- 8 9 A~~~s0~oo~8-------------------- 9 ~, .::~~: . Interest 10 Home mtg Interest and points reported to you on Form 1098 10 5, 3~' 1 . You Paid 11 Home mortgage interest not reported to you on Form 1098. If paid to the person from whom you bought the home, see instructions and show that person's name, identifying number, and address . (See --~----------------------~----- instructions.) --~~~-------------------------- ------~------------------------ Note. " Personal -------~---------------------~ 12 Points not reported to you on Form 1098. See instrs for spcl rules 12 interest is 13 Investment interest. Attach Form 4952 jf requjred. not deductible. (See instrs.) . 13 14 Add lines 10 through 13 ................ 14 5.32l. Gifts to 15 Gifts by cash or check. If you made any gift of $250 or more, Charily see instructions 15 4CU. If you made 16 Other than by cash or check. If any gift of $250 or a gift and more, see instructions. You must attach Form 8283 if got a benefit over $500 . 16 ~ ~,I:I . for it, see instructions. 17 Carryover from prior year . 17 18 Add lines 15 throunh 17 18 7~)(i . Casualty and Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See instructions.) 19 Job Expenses 20 Unreimbursed employee expenses - job travel, union dues, and Most job education, etc. Attach Form 2106 or 2106-EZ If Other Miscellaneous required. (See instructions.) . Deductions ------~-------- ------------~-------------~---- -------------------~----------- 20 21 Tax preparation fees 21 (See 22 Other expenses - investment, safe deposit box, etc. List instructions.) type and amount . -----------~-------- ------------------------------ 22 23 Add lines 20 through 22 23 24 Enter amount from Form 1040, line 37 I 24 I 25 Multiply line 24 by 2% (02) 25 26 Subtract line 25 from line 23. If line 25 is more than line 23, enter ~o~ 26 Other 27 Other - from list in the instructions. List type and amount . Miscellaneous ------~---------- Deductions ---------------------~---------- -----~_._----- 27 Total 28 Is Form 1040, line 37, over $142,700 (over $71,350 If MFS)? Itemized Deductions [jJ No. =~ Your deduction is not limited. Add the amounts in the far Q4ltt column for lines 4 through 27. Also, enter this amount on Form 1 , line 39. . 28 hi, >,:::7 OVes. Your deduction may be limited. See instructions for the amount to enter. BAA For Paperwork Reduction Act Notice, see Form 1040 instructions. FDIA0301 11102104 Schedule A (Farm 1040) 2004 SCHEDULE EIC (Form 104M or 1040) Derartment ot the Treasury Internal Revenue Service Earned Income Credit QualifYing Child Information Complete and attach to Form 1040A or 1040 only if you have a qualifying chUd OMS No. 1545.0074 2004 43 Name(s) shown on return Lydia D ~'Ihi te Yoursociill security number . -'1-3(-7819 Before you begin: See the instructions for Form 1040A, lines 41a and 41b, or Form 1040, lines 65a and 65b, to make sure that (a) you can take the Ele and (b) you have a qualifying child. . If you take the Ele even though you are not eligible, you may not be allowed to take the credit for up to 10 years. See the instructions for detaIls. CAUTION: . It will take us longer to process your return and issue your refund if you do not filfln alt lines that apply for each qualifying child. . Be sure the child's name on line 1 and social security number (SSN) on line 2 agree with the child's social security card. Otherwise, at the time we process your return, we may reduce or disallow your EIC. If the name or SSN on the child's social security card IS not correct, call the Social Security Administration at 1-800-772-1213. Qualifying Child Information Child 1 Child 2 1 Child's name First name Last name First name Last name If you have more than two qualifying children, you only Bobbv have to list two to net the maximum credit ............ G "lrJhi te II Eri ~: H VThi te 2 Child's SSN The child must have an SSN as defined in the Form 1040A or Form 1040 instructions unless the child was born and died in 2004. If your child was born and died in 2004 and did not have an SSN, enter 'Died' on this line and attach a copy of the child's birth certificate lE 3-E8-:~1 i:I(~ ~;'I):'-7U-4~'F~~! 3 Child's year of birth Year 1CJ87 Year 1'):~ ::: If born after 1985 skip lines 4a If born after 1985, skip lines 4a and 4b; no to fine 5 and 4b; no to line 5 4 If the child was born before 1986 - a Was the child under age 24 at the end of 2004 and DYes. DNa. DYes. DNa. a student? Go to line 5. Continue Go to line 5. Continue bWas the child permanently and totally disabled DYes. DNa. DYes. DNa. during any part of 2004? Continue The child is not a Continue The child is not a qualifying child. qualifying child. 5 Child's relationship to you (for example, ~~n, daughter, grandchild, niece, nephew, Son ;;;i)n foster Child, etc .... . . . . . . . . . . . . .. ..... .. .. ..... 6 Number of months child lived with you in the United States during 2004 0 If the child lived with you for more than half of 2004 but less than 7 months, enter '7'. 0 If the child was born or died in 2004 and your home was the child's home for the entire time he or she was alive dunng 2004, enter '12' . 1':::: months L months Do not enter more than 12 months Do not enter more than 12 months TIP You may also be able to take the additional child tax credit if your child (a) was under age 17 at the end of 2004, (b) is claimed as your dependent on line 6c of Form 1040A.or Form 1040, and (c) is a U.S. citizen or resident alien. For more details, see the Instructions for line 42 of Form 1040A or line 67 of Form 1040. BAA For Paperwork Reduction Act Notice, see Form 1040A or 1040 instructions. Schedule EIC (Form 1040A or 1040) 2004 FDIA7401 11102104 Form 1040 Line 6c Additional Dependents Statement . Attach to return (after all IRS forms) 2004 Statement Name(s) Shown on Return LVdid D Hhite Social Security Number .2.:21-30~7P,1':1 Dependents: (1) (2) (3) (4) First name Last name Dependent's Dependent's ,/ If qualifYing social security relationship child for number to you child tax credit - Andre'\,.j C 1iThite 17:!-7f--75J,3 .'yC>D --'-'-- HattheTd D 1'111i toe 171-78-3::'1~' Son --'-'- - - - - - - - - - - - - - - - - Tax Payments Worksheet ... Keep for your records 2004 Name(s) Shown on Return Lydia. 0 vJhi tp Social Security Number ~-'71-3c,-7~q~1 Estimated Tax Payments for 2004 (If more than 4 payments for any state or locality, see Tax Help) Federal State Local Date Amount Date Amount 10 Date Amount 10 1 (14/15/04 04/15/(14 04/15/i:i4 2 (1(:-/15/(14 0(/15/04 (1(/15/(14 3 09/15/CI4 09/15/04 O~,\/ IS/I_!4 4 ell/ 18/1~15 (11,/ l~j/(lS (ll/1r:/CiS 5 a b c d Total Estimated Payments. Tax Payments Other Than Withholding Federal State 10 Local 10 (If multiple states, see Tax Help) 6 Overpayments applied to 2004 . 1 Credited by estates and trusts 8 Totals Lines 1 through 7 . 9 2004 extensions Taxes Withheld From: Federal State Local 10 Forms W-2 soe) . 31 ::' . 147. 11 Forms W-2G . 12 Forms 1099-R 13 Forms 1 099-MISC and 1099-G . 14 Schedules K-1 15 Forms 1099-INT, DIV and 010 . 16 Social Security and Railroad Benefits. 11 Form 1099-B . St Lac - - 18a Other withholding St - Lac - b Other withholding St Lac - - c Other withholding St Lac - - 19 Total Withholding Lines 10 through 18c . 81)~J . 31 :., . 147. 20 Total Tax Payments for 2004 n (lei. 317, 147_ Prior Year Taxes Paid In 2004 State 10 Local 10 (If multiple states or localities, see Tax Help) 21 Tax paid with 2003 extensions. - 22 2003 estimated tax paid after 12/31/03 - 23 Balance due paid with 2003 return - 24 Other (amended returns, installment payments, etc) Federal Carryover Worksheet ~ Keep for your records 2004 Name(s) Shown on Return Lvdia 0 vJhi te Social Security Number ~"1-3..~-7t:l~1 2003 State and Local Tax Information (See Tax Help) (a) (b) (c) (d) (e) (I) (g) State or Paid With Estimates Pd Total With. Paid With TotalOver- Applied LocallD Extension After 12/31 heldlPmts Return Davment Amount Totals. Other Tax and Income Information 2003 2004 1 Filing status 1 4 HH 4 HH - 2 Number of exemptions for blind or over 65 (0 - 4) 2 3 Itemized deductions after limitation 3 If), 7(3. l(), 3~:~7. 4 Check box if required to Itemize deductions, 4 -----c~ -----0----- 5 Adjusted gross income. 5 7, ~j 3 ~i . l~.', 008. 6 Tax liability for Form 2210 or Form 2210-F . 6 U. I). 7 Alternative minimum tax 7 8 Federal overpayment applied to next year estimated tax 8 IRA Information 2003 2004 ga Basrs of Taxpayer's IRA(s) as of 12/31 . 9a b Basrs of Spouse's IRA(s) as of 12/31 b 10 a Taxpayer's excess IRA contributions as of 12/31 lOa b Spouse's excess IRA contrrbutlons as of 12/31 b 11a Taxpayer's excess Archer MSA contrrbutions as of 12/31 11a b Spouse's excess Archer MSA contributrons as of 12/31 b 12a Taxpayer's excess Roth IRA contrrbutlons as of 12/31 12a b Spouse's excess Roth IRA contrrbutlons as of 12/31 .. b 13a Taxpayer's excess Coverdell ESA contributions as of 12/31 13a b Spouse's excess Coverdell ESA contrrbutlons as of 12/31 b 14a Taxpayer's excess HSA contributions as of 12/31 14a b Spouse's excess HSA contrrbutions as of 12/31 b Loss and Expense Carryovers 2003 2004 15 a Short-term capital loss. 15 a b AMT Short-term capital loss. b 16 a Long-term caprtal loss 16a b AMT Long-term capital loss b 17a Net operating loss available to carry forward 17a b AMT Net operating loss available to carry forward. b 18a Investment interest expense disallowed 18a b AMT Investment interest expense disallowed b 19 Nonrecaptured net Section 1231 losses from: a 2004. 19a b 2003. b c 2002. c d 2001 d e 2000. e f 1999. f Federal Carryov~r Wor!<sheet page 2 2004 Lydia D Vlhite ::1-36-7::'1') Loss and Expense Carryovers (conl'd) 2003 2004 20 AMT Nonrecap'd net Sec 1231 losses from: a 2004. 20a b 2003. b e 2002. e d 2001 d e 2000. e f 1999. f Credit Carryovers 2003 2004 21 General business credit 21 22 Adoption credit from: a 2004. 22a b 2003. b e 2002. e d 2001 d e 2000. e f 1999. f 23 Mortgage Interest credit from: a 2004. 23a b 2003. b e 2002 e d 2001 d 24 Credit for prior year minimum tax 24 25 Dlstnct of Columbia first-time homebuyer credit 25 26 Amount overpaid less earned Income credIt. 26 39.3. Other Carryovers 2003 2004 27 Section 179 expense deduction disallowed 27 28 Excess a Taxpayer (Form 2555, line 44) 28a foreign b Taxpayer (Form 2555, line 46) b housing e Spouse (Form 2555, line 44) e deduction: d Spouse (Form 2555, line 46) d Charitable Contribution Carryovers 29 2003 Carryover of Other Property Capital Gain charitable contributions from: (a) 50% (b) 30% (e) 30% (d) 20% a 2003 b 2002. e 2001. d 2000. e 1999. 30 2004 Carryover of Other Property Capital Gain charitable contributions from: (a) 50% (b) 30% (e) 30% (d) 20% a 2004. b 2003 e 2002 d 2001. e 2000. Lydia D White 221-36-7819 Schedule A Line 16, Noncash Contributions DoneelDescriptlon Amount SALVATION AEH',{ UCP :-'75. (JI.! 55. (1) Total ?, 31). (lll n ~; ,..., .r::'I c:..? <:..,"1 ~ :? r,l :;;.~ S:~ --J -',-'- -.... (,) (..,) . BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE INVENTORY UNDER RULE 1920.33 Defendant, Lydia D. White, files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. She verifies that the statements made in this inventory are true and correct. She understands that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: '1-1- c ,- By: ~. {JL.( Lydia D. White, Defendant ASSETS OF PARTIES DEFENDANT, LYDIA D. WHITE, MARKS ON THE LIST BELOW THOSE ITEMS APPLICABLE TO THE CASE AT BAR AND ITEMIZES THE ASSETS ON THE FOLLOWING PAGES. (X) 1- Real Property (X) 2. Motor Vehicles (X) 3. Stocks, bonds, securities and options ( ) 4. Certificates of Deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit box( s) ( ) 8. Trusts (X) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) II. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation ( ) 17. (X) 18. (X) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (X) 24. (X) 25. ( ) 26. claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryiV.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) Other WHITEv. WHITE Date of Marriage - September 26,1981 Date of Separation - January 12, 2003 (22 years) MARITAL ASSETS Assets Wife's Husband's Master's Notes Value Value Value Real Estate Marital Home TBD First Mortgage exists on 701 Hilltop Drive residence through Members New Cumberland, P A First Federal Credit Union. Balance ofloan was $54,163.59 as of October 25, 2005. Home Equity Loan (Account No. 066429) exists on residence through NCFCU. Balance of loan was $16,441.84 as of September 2005. Retirement Assets CSRS Retirement account Require this information (Husband) TBD from Plaintiff. Wilmington Trust Retirement $1,121.81 No contributions made to plan Money Market Account since date of separation. Account No. 956-7033-245 (Wife) Value of account as of September 2005. Wilmington Trust Roth IRA $0.00 Husband closed out account Account No. 0956-7034 2004: $4,454.89. (Husband) Cash and Investment Assets Wilmington Trust Brokerage $6,991.92 Value of account as of Account September 2005. Account No. 009-680176 (Wife) NCFCU Savings Account $51.64 Value of account as of Account No. 066429 September 2005. (loint) NCFCU Checking Account $27.32 Value of account as of Account No. 066429 September 2005. (Joint) NCFCU Savings Account $50.51 Value of account as of Account No. 071193 September 2005. (Wife) NCFCU Checking Account $59.92 Value of account as of Account No. 071193 September 2005. (Wife) Citizens Bank Checking Account Nominal Defendant rarely carries a Account No. 620501-760-5 significant balance in this (Wife) account. Citizens Bank Savings Account $34.99 Account Statement as of Account No. 6246-656825 September 2005. (Wife) Members First Accounts $1,355.75 Statement date 10/05. (Joint) Savings: $133.00. Escrow: $1,122.75. Holiday Club: $100.00. Checking: $0.00. Shares of stock $839.51 Account statement as of Coca-Cola Company October 2005. Shares held: (Joint) 19.5053. Shares of stock $355.18 i Account statement as of ConAgra Foods September 2005. Shares held: (Wife) 15.409. Shares ofEPB Associates Approx: 80 shares owned by Wife in (Wife) $15,000.00 parent's business Giant Food Stores/Martins Food Total Account value as of October Markets shares of stock Account 2005. (Wife) Value: Wife participates in stock $2,711.59 purchase plan through her employer. She contributes approximately $15.00 per week from her paycheck toward this plan. Total Shares Held: 362.02827 Contributions made to plan since DOS: $2,055.00 Shares purchased since DOS: 278.55027 Wife sold 200.00 shares on 10/24/2005 to pay Marital Residence real estate taxes. Life Insurance Policy Prudential Life Insurance Policy Husband closed out policy and No. 73-389-416 $0.00 received funds, December 20, (Husband) 2004. Received $8,475.82. Prudential Life Insurance Policy $0.00 Husband closed out policy and No. 63-013-629 received funds, December 20, (Wife) 2004. Received $3,915.40. Prudential Life Insurance Policy $7,029.08 Net cash surrender value for No. 73-389-434 policy as of October 2005. (Wife) Miscellaneous/Automobiles IRS Refunds (for 2002 and 2003) $9,626.00 Husband: $2,087.00 (2002) Wife: $4,000.00 (2002) $3,539.00 (2003) Household Goods and Furnishings Nominal. 1998 Chevrolet Suburban 1500 $8,000.00 Husband traded in this vehicle Sport Utility vehicle (T rade- in to purchase another. (Joint) value received) 1998 Ford Club Van TBD Wife uses this vehicle. (J oint) DEBTS: Kohls $771.86 Balance as oD/03: $800.00. Charge Card Balance as of 9/05: $771.86 Home Depot $2,565.30 Balance as on/03: $800.00 Charge Card Balance as of 8/05: $2,565.30 Bank of America TBD This credit card was Credit Card established for work travel and (Husband) work expenses and was satisfied through travel vouchers submitted by and received by Husband Need account info from Plaintiff. Cingular TBD Need account info from (Husband) Plaintiff. MBNA America (LL BEAN) $9,041.31 Balance as of 8/05 VISA Credit Card (Wife) Balance as of 4/03: $11,987.93. Wife has maintained this account since DOS. Chase (Toys R Us) $14,129.36 Balance as of 8/05 VISA Credit Card (Wife) Balance as of 4/03: $9,427.68. Wife has maintained this account since DOS. Wilmington Trust Company TBD Husband states that he liquidated his Roth IRA account to satisfy this debt. Need account info. from Plaintiff. Personal loan to Wife's parents $10,000.00 Parties borrowed money from Wife's parents to purchase the 1998 Ford Club van. Members 1st Feder~l Credit Union Online - My Accounts - View Account Detail;; Page I of 1 You may sort your account register by date, ID. or amount by clicking on the appropriate column heading. Account: FIRST MORTGAGE/03 Current Balance Available Balance Year to Date Interest Payoff Amount 10/25/2005 10/25/2005 10/25/2005 10/25/2005 $54,163.59 $0.00 $3,228.56 $54,255.41 Interest Rate Prior Year Interest Next Payment Date Next Payment Amount 6.875 $4,020.67 02(01/2006 $723.74 Credit Date and ID Description Principal Paid Interest Paid Total Amount Paid Balance 10/16/2005 Payment - From Share 00 $415.59 $308.41 $724.00 $54,163.59 https.l/online.membersl st. org/servlet/tpservletOtransactiontype=accountDetailsActionBea.. 10/25/2005 H:nu 1Il4Ulne~ 10; STATEMENT OF ACCOUNT o NCFCU 0 1 NEW CUMBERLAND FEDERAL CREDIT UNION P.O. BOX 658 . NEW CUMBERLAND, PA 17070 (717) 774-7706. ] (800) 716-2328 VISA-RATES AS LOW AS 6.90% NO ANNUAL OR TRANSACTION FEE NO CASH ADVANCE FEE NO BALANCE TRANSFER FEE 25 DAY GRACE PERIOD Joint Owners CCOUNT NUMBE 066429 1",111",111",1",111"""111",1"1,1,,11,11,,,,,,11,"III BOBBY G WHITE, JR. LYDIA WHITE 701 HILLTOP DRIVE NEW CUMBERLAND PA 17070-1723 STATEMENT PERIOD From To A~~~TION EF~~~~IVE DESCRIPTION AMOUNT FINANCE CHARGE 0901 PREVIOUS BALANCE SI-PRIMARY SHARES 5161 0930 DIVIDEND 0 51 4 TH ANNUAL PERCENTAGE YIELD EARNED IS 0 71. 0930 NEW BALANCE DIVIDEND IS CALCULATE 51 4 USING A DAILY BALANCE METHOD. 0901 PREVIOUS BALANCE 54-SHARE DRAFTS 27 2 0930 NEW BALANCE 27 2 0901 PREVIOUS BALANCE L2 HOME EQUITY LOC 1692610 0901 PAYROLL DEDUCTION 004 -16 0 3 1676505 0915 PAYROLL DEDUCTION 004 -16 4 3 16603 3 0929 PAYROLL DEDUCTION 004 -16 7 3 16441 4 0930 NEW BALANCE-PERIODIC RATE.016438% RATE IS VARI 16441 4 >> ANNUAL PERCENTAGE RATE 6.000% << TOTAL DIVIDEND YEAR-TO-DATE 0 .27 TOTAL FINANCE CHARGE YEAR-TO-DATE for all savings except IRA savings. for all loans. Dividends shown, if over $10, will be reported to the Internal Revenue Service for this NOTICE: See reverse side for important information, calendar year. ..'.'.....',-.A..-!::C' !::t::t::crTI\/C r'l.o.Tc 833.81 0801217 ;tatement WILMINGTON TRUST RETIREMENT ACCOUNT: 0956-7033 OATE THIS STATEMENT DATE LAST STATEMENT STMT REF' 000005139 09/30/05 08/31/05 PAGE 1 LYOIA WHITE 701 HILLTOP OR NEW CUMBERLANO PA 17070 IF YOU ATTAINEO AGE 70 1/2 OURING 2005 YOU HAVE UNTIL APRIL 1. 2006 TO RECEIVE YOUR IRS MINIMUM DISTRIBUTIDN. IF YOU HAVE ANY QUESTIONS. PLEASE CDNTACT US AT 1-800-215-4960. THE PLAN SUMMARY SECTION BELOW IS FOR INFORMATIONAL PURPOSES ONLY AND INCLUOES ASSETS HELD AT DIFFERENT ENTITIES. YOUR WILMINGTON BROKERAGE SERVICES COMPANY (WBSC) ACCOUNT IS CARRIEO BY NATIONAL FINANCIAL SERVICES CORPORATION. A MEMBER OF THE NYSE AND SIPC. WBSC. A MEMBER OF THE SIPC. IS A WHOLLY OWNED SUBSIDIARY OF WILMINGTON TRUST COMPANY. QUESTIONS RELATEO TO YOUR WBSC ACCOUNT MAY BE OIRECTEO TO 302-651-1011. WILMINGTON TRUST FSB. WILMINGTON TRUST OF PENNSYLVANIA AND WILMINGTON TRUST COMPANY ARE BANKS. MEMBERS OF THE FOIC ANO OWNEO BY WILMINGTON TRUST CORPORATION. R E T IRE MEN T P LAN SUM MAR Y ----------------------------------------------------------------- ----------------------------------------------------------------- RETIREMENT PLAN 09567033IRA RTH MONEY MARKET RETIREMENT ACCOUNT WILMINGTON BROKERAGE ACCOUNT 009-680176 TOTAL VALUE 1,121.81 6.991.92 8,113.73 ----------------------------------------------------------------- ----------------------------------------------------------------- M 0 N E Y MAR K E T R E T IRE MEN T A C C 0 U N T (THIS ACCOUNT IS HELD BY WILMINGTON TRUST COMPANY. WHICH IS A MEMBER OF THE FDIC) 0956-7033-245 ISSUE DATE 04/15/99 OATE DESCRIPTION 08/31 PREVIOUS BALANCE 09/15 INTEREST EARNED 09/30 CURRENT BALANCE 09/30 INTEREST EARNED 09/30 CURRENT VALUE INTEREST PAlO THIS PERIOD INTEREST EARNED THIS PERIOD DAYS IN PERIOD ANNUAL PERCENTAGE YIELD EARNED DEBITS CREDITS BALANCE 0.71 1,12D.75 1,121.46 1.121.46 0.35 1,121.81 .71 .69 30 0.75% ---------------------------------------------------------------- >tatement WILMINGTON TRUST RETIRE~NT ACCOUNT: 0956-7033 DATE THIS STATEMENT DATE LAST STATEMENT STMT REF' 000005139 09/30/05 08/31/05 PAGE 2 YEAR-TO-OATE CONTRIBUTION FOR TAX YEAR 2005 0.00 ____________________________________________________.._________w.___________________________ ------------------------------------------------------------------------------------------ W I L M I N G TON B R 0 K ERA G E A C C 0 U N T (THIS ACCOUNT IS CARRIED BY NATIONAL FINANCIAL SERVICES CORPORATION. A MEMBER OF THE NYSE AND SIPC. WBSC IS ALSO A MEMBER OF SIPC.) FINANCIAL SUMMARY OPENING NET MONEY BALANCE CLOSING NET MONEY BALANCE TOTAL MARKET VALUE SEP 30 EQUITY SEP 30 0.00 0.00 6,991.92 6,991.92 DESCRIPTION INCOME/INTEREST THIS PERIOD TAX DEFERRED DIVIDENDS 13.18 YEAR TO DATE 161. 70 DATE TRANSACTION REGULAR ACCOUNT ACTIVITY QUANTITY DESCRIPTION AMOUNT 09/13 DIVIDEND RECEIVED LIMITED BRANDS INC 11.68 0.00000 09/13 REINVESTMENT LIMITED BRANDS INC REINVEST 0.55300 a 21.1282 TRADE DATE 09-08-05 TIME WARNER INC 11 .68- 09/15 DIVIDEND RECEIVED 1. 50 0.00000 09/15 REINVESTMENT TIME WARNER INC REINVEST 0.08200 a 18.2074 TRADE DATE 09-12-05 1. 50- ;tatement WILMINGTON TRUST RETIREMENT ACCOUNT: ACCT TYPE CASH QUANTITY 1,000.00000 CASH 40.00000 CASH 100.00000 CASH 78.39000 CASH 10.66700 CASH 44.51800 CASH 341.16900 CASH 30.08200 '" 0956-7033 DATE THIS STATEMENT DATE LAST STATEMENT STMT REF I 000005139 POSITIONS IN YOUR ACCOUNT SYMBOVCUSIP SECURITY DESCRIPTION BOSTQ BOSTON CHICKEN INC NO STOCKHOLDER EQ OS/26/00 Dividend Option Reinvest Capital Gain Option Reinvest EMC E M C CORP MASS Dividend Option Reinvest Capital Gain Option Reinvest 46261Yl02 IPET HLDGS INC NIC FROM 71676K109 Dividend Option Reinvest Capital Gain Option Reinvest LTD LIMITED BRANDS INC Estimated Yield 2.93Y. Dividend Option Reinvest Capital Gain Option Reinvest MCD MCDONALDS CORP Estimated Yield 2.00Y. Dividend Option Reinvest Capital Gain Option Reinvest Next Dividend Payable' 12/01/05 PG PROCTER & GAMBLE CO Estimated Yield 1.88Y. Dividend Option Reinvest Capital Gain Option Reinvest RAD RITE AID CORP Dividend Option Reinvest Capital Gain Option Reinvest TWX TIME WARNER INC N/C FROM 09/30/05 08/31/05 PAGE 3 MARKET VALUE ON SEP 30 PER SHARE TOTAL UNAVAIlAlllE 12.94000 UNAVAlLABL E 20.43000 33.49000 59.46000 3.88000 18.11000 517.60 1,601.51 357.24 2,647. 04 1,323.74 544.79 ;tatement WILMINGTON TRUST RETIREMENT ACCOUNT: 0956-7033 DATE THIS STATEMENT DATE LAST STATEMENT STMT REFt 000005139 09/30/05 08/31/05 PAGE 4 00184AI05 Estimated Yield 1.10y. Dividend Option Reinvest Capital Gain Option Reinvest TOTAL MARKET VALUE ON SEP 30 6,991.92 II:;:IIU IIlyUIIII;l~ IV. ::; IAII:MI:N I UI- Al,;l,;UUN I NCFCU 1 NEW CUMBERLAND FEDERAL CREDIT UNION P,O, BOX 658 . NEW CUMBERLAND, PA 17070 (717) 774-7706 . ] (800) 716-2328 VISA-RATES AS LOW AS 6.90% NO ANNUAL OR TRANSACTION FEE NO CASH ADVANCE FEE NO BALANCE TRANSFER FEE 25 DAY GRACE PERIOD Joint Owners CCOUNT NUMBE 071193 1.,.111",111",1",111"""111,.,1"1,1,,11,11.,,,,,11",111 LYDIA D WHITE 701 HILLTOP DRIVE NEW CUMBERLAND PA 17070-1723 STATEMENT PERIOD From To ANSACTION EFFECTIVE DESCRIPTION AMOUNT DATE DATE 0 FINANCE CHARGE 0901 0930 PREVIOUS BALANCE SI-PRIMARY SHARES DIVIDEND TH ANNUAL PERCENTAGE YIELD EARNED IS 0 73. NEW BALANCE DIVIDEND IS CALCULATE USING A DAILY BALANCE METHOD. o 5048 5051 0930 5051 0901 0930 PREVIOUS BALANCE S4-SHARE DRAFTS NEW BALANCE 5992 599 TOTAL DIVIDEND YEAR-TO-DATE for all savings except IRA savings. Dividends shown, if over $10, wilf be reported to the Internal Revenue Service for this calendar year. ~,. ,'""',...... ".....,....... ~CCCf"'TI\ft:: !'"lilT>=: o . 