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Home My WebLink About03-1077 .. KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 03 -/C;77 ~ : CIVIL ACTION - LA W : IN DIVORCE LARRY L. HARMAN, Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, One Courthouse Square, Carlisle, Pennsylvania. 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 RlGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty A venue Carlisle, Pelillsylvania 17013 Phone: (717) 249-3166 ~~ Susan M. Kadel, Esquire -----. Attorney for Plaintiff ..._~-~_.",_.-..- ....,_.__..,-_.""'-._'~--'-".__.....~_...._.,.~-~. . . j , KELL! S. HARMAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA ; NO. 0:1 ~ f~77 LARRY L. HARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Comi require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. #/ ~'~4 Prothonotary /.R? I ' KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 19:1."" /017 LARRY L. HARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Kelly S. Harman, social security no. 205-56-4114, who currently resides at 4902 Carlisle Pike, Unit 22B, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Larry L. Hannan, social security no. 171-60-3234, who currently resides at 36 Pine Road, Abbottstown, Adams County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on Decem ber 29, 1991, in Bellefonte, Centre County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Amled Services of the United States of America or its Allies. 8. The maJTiage is irretrievably broken. \ "'"--'-.~'-""" ,.-.-.-",,'-- ~-,.......,...........;..... ~ -""";jri-~~,.",,,-~,"..."...,, ",-, . --,~"""~~~_",--_",,,,,,,,,,,,,,,,,_',,,..........--........_~~..."~_._-- ... VERIFICA TION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: d Jrl-~ /0 ~ I L X~QL 2 ~ (;(AiM ~ Kelli _ Hannan ~. ".~~-~~~_.._,-----"...._....~,... \ ' ~~ ~~ " ~ ~ ~ ~ t, ~ " ~ V\. ~ ~ ,,~ 0&~ ) \\ , , ;. ~l~ ~ \ n ~~~~; a ,_ , -ri ('-~ ~~;( ~<' ~ KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 03-1077 LARRY L. HARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Larry L. Hannan, Defendant herein, accept service of the Divorce Complaint served upon me in the above-referenced matter. Date: March 15, 2003 L tJ ~<<- Latty L. mmnan, efendant 36 Pine Road Abbottstown, P A 17301 KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. 03-1077 Civil v. LARRY L. HARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March II, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301{c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. !l4904, relating to unsworn falsification to authorities. Date: 5) ,1 104 j/ t ~~ ~man, De endant ~.., ~~ :;..- c_ '- I C') o -n ~-I T-n rl1p :~2J ~J~)i 0c_.) ~ ') i " ' , Co,) CJ~ KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 03-1077 Civil LARRY L. HARMAN, Defendant : CIVIL ACTION -- LAW : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on March 11,2003. 2. The marriage of the Plaintiff and Defendant is irfl~trievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice ofIntention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904, relating to unsworn falsification to authorities. Date: <<>-/00Y KJ..U; "~. ~CVVV\;lAo,_L. Kelli S. Harman, Plaintiff a S; -::.~~ -oe' rl"!r; -7..' ,..., = = .c- L. S;; co ~ -t ::C-n n1-::= Fn =39 <::>0 ~!H~ ,.~{ ~ CJ (.n ~:5 ::< KELLI S. HARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 03-1077 LARRY 1. HARMAN, Defendant : CIVIL ACTION .. LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following informatlon, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section (XX) 3301(c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: March 15,2003; Acceptance of Service signed by the Defendant. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 330l(c) of the Divorce Code: by Plaintiff: June 14,2004; by Defendant: May 13,2004. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: All claims have been settled pursuant to a Postnuptial Agreement dated June 7, 2004. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: 6. Date and manner of service of Notice ofIntention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: June 14, 2004; by Defendant: May 13, 2004. and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: Plaintiff's Waiver is being filed simultaneously with this Praecipe; Defendant's Waiver was filed on June 8, 2004. JAMES, SMITH, DIETTERICK & CONNELLY LLP Date: ~ /7. d)CJOLj , / ~&J Susan . adel, Esquire Attorney for PlaintiJf Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA J.D. No. 44837 (") f~; ~g; -::-: :..;:,.. (i~ ;,:;;, ~.- "" = ~"" ...- <- C :d!: o -n .--< :1:11 rn-~ Fn ]19 S~-{Q =:::--d ~'=';(') r':')r-n ~~~1 "";:, ~: 0) ~ o ""n . . . . "':Ii :to '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF KELLI S. HARMAN, Plaintiff . VERSUS LARRY L. HARMAN, . Defendant . PENNA. No. 03-1077 DECREE IN DIVORCE AND NOW, jUIM- ~t:P"\. , '"2-J DECREED THAT K"ll i So Hi'lrm;m AND Larrv L. Harman ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 ATTES~~~~ , - - PROTHONOTARY J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~p .