27 TOTAL FINANCE CHARGE YEAR-TO-DATE for all loans. 0.00 NOTICE: See reverse side for important information, DBOle:lB ~" COt. B k ,.~ LJZenS an 1-888-910-4100 CaLL Citizens' PhoneBank anytime foraccount information, current rates and answers to yourquestiom. US259 BR294 L Y D I A D WH I TE 701 HILLTOP DR NEW CUMBERLAND Checking 10 1 Account Statement . OF 4 Beginning August 05, 2005 throug h September 07, 2005 Contents Checking Page 1 Savings Page 3 Check Images Page 4 PA 17070 SUMMARY Balance Calculation Previous Balance Checks Withdrawals Deposits & Additions Current Balance 3.05 333.22 6BO.94 933.11 + -78.00 ~ LYDIA 0 WHITE Green Checking 620501-760-5 Previous Balance TRANSACTION DETAILS Checks" 7here is a break in check sequrmce Check # Amount Date 196 50.00 OB/29 239' 75.22 OB/OB 243' 25.00 OB/OB 244 25.00 OB/30 245 25.00 08/30 Withdrawals ATM/Purchases Date OB/OB OB/I0 08/12 08/12 08/15 08/15 08/22 OB/22 OB/22 OB/22 OB/22 08/22 OB/22 08/23 OB/23 OB/23 08/26 08/26 08/26 08/26 OB/29 08/29 08/30 "";',,1,'-,,,..'-[" C (21::;,;,..11 Amount 10.45 34.32 17.97 5.72 48.79 28.44 20.00 57.4B 35.00 34.47 16.23 13.01 3.94 29.45 16.02 5.96 35.00 4.99 4.4B 3.59 55.29 6.18 1.00 Check # 246 247 248 249 250 Amount 25.00 15.00 15.00 39.00 39.00 Description Point Of Sale Debit - 007571 Hepfer's True Lemoyne PA Point Of Sale Debit - 241886 Wal-Mart #1886 Mechanicsb Ur PA Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa MMC Purchase - 0082 Giant Food Stores Mechanicsb Urgpa MMC Purchase - 999999 Hess 38419 Lemoyne PA Point Of Sale Debit - 174100 Wal-Mart Super Milford DE ATM Withdrawal - Ml6291 Giant Mechanicsburg, Mechanicsbur PA MMC Purchase - 999999 Hoss's Steak & Seamechanicsb Urgpa Point Of Sale Debit - 308035 Giant Food Sto New Cumber lA PA Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 725722 Gnc 7282 Mechanicsb Urgpa Point Of Sale Debit - 308035 Giant Food Sto New Cumoer LA PA Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa MMC Purchase. 999999 Charlotte Russe #2camp Hill PA Point Of Sale Debit. 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Oebit - 000000 Giant Food Sto Mechanicsb Urgpa Point Of Sale Debit - 000000 Giant Food Sto New Cumber Lanpa Point Of Sale Debit - 021316 CVS 1630 New Cumber Lanpa ATM Mini-Statement Fee Ml6291 02356 255 Cumberia Mechanicsbur PA Date 09/06 08/24 08/23 09/07 09/07 3.05 o Total Checks 333.22 ~~ Citizens Bank 1-888-910-4100 Call Citizens'PhoneBank anytime for account information, c:urrent rates and amwers to your questions. Checking continued from previous page Account Statement . OF 4 Beginning August 05, 2005 through September 07, 2005 ATM/Purchases (continued) Date Amount Description 09/02 48,93 Point Of Sale Debit - 241591 Wal-Mart #1591 Harrisburg PA 09/06 50.94 MMC Purchase - 999999 Hess 38419 Lemoyne PA 09/06 30.38 MMC Purchase - 01 Amoco Oil 0695shiremanst Ownpa 09/06 22.80 Point Of Sale Debit - 000000 Giant Food Sto New Cumber Lanpa 09/06 21. 3B MMC Purchase - 999999 Weis Markets #125 Camp Hill PA 09/06 11.45 MMC Purchase - 01 Amoco Oil 0695shiremanst Ownpa 09/06 7.28 MMC Purchase - 999999 CVS Pharmacy #1630camp Hill PA Deposits & Additions Date Amount 08/05 08/05 08/12 08/19 08/22 08/23 08/24 08/26 08/29 08/30 09/02 09/06 136.10 60.00 81.22 100.28 100.00 11.82 15.00 75.52 84.01 59.00 141. 44 68.72 Description Giant .Food Store Payrll Dep 050730 DepoSlt Giant Food Store Payrll Dep 050806 Giant Food Store Payrll Dep 050813 ATM Transfer From 6246656825 Ml6291 Giant Mechanicsburg, Mechanicsbur PA Transfer From 6246656825 Transfer From 6246656825 Giant Food Store Payrll Dep 050820 Transfer From 6246656825 Transfer From 6246656825 Giant Food Store Payrll Dep 050827 Transfer From 6246656825 Daily Balance Date Balance Date Balance Date 08/05 199.15 08/19 134.74 08/29 08/08 88.48 08/22 54.61 08/30 08/10 54.16 08/23 .00 09/02 08/12 111. 69 08/24 .00 09/06 08/15 34.46 08/26 27.46 09/07 ,'kl~l!'.:'Y @::'1:.:'" 1 ",.,'!.o Balance .00 8.00 100.51 .00 -78.00 LYDIA D WHITE Green Checking 620501-760-5 e Total Withdrawals 680.94 o o Total Deposits & Additions 933.11 CurrentSa!ance -78.00 ~~ Citizens Bank 1-888-910-4100 Call Citizens' Phone9ank anytime for account information, current rates and answers to your questions. Account Statement o OF 4 Beginning August 05, 2005 through September 07, 2005 Savings SUMMARY Balance Calculation Previous Balance Withdrawals Deposits & Additions Interest Paid Current Balance 93.49 358.55 300.00 + .05 + 34.99 = Balance Average Daily Balance Interest (urrent Interest Rate Annual Percentage Yield Earned Number of Days Interest Earned Interest Earned Interest Paid this Year 219.29 .25% .25% J4 .05 1.26 LYDIA 0 WHITE Basic Savings 6246-656825 Previous Balance DETAIlS 93.49 TRANSACTION Withdrawals ATM/Purchases Date Amount 08/22 100.00 08/29 20.00 Other WithdrawaLs Date Amount 08/23 08/24 08/29 08/30 09/06 11.82 15.00 84.01 59.00 68.72 Description ATM Transfer To 6205017605 Ml6291 Giant Mechanicsburg, Mechanicsbur PA ATM Withdrawal - Ml6291 Glant Mechanicsburg, Mechanicsbur PA Description Scheduled Transfer Scheduled Transfer Scheduled Transfer Scheduled Transfer Scheduled Transfer Deposits & Additions Date Amount Description 08/12 300.00 Deposit Interest Date Amount DesCription .05 Interest 09/07 Daily Balance Date 08/12 08/22 08/23 ;.I,.""!,, rF;::-t?:tr.(',.,' b.I',"",.;1 Balance Date 393.49 293.49 281. 67 08/24 08/29 08/30 Balance 266.67 162.66 103.66 Date 09/06 09/07 Balance 34.94 34.99 o Total Withdrawals 358.55 o Total Deposits 8. Additions 300.00 o <:) Total Interest Paid .05 Current Balance 34.99 Members 1st Fede!-a! Credit Union Online - Accounts Home Page I of 1 .. ,1st MEMBERS t~t I ~ ONLINE .;,~: '.ll~ ,- - - ",,;.;cdli,- . 'IIlI!J''' ~ ..../V'A.C:cn..;::; . .:' H:. Good Evening BOBBY WHITE You have 1 unread message from Members 1st Federal Credit Union, Click on a message to read it. To remove a message, click Delete. \ /1\'" /':, '.....'-.r-., r't.... .... .. r ,t,. ,I.. ,~ " . :::J Click on an Account to see details about it. PJ-:I-- b; / / due ii/I _ 5DI d 7.-VD ~W1 i'~At-" / L -Iv h;/f P"'i. LAcJuI-") -10/25/2005 (f,,,,;-;"~' c/v6 - 10/25/2005 /?, _ 10/25/2005 v> C r6V ~ _ 10/25/2005 S.4--t//:'}) $0.00 $100.00 $1,122.75 $133_00 10/25/2005 $54.163.59 Savings federally insured by NCUA. Equal Opportunity Lender. https.//online.membersl st .org/servlet/tpservlet?transactiontype=my AccountsActionBean 10/15/1005 Members 1st Fedel'al Credit Union Online - My Accounts - View Account Details Page 1 of 2 You may sort your account register by date, ID, or amount by clicking on the appropriate column heading. Account: CHECKING/ll Current Balance Available Balance Amount of Last Deposit Year to Date Interest 10/25/2005 10/25/2005 10/24/2005 10/25/2005 $0.00 $0.00 $261.82 $0.00 Rate Prior Year Interest 0.000 $0.00 10/24/2005 ACH Transfer - CHASE lYPE: AUTO PAY ID: -$353.00 1760039224 10/24/2005 Deposit - From Share 00 $261.82 $353.00 10/21/2005 Draft -$44.45 $91.18 10/21/2005 Draft -$34.64 $135.63 10/20/2005 Draft -$25.12 $170.27 10/20/2005 Draft -$22.00 $195.39 10/20/2005 Draft -$22.00 $217.39 10/20/2005 ACH Transfer - VERIZON lYPE: -$60.61 $239.39 PaymentREC ID: 9783397101 10/19/2005 Transfer From 5hare 00 $300.00 $300.00 10/18/2005 Draft -$360.00 10/18/2005 Deposit - From 5hare 00 $360.00 $360.00 10/17/2005 Draft -$230.00 10/17/2005 Draft -$160.00 $230.00 10/17/2005 Draft -$38.00 $390.00 10/17/2005 Draft -$31.00 $428.00 10/17/2005 Draft -$18.05 $459.00 10/17/2005 Deposit - From Share 00 $459.01 $477 .05 10/17/2005 Draft -$15.86 $18.04 10/17/2005 ACH Transfer - TWX*AOL SERVICE lYPE: -$28.90 $33.90 1005ID: 0000067819 10/17/2005 Draft Processed Check - HOME -$10.00 $62.80 DEPOT/EXPO 10/14/2005 Draft -$212.33 $72.80 10/14/2005 Draft -$154.00 $285.13 10/14/2005 Draft -$87.00 $439.13 10/14/2005 Draft -$28.36 $526.13 10/14/2005 Draft -$21.12 $554.49 10/14/2005 Draft -$15.00 $575.61 10/13/2005 Draft -$28.55 $590.61 https.//online.membersl st. org/servlet/tpservlet"transactiontype=accountDetaiJ sActionBea. 10/25/2005 Members 1st Feder~l Credit Union Online - My Accounts - View Account Details 10/12/2005 10/11/2005 10/11/2005 10/11/2005 10/11/2005 10/06/2005 10/06/2005 10/06/2005 10/06/2005 10/06/2005 10/05/2005 10/03/2005 10/01/2005 09/28/2005 09/28/2005 09/28/2005 09/27/2005 09/27/2005 Draft Draft Draft Draft Draft Draft Draft Draft Draft Draft Draft Draft Transfer From Share 00 Draft Draft Deposit by Cash Draft Draft -$14.10 -$81. 70 -$34.00 -$20.00 -$15.00 -$100.00 -$58.20 -$46.14 -$39.16 -$20.00 -$300.00 -$20.00 $1,200.00 -$125.45 -$25.00 $70.00 -$14.43 -$11.66 Savings federally insured by NCUA. Page:2 of:2 $619.16 $633.26 $714.96 $748.96 $768.96 $783.96 $883.96 $942.16 $988.30 $1,027.46 $1,047.46 $1,347.46 $1,367.46 $167.46 $292.91 $317.91 $247.91 $262.34 Equal Opportunity Lender. https//onlinememberslst .org/ servfet/tpservlet?transactiontype=accollntDetailsActionBea. 10/25/2005 Members I st Federal Credit Union Online - My Accounts - View Account Detail.s Page 1 of 1 You may sort your account register by date, !D. or amount by clicking on the appropriate column heading. Account: REGULAR SAVINGS/OO Current Balance Available Balance Amount of last Deposit Year to Date Interest 10/25/2005 10/25/2005 10/07/2005 10/25/2005 $133.00 $108.00 $2,571.00 $5.59 Rate Prior Year Interest 0.000 $8.15 10/24/2005 Withdrawal - To Share 11 -$261.82 $133.00 10/19/2005 Members 1st Online Transfer To Share 11 -$300.00 $394.82 10/18/2005 Withdrawal - To Share 11 -$360.00 $694.82 10/17/2005 Withdrawal - To Share 11 -$459.01 $1,054.82 10/16/2005 Withdrawal - To Loan 03 -$724.00 $1,513.83 10/16/2005 Withdrawal - To Share 05 -$300.00 $2,237.83 10/16/2005 Withdrawal - To Share 02 -$100.00 $2,537.83 10/13/2005 Check Received 646.48 Advice $0.00 ***** 10/13/2005 Check Received 12.96 Advice $0.00 ***** 10/13/2005 Check Received 10.00 Advice $0.00 ***** 10/13/2005 3 Checks Cashed for 669.44 Advice $0.00 ***** 10/07/2005 ACH Transfer - PA-SCDU TYPE: CHLD SUPPT $2.571.00 $2,637.83 ID: 1236003113 10/01/2005 Members 1st Online Transfer To Share 11 -$1,200.00 $66.83 10/01/2005 Deposit - From Share 02 $1.207.12 $1,266.83 09/30/2005 1.000% %% APY Earned 1.00% 09/01/05 to $0.53 $59.71 09/30/05 09/28/2005 ACH Transfer - PAWC -$85.82 $59.18 Savings federally insured by NeVA. Equal Opportunity Lender. https//onlinemembers I storg/servlet/tpservlet"traJJsactioJJtype=accouJJtDetaiJsActi oJJBea.. ] 0/25/2005 , Y/I;. (i@~ btYltj1ll1lf' STATEMENT OF HOlDINGS October 4, 2005 c/o EQUISEP,VE TRUST COMPANY, N.A. PO BOX 43023 PROVIDENCE, RI 02940-3023 To access and manage your account, you can contact us : iii! W;ii;,~7~i~:ei;~I:~"i. -I'll iiii ~.r.~'~i\oi';':'~ij 1\i'.f'li Iii aiii ;,1 ~..l.:r':i: c r.~~~tl,O::-i 'I'~i.iii iii By Internet: www.computershare.comJequiserve Internet Password 93378267 By Telephone: 800.265-3747 Telephone Password 93378267 By Mail: The Coca. Cola Company clo EQUISERVE TRUST COMPANY, NA PO BOX 43023 PROVIDENCE, RI 02940-3023 SAVETHIS STATEMENT FOR YOUR FINANCIAL RECORDS CMO~ <lOlU DM.l.~.I.Dl.lC'."D I~04l1 "lIUt , ~ 12_"___ IlVCotztM.n4!l~.OOO'.4UU6 nJn41nn"~U1 HMD~P XMIT 101 BOBBY G WHITE & LYDIA 0 WHITE JT TEN 701 HILL TOP DR NEW CUMBERLND, PA 17070-1723 The Coca-Cola Company Dividend Reinvestment Information Account Number 51965634 Cuslp Ticker Issue ID Security Plan 10 Number Exchange Symbol Dividend Option: coe eM COMMON DRPOQOl 191216100 NYSE KO Fun reinvest on an shares Record Payable Record Data Dividend Gross Tax Dividend Paid By Net Dollars Issue 10 Date Date Shares Rate Dividend Withheld Other Methods Reinvested Coc eM 09/15/2005 10/0112005 19.9800 0.280000 $5.49 10.00 10.00 $5.49 Account Activity Activity As Of Date: 10/04/2005 Gross Fee Amount Deducted Date Transaction Description 12131/2004 Balance forward 04/01/2005 Share purchase Dividgnd Purchas9 07/01/2005 Share purchase Dividend Purchase 10/0312005 Share purchase DivIdend Purchase $5.95 $5.99 $5.49 Net Price Per Fair Market Plan Transaction Plan Shares Dollars Share Value/Share Shares Held by Agent 18.1244 0.1287 18.2591 $5.95 $41.5826 0.1269 18.3800 $5.99 142.4750 0.1259 18.5059 15.49 $49.9510 Continued... The Coca-Cola Company CASH INVESTMENT TRANSACTION FORM l$sue 10: COCCM Account Number: 51965634 Plan 10: DRP0001 Amount Enclosed BOBBY G WHITE & LYDIA 0 WHITE JT TEN CASH INVESTMENTS ONLY: Make check payable to Computershare (amount enclosed in U.S. dollars drawn on a U.S. bank). Do hol send easn, Ihird party checks or money orders. h ,. Minimum: ,. ;~, ~ ." c . ; $10.00 Maximum: $125,000.00 IMPORTANT - ALL CASH INVESTMENTS MUST BE MAILED TO THIS ADDRESS. Do not send certificales or olher correspondence to this addle~s. '- ;- Computershare P.O. BOX 219350 KANSAS CITY, MO 64121-9350 1111111111111111111111 Iml 1111 1111 129280COCCMDRP000100051965634700001000125000001 --, J7(; @st!:t!J ~illfJtZllf era EQUISERVE TRUST COMPANY, NA PO BOX 43023 PAOvtDENCE, Rl 02940-3023 BOBBY G WHITE & LYDIA D WHITE ..IT TEN STATEMENT OF HOLDIN.GS October 4, 2005 To access and manage your account, you can contact us : By Internet: www.computershare.com/equiserve Internet Password 93378267 By Telephone: 800-265-3747 Telephone Password 93378267 By Mail: The Coca-Cola Company c/o EQUISERVE TRUST COMPANY, N.A. PO SOX 43023 PROVIDENCE, RI 02940-3023 SAVE THIS STATEMENT FOR YOUR FINANCIAL RECORDS The Coca-Cola Company cac CM - Total Holdings and Market Value Security COMMON Shares Held by You 1.0000 Non Plan Shares Held 0.0000 Shares Held: DRPOOOI 18.5053 Total Shares 19.5053 IIIIIIIIIIIIIWIIIIII~IIIIIIIIIII Markel Price Markel Value $43.0400 $839.51 Account Number 51965634 cac CM - Year-lo-Date Summary for 2005 Gross Dividends $18.17 Total Tax Withheld $0.00 Reportable Company Paid Commissions $0.00 Reportable Market Value Income $0.00 tM~~ ~Qgn DIol,I-!.40Z.ltI.ND ~~Q'U unH 2 2..12....__ H\ltOt:~tM..D4!~.PPQ\.4nU1 !l1n4'U291lllil1 nl.lDp., l<MIT 101 . ConAgrn Foods@ SHAREHOLDER SERVICE PLAN Dividend Reinvestment Plan Account Statement ~,"""""."~."'.~""" . . '.." ,. ~ " '.',','" . , ..'" . . ~: ..... .. ~ . . .. . . '.' Questions: u.s. telephone number: 800-214-0349 Outside US.: 651-450.4064 For frequently asked questions, please visit www.wellsfargo.com/shareownerservices Fax number for transaction requests: 651-450.4085 Cusip # 205887102 Account Summary Page 1 of1 I. VOlA WHITE 701 HII.L TOP DR NEW CUMBERI.ND PA 17070.1723 Current Dividend Record Date Payable Date Dividend Rate Account Value Market Value Date Market Value Price Account Market Value e Year.to-Date Activity Transaction or Settlement Date Transaction Type ORWARD Div Reinvested Div Reinvested Div Reinvested 08/01/05 09/01/05 $0.2725 09/01/05 $23.05 $355.18 GrOS8 Amount of Transaction ConAgra Foods, Inc. Account # 4001131495 September 2, 2005 Record Date Current 5.229 5.409 10.000 10.000 0.000 0.000 15.229 15.409 Share Balances Div Reinvestment Plan Certincate(s) Direct Registration Total Shares Year.to.Date Amounts Gross Dividends Reinvested Federal Tax Withheld Nonresident Alien Tax Withheld Cash Investments Service Charges Paid by You Service Charges Paid by Company Commissions Paid by You Commissions Paid by Company Service Charge Net Amount of Transaction Price Shar.8 Increased per Share or Decreased $27.8590 $26.2600 $23.0788 $12.33 $0.00 $0.00 $0.00 $0.00 $2.85 $0.00 $0.01 ) Total Share8 Held In Plan 4.926 5.072 5.229 5.409 ConAgra Foods, Inc. IS participating in the Direct Registration System ("DRS"). You may choose to have your Plan and/or DRS shares electronically delivered to or from your shareowner account. For information concerning authorization of electronic share movement, please contact your Broker/Dealer. - - - - - - - - - - - - - - - Detach here. Forward bottom portion fa the address shown below. $0.00 $0.00 $0.00 Transaction Request ConAgra Foods, Inc. Account # 4001131495 Mail to: Shareowner Services ConAgra Foods. Inc. C001 Dividend Reinvestment Plan PO Box 64856 Sl Paul MN 55164-0856 D Please change my address as indicated. LYDIA WHITE 701 HILLTOP DR NEW CUMBERLND PA 17070.1723 1111/11 !II~ !Im !IIII )1111 !~I~ mil !II~ !llmjllll ~lllm OPTIONAl. CASH PURCHASE ELECTION D Enclosed is a check made payable to Shareowner Services for: $ I Minimum $50.00 / Maximum$50,OOO.OO peryear Next deadline for Shareowner Services to invest your payment is: One business day prior to the purchase. Cash purchases are made bl.monthly on the 1st and the 15th. Shareowner Services will process your purchase instructions according to your Plan prospectus/brochure upon receipt of your properly completed request which includes account number or SSN and plan name. We will not be liable for any claim arising out of failure to purchase shares on a certain date or at a specific price. Requests submitted 0/1 this form will only affect Dividend Reinvestment Plan shares, not shares held in ORB. 1111~ 1111!1111 JIIII )1111111 '" " '" " ~ '" '" ~ ~ " <> " "- <.. 01 pur 244 Page I of2 Share Transaction Detail ; . I J\ 11') I. ,~ At ( ./' t"l C&1 Transaction History Vested Transaction Number 01 Dollar Price Vested Date Date Description Shares Amount Per Share 10124/2005 Sell Shares -200.00000 -$1.498.00 $7.49 09/30/2005 Stock Purchase 9.72384 $75.00 $7.71 0813112005 Stock Purchase 6.69344 $60.00 $8.96 07/3112005 Stock Purchase 8.34279 $75.00 $8.99 06/3012005 Stock Purchase 7.30834 $60.00 $8.21 05131/2005 Stock Purchase 7.92498 $60.00 $7.57 04130/2005 Stock Purchase 9.67081 $75.00 $7.76 03/31/2005 Stock Purchase 7.19588 $60.00 $834 02/28/2005 Stock Purchase 6.67341 $60.00 $8.99 01/31/2005 Stock Purchase 7.05725 $60.00 $8.50 1213112004 Stock Purchase 9.58822 $75.00 $7.82 11/30/2004 Stock Purchase 7.86328 $60.00 $7.63 1013112004 Stock Purchase 8.51994 $60.00 $7.04 09/30/2004 Stock Purchase 11.39731 $75.00 $6.58 0813112004 Stock Purchase 7.20888 $45.00 $6.24 07/31/2004 Stock Purchase 8.12337 $60.00 $7.39 0613012004 Stock Purchase 7.65004 $60.00 $7.84 05/31/2004 Stock Purchase 7.89837 $60.00 $7.60 0413012004 Stock Purchase 9.65027 $75.00 $7.77 03/3112004 Stock Purchase 7.20807 $60.00 $8.32 02/2912004 Stock Purchase 6.77821 $60.00 $8.85 01/31/2004 Stock Purchase 9.01161 $75.00 $8.32 12/31/2003 Stock Purchase 7.93797 $60.00 $7.56 12/17/2003 Sell Shares 0.00000 -$124.15 -$Infintty 11/2812003 Stock Purchase 7.49157 $60.00 $8.01 10/31/2003 Stock Purchase 8.56321 $75.00 $8.76 09/30/2003 Stock Pl/rchase 6.18601 $80.00 $9.70 08/29/2003 Stock Purchase 7.85644 $75.00 $9.55 07/31/2003 Stock Purchase 7.46268 $60.00 $8.04 06/30/2003 Stock Purchase 6.79817 $60.00 $8.83 05130/2003 Stock Purchase 9.74291 $75.00 $7.70 04/30/2003 Stock Purchase 11.70846 $60.00 $5.12 03/3112003 Stock Purchase 17.67773 $60.00 $3.39 02/28/2003 Stock Purchase 15.63681 $60.00 $3.84 01/31/2003 Stock Purchase 3.55560 $45.00 $12.66 12/31/2002 Stock Purchase 4.63610 $60.00 $12.94 1113012002 Stock Purchase 5.39960 $75.00 $13.89 10/31/2002 Stock Purchase 4.75170 $60.00 $12.63 09/30/2002 Stock Purchase 4.83440 $60.00 $12.41 09/09/2002 Stock Purchase 0.59700 $9.35 $15.66 08/31/2002 Stock Purchase 3.56770 $60.00 $16.82 07/31/2002 Stock Purchase 3.53340 $60.00 $16.98 06/30/2002 Stock Purchase 3.14880 $60.00 $19.05 05/31/2002 Stock Purchase 3.55680 $75.00 $21.09 05/0812002 Stock Purchase 0.89980 $21.46 $23.85 04/30/2002 Stock Purchase 2.37520 $60.00 $25.26 03/31/2002 Stock Purchase 2.27510 $60.00 $26.37 02/28/2002 Stock Purchase 2.55900 $60.00 $23.45 01131/2002 Stock Purchase 2.34870 $60.00 $25.55 12/31/2001 Stock Purchase 2.04100 $60.00 $29.40 11/30/2001 Stock PU1chase 2.55070 $75.00 $29.40 10/31/2001 Stock Purchase 2.13760 $60.00 $28.07 09/30/2001 Stock PU1chase 2.16410 $60.00 $27.73 09/05/2001 Stock Purchase 0.24240 $7.34 $30.28 06131/2001 Stock PU1chase 2.06660 $60.00 $29.03 https/lbnYlllystockcolll/ESPPHomeIBNYESPP 1203. asp 10/25/2005 Page :2 of :2 07/31/2001 stock Purchase 1.98210 $60.00 $30.27 06/30/2001 Stock Purchase 2.38060 $75.00 $31.50 05/31/2001 Stock Purchase 1.97400 $60.00 $30.40 05/16/2001 Stock Purchase 0.35100 $10.75 $30.63 04/30/2001 Stock Purchase 1.93570 $60.00 $31.00 03/31/2001 Stock Purchase 2.40910 $75.00 $31.13 02/28/2001 Stock Purchase 1.82770 $60.00 $32.83 01/31/2001 Stock Purchase 1.91830 $60.00 $31.28 12/31/2000 Stock Purchase 2.34520 $75.00 $31.98 11/30/2000 Stock Purchase 1.87650 $60.00 $31.97 11/01/2000 Stock Purchase 2.04140 $60.00 $29.39 10/31/2000 Balance Forward 3.19510 $93.46 $29.25 Pending Sale: 0.00000 Total Shares: 162.02827 https//bnYlllystockcolll/ESPPHollle/BNYESPP 1203. asp 10/25/2005 Prudential CB Financial Customer Service Office PO Box 7390 Philadelphia, PA 19176 (800) 778.2255 \NWIN ,prudential ,com LYDIA D WHITE 701 HILLTOP DR NEW CUMBERLND P A 17070-1723 Insured: Lydia D White Policyowner: Lydia D White Policy Number: 73 389434 October 14, 2005 Dear Lydia D White: 1 am writing in response to a request for information concerning the above-mentioned policy. You should find the following information helpful. I have outlined the information below. The approximate values have been calculated as of April 1, 2003. Gross Cash Surrender Value $4,141.50 Cash Value of Paid Up Additional Insurance $2,118.83 Termination Dividend $768.75 Outstanding Loan Value including Interest $0.00 Net Cash Surrender Value $7,029.08 If you have any questions, please call our Customer Service Office at (800) 778-2255, Monday through Friday, 8:00 a.m. to midnight, Eastern time. You can also reach us on Saturdays, between 8:00 a.m. and 3:00 p.m., Eastern time. If you are using a telecommunications device for the hearing impaired, please call at (800) 778-8633, Monday through Friday, 8:00 a.m. to 8:00 p.m., Eastern time. One of our customer service representatives will be happy to help you. Sincerely, !Frances 'E j{ughes Frances E Hughes Customer Service Associate Registered Representative Pruco Securities, LLC rr DECR133::04MH25 Life insurance issued by: The Prudential Insurance Company of America, located at 751 Broad Street, Newark, NJ 07102.3777, a Prudential Financial, Inc. company solely responsible for its own financial condition and contractual obligations. Prudential Financial is a service mark of The Prudential Insurance Company of America, Newark. NJ. and its affiliates. Page 1 of 1 >:...1:5 Account 040-7112-796 as 01 Sep 16, 2005 Your Payment is Due on Oc116, 2005 ~ '<""'. ...., ........ ';y,,::"j ::~: .. ,,~1L; Manage our account online. Click on Mv Kohl's CharCle from www.kohls.com. Or Call 1-800-564-57 40 for automated access. Previous Balance Total Charges Total Payments Total Credits Finance Charge e PROGRAM TO DATE Your Kohl's Charge purchases are $123.80. New Balance To Avoid FInance Charge Pay $600 in Kohl's Charge purchases from Feb. 200S-Jan. 2006 qualifies you for Exclusive MVC Privileges through Feb. 2007. Minimum Due s 893.79 0.00 13100 0.00 9.07 + + s 771.86 771.86 s 38.00 Transaction Summary of Account 040-7112-796 Total AUG 21 Thank You For The Payment......................................................................................................( $45.00) SEP 15 Thank You For The Payment at the Colonial Park Store........................................................( $86.00) SEP 16 Finance Charge ................................................................................................................................$9.07 Annual Percentage Rate 12.90% Account Type Revolvin Notice: See reverse side for important information, c~): Quantity greater than 99 Average Daily Balance $843.34 Nome or Address Change? Would you like to receive e-mail soles notification? Check box and write intormation on reverse side. Account number Due Date New Balance Minimum due Mail Payment by 111111I11I111111111111111I11111I1111111111111I11111111111111 040-7112-796 Oct 16, 2005 $771.86 38.00 Oclll,2005 Mail this portion with your payment. Kohl's Payment Center PO BOX 2983 MILWAUKEE WI 53201-2983 '.1.1...11...1.111"....11..'.11.111111'".11,',,',..111111..' 3 8 Amount Paid 162670P 1...111...111...1...111,,"..111,"1..1.1..11.11......11...III LYDIA D WHITE 701 HILLTOP DR NEW CUMBERLND PA 17070-1723 $ NOTE: Donotmailcosho,giflcads. FH';',:t 1.1';;',1 [':HE':.I, r:'~".;.HE 11'1 us. DC'LlP.RS 0000000 040711279652 0003800 0077186 7 . Please detach here. Payment must be received by 1;00 p.rn.local time on Payment Due Date. ~ Take Advantage of 'Do-It-Yourself Convenience" . , whee y'" V;,w. M,o", oed P'y Y'"' """0' , . online @ myhomedepOlaccolJnt.com. ll.: . Send NotIce 01 BIlling Errors to: HOME DEPOT CREDIT SERVICES Customer Service: 1 .BOO-677 -0232 PO BOX 689100, DES MOINES IA 50368-91 www.myhomedepotaccount.com This flccount Issued by Citibank USA, N.A Account: 6035 3201 0506 2168 Closing Date AUGUST 22, 2005 Next Closing Date SEPTEMBER 21, 2005 Credit Line $5,000,00 Credit Available $2,434.00 Previous Balance $2,443.96 Payments & Credits $25.00 + Purchases/Other Charges $143.45 + FINANCE CHARGES $2.89 Naw Balance $2,565,30 08/08 08/17 08/21 08/22 LocationfTransactions THE HOME DEPOT MECHANICSBURG PA SEASONAL/GARDEN ELECTRICAL AND LIGHTING THE HOME DEPOT MECHANICS8URG PA PAINT, ELECTRICAL AND LIGHTING LATE FEE PAYMENT - THANK YOU '8ILLED FINANCE CHARGES' THANK YOU FOR YOUR RECENT PAYMENT! Amount CURRENT ACTIVITY Transaction Data 08/07 $ 93.29 $ 20.16 $ 30.00 $ 25,00- $ 2.89 PLEASE SEE THE ENCLOSED NOTICE OF CHANGE IN TERMS FOR IMPORTANT I NFORMA TI ON . SEE 8ACK OF STATEMENT FOR INFORMATION ON GRACE PERIOD AND PROMOTIONAL OFFERS. ANNUAL PERCENTAGE RATE on the account: 21.00% Billed FINANCE CHARGES Expiration Date 10/10/05 Previous Balance $2,348.33 Payments & Credits Plart Balance $2,348.33 Accrued FINANCE CHARGES* $388.73 SPECIAL PROMOTIONS Transaction Date 10/03/04 NO INT-NO PMT FOR 12 MOS. ANANCECHARGESUM~RY Balance Subject to Finance Charge DAILY Periodic Rate Corresponding ANNUAL PERCENTAGE RATE Uays In Billing Period Periodic FINANCE CHARGES Other FINANCE CHARGES Current Billina Period L.L.Bean AlB.. Alii ERie..... www.mbnanetaccess.com ". chock I" ,111,1,.1., 1,1,,1., II" ,1,1" ,1.11,,1,1, I,,, 1,.11 l~to: CARDHOLDER SINCE 1997 MBNA AMERICA P.O. BOX 15289 WILMINGTON, DE 19886-5289 - - = LYDIA D WHITE 101 HILLTOP DR NEW CUMBERLND PA 11010-112301 For account Information call 1-600-297-2326 Print change of address or new telephone number below - - Address City ( I Home phone SbJto ( I Woril: phone Zip - FNTNUM:OO 1219 0077 3100 PAYMENT DUE DATE NEW IYLANCE TOTAL I 09/20/05 II $9.041.31 TOTAL MINIMUM PAYMENT DUE AMOUNT ENCLOSED ~248.00 II DETfJCH TOP pORTION AND RETURN WfTH PAYMENT - E 18 00904131000248000004800121900113100 Duo Po Duo""" Gash or Credit Available $12,000.00 Posting Dot. Transaction. AUGUST 2005 STATEMENT PAYMENTS AND 08/17 CREDITS 2373 VS TOTAL FOR EXPRESS PAYMENT - THANK YOU BILLING CYCLE FROM 07/22/2005 THROUGH 08/22/2005 LL BEAN COUPON DOLLARS: .00 MONTHLY 9.02 AVAILA8LE CIooi """ Total MInimum Pa 08/22/05 $248.00 09/20/05 Charges Credits (CfO $0.00 360.00 CR $360.00 CR IMPORTANT NEWS SUMMARYOFTRANSAcnONS TOTAl.. MINIMUM PAYMENT DUE Previous Balance (-J Payments (+) Cash (+) Purchases and ~~r10dJC Rate VlliansacUon Fee ("'j New Bal8nca lUldCredlts Advances Adjustments CE CHARGES I CE CHARGES Tolol $9,175.20 $360.00 $0.00 $0.00 $226.11 $0.00 $9.041.31 FINANCE CHARGE SCHEDULE Calegory Cash Advances A. 8ALANCE TRANSFERS, CHECKS.0.0766571. DLY B. ATM. BANK................ '0.076657% DLY C. PURCHASES................... 0.0766571. DL Y Corresponding Annual Percentage Rate Balance SUbJect to FInance Charge Periodic Rate 27.98% 27.98% 27.981. $0.00 $0.00 $9,217.43 FOR THIS 8!WNG PERIOD: ANNUAL PERCENTAGE RATE................... 27.98% (Inc/udN Pttrlodic R&te and T ramactJon Fee F1nsf'lC$ Charges.) Past Due Amount ................. $0.00 Current Payment .................. $248.00 1C1tl111 Minimum Payment Due ...................................... $248.00 FOR YOUR SATISFACTION. EVERY HOUR. EVERY DAY fa Cuslomer Sa6sfaclion and up 10 the minute automated informa6on including. balance. available credit, paymeats received. paymeats due, ckJe date'8,aymeol address informa6on, or 10 request duplicate slatements, call1-ROO-? 7-?3?6. for TOO (Telecommunication Device 101 the Deaf) assislance. call1-BOD-346-3178. Maipayments 10: MBNAAMERICA, P.O. BOX 15289, WILMINGTON, DE 191186-5289 . BUling rights are preserved only by wrilten inquiry. Mail biDing inquiries, using form on the back and other ilQ\!iries 10: MRNA AMFRICA PO ROX 150?6 WlI MINGTON OF 1 gR50.5D?6. 968 51B 128 0200 0000 00 ACCOUNT NUMBER l.l. Bean I 4800 1119 0077 3100 I PAYMENT DUE DATf NE'w' BAL....NCETOT AL I 05/11/03 I I $11,174.43 I TOTAL MINIMUM PAYMENT DUE AMOUNT ENCLOSED I M~kch~ck CAROHOLOER SINCE 1997 I $243.00 I I P:'9~bl~to: MBNA AMERICA 10 P.O. BOX 15019 V WILMINGTON. OE 19B86-5019 LYOIA 0 WHITE 701 HlLLlOP OR NEW CUMBERLNO PA 17070-171301 S 00000000000000000000000000000000000001117443000143000004BOOl11900773100 S 00119879300117650600000000000000000001117443000143000004800111900773100 lM."'SJN Tor AL MINIMUM PAYMENTOUCOAT'E ACCOUNT NUMBER CREDITUNE CMH OR CREDIT AVAILABLE CYCLE CLOSING DATE P,4,YMENTOUE 4BOO 1119 007) 3100 I $11,000 I $715.57 f30l 04-10-03 I $143.00 I 05/11/03 POS1lNGI~~~NSI~EfERENCE t::tnITR,4,NSACTIONS APRIL 1003 STATEMENT I CHARGES I CREDrrS(CR) LMTc Tf NUMBER PAYMENTS ANO CREOITS 0410 100613691)3 V5 PAYMENT - THANK YOU 1,000.00 CR PURCHASES ANO AOJUSTMENTS 0404 0401 1401946309350B738010013 VS C STORAGE OEPOT-WEST LEMOYNE PA 58.30 TOTAL FOR BILLING CYCLE FROM 3/11/1003 THROUGH 4/10/1003 $58.30 $1.000.00 CR L.L.BEAN COUPON OOLLARS: 0.19 MONTHLY 1.04 AVAILABLE IMPORTANT AN IMPORTANT AMENDMENT TO YOUR ACCOUNT TERMS IS ENCLOSEO. NEWS OON'T WORRY A80UT ECONOMIC UNCERTAINTIES! HELP PROTECT YOUR ACCOUNT. ENROLL IN OPTIONAL CREOIT PROTECTION. CONTACT US: 1-800-580-8847 OR WWW.MBNAPROTECT.CQM. L.L.BEAN CUSTOMERS RECEIVE PREFERREO RATES ON MBNA CO & MONEY MARKET ACCOUNTS. CALL 1-800-598-8917, M-F 8 A.M.-8 P.M., SAT 8-5 (EASTERN TIME). MEMBER FDIC. WWW.M8NANETACCESS.COM - AT YOUR SERVICE. SU MARY Of TRANSACTIONS TOTAL INIMU PAYMENT DUE Pte...ious 1- P a!jrnents + Cash + Purchases +Periodic Ra~TfanSaCt10n Fee '" New Balane'!' ast Due Amount $0.00 Balance and Credits Advances &Adjustments IN;,NCt CHAACiE IN^NCE CH,I,FlCiC. Totar urrent Payment $243.00 $11,987.93 $1.000.00 $0.00 $58.30 $118.10 $0.00 $11.174.43 otal Min Payment Due $143.00 FINANCE CHARGE SCHfOUlE Periodic Corresej)Onding Balance Category Rate Annual Sublectto Percentage Rat'!' Finance Charges FOR YOUR SATISFACTION. EVERV HOUR, EVERV DAY A. BALANCE TRANSFER. CHECKS .061958% OL Y 22.98% $0.00 . For our aulomaledOflect Connecl service, call B. ATM. BANK. . . . . . . .061958% OL Y 11.98% $0.00 1-800-19)-1316 C. PURCHASES . . . . . . . . .062958% OL Y 21.98% $11.081.10 . To speak to one 01 our Customer Satisfaction lepres:entativl!'s. caR O. OTHER BALANCES. . . . . . .000000% OLY 00.00% $0.00 1-BOO-197-1316 )fORTHIS BlLUNG PERIOD ~ . For TOO jTE'lecommunicatiOtlS ae..,ice for the Deaf) assistancE', can ANNUAL PERCENTAGE RATE. _. 22.98% I-BOO- 46-3]78 17Includes Periodic Rate And Transaction Fee Finance CharQes) 'Billing rights ar", preser'Jed only by writtl!'n inquiry. Mail billing inquiries THIS DOCUMENT IS A COPY Of YOUR STATEMENT. IT IS fOR YOUR RECORDS and an o~her account inquiries to: ONLY AND IS NOT....N OFfiCIAL B....NK DOCUMENT. THIS COPY IS NOT AN MBNA AMERICA P.O. BOX 15016 EXACT DUPLICATE AND M,4, Y NOT INCLUDE MESS....GES 'WHICH APPEAR IN PAGE ] OF 1 WILMINGTON, DE 19850-5016 THe IMPORT AWT NE'WS B1.OCK ON )'OOR ORIGINAl. PfRJDDJC STATEMENT. ""au"III"'''' Tor account numbef:4253 3300 0038 7206 New Balance Payment Due Date Past Due Amount Minimum Payment $14,129,36 09/19/05 $0,00 $320,00 CHASE 0 Amount Enclosed 1$ I Make your check payable to Chase Card Services, New address or e-mail? Print on back. Enroll me in the optional Payment Protector Plan. I unoerstand the enclosed offer and may cancel any time. Imtlals Date 425333000038720600032000014129365047395 05325 SEX Z 23705 C LYDIA WHITE 701 HILLTOP DR NEW CUMBERLND PA 17070-1723 1...111.1..1,.1,1..1,.11...1.1,.,.11.1.1..,11..\,1.,.11.,\1,,1 CARDMEM6ER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 1,..111...111..,1...111."...111...1..1.1..11.11......11..,111 .: 5000 lobO 28': 'ib 70000 38 7 20bOIl" ...~ Statement Date: Payment Due Date: Minimum Payment Due: 07/29/05 - 08/25/05 09/19/05 $320,00 CUSTOMER SERVICE In U,S, 1-800-442-3142 Espai\ol 1-1188-446-3308 TDD 1-800-955-8060 Outside U,S, call collect 1-302-594-8200 VISA ACCOUNT SUMMARY Account Number: 4253330000387206 ACCOUNT INQUIRIES p.o, 60x 15298 Wilmington, DE 19850-5298 $14,500 $370 $14,500 $370 PAYMENT ADDRESS P,O, Box 15153 Wilmington, DE 19886-5153 Previous Balance Payment, Credits Finance Charges New Balance $14,164,04 -$354,00 +$319,32 $14,129,36 Total Credit Line Available Credit Cash Access Line Available for Cash VISIT US AT: www.ctlase.comltovsrus Your next AutoPayment for $320.00 will be deducted trom your account and credited on your due date. Should you make a payment prior to your due date, that amount will be deducted from the AutoPayment amount identified above. g~QEEBEY QOLI",~RS_BEWAlIDS Sl!MMAR~___ Previous reward balance $5.21 Rewards earned on all other purchases $0.00 Remaining balance $5.21 Earn a $10 Toys 'R' U.'1 Gift Card every time you .reCich10 Geoffrey _ f?ollars. $5.21 Rewards due to expire July 1,2007 TRANSACTIONS Trans Date Reference Number Merchant Name or Transaction Description Amount Credit Debit 08/22 AUTOMATIC PAYMENT - THANK YOU $354,00 FINANCE CHARGES Category Daily Periodic Rale Corresponding 28 days in cycle APR Average Daily Balance Pu rchases Cash advances Promotions Promotions V .08080% V .08080% V .08080% V 080BO% 29.49% 29.49% 29.49% 29.49"/" $0,72 $0,00 $6,85 $14,105,89 Finance Charge Due To Periodic Rate $0,02 $0,00 $0,16 $319,14 Transaction Fee $0,00 $0,00 $0,00 $000 FINANCE CHARGES $0,02 $0,00 $0,16 $319,14 $319,32 Total finance charges L VDIA WHITE 12423 HSP Z '05284 Acet # 0()0()-l25333()()()()3~72()6 October I L 2005 Page 3 oU, PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 05130/2003 $8,290.94 $16500 ACCOUNT NUMBER: 4253 3300 0038 7206 Facsimile - Copy LYDIA WHITE 701 HILLTOP DR NEW CUMBERLND PA 17070-1723 o CHASE "'W B"'LANCE $8,29{)94 Ton "R" lis I Visl. I (;,,'01 ("ani I"r"lII C1,,",c M,"COUNT NUMBER: 42533300 003lol1206 Here is YOIll' Account Summal)': TOTAL PAYl..1EIH DUE DATE 05130/2003 TOTAL r.;REDITLINE- $13,000 TOTAL AVAilABLE CREDIT $4,709 STATEMENT CLOSING DATE 0510612003 PreviousBa~""e 1-1 Paymenls,Cred~s (+)Pu,ch..ses,Caeh,O<;bIls (+) FINANCE CHARGES (=JNewBalance Minjmu",P~ymcnl Due $9,427.68 1,30000 000 163.26 8,290.94 $16500 DESCRIPTION OF ;"RANSACTIO~~S CHARGES J161 PAYMENT - THANK YOU Tolalofyourcre<lnsandchafUIlS ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY. THE PLAN THAT HELPS PROTECT YOUR CREDIT RATING CHASE ONLINE IS THE EASIEST WAY TO MANAGE YOUR ACCOUNT PAY YOUR BILL VIEW ACCOUNT INFORMATION EVEN TRANSFER BALANCES ITS EASY, SAFE AND SECURE SIGN UP ATWWWCHASECOMlCARDS GEOFFREY DOLLARS SUMMARY OPENING BALANCE $5.13 DOLLARS EARNED THIS STATEMENT $00 COUPONS AWARDEOTHIS STATEMENT $ 00 CLOSI~.G BALANCE $5.13 DOLLARS EARNED SINCE 11.'95 $36513 1.300,00 000 Here's how we determined yom" Fimmce Chal'ge*: na~'s in Rilling C~,,'k: 2'.1 NOMINAL DAILY AVERAGE PERIODICIMlt~ TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAGE PERCENTAGe RATE BALANCE CHARGE CHARGE RATE RATE C~~1i 00664'1% $0.00 $0.00 $000 2424% O.OD'il. Purchases 0.06541'~ $8.477.25 $163.26 $163.26 2424'J> 2424% . Please """ reverse side for balance compulatjon method and other importanl information Questions abeul your accounl? Cmd~ Card 10<;1 or slolen? Call Chase Cuslome' Service 24 l1<lur~ a Day, 7 dayS a week. loll free, al 1-600-442-3142 Of write P,O BOX 15836. Wilmongton, DE 19866.5836 Para Serllicio al CI",nlc en Espal'lol. 1-600 545-0464 f'ag",luf1 _D -~ _0 =- =0 =- - -~ - ~ continues t t 12423 HSP Z 05284 L VOlA WHITE Accl # 00004253330000387206 OClober II, 2005 Page 4 of6 ACCOUNT NUMBER: 4253 3300 0038 7206 PAYMENT DUE DATE NEW BALANCE MINIMUM DUE 0510212003 $9,427.68 S36!HIO l YDIA WHITE 701 HILLTOP DR NEW CUMBERlND PA 17070-1723 Facsimile - Copy o CHASE T..."", "R" U~'_I Vi"..J C...1I1 C....rol {r..m elm"", AtCOUNT NUMBER; 4253 33011 0038 72116 "'W BALANCE $9,427_66 PAYMENT DUE DATE 0510212003 TOTAL CRI:DlTUNE $13,000 TOTAL AVAILABLE CREDIT $3,572 STATEMEI'lT CLOSING DAlE O<l/07t2OO3 Here is your Account Summat,.: TOTAL P,eviouaBalimce $9.079TB 1'1 Paymenls,Credrts "'00 (~) Pu.-char;es, Cash. Deblho 202,60 (+) FINANCE CHARGES 180.30 (=) New Balance 9,427.68 Min.inwmDue ""'" p.,&!OUe-Paylmme<lialely 18lJIO MinimumPaymenlDue $369,00 Hel"e a..... your Charges and C."edits at a glance: rRAN POST AC' DATE DATE "0 DESCRIPTION OF TRANSACTIONS CREDITS CtiARGES 0"," 03i26 V31X WESTSHORESOCCERCUJ6717.774.3625PA 13500 """ "'''' "">K GIANT FOOD STORE N253 NEWCUM6ERLANPA "'" ""'" "'~ "00 REFUNDOFLATE FEES 3500 LATE CHARGE - MIN PYMT NOT RECD BY DATE 35.00 Tolalofvourcredrtsandcharges 35.00 2m'" EFFECTIVE 4/1103. THE CARRIER FOR YOUR TRAVEL ACCIDENT INSURANCE CHANGED TO FEDERAl INSURANCE COMPANY DFS & A INSURANCE AGENCY IS THE NEW ADMINISTRATOR YOUR COVERAGE REMAINS THE SAME ENROLL IN CHASE PAYMENT PROTECTOR PLAN TODAY THE PLAN THAT HI:cLP$ PROTECT YOUR CREDlT RATING GEOFFREY DOLLARS SUMMARY OPENING BAlANCE $345 OOlLARS EARNED THIS STATEMENT "" COUPONS AWARDED THIS STATEMENT '00 CLOSING BALANCE $5.13 DOLLARS EARNED SINCE 11/95 $365.13 A FRlENOl Y REMINDER; YOUR ACCOUNT IS PAST DuE PLEASE SEND PAYMENT TO PROTECT YOUR CREOlT PRIVilEGES IF YOU'VE ALREADY PAID-THANK YOU Pall"1of2 12423 HSP Z ~5284 '" L VOlA WHITE Accl # 00004253330000387206 October I L 2005 Page 5 016 Hel'e's how we detel-mined yoU!" Finance Charge*: DlIrs in Billing C"de: 31 NOMINAL DAILY AVERAGE PERIODICIMIN TOTAL ANNUAL ANNUAL PERIODIC DAILY FINANCE FINANCE PERCENTAG PERCENTAGE RATE BALANCE CHARGE CHARGE RATE RATE Ca&i'I 0.1)6299% $000 $0.00 $000 22.99% (I.DO"" Purchasn 006299% $9,233.61 $180.30 $180.30 2299% Z2.99'lI. .P!eace......'everse&ldeforbalancecompulallonmelhodandQll1erlmportantinformalIOfl Questions abocrt your accounl? Credit Card k>>;1 or &loleol? Call Cha&e Cust,,",e! Ser,,;ce 24 00," a Day, 7 days a week, loll-Iree, aI1_800-4<12_3142 Ol write P,O. aox 15583. Wilmington, DE 1988$_1194. Para Servi<:k> al Cliente en E&pailol: 1-800-545-0464 Page2oT2 -=--0 ~ ====- =0 ====- =0 ====- N ~. N ~ ~ " " 12423 HSP Z 05284 L VDIA WHITE ACCI # OOOO~2533300003872()6 October I L 2005 Page 6 0[6 n C. ""'",' -> :",~" ~~:, o -n .-0 ~ f,l I -..! (l (..,.,' ,."l .< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BOBBY G. WHITE, JR., Plaintiff NO. 03-1027 CIVIL vs. CIVIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE To: The Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania Please mark the withdrawal of the undersigned as counsel for the Plaintiff in the above captioned matter. Thank you. /~~~ /G. Patrick O'Connor, Esquire Attorney LD. No. 64720 3501 Old Gettysburg Road Camp HilI, PA 17011 Phone: (717) 737-7760 Dated: 3/;1/4 , .... CERTIFICATE OF SERVICE I hereby certifY that I have, this day, served the foregoing Praecipe for Withdraw of Appearance by depositing same in the United States first-class mail, postage prepaid, addressed as follows: Cara A. Boyanowski Serratelli, Schiffman, Borwn & Calhoon 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 Gary 1. Rothschield, Esquire Northwood Office Center, Suite 35 2215 Forest Hills Drive Harrisburg, PAl 7112 E. Robert Elicker, II, Esq. Divorce Master 9 North Hanover Street Carlisle, P A 17013 DATE: c3/t1/t76 G. Patrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 170ll (717) 737-7760 Attorney for Plaintiff BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant CIVIL ACTION - LAW IN DIVORCE AMENDED INVENTORY UNDER RULE 1920.33 Defendant, Lydia D. White, files the following amended inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Due to her unavailability Cara A. Boyanowski, Esquire, counsel for Defendant, signs this document and verifies that the statements made in this amended inventory are true and correct to the best of her knowledge from the information provided by Defendant. She understands that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: lj -I?:.- -Olp By.o~~(l(1(}L0<'i~_ Cara A. Boyanowski, sqUire counsel for Lydia D. White, Defendant . ASSETS OF PARTIES DEFENDANT, LYDIA D. WHITE, MARKS ON THE LIST BELOW THOSE ITEMS APPLICABLE TO THE CASE AT BAR AND ITEMIZES THE ASSETS ON THE FOLLOWING PAGES. (X) I. Real Property (X) 2. Motor Vehicles (X) 3. Stocks, bonds, securities and options ( ) 4. Certificates of Deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit box(s) ( ) 8. Trusts (X) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) II. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation . , ( ) 17. (X) 18. (X) 19. ( ) 20. ( ) 2I. ( ) 22. ( ) 23. (X) 24. (X) 25. ( ) 26. claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) Military/VA benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) Other , , WHITE v. WHITE Date of Marriage - September 26, 1981 Date of Separation - January 12, 2003 (22 years) MARITAL ASSETS Assets Wife's Husband's Master's Notes Value Value Value Real Estate Marital Home TBD $240,000.00 First Mortgage exists on 701 Hilltop Drive residence through Members New Cumberland, PA First Federal Credit Union. Balance of loan was $54,163.59 as of October 25, 2005. Home Equity Loan (Account No. 066429) exists on residence through NCFCU. Balance of loan was $16,441.84 as of September 2005. Retirement Assets/Cash and Investment Assets CSRS Retirement account $147,709.00 $147,709.00 Actuary report performed by (Husband) Harry Leister on 12/8/05 and recalculated on March 6, 2006. Wilmington Trust Retirement $1,121.81 No contributions made to plan Money Market Account since date of separation. Account No. 956-7033-245 (Wife) Value of account as of Sentember 2005. Wilmington Trust Roth IRA $0.00 Husband closed out account Account No. 0956-7034 2004: $4,454.89. (Husband) HARRIS DIRECTIETRADE $1,322.47 Value of account as of FINANCIAL January 31,2006. Account No. 5741-0695 (Joint) Wilmington Trust Brokerage $6,991.92 Value of account as of Account (Roth IRA) September 2005. Account No. 009-680176 (Wife) . , NCFCU Savings Account $51.64 Value of account as of Account No. 066429 September 2005. (Joint) NCFCU Checking Account $27.32 Value of account as of Account No. 066429 September 2005. (Joint) NCFCU Savings Account $50.51 Value of account as of Account No. 071193 September 2005. (Wife) NCFCU Checking Account $59.92 Value of account as of Account No. 071193 September 2005. (Wife) Citizens Bank Checking Account Nominal Defendant rarely carries a Account No. 620501-760-5 significant balance in this (Wife) account. Citizens Bank Savings Account $34.99 Account Statement as of Account No. 6246-656825 September 2005. (Wife) Members First Accounts $1,355.75 Statement date 10/05. (Joint) Savings: $133.00. Escrow: $1,122.75. Holiday Club: $100.00. Checking: $0.00. Shares of stock $839.51 Account statement as of Coca-Cola Company October 2005. Shares held: (Joint) 19.5053. Shares of stock $355.18 Account statement as of ConAgra Foods September 2005. Shares held: (Wife) 15.409. Shares of EPB Associates Approx: 80 shares owned by Wife in (Wife) $15,000.00 parent's business Giant Food Stores/Martins Food Total Account value as of October Markets shares of stock Account 2005. (Wife) Value: Wife participates in stock $2,711.59 purchase plan through her employer. She contributes approximately $15.00 per week from her paycheck toward this plan. Total Shares Held: 362.02827 Contributions made to plan . . since DOS: $2,055.00 Shares purchased since DOS: 278.55027 Wife sold 200.00 shares on 10/24/2005 to pay Marital Residence real estate taxes. Life Insurance Policv Prudential Life Insurance Policy Husband closed out policy and No. 73-389-416 $0.00 received funds, December 20, (Husband) 2004. Received $8,475.82. Wife made the monthly premium payments on this policy from DOS until Husband liquidated the policy. She paid approx. $1,029.60 ($31.20 x 33), Prudential Life Insurance Policy $0.00 Husband closed out policy and No. 63-013-629 received funds, December 20, (Wife) 2004. Received $3,915.40. Wife made the monthly premium payments on this policy from DOS until Husband liquidated the policy. She paid approx. $1,617.00 ($49.00 x 33). Prudential Life Insurance Policy $7,029.08 Net cash surrender value for No. 73-389-434 policy as of October 2005. (Wife) Miscellaneous/ Automobiles IRS Refunds (for 2002 and 2003) $6,087.00 Husband: $2,087.00 (2002) 2002: $6,087.00 Wife: $4,000.00 (2002) 2003: $3,539.00 $3,539.00 (2003) Wife does not believe the 2003 income tax return refund should be included as a marital asset. She only filed with Husband in order to save him approx. $10,000.00 in federal income taxes. Household Goods and Furnishings Nominal. 1998 Chevrolet Suburban 1500 $8,000.00 Husband traded in this vehicle Sport Utility vehicle (T rade- in to purchase another. (Joint) value received) 1998 Ford Club Van Approx. Wife uses this vehicle. (Joint) $5,000.00 DEBTS: Kohls $771.86 Balance as on/03: $800.00. Charge Card Balance as of9/05: $771.86 Home Depot $2,565.30 Balance as of3/03: $800.00 Charge Card Balance as of 8/05: $2,565.30 Bank of America $0.00 This credit card was Credit Card established for work travel and (Husband) work expenses and was satisfied through travel vouchers submitted by and received by Husband It should not be considered a marital debt. Cingular TBD Need account info from (Husband) Plaintiff. MBNA America (LL BEAN) $9,041.31 Balance as of 8/05 VISA Credit Card (Wife) Balance as of 4/03: $11,987.93. Wife has maintained this account since DOS. She has made monthly payments of aoorox. $10,663.00. Chase (Toys R Us) $14,129.36 Balance as of 8/05 VISA Credit Card (Wife) Balance as of 4/03: $9,427.68. Wife has maintained this account since DOS. She has made monthly payments of aoprox. $10,674.00. Wilmington Trust Company TBD Husband states that he liquidated his Roth IRA account to satisfY this debt. Need account info. from . Plaintiff. Personal loan to Wife's parents $10,000.00 Parties borrowed money from Wife's parents to purchase the 1998 Ford Club van. Ty Eby Real Estate Appraisals File No. WHITE RL 06 Case No. Uniform Residential A ort rovidelhe lenderlclienlwith an accurate, and ade uale! su rted, inion ofthemarkel va!ueollhesub'ecl ro e Ci NEW CUMBERLAND Stale PA Zi Code 17070 WHITE Goun CUMBERLAND The u seollhissumma a raisalre rtislo P e Address 701 HILLTOP DRIVE Bofrower WHITE Le al Descn lion ATTACHED Assessor's Parcel # 26-24-809-447 Nei hborhood Name DREXEL HILLS Ma Oecu anI Owner 0 Tenant Vacant S edalAssessments$ N/A Pr Ri htsA raised X FeeSim Ie Leasehold Other describe N/A Assi omenlT e Purchase Transaction Refinaoce Transaction X Other describe PARTITION PURPOSES \..entlerlClient MR. GARY ROTHSCHILD ESQU1RE Address 2215 FOREST HILLS DRIVE HARRISBURG PA 17112 IslhesU ect ro currentl olferedforsaleorhasHbeenofferedforsaleinthelwelvemonlhs riortotheeffeclivedaleoflhisa isal? Re rt data so s used,offedn 5 tice S ,and date s. CENTRAL PENN MlS. Owner of Public Record Tax Vear 2006 Reference 26-24-809-447 Census Trad PUD HOA $ N/A R.E. Taxes $ 107 er ear ermonlh Yes X No X did flot analyze the contracl for sale for the subject purchase lransilction. Explain lhe results of the analysts af the contract for sale or why the analysis was no\ NIA Note: Race and the racial com osition of the nel hborhood are nol a raisal factors. No loca~on Urban X Suburban Rural Pro e Values X Increasin Slable Declinin PRICE AGE One-Unit 50 % BuRt-U Over75% X 25-75% Under25% Demand/Su Shorta e X In Balance QverSu $ 000 IS 2-4 Unit 5 % GrowIh Ra'ld X Stable Slow Mar'kelin Time Under3mlhs X 3-6mlhs 0ver6mlls 60 low 0 Muiti-Famil 5 % Nei hborhood Boundaries I CONSIDER THE MARKETING AREA TO BE THE WEST SHORE: SCHOOL 500 Hi h 60+ Commercial 5 % DISTRICT. 