~ ~/ ~/{, /IV fir: 'l ~ p~~ ~ /p/;rJ.lC'-t'j . .. ~ '-,' ..., ,- >, ~" ',."'" ',. F:\FILESIDA T AFILE\GeneraIlCurrentI11796.1.petltJona Created: 9/20104 0;06PM Revised;,11/14/05 4;36PM " " '. '. Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE PETITION TO ENFORCE POSTNUPTIAL AGREEMENT AND FOR BREACH OF CONTRACT AND NOW, comes Petitioner, Larry L. Hannan, by and through his attorney, Jennifer L. Spears, brings this Petition to Enforce Postnuptial Agreement and for Breach of Contract and, in support thereof, avers as follows: I. Petitioner is Larry Harman, who was the Defendant in a divorce action between the parties. 2. Respondent is Kelli S. Harman, who was the Plaintiff in that action. 3. The parties were married on December 29, 1990, and separated on January 5,2003. 4. A Postnuptial Agreement was entered into by the parties on June 7, 2004, a copy of which is attached hereto as Exhibit "A, " which provided in part, the following: 6. REAL PROPERTY. . . Wife agrees to pay to Husband the sum of Thirty-Five Thousand ($35,000.00) Dollars at the time of Husband's execution of the Deed. In exchange for Husband's transfer of his interest in the marital Home to Wife, Wife shall pay one additional lump sum to Husband of Twenty Thousand ($20,000.00) Dollars payable within one (I) year of Husband's receipt of the first lump sum payment. " " " " In the event Wife fails to make the aforementioned payment when due and Husband retains counsel to assist in enforcing the terms thereof, Wife agrees that she will pay all attorney's fees, court costs and expenses that are incurred by Husband in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific agreement and intent of the parties that Wife shall bear the obligation of any and all costs, expenses and counsel fees incurred by Husband in protecting and enforcing his rights under this Agreement. 5. Petitioner received the first installment of $35,000.00 in June 2004. 6. A final Decree in Divorce was issued on June 23, 2004, by the Honorable Edgar B. Bayley, and a copy is attached hereto as Exhibit "B." 7. Respondent has failed to pay Petitioner the agreed upon sums, despite Petitioner's willingness to set up a payment plan with her. 8. Respondent is in breach ofthe parties' contract for failing to comply with the terms of Paragraph six (6) of the Postnuptial Agreement. 9. Respondent should be responsible for Petitioner's counsel fees and costs III connection with the instant petition because she agreed to same in the Postnuptial Agreement. WHEREFORE, Petitioner, Larry L. Harman, hereby respectfully requests that this Court enter an Order finding that Respondent has breached a contract between the parties and directing Respondent within 60 days to comply with all requirements of the Postnuptial Agreement and pay all attorney's fees and costs of Defendant IPetitioner in bringing and prosecuting this Petition to Enforce Postnuptial Agreement and for Breach of Contract. By Jennifer 10 East gh Street Carlisle, P A 17013 (717) 243-3341 (l AJJ vl. Date: November 14, 2004 Attorneys for Defendant/Petitioner '. . ., ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW IN DIVORCE: KELLI S. HARMAN, Plaintiff No. 03-1077 v. LARRY L. HARMAN, Defendant POSTNUPTIAL AGREEMENT AGREEMENT made this 7Lf/z day of 4:c.a e.- U between Kelli S. Harman, hereinafter called "Wife," , 2004, by and A N D Larry L. Harman, hereinafter called "Husband." WHEREAS, the parties were married on December 29,1990; and WHEREAS, two (2) children were born of the marriage, to wit, Rachel Harman and Trevor Harman; and WHEREAS, in consequence of disputes and unhappy differences, the parties are separated and living apart from each other; and 00095729.1 -1- EXHIBIT "A" '. . " >, WHEREAS, the parties desire to confilID their separation and make arrangements in connection therewith, including the final settlement of their property rights and other rights and obligations growing out of their marriage relationship. IT IS THEREFORE AGREED: 1. CONSIDERATION - The consideration for this Agreement is the mutual promises, covenants and agreements herein contained. 2. SEP ARA nON - It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. 3. NO INTERFERENCE - Each party shall be free from interference, authority and control, direct or indirect, by the other, as fully as ifhe or she were single and unmarried. 