175 Pred. 30 Other 35 % Ne' hborhoodDescri tion WEST SHORE SCHOOL DISTRICT CONTAINS SMALL TOWNS AGRICULTURAL AND COMMERCIAL LAND USES. MOST AMENITIES ARE LOCATED IN A SHORT 30 MINUTES OR LESS COMMUTING DIST!\NCE. rt flY the above conclusions THE MARKET REMAINS ACTIVE WITH RELA TIVEl Y LOW INTEREST RATES. Dlmens\OTIS 120'X9S'X116.12'X60.21'X65.53' Area 0.33 ACRE Sha e IRREGULAR S ecilic Zonin Classifica~on R-1 Zonin Descri tion R.1 LOW DENSITY RESIDENTIAL 1000in Co lance X L La I NOfICOl'IfOlmi Gramlfa\heled Use Mo Zenin Ille al describe Is the hi heslandbesluseofsub.ect 0 asim roved oras ro sed r iansands ecificalions the resenlvse? X Yes View AVERAGE .No II No, describe. Utilities Public Other descrIbe Public Other describe Off-site 1m rovemenls- T e Public PrIvate 8eclrici X 200 AMP CBS Water X Street ASPHALT X Gas Sanita Sewer X All NONE FEMAS ecialFloodHazardArea Yes X No FEMAFloodZOlle C FEMAMa # 420366-1B FEMAMa Dale 2/16177 he the ulilitias andloroff-s\te \ ments icalforthemarke\area? X Yes No lINo,descnbe. Are there an adverse sile candidons or extemallaclors easemenls, encroachments, environmental conditions, land uses, etc. ? Yes X No If Yes, describe. . . Floors OAKNINYUGOOD wans DRYWAlUAVG TrimtFinish WOOD/AVERAGE Bath Floor CERAMIC/AVG Bath Wainscol TILE/NONE CarSlora e NOlle Drivewa # of Cars Orlvewa Surface ASPHALT X Gara e #01 Cars 2 ea ort #ofCars All. Det. X Buill-in Units X One One with Access Unit Concrete Slab Crawl S ace Foundation Walls BLOCK #oIS\ories TWO X Full Basement Partial Basement ExleriorWarts ALUM/SPlTROCK T e X Det All. S-DetJEnd Unit BasemenlArea 1591 s . fl. Roof Surface COMPOSITE SHING X Exl$. P e Ul'IderConsL Basement.Finish NJA % Gulters&Downs uls ALUM Desi n SI e 2 STORY X Outside En {Exit Sum Pu WindowT DBL-HUNG Year Built 1964 Evidence of Infestation Storm Sash/Insulated YES Effective A e rs 15 Dam ness Settlement Screens YES Allie None Heafi FWA X HWS Radiant Amenities Woodslove s # o Stair Stairs Other Fvel Oil X Fire lace s # X Fence Floor X Scuttle Coolin X CentralAirCooditionin X PatioJDeck Porch COVERED Rnished Heated lndlvldual Other Pool Other liances Rem erator X Ran elOven X Dishwasher X Cis ossl X Microwav WasherlD er Other describe Finished area above ade contains: 9 Rooms 4 Berlrooms 2.50 Bath s 3004 S uare Feel of Gross Livin Area Al>ove Grade AddWonal fealures s cial ene efficient items elc. OAK FLOORS IN THE LIVING ROOM DINING ROOM FAMILY ROOM AND BEDROOMS' OAK TREAD/PAINTED RISER STAIRS. BUILT-IN SHELVES CABINETS AND CORIAN TOP BUilT-INS tN THE FAMILY ROOM' FOUR YEAR OLD Describe the condition of the ro includi needed re airs deterioration reno....ations remodelin elc.. THE MASTER SA THROOM WAINSCOTING HAS BEEN REMOVED AND IS CURRENTLY CONCRETE UNDERLAYMENT. THERE ARE SOME LOOSE TILES IN THE MAIN BATHROOM WAlNSCOTING. THERE IS A PIECE OF FASCIA MISSING ON THE RIGHT SIDE OF THE HOME AND A PIECE OF GUTTER MISSING ON THE SECOND FLOOR REAR ON THE LEFT SIDE OF THE IMPROVEMENT. THESE ITEMS WERE CONSIDERED IN THE SALE COMPARISON ANALYSIS. Are there an h sicai deficiencies or ad....erse conditions lhal affect the livabili soundness, or structural int ril olthe ro 7 Yes X No If Yes describe *APPLlANCES' T1LEW BACKS PLASH IN THE KITCHEN. LIVING BOW WINDOW REPl..!\CED. NEW OAK FLOORING IN THE FAMll Y ROOM AND LAUNDRY ROOM enerall conform 10 the nei hborhood lunctionaiuUlit ,s Ie, condiliOl1, use, construction, elc.? X Yes Freddie Mac Form 70 March 2005 ClickFORMS Appraisal Software 8Q0--622-8727 No IINo,describe FannieMaeForm1004 March2005 Page 1 01 13 Ty Eby Real Eslate Appraisals File No. WHITE Rl 06 Case No. Uniform Residential Appraisal Report There are 48 comoarable orooerties currenUvoflered for sale in the subiect nelohborhood rano inoin orice from $ 150 000 10$ 300 000 There are 278 comoarable sales in the su 'eel neiohbolhood withjn the oastlwelve months tallQir1Q in sale orice from $ 150 000 10$ 300 000 FEATURE SUBJECT COMPARABLE SALE # 1 COMPARABLE SALE # 2 COMPARABLE SALE # 3 Address 701 HILL TOP DRIVE 615 HILLTOP DRIVE 501 7TH STREET 345 BLACKLA TCH LANE NEW CUMBERLAND PA 1707n NEW CUMBERLAND PA ~7D70 NEW CUMBERLAND PA 17070 CAMP HILL PA 17011 ProximilVloSubiect 0,11 miles 0,49 miles 0.61 mites Sale Price I N/A I 220 000 I 195 000 $ 245 000 Sale PricelGross Liv. Area ft. $ 107.84 sn.fl. $ 97.60 so.ft. I 96.88 sa. fl. DalaSource(s' MLS/REAL TOR'S OFFICE MLSIREAl TOR'S OFFICE MLS/REALTOR'S OFFICE VerificaliOllSource{sl COURTHOUSE RECORD COURTHOUSE RECORD COURTHOUSE RECORD VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION +r-\SAdluslment DESCRIPTION +1~l$Adiuslment DESCRIPTION +(.' $ Ad'uslmen Sale or Firlal'lCina CONVENT1ONAL CONVENTIONAL CONVENTIONAL Concessions NONE KNOWN NONE KNOWN NONE KNOWN DaleofSalefTime 12/05 5105 10/05 Location SUBURBAN SUBURBAN SUBURBAN SUBURBAN LeaseholdlFeeSimole FEE SIMPLE FEE SIMPLE FEE SIMPLE FEE. SIMPLE Site 0.33 ACRE 0.34 ACRE 0.29 ACRE 0.61 ACRE ~1O 00 ~ew AVERAGE AVERAGE AVERAGE AVERAGE DesinnlSMe' 2 STORY 2 STORY 2 STORY 2 STORY Quatilvof Conslruclion AVERAGE AVERAGE AVERAGE AVERAGE AclualAoe 42 YEARS 37 YEARS 36 YEARS 41 YEARS Condition AVG/GOOD SIMILAR SIMILAR SUPERIOR -500 Above Grade Totaf Bdrmsl 8aths Tolal IBdrms Saths T ola lBdrms I Baths Total ISdrmsl Salhs RoomCounl 91412.50 914 2.50 -150 7 3 2.50 -150 10 5 I 3.50 -400 Gross Livino Ar'ea 3004 sa.n 2040 so.n. +2410 1998 so. ft. +2515C 2529 so. ft. -+1187:: Basement 8. Finished FULL FULL FULL FULL Rooms Selow Grade UNFINISHED REC ROOM -300 SEMI-FIN REC RM/KIT -50OC Functional U\ilil\r AVERAGE AVERAGE AVERAGE AVERAGE HeatinalCoolino HWBB/CA HWBB/CA EBBINONE +400 EBB/NONE +4000 EnemvEfficientllems STANDARD STANDARD STANDARD STANDARD GaraoelCaroorl 2 CAR INTEG 2 CAR ATT 2 CAR ATT 2 CAR ATT POl"ChIPatialDeck PRCH/DECKlPAT PORCHES PORCH .2.00< COV PORCHES FIREPLACE FIREPLACE NONE +200 2 FIREPLACE -150C REMOD KIT -500 Net Adiustment 1T0tall IX .1 $ 19600 xl+f ,- I 31650 + Xl - $ -14625 Adjusted Sale Price Net AOj: 9% Net Adj: 16% Net Adj: -6% . ofComoarables Gross Adi : 13% $ 239 600 Gross Ad!: 18% I 226 650 Gross Adi: 19% I 230375 61 X I did I !did nol research the sale or lransferhislorvof the sublecl orooertv and comnarable sales. If not, exnlain . did not reveal any orior saJes or transfers of the subiecl prapertv lor lhe t hree vears prior 10 the effeclivedate of this appraisal. MYresearch I didlX Data sourcelsl MLS COURTHOUSE RECORD M'1 research I Idkl r-X I did not reveal any prior sales or translers of the comparable sales for the year prior 10 the date of sale of the comparable sale Data sourcelsl MLS COURTHOUSE RECORD ReDOrt the results of the researcl\ and analysis of \he prior sale Of transfer history of the subject properly and comnarabie sales lrenort additional prior sales on page 3). ITEM SUBJECT GOMPARABLE SAlE # 1 COMPARABLE SALE # 2 COMPARABLE SALE # 3 Dale of Prior SalelTransfer 12/1990 NO OTHE.R TRANSFER NO OTHER TRANSFER NO OTHER TRANSFER Price of PriorSaJelTransfer 116 ODD IN THE PAST YEAR IN THE PAST YEAR IN THE PAST YEAR DataSourte(s) COURTHOUSE RECORD COURTHOUSE RECORD COURTHOUSE RECORD COURTHOUSE RECORD EftectiveDaleofDalaSource(s' 3/2006 3/2006 3/2006 3/2006 Analvsis of prior sale or transfer history of the suhiecl nronertv and comnarable sales THERE ARE NO A TYPICAL TRANSFERS OF THE SUBJECT OR COMPARABLE PROPERTIES. Summary of Sales Comparison Approach ALL OF THE COMPARABLE SALES ARE LOCATED IN THE SAME SCHOOL DISTRICT AS THE SUBJECT PROPERTY. SALE ONE AND TWO ARE LOCATED IN THE IMMEDIATE NEIGHBORHOOD AND ARE IN SIMILAR CONDITION RELATtVE TO THE SUBJECT PROPERTY. SALE THREE AND FOUR MORE CLOSELY RESEMBLE THE GROSS LIVING AREA OF THE SUBJECT PROPERTY aUT HAVE HAD MORE REMODELING THAN THE SUBJECT PROPERTY. SEE THE COMMENT ADDENDUM. Indicated Value bv Sales Comoarison Annroach $ 240 000 Indlcated Value by: Sales Comparison Approach $ 240 000 Cost Approach Ijfdevelopedl $ N1A Income Approach (if developed) $ NIA f HAVE FAVORED SALES COMPARISON ANALYSIS IN ESTIMATING THE MARKET VALUE OF THE SUBJECT PROPERTY. This appraisal is made W 'as is," U subiect to campletioo per plans aOO specilicatioos on the basis of a hypo\l1etical condition lhallhe improvemen!s have been completed, Dsubjecllo the following repairs oraJterafionS on the basis of a hypothetical condition that the repairs or alterations have been compleled, or 0 subject to !he followirlQ reouiredirlsoectiOl1 based on the extraordinarv assumplion lhatlhe conditiooordeficiencvdoesnotreQulrealteraUonmreDQir. Based on a complete visual inspection olthe interior and exterior areas ofthe subject property. defined scope of work, statement of assumptions and limiting t.cntll\lons, and appraiser's certification, my (our) opInion of the market value, as defined, of the real property that is the subject of thIs reporl is $ 240 000 llsof 3/1612006 which is the date of insoectJon and the effective date of this aoorais al. ClickFORMS Aooraisal Software 800-622-8727 Fannie Mae Form 1004 March 2005 Paqe 2 of 13 FreddieMacForm70 March2005 Ty Eby Real Es.late Appraisals. Uniform Residential A raisal Re ort THE INTENDED USER OF THIS APPRAISAL REPORT IS THE LENDER/CLIENT. THE INTENDED USE IS TO EVALUATE THE PROPERTY THAT IS THE SUBJECT OF THIS APPRAISAL FOR PARTlTON PURPOSES SUBJECT TO THE STATED SCOPE OF WORK PURPOSE OF THE APPRAISAL REPORTING REQU1REMENTS OF THIS APPRAISAL REPORT FORM AND DEFINITION OF MARKET VALUE. NO ADDITIONAL. INTENDED USERS ARE IDENTIFIED BY THE APPRAISER. File No. WHITE RL 06 Case No. THIS APPRAISAL IS NOT A HOME INSPECTION. I HAVE VISUALLY INSPECTED ACCESS ISLE AREAS. THIS REPORT CANNOT BE RELIED UPON TO DISCLOSE CONDITIONS AND/OR DEFECTS IN THE PROPERTY. THE PRIMARY SOURCE OF DATA USED IN THE PREPARATION OF THIS REPORT WAS OBTAINED FROM THE LOCAL MULTIPLE LISTING SERVICE S . A SECONDARY SOURCE OF DATA UPON WHICH THE PRIMARY DATA SOURCE IS COMPARED FOR ACCURACY IS THE COUNTY SALES REPORT OTHERWISE KNOWN AS STATE TAX EQUALIZATION BOARD STEB REPORT. DATA FROM NUMEROUS SALES IS OBTAINED FOR COMPARISON TO THE SUBJECT PROPERTY. SALES USED AS COMPARABLES ARE VOLUNTARY "ARM'S LENGTW TRANSACTIONS SIMILAR PHYSICALLY AND IN TYPE OF LOCATION AND ARE AS RECENT AS POSSIBLE. THE SALES SELECTED AS COMPARABlES ARE CONSIDERED TO BE MOST REPRESENTATIVE OF THE SUBJECT PROPERTY. DOLLAR ADJUSTMENTS ARE MADE FOR DIFFERENCES BETWEEN THE SUBJECT PROPERTY AND THE COMPARABLES TO REFLECT MARKET REACTION TO ITEMS OF SIGNIFICANT VARIATION. I HAVE FAVORED SALES COMPARISON ANALYSIS IN ESTIMATING THE MARKET VALUE OF THE SUBJECT PROPERTY. THERE ARE SEVERAL POSSIBLE SOURCES OF INFORMATION TO VERIFY THE SUBSTANTIVE DATA I. E. SALES PRICE GROSS LIVING AREA AMENITIES. THESE INCLUDE BUT ARE NOT LIMITED TO INSPECTION REALTORS OR OTHERS PARTY TO THE SALE MLS SERVICES AND COURTHOUSE INFORMATION FROM SEVERAL SOURCES. SOMETIMES THIS lNPORMATION DIFFERS SIGNIFICANTLY WHEN VERIFIED BE1WEEN THE SOURCES. I ATTEMPT TO USE THE INFORMATION WHICH I BELIEVE TO BE THE .. MOST CORRECT AND CONSISTENT FOR THIS APPRAISAL REPORT. Providead uateinformationforthelender/clienltore kale urcoslfi l.lresandcaJculations. Su rt for the 0 'nion of sne value summa of com arable land saies or other methods for esUmsUn site value THE SITE ESTIMATE IS BASED ON SALES OF LOTS IN THE MARKETING AREA. ESTlMATED REPRODUCTION OR REPLACEMENT COST NEW . Soun;:eofcostdata Oualil ratin rromcostservice Effective dale ofcosl data Comments on Cost roach ross ~vin area calculations, de edatiorl etc, THE COST APPROACH IS NOT RELIABLE FOR PROPERTIES OF . THIS AGE DUE TO THE DIFFICULTY IN ESTIMATING DEPRECIATION. OPINION OF SITE VALUE Dwem 3004 S.Ft. Bsmt 1591 S .Ft "$ "$ "$ 50 000 Gam elCa ort S .Ft. $ Total Estimale ofCost-new Less Ph ital 25 FW'donal De reciation 0 De recialed Cost of 1m ovements "As-is"ValueofSkelm rovemenls "$ "I Erlemal "I "$ 4 o o Eslimaled Remainin Economic Life HUD and VA on 45 Year IndicatedValueB CoslA roach "I NIA Estimaled Monthl Mar1tel Rent $ N/A X Gross Multi lier Summa ollncome roach includin su rt for market renl and GRM FOR SINGLE FAMILY DETACHED HOMES. N/A =$ N/A Indicated Value b Income A roach THE INCOME APPROACH TO VALUE IS NOT THE PREFRRED APPROACH ij .!r Ila'bl. ls.lhedevelo rlbu~c!eril'tcontrolof\heHomeownefsAssocia\ion HOA? Yes No Unit es Delached Attached Provide the tollowin informalion lor PUDs ONLY if the develo r!builder is in control of the HOA and the su "ect ro e is an attached dwellin unit. l alNameofPro'ect Total number of hases T alai number of uoits Total numtler ofunits sold Total number of units rented Total number of unils for sale Dala source s Waslhe 'eclclBatedb Iheconversionofexistin buildin 5 intoaPUD? Yes No If Yes, date of conversion. Does the to'eel cootain an mulli-clwellin unils? YeS No Data source. . Are the unlts, common elements and teClealion facilities com lele? Yes No If No, describe the status of com letioo. Are the common elements leased 10 or b the Homeowner's Association? v" No If Yes, describe lhe renlal terms and 0 lions. Descritle common eiements and recreational facilities. Ctic\<;FORMS Appraisal Software 800-622-B727 Fannie Mae Form 1004 March2005 Page 3 of 13 FIBddie Mac Form 70 March2005 Ty Eby Real Estate Appraisals Uniform Residential Aooraisal Renort File No. WHITE RL 06 Case No. This report form is designed 10 report an appraisal of a one-unit property or a one-unit property with an accessory unit; including a unil in a planned unit development (PUD). This report form is not designed to report an appraisal of a ma.nufa.ctured home or a unit in a condominium or cooperative project. This appraisal report is subject to the following scope of wort.., intended use, intended user, deflnition of market value, slalement of assumptions and limiting conditions, and certifications. Modifications, additions, or deletions to the intended use, intended user, definition of market value, or assumplions and limiting conditions are not permmed. The appraiser may expand the scope of work to Include any additional research or analysis necessary based on the complexity of this appraisal assignment Modifications or deletions to the certifications are also not permitted, Howe\"er, addilionaJ certifications that do not constitute malerial alleralions to this appraisal report, such as those required by law or those related to the appraiser's continuing education or membership in an appraisal organization, are permitted. SCOPE OF WORK: The scope of work for this apPlClisal is defined by the complexity of this appraisal assignment and the reporting requirements of this appraisal report form, including the following definition of macket value, statement of assumplions and limiting conditions, and certifications. The appraiser must, at a minimum: (1) perform a complete visual inspection of the interior and exterior areas of the subject property, (2) inspect the neighborhood, (3) inspect each of the comparable sales from at leasl the streel, (4) research, verify, and analyze data from reliable public and/or private sources, and (5) report his or her analysis, opinions, and conclusions in this appraisal report. INTENDED USE: The intended use of this appraisal report is for the lender/client to evaluate the property that is the subject of this appraisal for a mortgage finance trans~tion. INTENDED USER: The intended user of this appraisal report is lhe lender/client. DEFINITION OF MARKET VALUE: The most probable price which a property should bring in a competitive and open market under all conditions requ]site to a fair sale, the buyer and seller, each acting prudently, knowledgeably and assuming the price is not affected by undue stimulus. Implicil in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby: (1) buyer and seller are typically motivated; (2) both parties are well informed orwell advised, and each acting in what he or she considers his or her own besllnterest; (3) a reasonable time is allowed for exposure in the open market; (4) payment is made in terms of cash in U. S. dollars or In terms of financial arrangements comparable thereto; and (5) the price represents Ihe normal consideration for the property sold unaffected by special or creative financing or sales concessions. granted by anyone associated with the sale. .Adjustments to the comparables must be made for special or creative financing or sales concessions. No adjuslments are necessary for those costs which are normally paid by sellers as a result of tradition or law in a market area; these costs are readily identifiable since the seller pays these costs in virtually all sales lransactions. Special or creative financing adjustments can be made to the comparable property by comparisons to financing terms offered by a third party Institutional lender that is not already Involved In the property or transaction. Any adjustment should not be calculated on a mechanical dollar for dollar cost of the financing or concession bul the dollar amount of any adjustment should approximate the market's reaction to the financing or concessions based on lhe appraiser's Judgment. STATEMENT OF ASSUMPTIONS AND LIMITING CONDITIONS: The apprai..,s certificalion In this report is subject to the following assumptions and limiting conditions: 1. The appraiser will not be responsible for matters of a legal nalur8 that affect either the property being appraised or the title to it, except for information that he or she became aware of during the research involved in perfonning this appraisal. The appraiser assumes lhatlhe title is good and marketable and will not render any opinions about the title. 2. The appraiser has proVided a sketch in this appraisal report to show the approximale dimensions of the improvements. The skelch is included only to assisl the reader in visualizing the property and understanding the appraiser's determination of its size. 3. The appraiser has examined the a\lanable flood maps that are provided by the Federal Emergency Management Agency (or other data sources) and has noted in lhis appraisal report whether any portion of the subject site is located in an identified SpeCial Flood Hazard Area. Because the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding this delermlnation. 4. The appraiser will not give testimony or appear in court because he or she made an appraisi31 01 the property in question, unless specific arrangements to do so have been made beforehand, or as otherwise required by law. 5. The appraiser has noled in this appraisal report any adverse conditions (such as needed repairs, deterioralion, the presence of hazardous wastes, toxIC subs.tances, etc.) obsel'\led during the inspection of the subject property or that he or she became aware of during the research involved in performing this appraisal. Unless otherwise stated in this appraisal report, the appraiser has no knowledge of any hidden or uneJPparent physical deficiencies or adverse conditions of the property (such as, but not limited to, needed repairs, deterioration, the presence of hazardous wasles, toxic substances, adverse environmental conditions, etc.) that would make the property less valuable, and has assumed thai there are no such condnkms and makes no guarantees or warranties, express or implied. The appraiser will not be responsible for any such conditions that do exisl or for any engineering or lesting that might be required 10 discover whether such conditions exisl. Because the appraiser is not an expert In the field of environmental hazards, th'ls appraisal report must not be considered as an environmenlal assessment of the property. 6. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfaclory completion, repairs, or atteralions on the assumption lhat the completion, repairs, or allerations of the subject property will be performed in a professional manner. ClickFORMS Appraisal Software 800.622-B727 Fanoie Mae Form 1004 March 2005 Page 4 of 13 Freddie Mac Form 70 March2005 Ty Eby Real Estale Appraisals Uniform Residential Aooraisal Reoort File No. WHITE RL 06 Case No. APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees thaI: 1. I have, at a minimum, developed and reported this appraisal In accordance with the scope of work requirements stated in this appraisal report. 2. t performed a complete vls.uallns.pectlon of the Interior and exterior areas of the subject property. , reported the condition of the Improvements in factual, specific terms. I identified and reported the physical deficiencies that could affect the livability, soundness, or slructurallntegrity of the property. 3. I performed this appraisal in accordance with the requirements of the Uniform Standards of Professional Appraisal Pracllce that were adopted and promulgated by lhe Appraisal Standards Board ofThe Appraisal Foundation and that were in place at the time this appraisal report was prepared. 4. I developed my opinion of the market value of the real property that is the subject of this report based on the sales comparison approach 10 value. I have adequate comparable market data to develOp a reliable sales comparison approach for this appraisal assignment. I further certify that I considered the cost and income approaches to value but did not develop them, unless otherwise indicated in this report. 5. I researched, verified, analyzed, and reported on any current agreement for sale for the subject property, any offering for sale of \he subject property in thE! twelve months prior to the effective date of this appraisal, and the prior sales of the subjecl property for a minimum of three years prior 10 the effective date of lhis appraisal, unless otherwise Indicated in this report. 6. I researched, verified, analyzed, and reported on the prior sales of the comparable sales for a minimum of one year prior to the date of sale of lhe comparable sale, unless otherwise indicated in this report. 7. I selected and used comparable sales that are locatlonally, physically, and fUnctionally the most similar to the subject property. 8. I have not used comparable sales that were the result of combining a land sale with the contracl purchase price of a home thai has been built or will be built on the land. 9. I have reported adjustments to the comparable sales that reflect the market's reaction to the differences between the subject property and the comparabte sales. 10. I verified, from a disinterested source, all information in this report that was provided by parties who have a financial interesl in the sale or financing of the subject property. 11. I have knolNledge and experience in appraising this type of property in this market area. 12. I am aware of, and have access to, the necessary and appropriale public and private data sources, such as mUltiple listing services, tax assessment records, public land records and other such data sources for the area in which the property is located. 13. I obtained the information, estimates, and opinions furnished by other parties and expressed in this appraisal report from reliable sources that I believe to be true and correct. 14. , have taken into consideration the factors that have an impact on value with respect to the subject neighborhood, subject property, and the proximity of the subject property to adverse influences in the development of my opinion of market value. I have noted in this appraisal report any adverse conditions (such as, but \'\Ot limited to, needed repairs, deterioration, the presence of hazardous wastes, toxic substances, adverse environmental conditions, etc.) observed during the inspection of the subject property or thai I became aware of during the research involved in performing this appraisal. I have considered these adverse conditions in my analysis of the property value, and have reported on the effect of the conditions on the value and marketability of the subject property. 15. I have not knowingly withheld any significanl information from this appraisal report and, 10 lhe best of my knowledge, all statements and information il\ this appraisal report are true and correct. 16.1 stated in this appraisal report my own personal, unbiased, and profeSSional analYSIS, opinions, and conclusions, which are subject only to the assumptions and limiting conditions in this appraisal report. 17. I have no present or prospective interest in the property lhat is lhe subject of this report, and I have no presenl or prospective personal interest or bias with respecl to the participants in the transaction. I did nol base, either partially or completely, my analysis and/or opinlon of market value in this appraisal report on the race, color, religion, sex, age, marital status, handicap, familial status, or national origin of either the prospective owners or occupants of the subjecl property or of the present owners or occupants of the properties. in the vicinity of the subject property or on any other basis prohibited by law. 18. My employment and/or compensation for performing this appraisal or any future or anticipated appraisals was not conditioned on any agreement or understanding, written or otherwise, thai I would report (or presenl analysis supporting) a predetermined specific value, a predetermined minimum value, a range or direction in value, a value that favors the cause of any party, or the attainment of a specifiC result or occurrence of a specific subsequent event (such as approval of a pending mortgage loan application). 19. I personally prepared all conclusions and opinioos about the real estate that were set forth in this appraisal report. 111 relied on significant real property appraisal assistance from any individual or individuals in the performance of this appraisal or the preparation of this appraisal report, I have named such indJvidual(s} and disclosed the specific tasks performed In this appraisal report. I certify that any individual so named is qualified to perform lhe tasks. I have not authorized anyone to make a change to any item in this appraisal report: therefore, any change made to this appraisal is unauthorized and I will take no responsibility for it. 20. I identified the lender/client in this appraisa.l report who is the individuai, organization, or agent for the organizalion that ordered and will receive this a"''''raisal rer,nrt. FreddieMacForm70 March2005 ClickFORMS Appraisal Software 800-622-8727 FannieMaeForml004 March2005 Page 5 of 13 Ty Eby Real Estate Appraisals Fife No. WHITE RL 06 Case No. Uniform Residential A raisal Re ort 21. The lender/cllent may disclose or distribute this appraisal report 10: the borrower; another lender at the request of the borrower; the mortgagee or its successors and assigns; mortgage insurers: government sponsored enterprises; other secondary market participants; data collection or reporting services; professional appraisal organizations; any department, agency, or instrumentality oflhe United States; and any state, the Districl of Columbia, or other Jurisdictions; without having to obtain the appraiser's or supervisory appraiser's (if applicable) consent. Such consent must be obtained before this appraisal report may be disclosed or distrlbuled to any other party (including. but not limiled to, the public through advertising. public relalions, news. sales, or other media). 22. I am aware that any disclosure or distribution of this appraisal report by me or the lenderfclient may be subject to certain laws and regulations. Further, I am also subject to the provisions of Ihe Uniform Standards of Professional Appraisal Practice that pertain to disclosure or distribution by me. 23. The borrower, another lender at the request of the borrower, the mortgagee or its successors and assigns. mortgage insurers, government sponsored enterprises, and other secondary market participants may rely on this appraisal report as part of any mortgage finance transaction that involves anyone or mote of these parties. 24. If this appraIsal report was transmitted as an "electronic record- containing my "electronic signature: as those terms are defined in applicable federal and/or state laws (excluding audio and video recordings), or a facsimile lransmission of this appraisal report contaif"ling a copy or reP'"esentation of my signature, the appraisal report shall be as effecflve, enforceable and valid as if a paper version of this appraisal report were delivered containing my original hand written signature. 25. Any intentional or negligenl misrepresentation{s) contained in this appraisal report may result in civil liability and/or criminal penalties including, but nollimiled to. fine or imprisonmenl or both under the provisions of Title 18, United States Code, Section 1001, et seq., or similar state laws. SUPERVISORY APPRAISER'S CERTIFICATION: The Supe""o')' Apprai,e, certifies aod agre.. that 1. I dlreclly supervised the appraiser for this appraisal a&signment. have read the apP'"aisal report, and agree with the appraiser's analysis, opinions, statements, conclusions, and the appraiser's certification. 2. I accept full responsibility for the conlents of this appraisal report including, but nollimiled to, the appraiser's analysis, opinions, statements, conclusions. and the appraiser's certification. 3. The appraiser identified in this appraisal report is either a sub-contractor or an employee of the supervisory appraiser (or the appraisal firm). is qualified to perform this appraisal. and is acceptable to perform this appraisal under the applicable state law. 4. This appraisal report compiles with the Uniform Standards of Professional Appraisal Practice that were adopted ~nd promulgated by the Appraisal Slandards Board of The Appraisal Foundation and thai were in place al the time this appraisal report was prepared. 5. If this appraisal report was transmilled as an -electronic rElcord~ containing my -electronic signalure, ~ as those lenns are defined in applicable federal and/or slale laws (excluding audio and video recordings), or a facsimile transmission of this appraisal report containing a copy or representation of my signature, the appraisal report shall be as effective, enforceable and valid as if a paper version of this appraisal report were delivered containing my onginal hand written signature. APPRAISER SUPERVISORY APPRAISER (ONLY IF REQUIRED) Signature Name T Company Nam v Ebv eal Estate ADPraisals Company Address 104 Cedar Avenue Hershev. PA 17033 Telephone Number 717 312-1337 Email AddressEBREA@COMCAST.NET Date of Signature and Report 4/5/2006 Effective Date of Appraisal 3/16/2006 State Certification # PA RL 000685L or State License#- PA STATE CERT RESIO. RE APPR or Olher (describe) State # State Expiralion Dale of Certification or License 6/30/2007 Signature Name Company Name Company Address Telephone Number Email Address Date of Signature State Certification # or State License # Slate Expiralion Date of Certification or License SUBJECT PROPERTY ADDRESS OF PROPERTY APPRAISED 701 HILL TOP DRIVE NEW CUMBERLAND. PA "17070 8 Did nol inspect subject property Did Inspect exterior of subject property from streel Date of Inspection o Did inspect interior and exterior of subject property Dale of Inspection APPRAISED VALUE OF SUBJECT PROPERTY $ 24Q 000 LENDER/CLIENT Name Company Name MR. GARY ROTHSCHILD. ESQUIRE Company Address 2215 FOREST HILLS DRIVE HARRISBURG, PA 17112 Emaii AddressGLROTHLAW@COMCAST.NET COMPARABLE SALES 8 Did not inspect exterior of comparable sales from slreet Did inspect exterior of comparable sales from street Date of Inspection ClickFORMS Appt<lisal Software 800-622-8727 Fannie Mae Form 1004 March 2005 Page 6 of 13 FrecldieMacForm70March 2005 Ty Eby Real Estate Appraisals EXTRA COMPARABLES 4-5-6 File No. WHITE RL 06 Case No. Borrower WHITE Property Address 701 HILLTOP DRIVE City NEW CUMBERlAND County CUMBERLAND State PA Zip Code 17070 Lender/Client MR. GARY ROTHSCHILD, ESQUIRE Address 2215 FOREST HILLS DRIVE, HARRISBURG. PA 17112 FEATURE I SUBJECT COMPARABLE SALE # 4 COMPARABLE SALE # 5 COMPARABLE SAlE # 6 I\dd"" 701 HILL TOP DRIVE 232 WINDING WAY NEW CUMBERLAND PA 17070 CAMP HILL PA 17011 Proximilvto Subfect 0.75 miles ~I ~$ Sale Price 1$ NIA I 279 900 I $ SaIePriceJGlOSs~iv.Area $ 0.00 s,ft.$ 91.92 so. ft. "..ft. s".ft.. DalaSourcersl MLSIREAL TOR'S OFFICE VerificatlonSource/s) COURTHOUSE RECORD VALUE ADJUSTMEN1S DESCRIPTION DESCRIPTJON t(-l$Adil,lslmenl DESCRIPTION +f-l$Adiuslmenl DESCRIPTION t(.l$ Adiuslmen Sale or financing CONVENTIONAL Concessions NONE KNOWN Date of SalelTime 7/05 Loca6on SUBURBAN SUBURBAN LeaseholdIFeeSim Ie FEE SIMPLE FEE SIMPLE Site 0.33 ACRE 0.34 ACRE "ow AVERAGE AVERAGE Desion SMe 2 STORY 2 STORY Oual\lv of Conslruc\ioo AVERAGE AVERAGE Aclua!AQ8 42YEARS 27 YEARS Condition AVG/GOOO SUPERIOR .500< Above Grade Tolal Bdnns Baths TolallBdrmsJ Baths TotallBdrms Baltls Total IBdrms Baths Room Count 9 I 4 2.50 10 I 5 I 3.50 .400C I I I I Gross Uvinn Area 3004 M.ft. 3045 so. ft. sn.ft. so. ft. 8asemenl&Finished FULL FULL Rooms Below Glilde UNFINISHED REC ROOM .300 Func60nalUlilitv AVERAGE AVERAGE HeatioolCoolinQ HWBBICA FNCA Enemv Effidenlllems STANDARD STANDARD . Garaoe/Carnort 2 CAR INTEG 2 CAR ATT Porch/Patio/Deck PRCH/DECK/PAT PORCH+SUNRM -500 I!oI FIREPLACE FIREPlACE . REMOD KIT/BAT -1000 . Net Alliustrnent lTolal) 1 1...IXl. I -27 000 IX . I. I 0 IIX . I. I 0 . AdjusledSale Price Nel Adj: -10% Net Ad): 0% Net Adj: 0% ofCnmnarables Gross Adi : 10% $ 252 900 Gross Adi: 0% I 0 Gross Adi: 0% I 0 Reoort the resulls of the research and analvsis of !he nrior sale or transfer lUsoo of the s.uhiect oroo.ertv and comr.:l.rable sales ITEM SUBJECT COMPARABlE SA~E # 4 COMPARABLE SALE # 5 COMPARABLE SALE # 6 Date of Prior Sale!Transfer 12/1990 NO OTHER TRANSFER Price of Prior SaleITransfer 116000 IN THE PAST YEAR DataSource(sl COURTHOUSE RECORD COURTHOUSE RECORD EflWi'lc Dale of Data Source s 312006 3/2006 Analvsls of Drior sale or transfer tistoN of the sub'eet orooertv and comoarable sales NO A TYPICAL SALES IN THE PAST THREE YEARS fOR THE SUBJECT PROPERTY OR THE PAST ONE YEAR FOR THE COMPARABLE SALES. Summary of Sales Comnarison Annroach ClickFORMS Appmisal Software 800-622-8727 Page 7 of 13 Ty Eby Real Eslate Appraisals SUBJECT PHOTO ADDENDUM File No. WHITE RL 06 Case No. Borrower WHITE Property Address 701 HILLTOP DRIVE City NEW CUMBERLAND County lender/Client MR. GARY ROTHSCHILD. ESQUIRE CUMBERLAND State PA Zip Code 17070 Address 2215 FOREST HILLS DRIVE. HARRISBURG, PA 17112 FRONT OF SUBJECT PROPERTY 701 HILLTOP DRIVE NEW CUMBERLAND, PA 17070 REAR OF SUBJECT PROPERTY STREET SCENE ClickFORMS Appraisal Software 800-622-8727 Page 8 of 13 Ty Eby Real Estale Appraisals SUBJECT PHOTO ADDENDUM File No. WHITE RL 06 Case No. . Borrower WHITE Property Address 701 HILLTOP DRIVE CIlv NEW CUMBERLAND Couolv lender/Clienl MR. GARY ROTHSCHILD. ESQUIRE CUMBERLAND Stale PA Zip Code 17070 Address 2215 FOREST HILLS DRIVE. HARRISBURG, PA 17112 MASTER SHOWER FASCIA GARAGE DOORS ClickFORMS Appraisal Software 800-622-8727 Page of 13 , Borrower WHITE Property Address 701 HILLTOP DRIVE GiN NEW CUMBERLAND County Lender/C1ienl MR. GARY ROTHSCHILD, ESQUIRE Ty Eby Real E.state Appraisals CQMPARABLES 1.2-3 File No. WHITE RL 06 Case No. CUMBERLAND State PA Zip Code 17070 Address 2215 FOREST HILLS DRIVE, HARRISBURG, PA 17112 ClickFORMS Appraisal Software 800-622-8727 COMPARABLE # 1 615 HILLTOP DRIVE NEW CUMBERLAND, PA 17070 COMPARABLE # 2 501 7TH STREET NEW CUMBERLAND, PA 17070 COMPARABLE # 3 345 BLACKLA TCH LANE CAMP HILL. PA 17011 Page 10 of 13 1y Eby Real Estate Appraisals COM PARABLES 4-5.6 File No. WHITE RL 06 Case No. Borrower WHITE Property Address 701 HILLTOP DRIVE City NEW CUMBERLAND County lender/CJienl MR. GARY ROTHSCHILD. ESQUIRE CUMBERLAND Slale PA Zio Gode 17070 Address 2215 FOREST HILI..S DRIVE, HARRISBURG. PA 17112 COMPARABLE # 4 232 WINDING WAY CAMP HILI... PA 17011 COMPARABLE # 5 COMPARABLE # 6 ClickFQRMS Appraisal Software 800-622~8727 Page 11 of 13 . , !y. Eby Real Estate Appraisals SKETCH ADDENDUM File No. WHITE RL 06 Case No. BcIrower WHITE ProperlY Address 701 HILL TOP DRIVE City NEW CUMBERLAN.D County lender/Clienl MR, GARY ROTHSCHILD, ESQUIRE CUMBERLAND Slale PA Zip Code 17070 Mdress 2215 FOREST HILLS DRIVE. HARRISBURG, fA 17112 58.0' 37.0' Kitchen 14.08.0' I 12.0' Laundry Room Dining Closet Dining Room Bedroom B,th Bath - 7.0' B," 29.0' 31.0' 19.0' Bedroom 19.0' FamilyRoom Living Room Bedroom Foyer Bedroom 1<0 37.0' 14.0'.0' I 14.0' 37.0' 58.0' 12.0' 7.0' 29.0' 19.0' 2.0' 37.0' 14.0' SKEJCHCA.LCUlATIOHS PerImeter Aria I ^' A1 :58.0)[ 12.0= 696.0 A2 :51.0x 17.0= 867.0 ~ A3, 14.0x2.0= 28.0 ~ FirstFbor 1591.0 c:J A4 :37.0)[8.0= 296.0 AS : 51.0 x 19.0::: 969.0 A6 : 37.0 x 4.0 = 14B.Q Second Floor 14r~.O 6 A7 :58.0)( 12.0= 696.0 A8 :51.0)(17.0;:; 867.0 A9: 14.0x2.0= 28.0 Baserrent 1591.0 Total Uvlng Area 3004.0 I ClickFORMS AppraIsal Software 800-622-8727 Page 12 of 13 . Ty Eby Real Estate Appraisals LOCATION MAP ADDENDUM File No. WHITE RL 06 Case No. Borrower WHITE Property Address 701 HILLTOP DRIVE City NEW CUMBERLAND County Leoder/Cfient MR. GARY ROTHSCHILD, ESQUIRE CUMBERLAND Stale PA Zip Code 17070 Address 2215 FOREST HILLS DRIVE. HARRISBURG. PA 17112 ,'~ /,-'1 / \\ "},' '~,JI S@'~. \~,\)l.P,3, 1 ..)i .,,"v '\;" .~/ '~'.f '$ }.-...._,-~.____,.,.. _~". ",1 _ff J',' .r-------~..."1 r. ...-_;:_'::) l~ ~7' ,.rj./ .~~, r;:""~. ." .,,->> ~~~ ,.', (, I,' . .~ ""'''''''''''- 1/ '~~::.:\ ~"'''''' ,/j. r(f:/?... '" t ( '. i-;;:' (/ -....; ~~:::::::,'~ . /j/'/ I: 1 ~ , '. "'-;."-~'" , ~06Mj<=~~ilCO.'b04NAYti:Q.W.r(r$t:t. \\ \,,,; ,'"c' ....:.' '. e,.\, . <I I' '~~;::f1:;::). . q ".,.;;" ClickFORMS Appraisal Software 800-622-8727 Page 13 of 13 ,~ ' tv. .,.-. ',~ ; _.,.,.AX.~" ", ..,..:...&;.,.'~""'" ",,': .." ,;:..".;' ~lf~~.; ,.,.:;;;;; ~~~fllU~~ ::~:.: 5'a~iihJ~~!Jm;tUHH~m;!!;:E;;L~"'~11 ~:'~~'E:i:-d1;~:,::;"-",~~,,:""" :~Uflijln~~,,::];H:Hfl: .~~~n:::~mtUrtHiJ~~;:;; \. District arc.IID roperty Addr IfyStateZlp .rDIs Ia 26 26240809447 701 HILLTOP DR NEW CUMBERLAND PA 17070 1723 BOBBY G & L VDIA WHITE JR 9 2620 107 6 Property Type Land Use Code Land Oescription Lot Condo Unit 10 Latlhlde Lon itude Full Report ,~ Owne, Name UallAddr Man Addr2 Subdlvlsion House Number WHITE BOBBY G JR & L YOlA 701 Hili TOP DRIVE NEW CUMBERLAND PA 17070 DREXEL HILLS 701 R RESIDENTIAL BUILDING 101 RESIDENTIAL 1 FAMilY LOT14SEC4BLKKPB11 PG1 4-0014 40.224491 76.880034 Land Value $39,290.00 alai Value $216650.00 ;:m~~._. ~~~,;;~o fJ: Building Valu. Clean And Green Ilmt'_~_ ~~~'::~~ 0034X ;--~..=;.J_~' ~ :Dml:l.ll,p;;.j =2:'~' ear Built Err V..r Built lYing Area SF IRg Area Factor Ing Area Total mltin Factors 1964 1964 2939 62.86 184746 $177,360.00 Deeded Acree Storie. Dwelling Type Sawer Type Road Type Water Source 0.34 2 DETACH PUBUC PAVED PUBLIC 1112218566 G.L. ROTHSCHILD. E5Q ~ B3IB1i2SB6 .1B.:~~" ". I,. d' T.....lIM:~lIC~ .........- " ~r~ \. 3"i p~: Q14f.u Ju1Itutun....;.. , *'t" ". *>>Pa ;. ~ l'tO 1: Ct.:} .... I1ctwtt:ll ~ a-r. ~ ., t>> ,.tu. .f IJiUa.-. .}lU01.. ......;.. In. .. .. a.kd.. .......... ~1... .,.....,.. ....,1.-..1. . '. ~....dller..""').,,(..._f!I'fllJ4 ....,. G. lIId.e.. ,$... ... .IoJil& .~. 1Il.. vtCil ~... ..o-loIIl(I)..ol.....,..,.... .Ilqq.dh ......_" ... PI:.1:J.iiiii ...... .... ~/100 (flU,OOI.OO) ~ IlL....,... ~ ~ ""-""....,.......... ....~"i_...,pt.......... MIl ~ t.1&U$M1r",:... . ".IIIlIIp\ ..~t...,tM..tu.ctH "41J.'ItiS~ r.t: ft~tr..-., 1-' .i...~ lit ~~ .'.w~~.' .....tJ .1 ~C'..... ... RIIt. .t .......,.b...f,c. .... pant:CIILttt,. __... ..C ohHrtNl .. f.1~. t. wit, htDIIW; .. . ""s.t .e:'"" M1'~t an:Q~ Df ~. hC-..1ittft .( lilh.p ~ ... I'_ri... Drl....1 ~ ...tw.~lJ...d.eq"""""'l'thd, U.. .f IS.U_ 11ft.... u. .t.t te ...)llL'Jtl~ ."nialfuC17 do.& th ......-1, U.. t.f 1..1' ... 1S, 111rfJI ..~ .. tk '-QlIIal:.r _U4U4 P,"-. 'J I. t.. . )41""1 t_'" ...t'lat.U)' .1oq tM ,-1:Itrl, u.. of :.ot .... U. .hell K. U'.U faa' t. .. ,..tat ... tW ..U.d7 1111& ,I ""1...- Ildftl t..... ~ ttIIo lat. u.. ~~l,.,... CIll'n t. ~ ript ,-.t.. . 1'..1....' of 210 ,.,.t, .. '" ..u~ '" ".n h.r to & "~I ~Ilt. ...,i-..Ur,l; "'~';41J: .t.. Ik:-tl.. Jrt.. 15.51 fnt Co tIN. ,hee 01 ~. IIDfO t.oI: h. U. .lMk 1(. ,,0" till Ita ..r ....tift ". JInJ;.l .Qt.. q".'''''''3&; nlMJrll.1I fA tM c.Md.. c..ty \I,"".,,'. OffiGll ... to1M)OfIII; u. ,al4l11. lAYIlO UDSW lUcre .. _ lIit.ty ,.....W "'llb, m.. 1toV'lftl ..... ...... .. 701 . .Ult.~I'rf;". U1JO tJM ................. tIItt.U. IIINIII .i. LICI~ ~ kr ..... '-,..... .......r 4. l"~ ... "4..... _ tJIot o.k'r~ DiMIIIItr ........... oUi_ ... ~_ JHIt U.*, tal' U. BOllY."'" bt 'ofllli.. It. Ano14 .... ..... 4. U. ....14:1 D. ..U ....... 4.. 1.1."" Ar;IoU ,.a4ua.uri t'" ..1.4 mu..... Anaollll, tilt ..U W1UIMl ~. .lrMl.f __ * Nl. OIrMT .f tM ...14 ~.. .. /I .-t't'4"'''''' Uqal: " n. nthtu.. .... 4ht l..ut. (~Jd, IS. ""D. I1lIi b.,l will .. <<.~t .... .oht" .. 4.....t r. 'L9tO ., tM ..&t.tat'.f 11111, .f ~rlAd OPDJatT. '...,l....a.1., .... Jo.tun 'l'..t......~.., u...... << hlllUl )iIII4:r. tbt OC..U.. \."i... . \ , i"b I 1tI.......~ ......Plat.0Mtr.~,.. ,)..S__.I!IlIlI!l.........,.. Q.# :,t... ~~~.._,f"". plf/,.;...H.~, ........~.'r..!"....a~..;~;':~..l, ~ :! ill ~ :;Si'" !::C;!j;~ ~ Q- - ",O:-b .~ ~~~ u;r ~E~ ~ ~..~ _..Z~t:..uJ -- . -I........~ ....,/I..,.'..,.~~<;;r() .t:! .t.~_I/..._- . "-'.~1. ....,.... i.'f'M ~,~ ," , . . ~.. "j " ('t": ";:.:( . -.', I-'Pklt. 'OJ ~ Conrad Siegel ACTUARIES 501 Corporale Circle. P.O. Box 5900. Harrisburg, PA 17110-0900 Phone (717) 552-5633 Fax (717) 540-9106 The Employee Benefits Company www.conradsiegel.com ConradM. Siegel,F.SA HarryM.leister,Jr., F.S.A. March 6, 2006 ClydeE. Gingrich, F.S.A. Earl L Mummert, M.A.A.A. David F. Stirling, AS.A. Gary L. Rothschild, Esquire The Law Offices of Gary L. Rothschild Northwood Office Center 2215 Forest Hills Drive, Suite 35 Harrisburg, PA 17112 Robert J. Dolan, A.S.A Robert J. Mrazik, F.SA. David H. Klllick, F.SA Re: Bobby G. White, Jr. JeffreyS. Myers, F.S.A. Thomas L Zimmennan, F.S.A. Dear Mr. Rothschild: Kevin A Erb, F.S.A This is an update to our December 8, 2005, report. You requested that we calculate the present value of benefits using the new PBGC annuity assumptions made effective January I, 2006. Glenn A. Hafer, F .SA. Frank S. Rhodes, F.S.A., A.C.A.S. Holly A. Ross, F.S.A. We were provided with the following information concerning Bobby G. White, Jr.: Janel M. Leymeister, CEBS 1. Date of birth - October 25,1957. MarkA.Bonsall,F.S.A. 2. Service computation date - October 27, 1980. JohnW. Jeflrey, F.S.A. Denise M. Polin, F.S.A. 3. Date married - September 26, 1981. ThomasW.Reese,A.S.A. 4. Date separated - January 12, 2003. Jooatllw O. C!amef. ~.SA 5. Yearly Adjusted Basic Pay as follows: JoIm D. Vargo, f.SA. Robert M. Glus, A.SA As of Pay Period EndiIll! Amount Bruce A Senft, CESS laura V. Hess, A.SA. 12-27-2003 12-25-2004 11-12-2005 $ 95,275 96,760 100,306 Vicki L Delfigatti Currently, Bobby G. White, Jr. is 48 years of age (age nearest birthday). The Civil Service Retirement System (CSRS) is a defined benefit pension plan. The figure that is marital property for divorce purposes is the net present value of the pension earned during the marriage. The pension benefit provided by the Civil Service Retirement System is based upon the final three-year average earnings and the years of service. Based upon l '.==J Conrad Siegel ~ ACTUARIES Gary L. Rothschild, Esquire March 6, 2006 Page 2 the above data, we determined that Bobby G. White, Jr. had accrued a monthly pension as of December 31, 2005, of $3,785. In accordance with our telephone conversation, we made calculations for retirement at 65. The following table shows the present value of the CSRS pension, the coverture fraction, the present value of the CSRS pension earned during the marriage, the present value of the Social Security offset and the net present value of the pension earned during the marriage for retirement at age 65: Present Value Net Present CSRS Pension Present Value Value Pension Retirement Present Value Coverture Earned During Social Security Earned During Age CSRS Pension Fraction Marriage Offset Marriage 65 $246,917 .85 $209,879 $62,170 $147,709 The present value of the CSRS pension is based upon the pension previously indicated of $3,785. Since the pension of $3,785 takes into account .91 of a year of service before the date of marriage and 2.97 years of service after the date of separation, it is necessary to multiply by a "coverture fraction" in order to determine the present value ofthe pension earned during the marriage. The numerator of the "coverture fraction" is 21.30 (the years from the date of marriage until the date of separation) and the denominator is 25.18 (the years from the service computation date until December 31, 2005). Thus, the "coverture fraction" is .85 (21.30 divided by 25.18). The present value of the CSRS pension earned during the marriage was determined by multiplying the present value of the CSRS pension by the coverture fraction. While Bobby G. White, Jr. is covered under the Civil Service Retirement System, he is not covered for Social Security benefits. In accordance with the Cornbleth v. Cornbleth decision, it is necessary to calculate what his Social Security benefit would have been if he had been covered for this benefit. On the basis of the earnings information previously indicated and assuming the previous earnings increased in accordance with the increase in the U.S. average salaries and taking into account an appropriate coverture fraction, the estimated Social Security benefit attributable to the marriage to start at age 65 is $953. The present value of the Social Security offset in the above table is based upon these estimated Social Security benefits. The net present value of the pension earned during the marriage is the excess of the present value of the CSRS pension earned during the marriage over the present value of the Social Security offset. ~ '~ Conrad Siegel ~ ACTUARIES Gary L. Rothschild, Esquire March 6, 2006 Page 3 The Social Security benefit and the pension benefit provided by the Civil Service Retirement System are indexed. What this means is that each year the benefit increases in accordance with the Consumer Price Index. The present value calculations are based on the assumption that the Consumer Price Index would increase at the rate of 2. 75% per year. The Consumer Price Index increased on the average at the rate of 4.39% per year over the last 30 years, 3.03% per year over the last 20 years and 2.51% per year over the last 10 years. The present values have been based upon the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations. The interest rate is 5.70% per year for the first 20 years followed by 4.75% per year. The mortality is in accordance with the 1994 Group Annuity Basic Mortality Table for males with Projection Scale AA to 2016. In our opinion, the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations are appropriate for the purpose of determining the present values. With best regards, Yours sincerely, :) ,~ . ~~l {.~7J~. 0 ' I C/ Harry . Leister, Jr., IF.S.A. ConsUlting Actuary HML:JDC:kad AM~ '..j Jonathan D. Cramer, A.S.A. Consulting Actuary ~ ' APR-10-2006 08:23 PM ~ ! J ! '.~ := ::2 'I, II " ~'\"""'.'''' " '/),': ", 1 .~ l' , . , L , <(;~"": tJ;A I ~:'~ l~:" nfi~.'1 t. .'. ~;~f ..II. z ';' i!f;:- f ..,.11. '" " .'\" i i.. I r" . I :1"11\" 'J:."; ,,'':l~I\Uny 31. 2006 ,_. .e' "1< 'J 'l~':~-7'f 574'~069!5 ...., dll'" .'1" JOIN,. ! "J'.t'.~>" !:,.. II' Iji,'~ LLC .1 ,.. h": \.~' ;' '. r, , 300.387-2331) ., I ' 'I \."\ NASO/SIPC .MP<lH! (,N! Wq:-nMAiION: " 1'.." 'I.' ,j .\ ','{, 11:1 e::TRADE Securities, ;'1 II' 1;1; \" ,.,:(~iV6 two Ilccount ". 