4. DIVISION OF PERSONAL PROPERTY - The parties have heretofore divided their personal property to their mutual satisfaction, and hereafter each shall own and enjoy, independently of any claim or right of the other, all items of personal property of every kind, which are now owned or held or which may hereafter belong or come to him or her, with full power of disposition as if he or she were unmarried. The parties agree that all of the furniture in the marital home located at 5455 Bonnyrigg Court, Mechanicsburg, Pennsylvania shall belong exclusively to Wife, with the exception of the 00095729.1 -2- '. . " " following items which shall be awarded to Husband and removed from the home within sixty (60) days of the date of this Agreement: . Basement furniture . Work-out equipment . Desk in basement . Big screen television 5. PETS - Husband and Wife are the owners of three (3) cats; Bob, Suzie and Minnie. Wife shall maintain possession of all cats. 6. REAL PROPERTY - Husband and Wife hold title as tenants by the entireties to the marital residence identified as 5455 Bonnyrigg Court, Mechanicsburg, Pennsylvania. There is presently outstanding against the real estate a mortgage held by Washington Mutual having a principal balance of approximately $159,176.00 as of April 30,2004. Commencing on the date of execution of the Agreement, Wife shall be solely responsible for the timely payment of all past, present, and future principal, interest and other fees due under the mortgage. Wife intends, however, to refinance the mortgage into her name alone. Husband agrees to execute a Deed transferring his interest in the property to Wife within five (5) days of the date of execution of this Agreement, or at the settlement for the refinancing of the mortgage, whichever first occurs. 00095719.\ -3- " ., Wife agrees to pay to Husband the lump sum of Thirty-Five Thousand ($35,000.00) Dollars at the time of Husband's execution of the Deed. In exchange for Husband's transfer of his interest in the marital home to Wife, Wife shall pay one additional lump sum to Husband of Twenty Thousand ($20,000.00) Dollars payable within one (1) year of the date of Husband's receipt of the first lump sum payment. In the event Wife fails to make the aforementioned payment when due and Husband retains counsel to assist in enforcing the terms thereof, Wife agrees that she will pay all attorney's fees, court costs and expenses that are incurred by Husband in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific agreement and intent of the parties that Wife shall bear the obligation of any and all costs, expenses and counsel fees incurred by Husband in protecting and enforcing his rights under this Agreement. 7. TAX FILING STATUS - The parties agree to file separate Federal and State Income Tax Returns for the 2003 tax year. 8. ALIMONY - Husband and Wife do hereby waive, release, discharge and give up any rights which either may have against the other to receive spousal support, alimony pendente lite, alimony or other pre- or post-divorce maintenance or support. From the execution date of this Agreement, it shall be the sole responsibility of each party to sustain himself or herself without seeking any support from the other. 00095729.\ -4- 'I 'I 9. INSURANCE - Husband agrees to cany hospitalization and major medical coverage for the Plliiies' minor children as long as they continue to qualify as his dependants under such policies. Wife agrees to pay for all uncovered medical and dental expenses of the children up to Two Hundred Fifty Dollars ($250.00) per child/per year. All additional uncovered medical and dental expenses shall be paid equally by Husband and Wife or as determined by the Domestic Relations Section. Husband agrees to maintain his children as beneficiaries of a New York Life insurance policy he presently owns in a minimum amount of Two Hundred Fifty ..\. Thousand Dollars ($250,000.00). Husband agrees that he will not default on premium payments or borrow on said policy or in any way reduce the value of this policy so as to provide fewer benefits for his children. This obligation shall cease upon the youngest child attaining the age of twenty-three (23) years. If Husband has failed to maintain adequate life insurance as provided in this Agreement, Wife shall have the right to collect any deficit which results therefrom from the Husband's estate. In addition, Husband shall provide to Wife, upon execution of this Agreement, proof of his compliance with the provisions of this paragraph. Thereafter, he shall provide such proof to Wife on each one (1) year anniversary date of execution of this Agreement. 00095729.l -5- -I 'l 10. VEHICLES - Husband and Wife agree that hereafter Wife shall be and remain the sole owner of the Jaguar automobile currently titled in her name. Husband and Wife agree that Wife shall transfer to Husband the Ford Explorer currently titled in Wife's name. Husband agrees to assume and pay the indebtedness with Waypoint Bank and to indemnifY and hold Wife harmless from the payment thereof. The model years of the aforesaid vehicles may not be exact and are used for general identification of the vehicles only. II. MEDICAL INSURANCE FOR WIFE - Wife hereby elects to maintain her health, dental and medical insurance, under the applicable provisions of COBRA, with Husband's group health insurance plan. Husband shall be responsible for payment of the premiums for the plan, for a period of six (6) months following the month in which the divorce decree is issued. After the six (6) month period Wife may elect to continue the coverage and shall be responsible for payment of the premiums for the plan. The parties agree that a notice of election shall be forthwith be sent by Wife's counsel to Husband's employer. 