'I' '"I!", "." ;"!~I(el;t ~Hlf81l"lont under . (, ','. ,,' '\~Imber reflecting ..:., 1'.1 ;.,;." 1:~I:(Jc:ort"msion,8nd : . . !":,~ : i : ,r Ir.':~ !\fJJtttmltn't chowing " '\ I','~ I rJnven;lon e.ndbQftrif\Q '.1. 1;".,/' _.! 1\j'l1b~r, .L ',1'-;'1'; ,'.I:!:' 1'1 Fli '..800.825-5723 /1000<1111 At A (;lnnce $1,322.47 A.oI01/31/06 " '., \'. ."1 ""', ',.!S f"1 17070.1723 ',t, " . ':1"\ ~ I. ,.);, F,< 10 ElITRADE Cloarlng LlC, 0.:. ').' l. .1 I. .1.>I,!1 , l,it'"I'\ ~.I....C ') ., \", .', ifl.t542 RECE1YED TIME APR. 10, 9:38AM PAGEl Of 6 000Z7S74 01 AT 0.30801 TR 00105 EFADZ203 000100 1,,,11I,,,111,..1,,,11I,,,,,,111.,,1,,1,/,,1/.11,,,,,,//,,,111 BOIlBY G WHITE ... LYDIA D WHITE J1WROS 701 HILLTOP DRIVE NEW CUMBERLAND PA 17070. 1723 II e= !i II!! Securff]fll product. and lI"rvlCtI' fire offl!r~d bV €'~AOE S~elJrltio; 1I.C, SWlJep [)epo.1t ACI;:QUnl Is. bank depoak ItCCOUn! whh e'"1AADE Ollnl(. fl fludaral.avlllQI bank, Membef FDlC. 6.,tt dlpo!llr! aro FOIC-ifl.U(l'ld II" '0 '100,000. Socur)tlos pt'oqUCtl and clllh blll.ne8& other Hum ~~ OtlpoBlt Accoullt fund. arB nol FDIC-Inaured. are "O~ g~lafiJn\eed dtlposltl Of obllWllinnt Q(f"'J'AADE Blink. Inti ...el!lubfec, to i"v8Sllnont rilk, including ponible loti or the p,lnelpel ;nvlJ!ltlld. P.12I3 \\I mA,CHH!JiIt" .... PIe... do not send cash 00114/'11 tenta TOTAL DEPOSIT 0131200b0001 111574106956 ~ APR-10-2006 08:23 PM . - ! g eJ : .1, . . .. 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N :1; K ell 2 ~ ~ . ... 'C ~ oJ> w 0 ~ ... . \IJ . , f ", '(, .--~ D. ~. .) BOBBY G. WHITE, JR., Plaintiff ; IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA I v. : NO. 03-1027 CIVIL ; CNIL ACTION - LAW LYDIA D. WHITE, Defendant ; IN DNORCE PRAECIPE TO WITHDRAW COUNTS TO THE PROTHONOTARY; Please withdraw Counts II, III, and IV of Defendant's Counterclaims in the above-captioned matter. Respectfully submitted, Date: \\-l.\-Ou> ByD.otlli~QLUSL. Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road, Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 Attorney for Defendant r--..) = <=> 0-' o jT'l n I 00 o ." :c! rn:!J -oF;; :DC ,.-~ i :;j~' (,~j~ 0rn ~:::j ~ :0 -< ~ ::It' Q o .:;- BOBBY G. WHITE, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL CIVIL ACTION - LAW LYDIA D. WHITE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under g 3301(C) of the Divorce Code was filed on March 7, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g 4904 relating to unsworn falsification to authorities. Date: )..?.7ttv- /ddp By: Social Security Number: 221-42-2204 ,...., c:::> = c::r> t::l 1""'1 C'J I CO o -n ..... :t:-n m;= -c'J r1'l -::;:]9 ~1~~ )-., -:~ "'~( i :.,c,. en :~ -I> en =< ;po. ::IT.: s> o .r:- BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LAW LYDIA D. WHITE, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301 (C) 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 ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g 4904 relating to unsworn falsification to authorities. Date~~ ~6 S? o en ~ c::::. C:::;, <::r'\ o f"lj {; I CO ~ ~ m::JJ r- ~~Q rr: ~:-}9 ':~)(-l -1-- '9!~ Om -::-1 5:1 -< .::to.. ::z Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 Attorney for Defendant BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 7, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. Date: 11-llrOln By: ~. c.d:t Lydi . D. White, Defendant Social Security No. cXcJ.1- 06- 7 eP/7 o c '" '~.r ~ c;;.? 0" o \-" C"") \ Q:) ~ ~,.,. .,.;,;;.... ~ -' -t: -., rnr=:: --0 i;JJ, -0......;-'"- ~, }1J :..-::. <? c::> .r:" Cara A. Boyanowski, Esquire Supreme Court J.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PAl 711 0 (717) 540-9170 Attorney for Defendant BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 03-1027 CIVIL LYDIA D. WHITE, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(C) 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 I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. Date: li::J IJ - Ql.p By: ~- uid- Lydia f5. White, Defendant J-o..:) (= = 0"' o fT1 rJ I CO o -n ~-n m- -os:; :DO ;~~(~l ;-~~ 1"5,n :;! ;.0 -< ;ct~ _.... -~ is .. o ()1 , . ~ Gary L. Rothschild, Esquire Counsel for Husband AGREEMENT BETWEEN BOBBY G. WHITE, JR. AND LYDIA D. WHITE v3 - /~.;2 7 Cara A. Boyanowski, Esquire Counsel for Wife l . TABLE OF CONTENTS SECTION I: Introduction 3 SECTION II: General Provisions 4 SECTION III: Alimony and Alimony Pendente Lite Provisions and Health Insurance Provisions 10 SECTION IV: Child Custody, Child Support, and Health Insurance Provisions 12 SECTION V: Property Distribution Provisions 14 SECTION VI: Closing Provisions and Execution 22 SECTION I INTRODUCTION THIS AGREEMENT made this 2ZNf> day of /lIol/Ef15€1<. , 2006, by and between BOBBY G. WHITE, JR. ("Husband") and LYDIA D. WHITE ("Wife"). WITNESSETH: WHEREAS, Bobby G. White, Jr., Social Security Number 221-42-2204, was born on October 25, 1957, and currently resides at 23290 Harmon Street, S1. Clair Shores, Michigan 48080. WHEREAS, LydiaD. White, Social Security Number 221-36-7819, was born on September 6, 1958, and currently resides at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania 17070. WHEREAS, the parties hereto are Husband and Wife, having been married on September 26, 1981, in New Castle, New Castle County, Delaware. Wherein thereafter, the parties separated on January 12,2003. WHEREAS, the union of the parties produced six children, namely Bobby White, III, born on February 14, 1987, Erik White, born on September 1, 1988, Annamarie White, born on April 8, 1991, Sarah White, born on August 13, 1993, Andrew White, born on September 5, 1995, and Matthew "Max" White, born on May 22, 1998. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for other good and valuable considerations, Wife and Husband, each intending to be legally bound hereby agrees as follows: SECTION II GENERAL PROVISIONS 1. MUTUAL CONSENT DIVORCE The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of Section 3301 ( c) of the Divorce Code of 1980, as amended and will execute the documents necessary to effectuate a divorce under those provisions concurrently with the execution of this Agreement. 2. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE DECREE The provisions of this Agreement may be incorporated by reference but shall not be deemed merged into any judgment or decree for divorce obtained by either party. This agreement shall survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend that all obligations contained herein shall retain their contractual nature in any enforcement proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement action filed to the divorce complaint. 4. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date, otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to Husband by his attorney, Gary L. Rothschild, Esquire, and to Wife by her attorney, Cara A. Boyanowski, Esquire. The parties acknowledge that they fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and each party acknowledges that there has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective incomes, which has been provided to each party. 7. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS Each party understands that he or she has the right: (I) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 8. BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' mutual assets and all other rights determined by this Agreement shall be subject to Court determination the same as if the parties had never executed this Agreement. 5 . . 9. TAX PROVISIONS The parties believe and agree, and have been so advised by their respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 10. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any contact, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means whatsoever with him or her. 11. MUTUAL RELEASES Except as otherwise expressly provided by this Agreement: A. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either may have or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and 6 . . amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the other not expressly set forth herein. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrations, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities or the other or by way of dower, curtsy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to receive any insurance proceeds at the death of the other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion ofthe other's estate under his or her will, or to act as personal representative or executor if so named by the will ofthe other, whether such will was executed prior or subsequent to this Agreement. C. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. 12. PRESERVATION OF RECORDS Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 7 . . 13. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 14. REMEDIES IN THE EVENT OF A BREACH Any party breaching this Agreement shall be liable to the other party for all costs, including reasonable counsel fees incurred by the non-breaching party to enforce his or her rights under the provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of whether litigation is instituted. In the event of default of any of the provisions of this Agreement by one of the parties, the remedies available to the other are cumulative and include all remedies at law and in equity, including those for breach of contract, under theories or equity, under the Domestic Relations Code as amended, including Section 3105 of the Domestic Relations Code (which includes contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies specifically referred to in this Agreement. 15. LAW OF PENNSYL VANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 16. AGREEMENT BINDING ON HEIRS Except as may otherwise be provided, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assIgns. 17. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 8 . . 18. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (within ten (l0) days at most after demand thereof) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 19. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. 20. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 21. MANNER OF GIVING NOTICE Any notice required by this Agreement to be sent to Husband shall be sent by certified mail, return receipt requested, to Bobby G. White, Jr., 23290 Harmon Street, St. Clair Shores, Michigan 48080, and counsel for Bobby G. White, Jr., or such other address as Husband from time to time may designate in writing. Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return receipt requested, to Lydia D. White, 701 Hilltop Drive, New Cumberland, Pennsylvania, 9 . c 17070, or counsel for Lydia D. White, or such other address as Wife from time to time may designate in writing. 22. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. SECTION III ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS AND HEALTH INSURANCE PROVISIONS 1. ALIMONY A. Amount and Term of Monthly Alimony Payments - Husband shall pay to Wife, commencing on the first day of the first month, following the execution date of this Agreement, for her separate support and maintenance, the sum of Six Hundred ($600.00) Dollars, per month, for a period of fifteen (15) years. All monthly alimony payments shall be made to Wife no later than the first day of each month. Husband and Wife agree that all alimony payments are to be made by direct payment from Husband to Wife, preferably through a direct deposit of funds from Husband's account to Wife's account. The parties acknowledge and agree that the provisions of this Agreement providing for the payment of alimony to Wife by Husband are fair, adequate, and satisfactory and are based upon Wife's actual need, Husband's ability to pay, the duration of the parties' marriage and otherrelevant factors which have been taken into consideration by the parties. The approval of this Agreement by a court of competent jurisdiction in connection with an action in divorce or annulment filed by Husband or Wife shall be deemed an order of the court and may be enforced as provided in 23 Pa.C.S.A. Section 3701. 10 . , B. Modification of Alimony - The parties agree that this award of alimony shall not be modifiable and shall terminate upon the first of the following events: 1) the death of Wife, 2) the death of Husband, 3) the romantic cohabitation of Wife with a member of the opposite sex, 4) the remarriage of Wife, or 5) Husband's complete payment of One Hundred Eight Thousand ($108,000.00) Dollars, which represents one hundred and eighty separate alimony payments. No other conditions shall be the basis for modification or termination of these payments. C. Tax Treatment - These payments shall be income to Wife under Section 71 of the Internal Revenue Code and deductible to Husband under Section 215 of the Internal Revenue Code. 2. SPOUSAL SUPPORT ORDERlHEAL TH INSURANCE PROVISIONS Wife acknowledges that she filed a spousal and child support complaint with the Cumberland County Domestic Relations Office, on or about November 19, 2003, at docket number 0 1055 S 2003 and PACSES Case Number 314105975. Wife agrees, within ten (10) days of the filing ofa final Decree in Divorce, she will notify the Cumberland County Domestic Relations Office, in writing, that the spousal support account should be terminated, effective the first day of the first month, following execution of this Agreement, so as to coincide with the comniencement of Wife's receipt of alimony payments from Husband. Thereafter, Husband's obligation to provide monthly spousal support payments to Wife shall cease, but Husband's obligation to provide monthly child support payments shall continue. The parties also acknowledge in Paragraph Four of the Support Order, Husband is directed to provide health insurance coverage for Wife and pay a portion of her out-of-pocket medical expenses. Wife acknowledges and understands, effective the first day of the first month, following execution of this Agreement, so as to coincide with the commencement of Wife's receipt of alimony payments from Husband, Husband shall no longer be obligated to provide health insurance coverage for Wife or reimburse her for any portion of her out-of-pocket medical expenses. Wife agrees, within ten (10) days of filing of a final Decree in Divorce that she will notify the Cumberland County Domestic Relations Office, in writing, to terminate Husband's obligation to provide health insurance coverage for Wife or reimburse her for any portion of her out-of-pocket medical expenses, effective the first day of the first month, following execution of this Agreement. 11 . . SECTION IV CHILD CUSTODY, CHILD SUPPORT AND EXPENSES, HEAL TH INSURANCE PROVISIONS AND INCOME TAX DEDUCTIONS 1. LEGAL CUSTODY The parties agree that legal custody of their children, Bobby, III, born February 14, 1987, Erik, born September 1, 1988, Annamarie, born April 9, 1991, Sarah, born August 13, 1993, Andrew, born September 5, 1995, and Matthew, born May 22, 1998, shall be shared equally between them. The parties agree that major decisions concerning their children, including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions, which must be made, the party having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional, or authority, and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. 5309. 2. PHYSICAL CUSTODY A. Primary Physical Custody - The parties agree that Wife shall have primary physical custody of the parties' minor children. B. Partial Physical Custody - Husband shall have periods of partial physical custody with the parties' minor children at all times mutually agreeable to the parties. 3. CHILD SUPPORT AND EXPENSES The parties acknowledge and agree that Husband's current net monthly income is 12 approximately $5,274.05 and Wife's current net monthly income is approximately $1,006.25. Utilizing the Pennsylvania Rules of Civil Procedure, as they relate to the Pennsylvania Support Guidelines, and the parties' respective net income levels, Husband agrees to provide Wife with a monthly child support payment of$I,979.86, effective the first day of the first month following the entrance of the parties' Decree in Divorce. These payments shall cease on July 1,2007, at which time, the parties will agree to recalculate Husband's child support obligation, based upon Erik's graduation from high school. Husband's total child support obligation shall be broken down to include a monthly basic child support obligation of$I,625.01 and a montWy credit to Husband in the amount of$40.98 for Wife's share of the children's health insurance premiums paid by Husband. Provided that Wife documents her payment of the following expenses, Husband agrees to provide additional child support as follows: a monthly adjustment of$175.00 which represents Husband's portion, i.e. 84%, of Erik's tuition payment to the Capital Area School for the Arts ($2,100.00/ annual), a monthly adjustment of$175.00 which represents Husband's portion, i.e. 84%, of Sarah's tuition payment to the Prince of Peace School ($2,100.00/ annual), and a monthly adjustment of $45.83 which represents Husband's portion, i.e. 50%, of Max's tuition payment to the Prince of Peace School ($ 550.00/annual). All monthly child "Support payments shall be made by Husband to P ACSES no later than the fifth day of each month. Husband and Wife agree that all child support payments are to be made by direct payment from Husband to P ACSES. 4. HEALTH INSURANCE Husband shall provide health insurance for the parties' children, at the present levels and providing substantially the same benefits as are now in effect, for so long as the children are eligible to receive coverage under his health care plan. In the event Husband's coverage should lapse, or the children are no longer eligible to receive coverage under Husband's plan, the parties agree to cooperate in providing health insurance for the children in the most advantageous manner possible. The parties further agree that Wife shall pay the first $250.00 of out of pocket expenses, per year, per child, and any out of pocket expenses for the children shall be split between the parties, after each child has reached the necessary $250.00 deductible, each and every calendar year, as follows: 84% to be paid by Husband and 16% to be paid by Wife. Wife agrees to pay for such expenses and submit documentation to Husband of the expense and her payment on a quarterly basis so as to spread out Husband's payments throughout the course of the year. 13 . ' SECTION V PROPERTY DISTRIBUTION PROVISIONS 1. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever, abandon any claims, which either may have with respect to the above items, which shall thereafter be the sole and exclusive property of the other. 2. RETIREMENT BENEFITS A. Civil Service Retirement System: Husband is a Participant under the Civil Service Retirement System (hereinafter referred to as Plan). For the purposes of marital property division, Wife is hereby granted a portion of Husband's retirement benefits under the Plan as designated below. Wife's ownership interest in the specified portion of Husband's retirement benefits shall become effective on the Assignment Date, which shall be the date the Decree in Divorce is filed by the court. Effective as of the such Assignment Date, Wife shall be assigned a portion of Husband's retirement benefits, in an amount equal to $40,586.00 commencing as of Husband's benefit commencement date, or Wife's benefit commencement date, if earlier. In the event that the Plan does not permit Wife to receive her benefits in the form of an actuarially equivalent life annuity based on her life expectancy, the form of benefits payable to Wife shall be based on the life expectancy of Husband. Additionally, Husband shall be required to elect his benefits in the form of a Joint and Survivor Annuity in order to provide Wife with postretirement survivorship protection to the extent of Wife's share of Husband's retirement benefits. Husband shall assume responsibility for all payments necessary to make and sustain this election. Further should any early commencement reduction be necessary in the event that Wife 14 . , commences her benefits prior to Husband's Normal Retirement Date under the Plan, such reduction shall be applied to Wife's benefits in accordance with applicable Plan provisions. For purposes of Sections 401(a)(1) and 72 of the Internal Revenue Code, Wife shall be treated as the distributee of any distribution or payments made to her under the terms of the Court Order and, as such, will be required to pay the appropriate federal, state, and local income taxes on such distribution. In the event that the Plan Trustee inadvertently pays to Husband any benefits that are assigned to Wife pursuant to the terms of the Court Order, Husband shall immediately return such payments to the plan administrator. Upon receipt of the repayment, the plan administrator shall issue an amended Form 1099 to Husband so that he is not liable for any income taxes associated with Wife's assigned share of the benefits. In order to effectuate the Assignment provision of this Marital Settlement Agreement regarding the division of Husband's retirement benefits under the Plan, a Court Order shall be prepared by counsel for Husband in accordance with the terms of this Agreement and submitted to the Plan Administrator for processing. Notwithstanding the previous sentence, in the event that Husband predeceases Wife prior to the date that the Court Order is officially approved by the Plan Administrator, it is hereby ordered that the terms and provisions of this Agreement shall, in and of itself, be deemed a Court Order by such Plan Administrator and processed accordingly pursuant to the survivor language contained herein. The court shall retain jurisdiction to amend the provisions contained herein in order to establish and/or maintain the qualified status of the Court Order and to effectuate the original intent of the parties. The court shall also retain jurisdiction to enter such further orders that are just, equitable, and necessary to enforce, secure, and sustain the benefits awarded to Wife, in the event that Husband and/ofthe Plan Administrator fail to comply with any or all of the provisions contained herein. Such further orders may also include, but not be limited to, nunc pro tunc orders or orders that recharacterize the benefits awarded under the Plan to apply to benefits earned by Husband under another plan, as applicable, or orders that award spousal or child support, to the extent necessary to carry out the intentions and provisions of this Agreement. Husband shall not take any actions, affirmative or otherwise, that can circumvent the terms and provisions of this Agreement, or that could diminish or extinguish the rights and entitlements of Wife as set forth herein or under the terms of the Court Order. Should Husband take any action or inaction to the detriment of Wife, Husband shall be required to make sufficient payments directly to Wife to the extent necessary to neutralize the effects of his actions or inactions and to the extent of Wife's full entitlements hereunder. 15 . , B. Wilmington Trust Company Individual Retirement Account and Roth Individual Retirement Account: Wife is the owner of both a traditional Individual Retirement Account (IRA) and a Roth Individual Retirement Account (IRA) through the Wilmington Trust Company. These two retirement accounts shall remain the sole and separate property of Wife and Husband specifically releases and waives any and all interest, claim or right that he may have to these retirement assets. C. Wilmington Trust Company Roth Individual Retirement Account: Husband was the owner of a Roth Individual Retirement Account (IRA) through the Wilmington Trust Company. The parties acknowledge that Husband liquidated these retirement funds in 2004 and received 100% of the funds deposited therein, which were used to payoff marital credit card debt to Wilmington Trust Company. These funds shall remain the sole and separate property of Husband and Wife specifically releases and waives any and all interest, claim or right that she may have to these retirement assets. 