12. BUSINESS INTERESTS - Wife hereby waives any right, title and/or interest that she may have in Husband's 1/3 ownership interest in US Ultrasound Company. 00095129.\ -6- 'j . i Husband hereby waives any right, title and/or interest that he may have in Wife's 100% ownership of The Harman Agency. From the date of execution of this Agreement, each party shall retain all right, title and/or interest in and to the aforesaid business entities as his or her sole and exclusive property . Each party acknowledges that he or she had the opportunity to have a business valuation performed of the other's business interests, however, they each chose to waive that right. 13. COUNSEL FEES- A. Husband agrees to pay all counsel fees incurred by him since the separation of Husband and Wife. B. Wife agrees to pay all counsel fees incurred by her since the separation of Husband and Wife. 14. DEBTS AND OBLIGATIONS- A. The following obligations of the parties hereto shall henceforth be and belong solely and exclusively to Husband, who hereby agrees to timely meet and pay the same, and furthermore, to indemnify, protect and save Wife harmless from any and all claims that may be brought against Wife because of or by virtue of his failure to meet and pay said joint obligation of the parties for which Husband hereby assumes responsibility: 00095729.1 -7- 01 " Creditor Approximate Balance National City $2,000.00 Citibank Credit Card $3,500.00 SLSC Loan $4,000.00 B. The following obligation of the parties hereto shall henceforth be and belong solely and exclusively to Wife, who hereby agrees to timely meet and pay the same, and furthermore, to indemnifY, protect and save Husband harmless from any and all claims that may be brought against Husband because of or by virtue of his failure to meet and pay said joint obligation of the parties for which Wife hereby assumes responsibility: Creditor Approximate Balance Internal Revenue Service 2002 taxes and penalties $15,000.00 Internal Revenue Service 2003 taxes and penalties Presently unknown 15. WAIVER OF PENSION BENEFITS - Husband and Wife agree that each shall execute any documents necessary to release and waive forever any right, title or interest each party may have in the other party's retirement plan (which is defined to mean pension, profit-sharing, or any other plan or account for retirement or deferred income). Specifically, Husband has a Pension Plan with Woodstream Corporation. Each party agrees to execute whatever documents are required to effectuate the purpose of this paragraph. Each party appoints the other as attorney-in-fact for the 00095729.1 -8- " 'j purpose of consenting to any election under any plan under Section 417 of the Internal Revenue Code or Section 205 of the Employee Income Security Act of 1974. It is specifically agreed that each party's rights under their respective retirement plans constitute their own separate property. 16. WIFE'S DEBTS - Wife represents and warrants to Husband that she will not contract or incur any debts or liabilities for which Husband or his estate may be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 17. HUSBAND'S DEBTS - Husband represents and warrants to Wife that he will not contract or incur any debts or liabilities for which Wife or her estate may be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 18. WAIVER AND RELEASE OF ESTATE RIGHTS - Each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, 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 otheIWise, 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 of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or 000957291 -9- ., " 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 ofa surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, Commonwealth or territory of the United States, or any other counhy The parties each waive, release and disclaim any and all right to receive the benefits of any property passing outside of the other's Will (including, without limitation, life insurance proceeds, and retirement, pension and profit sharing plan benefits), except as otherwise set forth in this Agreement. The parties further waive, release and disclaim any and all right to receive any legacy, bequest or residuary portion of the estate of the other under his or her Will or to act as personal representative of the estate of the other, unless such a legacy, bequest or residuary portion has been specifically made to the other and a specific acknowledgement as to the existence of this Agreement is made therein. 19. SUBSEQUENT DIVORCE - The parties hereby acknowledge that Wife has filed a Complaint in Divorce in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to number 03-1077, claiming that the marriage is irretrievably broken under the no fault, mutual consent provision of Section 3301 (c) of the Pennsylvania Divorce Code. The parties hereby express their agreement that the marriage is irretrievably broken and express their intent to execute any and all Affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code as soon as practicable. The parties hereby waive all 00095729.1 -10- " '. rights to request court-ordered counseling under the divorce code. Neither party to such action shall seek alimony, alimony pendente lite, or spousal support or maintenance of any nature contrary to the provisions of this Agreement. It is further specifically understood and agreed by the parties that the provisions of this Agreement relating the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Nothing herein contained shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against the other in any jurisdiction based upon any past or future conduct of the other, nor to bar the other from defending any such suit. In the event any such action is instituted, the parties shall be bound by all terms of this Agreement. 20. EOUIT ABLE DIVISION OF PROPERTY - By this Agreement, the parties have intended to effect an equitable division of their marital property. This division is not intended by the parties to constitute in any way a sale or exchange of assets. 21. FINANCIAL DISCLOSURE - This Agreement is made upon the assurance that each party has made a full, complete and total disclosure to the other of his or her income and the nature, extent and value of all of the spouses' respective assets and obligations, for the purpose of inducing the other party to enter into this Agreement, and therefore, to the extent that a party has failed to make such full and complete disclosure, 00095729.1 -11- " Ij then the releases and waivers contained in this Agreement shall be null and void as to any income, property or asset of the other which he or she has not disclosed; and any such property is unaffected by this Postnuptial Agreement. In the event that by reason of such nondisclosure by one party, the other party incurs additional counsel fees or incurs or expends suit money or costs in order to protect or assert his or her rights or claims, the nondisciosing party shall be obligated to and shall forthwith pay to the other party all such reasonable attorney's fees, court costs, and suit money, and further, that party shall hold harmless and inderrmify the other from all [mandai detriment thereby incurred by that party. 22. TAX ADVICE - The parties acknowledge that they have been separately advised by their respective attorneys that there may be certain tax consequences pertaining to this Agreement, that neither attorney has .furnished tax advice with respect to tins Agreement, that each party has been directed and advised to obtain independent tax advice from qualified tax accountants or tax counsel prior to signing this Agreement and that they have had the opportunity to do so. 23. MUTUAL RELEASE - Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, or his or her heirs, legal representatives, executors, administrators and assigns, release, and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties have, or ever had against the other. 00095729.1 -12- . . .. . , 24. BREACH - If either party breaches any provision hereof, then the non- breaching party shall have the right, at his or her election, to sue for damages for said breach, or seek such other remedies for relief as may be available to him or her, and the defaulting party shall be responsible for payment of all legal fees and costs incUlTed by the other party in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in a Court of Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the ground of lack of jurisdiction of said court or on the ground of an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by their agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the genera/jurisdiction of courts in equity over Agreements such as this one. The parties hereto agree that the provisions of this Agreement, including support, visitation or otherwise, may be entered and enforced by an appropriate court order at the action of the entitled party and against the obligated party, as the case may be, in the instance in question, when any problem anses. 