3. BANK ACCOUNTS AND CERTIFICATE OF DEPOSIT Husband and Wife are the owners of several bank accounts and a certificate of deposit. Husband and Wife agree that Wife shall retain sole ownership and possession of the following accounts: 1. The jointly titled NCFCU bank accounts, which include savings account number 066429 and checking account number 066429; 2. Wife's NCFCU bank accounts, which include savings account number 071193 and checking account number 071193; 3. The jointly titled Certificate of Deposit. The parties acknowledge that Wife liquidated this asset and received 100% of the funds deposited therein. These funds shall remain the sole and separate property of Wife; 4. Wife's Citizens Bank Savings account number 6246-656825; and 5. The jointly titled Members First bank accounts, which include a savings account, real estate escrow account, holiday club account, and checking account. Husband specifically releases and waives any and all interest, claim or right that he may have in the above listed bank accounts and certificate of deposit, which as of the signing of this Agreement become the sole and separate property of Wife. 16 . , \ f I. , Wife agrees that any bank accounts opened and established by Husband after January 12, 2003, shall remain the sole and separate property of Husband, and Wife waives any interest, right or title that she may have in these accounts and the funds deposited, therein. Furthermore, Husband agrees that any bank accounts opened and established by Wife after January 12,2003, shall remain the sole and separate property of Wife, and Husband waives any interest, right or title that he may have in these accounts and the funds deposited, therein. 4. INVESTMENT ACCOUNTS AND SHARES OF STOCK Husband and Wife are the owners of an investment portfolio and several different shares of stock. Husband and Wife agree that Wife shall retain sole ownership and possession of the following: 1. The jointly titled Harris DirectlEtrade Financial investment account number 5741- 0695; 2. The jointly titled shares of stock held in Coca-Cola Company; 3. Wife's shares of stock held in ConAgra Foods; 4. Wife's shares of stock held in EPB Associates; and 5. Wife's Giant Food StoreslMartins Food shares of stock, which she acquires through a stock purchase plan offered by her employer. Husband specifically releases and waives any and all interest, claim or right that he may have in the above listed investment account and shares of stock, which as of the signing of this Agreement become the sole and separate property of Wife. Husband agrees to execute whatever documents are necessary to transfer the above listed investment account and jointly titled shares of stock into the sole name of Wife. Wife agrees to assume sole responsibility for any federal, state or local tax implications associated with the transfer of the jointly titled investment account and shares of stock into her sole name. 5. AUTOMOBILES Husband and Wife agree that the 1998 Ford Club Van, currently in the possession of Wife, 17 . , . 4 '" ; shall become the sole and separate property of Wife, and Husband waives any right, title or interest he may have in this vehicle. Husband acknowledges that he owned a 1998 Chevrolet Suburban 1500 Sport Utility vehicle during the parties' marriage, which has been traded in to purchase another vehicle. Husband received a trade in value of $8,000.00 for the Suburban. Husband and Wife agree that the trade-in proceeds realized from the 1998 Chevrolet Suburban shall be the sole and separate property of Husband and Wife agrees to waive any right, title, or interest she may have to same. Husband agrees to execute whatever documents are necessary to transfer the above listed vehicle into the sole name of Wife, if necessary. Wife agrees to accept sole responsibility for the personal loan issued by her parents to purchase the 1998 Ford Club Van and agrees to indemnify and hold Husband harmless from such. 6. LIFE INSURANCE Husband was the owner, and insured, of two separate life insurance policies through Prudential Life Insurance Company. The parties acknowledge that Husband liquidated these insurance policies in 2004 and received 100% of the cash surrender values for them. These monies shall remain the sole and separate property of Husband and Wife specifically releases and waives any and all interest, claim or right that she may have to these retirement assets. Wife is the owner, and insured, of one life insurance policy through Prudential Life Insurance Company. This life insurance policy and its cash surrender value, shall become the sole and separate property of Wife. Husband agrees to waive any right, title or interest he may have in this asset and its cash surrender value. Wife shall be responsible for all premiums due upon her policy. Husband is also the owner, and insured, of a group term life insurance policy through his employer. So long as it is available to Husband by his employer, Husband agrees to maintain Wife as the beneficiary under this policy for the current death benefit amount, which is approximately $112,000.00, with a doubling of value in the case of accidental death, until such time as the parties' oldest child, Bobby III, graduates from college. Upon Bobby Ill's graduation date, and each subsequent child's graduation date from high school or college, so long as he or she elects to enroll in college within one year of graduating from high school, Husband may elect to decrease the death benefit amount to be received by Wife by one-sixth, i.e, $18,667.00. When the parties' youngest child graduates from high school, or college, so long as he elects to enroll in college within one year of graduating from high school, the election to maintain Wife as a beneficiary under Husband's group term life insurance policy shall become completely voluntary. Husband shall be responsible 18 . , " .(, . for all premiums due upon this policy until the graduation date of the parties' youngest child from high school or college. Husband agrees to surrender to Wife, upon her request, proof of benefits and beneficiary elections, as designated above. Husband shall be entitled to name additional beneficiaries, should he elect to increase the death benefits or accidental death benefits in excess of the limits currently in place. 7. 2002 AND 2003 FEDERAL INCOME TAX RETURN REFUNDS The parties filed j oint tax returns for the years ending December 31 , 2002 and December 31, 2003. The refund check realized by the parties in 2002 totaled $6,087.00. From this amount, Wife received $4,000.00 and Husband received $2,087.00. The refund check realized by the parties in 2003 totaled $3,539.00. From this amount, Wife received $3,539.00. Husband agrees that all refund monies received by Wife for tax years 2002 and 2003 shall be the sole and separate property of Wife and Husband waives any right, title or interest he may have to same. Furthermore, Wife agrees that all refund monies received by Husband for tax year 2002 shall be the sole and separate property of Husband and Wife waives any right, title or interest she may have to same. 8. CURRENT LIABILITIES The parties are the owners of several jointly titled debts. Wife agrees to assume sole responsibility for the following marital debts, which she agrees to indemnify and hold Husband harmless from: 1. Kohls charge card Approximately $ 800.00 2. Home Depot charge card Approximately $ 2,600.00 3. MBNA America (LL Bean) credit card Approximately $12,000.00 4. Chase (Toys R Us) credit card Approximately $11,000.00 The parties further acknowledge that Wife is in the process of refinancing the first mortgage and home equity loans secured by the Marital Residence into her sole name. Wife shall take all actions necessary to request additional monies from the refinance process in order to satisfy the above listed marital debts. Once these marital debts are satisfied, Wife agrees to close all jointly 19 . , I', J fa 4' ,; titled accounts and destroy the credit and charge cards associated with them. Furthermore, the parties hereto mutually represent to the other that neither of them has incurred any debts in the name of the other not previously disclosed or provided for in this agreement. Each of the parties hereby represents to the other that neither one of them have incurred or contracted for debts in the name of the other or for which the other is or would be legally liable for, after the date of the parties' separation. Both parties hereto mutually agree and promise that neither of them will contract, nor otherwise incur debts in the other's or joint names without the prior permission and consent of the other party hereto. Both parties hereto represent and warrant to the other party that they have not so contracted any debts unbeknownst to the other up to the time and date of this Agreement and hereby indemnify and hold the other party harmless from any such debts. 9. PAYMENT OF LEGAL FEES Each party hereby agrees to be responsible for any legal fees incurred on their behalf. 10. AFTER-ACQUIRED PROPERTY Each ofthe parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired by him or her after the parties' date of separation, that being, January 12,2003, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as through he or she were unmarried. 11. REAL ESTATE A. Marital Residence: The parties acknowledge that they are the owners of real property, titled as tenants by the entireties, located at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania (hereinafter referred to as "Marital Residence"), which is subject to a mortgage through Members First Federal Credit Union and a home equity loan through New Cumberland Federal Credit Union. The parties agree as follows with respect to the Marital Residence: (1) Husband shall execute all documents necessary, including a deed, to transfer all of his right, title and interest in the Marital Residence to Wife, and shall deliver said documents to his counsel. Upon Wife's refinance of the mortgage 20 . . I . 4 . I ,. through Members First Federal Credit Union, the home equity loan through New Cumberland Federal Credit Union and the four debts set forth in Section V, Paragraph 8, ofthis Agreement, Husband's counsel shall transfer said deed to Wife's counsel and thereafter, Wife shall be the sole and separate owner of the Marital Residence. (2) Husband agrees that as of the date of execution of this Agreement, any and all title policies and any other policy of insurance with respect to the Marital Residence shall be endorsed to reflect Wife as the sole owner thereof and further agrees that Wife shall be entitled to receive any payments now or hereafter due under any such insurance policies. (3) Commencing on the execution date of this Agreement, Wife shall be solely responsible for all costs, expenses and liabilities associated with or attributable to the Marital Residence regardless of when the same shall have been incurred including, but not limited to, mortgage payments, equity loan payments, taxes, insurance premiums and maintenance and Wife shall keep Husband and his property, successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, costs or expense, including attorney's fees, which may be incurred in connection with such liabilities and expenses or resulting from Husband's ownership interest in said property. (4) Wife shall take all steps necessary to refinance the Members First Federal Credit Union mortgage, the New Cumberland Federal Credit Union home equity loan, and the four debts set forth in Section V, Paragraph 8, of this Agreement, into her sole name within sixty (60) days of the execution date of this Agreement. Should Wife be unable to refinance these debts as provided herein, Husband shall have the option of making alimony payments to any such debts which become delinquent and said payment shall be considered a direct payment to Wife for which Husband shall receive credit against his obligation under Section III, Paragraph 1, of this Agreement. 21 .. . . 1 ... . . . . SECTION VI CLOSING PROVISIONS AND EXECUTION Each of the parties has carefully read and fully considered this Agreement and all of the statements, terms, conditions, and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on the date indicated below. (;Jill /l !l/brCJ-- Q(lU\ (tjb()y Mow:L WITNESS ~~6 DATE ~"u4 L YD A D. WHITE II-jlJ,-DL., DATE 22 (') ~,~ ~ c~::J ~-:,~ C I'l\ C') 1 c::t) ~~ _,.c.. ~ ~ ::L-n rnc: -f.1~ -I:~": "'-('" ~~~ ~\ . c' iT\ r~) ::,.\ 'i> ~ <2 o ,.n BOBBY G. WHITE, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 03 - 1027 CIVIL LYDIA D. WHITE, Defendant IN DIVORCE ORDER OF COURT \}~ day of ~ AND NOW, this 2006, the economic claims raised in the proceedings having been resolved in accordance with an agreement dated November 22, 2006, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, Q~~ Edgar B. Bayley, P.J. cc: ~y L. Rothschild Attorney for Plaintiff ~a A. Boyanowski Attorney for Defendant ~ ~ I :2 ~,ld 21 :130 900l AH110rJiJi-LCdd 3Hl :10 3~)H:[O-{)jl!:l , Gary L. Rothschild, Esquire Counsel for Husband AGREEMENT BETWEEN BOBBY G. WHITE, JR. AND LYDIA D. WHITE Cara A. Boyanowski, Esquire Counsel for Wife , TABLE OF CONTENTS SECTION I: Introduction 3 SECTION II: General Provisions 4 SECTION III: Alimony and Alimony Pendente Lite Provisions and Health Insurance Provisions 10 SECTION IV: Child Custody, Child Support, and Health Insurance Provisions 12 SECTION V: Property Distribution Provisions 14 SECTION VI: Closing Provisions and Execution 22 SECTION I INTRODUCTION THIS AGREEMENT made this 2ZNJ> day of /!/oVEM act{ , 2006, by and between BOBBY G. WHITE, JR. ("Husband") and LYDIA D. WHITE ("Wife"). WITNESSETH: WHEREAS, Bobby G. White, Jr., Social Security Number 221-42-2204, was born on October 25, 1957, and currently resides at 23290 Harmon Street, St. Clair Shores, Michigan 48080. WHEREAS, Lydia D. White, Social Security Number 221-36-7819, was born on September 6, 1958, and currently resides at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania 17070. WHEREAS, the parties hereto are Husband and Wife, having been married on September 26, 1981, in New Castle, New Castle County, Delaware. Wherein thereafter, the parties separated on January 12,2003. WHEREAS, the union of the parties produced six children, namely Bobby White, III, born on February 14, 1987, Erik White, born on September 1, 1988, Annamarie White, born on April 8, 1991, Sarah White, born on August 13, 1993, Andrew White, born on September 5, 1995, and Matthew "Max" White, born on May 22, 1998. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for other good and valuable considerations, Wife and Husband, each intending to be legally bound hereby agrees as follows: SECTION II GENERAL PROVISIONS 1. MUTUAL CONSENT DIVORCE The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of Section 3301 (c) of the Divorce Code of 1980, as amended and will execute the documents necessary to effectuate a divorce under those provisions concurrently with the execution of this Agreement. 2. EFFECT OF DIVORCE DECREE The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE DECREE The provisions of this Agreement may be incorporated by reference but shall not be deemed merged into any judgment or decree for divorce obtained by either party. This agreement shall survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend that all obligations contained herein shall retain their contractual nature in any enforcement proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement action filed to the divorce complaint. 4. DA TE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date, otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. S. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to Husband by his attorney, Gary L. Rothschild, Esquire, and to Wife by her attorney, Cara A. Boyanowski, Esquire. The parties acknowledge that they fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and each party acknowledges that there has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective incomes, which has been provided to each party. 7. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions ofthis Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 8. BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' mutual assets and all other rights determined by this Agreement shall be subject to Court determination the same as if the parties had never executed this Agreement. 5 9. TAX PROVISIONS The parties believe and agree, and have been so advised by their respective attorneys, that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her federal or state income tax returns. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaidjoint returns. 10. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any contact, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means whatsoever with him or her. 11. MUTUAL RELEASES Except as otherwise expressly provided by this Agreement: A. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either may have or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and 6 amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the other not expressly set forth herein. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrations, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities or the other or by way of dower, curtsy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to receive any insurance proceeds at the death ofthe other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest or residuary portion of the other's estate under his or her will, or to act as personal representative or executor if so named by the will of the other, whether such will was executed prior or subsequent to this Agreement. C. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. 12. PRESERVATION OF RECORDS Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 7 13. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 14. REMEDIES IN THE EVENT OF A BREACH Any party breaching this Agreement shall be liable to the other party for all costs, including reasonable counsel fees incurred by the non-breaching party to enforce his or her rights under the provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of whether litigation is instituted. In the event of default of any of the provisions of this Agreement by one of the parties, the remedies available to the other are cumulative and include all remedies at law and in equity, including those for breach of contract, under theories or equity, under the Domestic Relations Code as amended, including Section 3105 of the Domestic Relations Code (which includes contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies specifically referred to in this Agreement. 15. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsy I vania. 16. AGREEMENT BINDING ON HEIRS Except as may otherwise be provided, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and aSSIgns. 17. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 8 18. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most after demand thereof) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 19. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. 20. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision ofthis Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 21. MANNER OF GIVING NOTICE Any notice required by this Agreement to be sent to Husband shall be sent by certified mail, return receipt requested, to Bobby G. White, Jr., 23290 Harmon Street, St. Clair Shores, Michigan 48080, and counsel for Bobby G. White, Jr., or such other address as Husband from time to time may designate in writing. Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return receipt requested, to Lydia D. White, 701 Hilltop Drive, New Cumberland, Pennsylvania, 9 17070, or counsel for Lydia D. White, or such other address as Wife from time to time may designate in writing. 22. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. SECTION III ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS AND HEALTH INSURANCE PROVISIONS 1. ALIMONY A. Amount and Term of Monthly Alimony Payments - Husband shall pay to Wife, commencing on the first day of the first month, following the execution date of this Agreement, for her separate support and maintenance, the sum of Six Hundred ($600.00) Dollars, per month, for a period of fifteen (15) years. All monthly alimony payments shall be made to Wife no later than the first day of each month. Husband and Wife agree that all alimony payments are to be made by direct payment from Husband to Wife, preferably through a direct deposit of funds from Husband's account to Wife's account. The parties acknowledge and agree that the provisions of this Agreement providing for the payment of alimony to Wife by Husband are fair, adequate, and satisfactory and are based upon Wife's actual need, Husband's ability to pay, the duration of the parties' marriage and other relevant factors which have been taken into consideration by the parties. The approval of this Agreement by a court of competent jurisdiction in connection with an action in divorce or annulment filed by Husband or Wife shall be deemed an order of the court and may be enforced as provided in 23 Pa.C.S.A. Section 3701. 10 B. Modification of Alimony - The parties agree that this award of alimony shall not be modifiable and shall terminate upon the first of the following events: 1) the death of Wife, 2) the death of Husband, 3) the romantic cohabitation of Wife with a member of the opposite sex, 4) the remarriage of Wife, or 5) Husband's complete payment of One Hundred Eight Thousand ($108,000.00) Dollars, which represents one hundred and eighty separate alimony payments. No other conditions shall be the basis for modification or termination of these payments. C. Tax Treatment - These payments shall be income to Wife under Section 71 of the Internal Revenue Code and deductible to Husband under Section 215 of the Internal Revenue Code. 2. SPOUSAL SUPPORT ORDERlHEALTH INSURANCE PROVISIONS Wife acknowledges that she filed a spousal and child support complaint with the Cumberland County Domestic Relations Office, on or about November 19,2003, at docket number 01 055 S 2003 and PACSES Case Number 314105975. Wife agrees, within ten (10) days of the filing ofa final Decree in Divorce, she will notify the Cumberland County Domestic Relations Office, in writing, that the spousal support account should be terminated, effective the first day of the first month, following execution of this Agreement, so as to coincide with the commencement of Wife's receipt of alimony payments from Husband. Thereafter, Husband's obligation to provide monthly spousal support payments to Wife shall cease, but Husband's obligation to provide monthly child support payments shall continue. The parties also acknowledge in Paragraph Four of the Support Order, Husband is directed to provide health insurance coverage for Wife and pay a portion of her out-of-pocket medical expenses. Wife acknowledges and understands, effective the first day of the first month, following execution of this Agreement, so as to coincide with the commencement of Wife's receipt of alimony payments from Husband, Husband shall no longer be obligated to provide health insurance coverage for Wife or reimburse her for any portion of her out-of-pocket medical expenses. Wife agrees, within ten (10) days of filing of a final Decree in Divorce that she will notify the Cumberland County Domestic Relations Office, in writing, to terminate Husband's obligation to provide health insurance coverage for Wife or reimburse her for any portion of her out-of-pocket medical expenses, effective the first day of the first month, following execution of this Agreement. 11 , , SECTION IV CHILD CUSTODY, CHILD SUPPORT AND EXPENSES, HEAL TH INSURANCE PROVISIONS AND INCOME TAX DEDUCTIONS 1. LEGAL CUSTODY The parties agree that legal custody of their children, Bobby, III, born February 14, 1987, Erik, born September 1, 1988, Annamarie, born April 9, 1991, Sarah, born August 13, 1993, Andrew, born September 5, 1995, and Matthew, born May 22, 1998, shall be shared equally between them. The parties agree that major decisions concerning their children, including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the party then having physical custody. With regard to any emergency decisions, which must be made, the party having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that party shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional, or authority, and to have copies of any reports given to either party as a parent pursuant to 23 Pa.C.S. 5309. 2. PHYSICAL CUSTODY A. Primary Physical Custody - The parties agree that Wife shall have primary physical custody of the parties' minor children. B. Partial Physical Custody - Husband shall have periods of partial physical custody with the parties' minor children at all times mutually agreeable to the parties. 3. CHILD SUPPORT AND EXPENSES The parties acknowledge and agree that Husband's current net monthly income is 12 , I approximately $5,274.05 and Wife's current net monthly income is approximately $1,006.25. Utilizing the Pennsylvania Rules of Civil Procedure, as they relate to the Pennsylvania Support Guidelines, and the parties' respective net income levels, Husband agrees to provide Wife with a monthly child support payment of $1,979.86, effective the first day of the first month following the entrance of the parties' Decree in Divorce. These payments shall cease on July 1,2007, at which time, the parties will agree to recalculate Husband's child support obligation, based upon Erik's graduation from high school. Husband's total child support obligation shall be broken down to include a monthly basic child support obligation of$I,625.01 and a monthly credit to Husband in the amount of$40.98 for Wife's share of the children's health insurance premiums paid by Husband. Provided that Wife documents her payment of the following expenses, Husband agrees to provide additional child support as follows: a monthly adjustment of$175.00 which represents Husband's portion, i.e. 84%, of Erik's tuition payment to the Capital Area School for the Arts ($2,100.001 annual), a monthly adjustment of$175.00 which represents Husband's portion, i.e. 84%, of Sarah's tuition payment to the Prince of Peace School ($2,100.001 annual), and a monthly adjustment of $45.83 which represents Husband's portion, i.e. 50%, of Max's tuition payment to the Prince of Peace School ($ 550.00/annual). All monthly child support payments shall be made by Husband to P ACSES no later than the fifth day of each month. Husband and Wife agree that all child support payments are to be made by direct payment from Husband to PACSES. 4. HEALTH INSURANCE Husband shall provide health insurance for the parties' children, at the present levels and providing substantially the same benefits as are now in effect, for so long as the children are eligible to receive coverage under his health care plan. In the event Husband's coverage should lapse, or the children are no longer eligible to receive coverage under Husband's plan, the parties agree to cooperate in providing health insurance for the children in the most advantageous manner possible. The parties further agree that Wife shall pay the first $250.00 of out of pocket expenses, per year, per child, and any out of pocket expenses for the children shall be split between the parties, after each child has reached the necessary $250.00 deductible, each and every calendar year, as follows: 84% to be paid by Husband and 16% to be paid by Wife. Wife agrees to pay for such expenses and submit documentation to Husband of the expense and her payment on a quarterly basis so as to spread out Husband's payments throughout the course of the year. 13 . , SECTION V PROPERTY DISTRIBUTION PROVISIONS 1. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever, abandon any claims, which either may have with respect to the above items, which shall thereafter be the sole and exclusive property of the other. 2. RETIREMENT BENEFITS A. Civil Service Retirement System: Husband is a Participant under the Civil Service Retirement System (hereinafter referred to as Plan). For the purposes of marital property division, Wife is hereby granted a portion of Husband's retirement benefits under the Plan as designated below. Wife's ownership interest in the specified portion of Husband's retirement benefits shall become effective on the Assignment Date, which shall be the date the Decree in Divorce is filed by the court. Effective as of the such Assignment Date, Wife shall be assigned a portion of Husband's retirement benefits, in an amount equal to $40,586.00 commencing as of Husband's benefit commencement date, or Wife's benefit commencement date, if earlier. In the event that the Plan does not permit Wife to receive her benefits in the form of an actuarially equivalent life annuity based on her life expectancy, the form of benefits payable to Wife shall be based on the life expectancy of Husband. Additionally, Husband shall be required to elect his benefits in the form of a Joint and Survivor Annuity in order to provide Wife with postretirement survivorship protection to the extent of Wife's share of Husband's retirement benefits. Husband shall assume responsibility for all payments necessary to make and sustain this election. Further should any early commencement reduction be necessary in the event that Wife 14 , . commences her benefits prior to Husband's Normal Retirement Date under the Plan, such reduction shall be applied to Wife's benefits in accordance with applicable Plan provisions. For purposes of Sections 401(a)(1) and 72 of the Internal Revenue Code, Wife shall be treated as the distributee of any distribution or payments made to her under the terms of the Court Order and, as such, will be required to pay the appropriate federal, state, and local income taxes on such distribution. In the event that the Plan Trustee inadvertently pays to Husband any benefits that are assigned to Wife pursuant to the terms ofthe Court Order, Husband shall immediately return such payments to the plan administrator. Upon receipt of the repayment, the plan administrator shall issue an amended Form 1099 to Husband so that he is not liable for any income taxes associated with Wife's assigned share of the benefits. In order to effectuate the Assignment provision of this Marital Settlement Agreement regarding the division of Husband's retirement benefits under the Plan, a Court Order shall be prepared by counsel for Husband in accordance with the terms of this Agreement and submitted to the Plan Administrator for processing. Notwithstanding the previous sentence, in the event that Husband predeceases Wife prior to the date that the Court Order is officially approved by the Plan Administrator, it is hereby ordered that the terms and provisions of this Agreement shall, in and of itself, be deemed a Court Order by such Plan Administrator and processed accordingly pursuant to the survivor language contained herein. The court shall retain jurisdiction to amend the provisions contained herein in order to establish and/or maintain the qualified status of the Court Order and to effectuate the original intent of the parties. The court shall also retain jurisdiction to enter such further orders that are just, equitable, and necessary to enforce, secure, and sustain the benefits awarded to Wife, in the event that Husband and/ofthe Plan Administrator fail to comply with any or all of the provisions contained herein. Such further orders may also include, but not be limited to, nunc pro tunc orders or orders that recharacterize the benefits awarded under the Plan to apply to benefits earned by Husband under another plan, as applicable, or orders that award spousal or child support, to the extent necessary to carry out the intentions and provisions of this Agreement. Husband shall not take any actions, affirmative or otherwise, that can circumvent the terms and provisions of this Agreement, or that could diminish or extinguish the rights and entitlements of Wife as set forth herein or under the terms of the Court Order. Should Husband take any action or inaction to the detriment of Wife, Husband shall be required to make sufficient payments directly to Wife to the extent necessary to neutralize the effects of his actions or inactions and to the extent of Wife's full entitlements hereunder. 15 t .. I B. Wilmington Trust Company Individual Retirement Account and Roth Individual Retirement Account: Wife is the owner of both a traditional Individual Retirement Account (IRA) and a Roth Individual Retirement Account (IRA) through the Wilmington Trust Company. These two retirement accounts shall remain the sole and separate property of Wife and Husband specifically releases and waives any and all interest, claim or right that he may have to these retirement assets. C. Wilmington Trust Company Roth Individual Retirement Account: Husband was the owner of a Roth Individual Retirement Account (IRA) through the Wilmington Trust Company. The parties acknowledge that Husband liquidated these retirement funds in 2004 and received 100% of the funds deposited therein, which were used to pay off marital credit card debt to Wilmington Trust Company. These funds shall remain the sole and separate property of Husband and Wife specifically releases and waives any and all interest, claim or right that she may have to these retirement assets. 3. BANK ACCOUNTS AND CERTIFICATE OF DEPOSIT Husband and Wife are the owners of several bank accounts and a certificate of deposit. Husband and Wife agree that Wife shall retain sole ownership and possession of the following accounts: 1. The jointly titled NCFCU bank accounts, which include savings account number 066429 and checking account number 066429; 2. Wife's NCFCU bank accounts, which include savings account number 071193 and checking account number 071193; 3. The jointly titled Certificate of Deposit. The parties acknowledge that Wife liquidated this asset and received 100% of the funds deposited therein. These funds shall remain the sole and separate property of Wife; 4. Wife's Citizens Bank Savings account number 6246-656825; and 5. The jointly titled Members First bank accounts, which include a savings account, real estate escrow account, holiday club account, and checking account. Husband specifically releases and waives any and all interest, claim or right that he may have in the above listed bank accounts and certificate of deposit, which as of the signing of this Agreement become the sole and separate property of Wife. 16 . I' Wife agrees that any bank accounts opened and established by Husband after January 12, 2003, shall remain the sole and separate property of Husband, and Wife waives any interest, right or title that she may have in these accounts and the funds deposited, therein. Furthermore, Husband agrees that any bank accounts opened and established by Wife after January 12,2003, shall remain the sole and separate property of Wife, and Husband waives any interest, right or title that he may have in these accounts and the funds deposited, therein. 4. INVESTMENT ACCOUNTS AND SHARES OF STOCK Husband and Wife are the owners of an investment portfolio and several different shares of stock. Husband and Wife agree that Wife shall retain sole ownership and possession of the following: 1. The jointly titled Harris Direct/Etrade Financial investment account number 5741- 0695; 2. The jointly titled shares of stock held in Coca-Cola Company; 3. Wife's shares of stock held in ConAgra Foods; 4. Wife's shares of stock held in EPB Associates; and 5. Wife's Giant Food Stores/Martins Food shares of stock, which she acquires through a stock purchase plan offered by her employer. Husband specifically releases and waives any and all interest, claim or right that he may have in the above listed investment account and shares of stock, which as of the signing of this Agreement become the sole and separate property of Wife. Husband agrees to execute whatever documents are necessary to transfer the above listed investment account and jointly titled shares of stock into the sole name of Wife. Wife agrees to assume sole responsibility for any federal, state or local tax implications associated with the transfer of the jointly titled investment account and shares of stock into her sole name. 5. AUTOMOBILES Husband and Wife agree that the 1998 Ford Club Van, currently in the possession of Wife, 17 .. f' . shall become the sole and separate property of Wife, and Husband waives any right, title or interest he may have in this vehicle. Husband acknowledges that he owned a 1998 Chevrolet Suburban 1500 Sport Utility vehicle during the parties' marriage, which has been traded in to purchase another vehicle. Husband received a trade in value of $8,000.00 for the Suburban. Husband and Wife agree that the trade-in proceeds realized from the 1998 Chevrolet Suburban shall be the sole and separate property of Husband and Wife agrees to waive any right, title, or interest she may have to same. Husband agrees to execute whatever documents are necessary to transfer the above listed vehicle into the sole name of Wife, if necessary. Wife agrees to accept sole responsibility for the personal loan issued by her parents to purchase the 1998 Ford Club Van and agrees to indemnify and hold Husband harmless from such. 6. LIFE INSURANCE Husband was the owner, and insured, of two separate life insurance policies through Prudential Life Insurance Company. The parties acknowledge that Husband liquidated these insurance policies in 2004 and received 100% of the cash surrender values for them. These monies shall remain the sole and separate property of Husband and Wife specifically releases and waives any and all interest, claim or right that she may have to these retirement assets. Wife is the owner, and insured, of one life insurance policy through Prudential Life Insurance Company. This life insurance policy and its cash surrender value, shall become the sole and separate property of Wife. Husband agrees to waive any right, title or interest he may have in this asset and its cash surrender value. Wife shall be responsible for all premiums due upon her policy. Husband is also the owner, and insured, of a group term life insurance policy through his employer. So long as it is available to Husband by his employer, Husband agrees to maintain Wife as the beneficiary under this policy for the current death benefit amount, which is approximately $112,000.00, with a doubling of value in the case of accidental death, until such time as the parties' oldest child, Bobby III, graduates from college. Upon Bobby Ill's graduation date, and each subsequent child's graduation date from high school or college, so long as he or she elects to enroll in college within one year of graduating from high school, Husband may elect to decrease the death benefit amount to be received by Wife by one-sixth, i.e, $18,667.00. When the parties' youngest child graduates from high school, or college, so long as he elects to enroll in college within one year of graduating from high school, the election to maintain Wife as a beneficiary under Husband'segroup term life insurance policy shall become completely voluntary. Husband shall be responsible 18 f: ,4 . for all premiums due upon this policy until the graduation date of the parties' youngest child from high school or college. Husband agrees to surrender to Wife, upon her request, proof of benefits and beneficiary elections, as designated above. Husband shall be entitled to name additional beneficiaries, should he elect to increase the death benefits or accidental death benefits in excess of the limits currently in place. 7. 2002 AND 2003 FEDERAL INCOME TAX RETURN REFUNDS The parties filed j oint tax returns for the years ending December 31 , 2002 and December 31, 2003. The refund check realized by the parties in 2002 totaled $6,087.00. From this amount, Wife received $4,000.00 and Husband received $2,087.00. The refund check realized by the parties in 2003 totaled $3,539.00. From this amount, Wife received $3,539.00. Husband agrees that all refund monies received by Wife for tax years 2002 and 2003 shall be the sole and separate property of Wife and Husband waives any right, title or interest he may have to same. Furthermore, Wife agrees that all refund monies received by Husband for tax year 2002 shall be the sole and separate property of Husband and Wife waives any right, title or interest she may have to same. 8. CURRENT LIABILITIES The parties are the owners of several jointly titled debts. Wife agrees to assume sole responsibility for the following marital debts, which she agrees to indemnify and hold Husband harmless from: 1. Kohls charge card Approximately $ 800.00 2. Home Depot charge card Approximately $ 2,600.00 3. MBNA America (LL Bean) credit card Approximately $12,000.00 4. Chase (Toys R Us) credit card Approximately $11,000.00 The parties further acknowledge that Wife is in the process of refinancing the first mortgage and home equity loans secured by the Marital Residence into her sole name. Wife shall take all actions necessary to request additional monies from the refinance process in order to satisfy the above listed marital debts. Once these marital debts are satisfied, Wife agrees to close all jointly 19 .... . I . titled accounts and destroy the credit and charge cards associated with them. Furthermore, the parties hereto mutually represent to the other that neither of them has incurred any debts in the name of the other not previously disclosed or provided for in this agreement. Each of the parties hereby represents to the other that neither one of them have incurred or contracted for debts in the name of the other or for which the other is or would be legally liable for, after the date of the parties' separation. Both parties hereto mutually agree and promise that neither of them will contract, nor otherwise incur debts in the other's or joint names without the prior permission and consent of the other party hereto. Both parties hereto represent and warrant to the other party that they have not so contracted any debts unbeknownst to the other up to the time and date of this Agreement and hereby indemnify and hold the other party harmless from any such debts. 9. PAYMENT OF LEGAL FEES Each party hereby agrees to be responsible for any legal fees incurred on their behalf. 10. AFTER-ACQUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired by him or her after the parties' date of separation, that being, January 12,2003, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as through he or she were unmarried. 11. REAL ESTATE A. Marital Residence: The parties acknowledge that they are the owners of real property, titled as tenants by the entireties, located at 701 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania (hereinafter referred to as "Marital Residence"), which is subject to a mortgage through Members First Federal Credit Union and a home equity loan through New Cumberland Federal Credit Union. The parties agree as follows with respect to the Marital Residence: (1) Husband shall execute all documents necessary, including a deed, to transfer all of his right, title and interest in the Marital Residence to Wife, and shall deliver said documents to his counsel. Upon Wife's refinance of the mortgage 20 '\ . ~ ~ through Members First Federal Credit Union, the home equity loan through New Cumberland Federal Credit Union and the four debts set forth in Section V, Paragraph 8, of this Agreement, Husband's counsel shall transfer said deed to Wife's counsel and thereafter, Wife shall be the sole and separate owner of the Marital Residence. (2) Husband agrees that as of the date of execution of this Agreement, any and all title policies and any other policy of insurance with respect to the Marital Residence shall be endorsed to reflect Wife as the sole owner thereof and further agrees that Wife shall be entitled to receive any payments now or hereafter due under any such insurance policies. (3) Commencing on the execution date of this Agreement, Wife shall be solely responsible for all costs, expenses and liabilities associated with or attributable to the Marital Residence regardless of when the same shall have been incurred including, but not limited to, mortgage payments, equity loan payments, taxes, insurance premiums and maintenance and Wife shall keep Husband and his property, successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, costs or expense, including attorney's fees, which may be incurred in connection with such liabilities and expenses or resulting from Husband's ownership interest in said property. (4) Wife shall take all steps necessary to refinance the Members First Federal Credit Union mortgage, the New Cumberland Federal Credit Union home equity loan, and the four debts set forth in Section V, Paragraph 8, of this Agreement, into her sole name within sixty (60) days of the execution date of this Agreement. Should Wife be unable to refinance these debts as provided herein, Husband shall have the option of making alimony payments to any such debts which become delinquent and said payment shall be considered a direct payment to Wife for which Husband shall receive credit against his obligation under Section III, Paragraph 1, of this Agreement. 21 <if L . . SECTION VI CLOSING PROVISIONS AND EXECUTION Each of the parties has carefully read and fully considered this Agreement and all of the statements, terms, conditions, and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals on the date indicated below. ~* J7 ttlb7?----- QWtClJbc4MomL WITNESS ~/l 2ttJ6 DAT ~ "1M L YD A D. WHITE II-I~~O~ DATE 22 BOBBY G. WHITE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1027 CIVIL : CIVIL ACTION - LA W LYDIA D. WHITE, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD '- TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service by counsel for Defendant on March 9,2005. 3. Date of execution ofthe affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff 11/22/06; By Defendant 11/16/06. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: 12/8/06; Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: 12/8/06. Respectfully submitted, ~ -'--~.' Date: I~t By: G L. Rothschild, Esquire Supreme Court I.D. No. 62041 2215 Forest Hills Drive, Suite 35 Northwood Office Center Harrisburg, P A 17112 (717) 540-3510 Attorney for Plaintiff ------- r-' c'::) l~ C...... C'J en r:~ r, "'r1 .-\ '1: -n ~-'l1E~ _))1 '<C) CD -'ei .-.: .~r;: C? ~ (..-) ~.--~, rr. -~;~ ~ ",~-.~~ - ;+;~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BOBBY G. WHITE, JR., Plaintiff No. 03-1027 CIVIL VERSUS LYDIA D. WHITE, Defendant DECREE IN DIVORCE '- p~\C?j ~hlT IS ORDERED AND AND NOW, BOBBY G. WHITE, JR. , PLAI NTI FF, DECREED THAT AND LYDIA D. WHITE , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. Further, the Matrimonial Settlement Agreement, executed by the parties and dated November 22, 2006, attached hereto, is incorporated herein for purposes of enforcement but shall not be merged into said Decree. The parties are ordere 0 y with the erms 0 sa! greement. ./"" .4.AA.~ .. ~ "" PROTHONOTARY J. ./ ., ?~'f/ ~'f' ~::M1 '7"",/,,12 ! ( c17 /r~#'c/ (,.t;i7 1- Aff'-;"'/f~) .l~) ,7/ Ie' e '- ;f' / /r r ' [/ .v / ~ I