25. WAIVER OF PENNSYLVANIA DIVORCE CODE RIGHTS - All property set apart herein either now or in the future as the separate property of either 00095729.1 -13- .. " Husband or Wife and all property now owned by or titled to Husband or Wife individually and all property acquired by Husband or Wife individually at any time after the execution of this Agreement shall remain the separate property of Husband or Wife and shall under no circumstances be considered as or deemed to be or construed to be "marital property" as that term is used in the Pennsylvania Divorce Code, and such property shall expressly not be subject to equitable distribution nor shall any appreciation in value of such property be subject to equitable distribution, This Agreement shall be deemed to be and construed to be a full and final property settlement and each agrees that he or she has no further claims against the other for equitable distribution of the property, alimony or any other property claim permitted by the Pennsylvania Divorce Code now or in the future enacted. 26. ADDITIONAL INSTRUMENTS - Each of the parties shall, from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments which may be reasonably required to give full force and effect to the provisions of this Agreement. 27. EFFECT OF RECONcrLIA TrON. COHABIT AnON OR DIVORCE - This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof GOO9S1Z9.1 -14- ., unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 28. VOLUNTARY EXECUTION - The provisions of this Agreement and their legal effect have been fully explained to the parties and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by his or by her counsel. Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Wife has been independently represented by counsel; Susan M. Kadel, Esquire, and that Husband, has been independently represented by counsel; John James Mooney, III, Esquire. Each party hereby confirms that he or she fully understands the terms, conditions and provisions hereof and believes same to be fair, just, adequate and reasonable under the existing facts and circumstances. The parties further declare that each is executing the Agreement freely and voluntarily, having either obligations or, if counsel has not been consulted, expressly waiving the right to obtain such knowledge. The parties each acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 00095729.1 -15- ',' _. \'1 29. ENTIRE AGREEMENT - This Agreement contains the entire understanding of the parties, and there are no representations, waivers, covenants or undertakings other than those expressly set forth herein. 30. MODIFICATION AND WAIVER - A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist on strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 3 I. SITUS - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 32. PARTIAL INVALIDITY -lfany provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 33. BINDING EFFECT - Except as otherwise stated within, all the provisions of this Agreement shall be binding upon the respective heirs, next of kin, executors, and administrators of the parties. 34. INTENT OF PARTIES -It is the intention of the parties hereto that this Agreement is a complete and [mal disposition of their property rights and not a mere Separation Agreement. 00095729.1 -16- .. '" 35. INCORPORATION - It is the intent of the parties that this Agreement be incorporated but not merged into any final decree of divorce which might be entered in the future. IN WITNESS WHEREOF, the parties have signed, sealed and acknowledged this instrument the day and year first above written. WITNESSES: ~A~~~~ Susan M. Kadel, Esquire Counsel for Kelli S. Hannan KLQc;' ~. 4UNU'l~AL) Kelli S. Hannan ( ~~ J."~ squi LaiTy L. annan (SEAL) 000957291 -17- " " , . ._," o. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ti__~ :ss. On this 1;tL day of Y-1/lJl..-/ , 2004, before me, a Notary Public, the undersigned officer, personally appeared Kelli S. Harman, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~. ~/liJu(SEAL) Notary pW My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jean L. Kos\er, Notary Public '-;"'''Y ,wp.. . =unly My Commission Expires Mar. 3, 2008 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA :ss. COUNTY OF : On this / J YI7 day of ~tZ~ , 2004, before me, a Notary Public, the undersigned officer, personally appearefLarry L. Hannan, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. My Commission Expires: Notarial Seal Pamela L. Rockwell, Notary Public Hanover Bo~o. York. County My Commission Expires Oct. 31. 2005 Member. PennsylVania Association of Notaries 00095729. ] -18- . . . ~-=-= -='-~ . .. . " \N THE COURT'O'F'COMMON PLEAS ..... OF CUMBERLAND COUNTY STATE OF KELLI S. HARMAN, Plaintiff VERSUS LARRY L. HARMAN, Defendant PENNA. No. 03-1077 DECREE IN DIVORCE AND NOW, JuvJ- ~, '2.J DECREED THAT KeJli S. H"nMn . . AND Larrv L. Hart1'aIl ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND PLAINTIFF. DEFEN DANT, 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 . . . . . . . ... ~~++~+++ +++++ ++++ . Am'~tq~ - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I .. . ,. .. . J. . . . . . . . . . . . . . +++++++++++++++++++++++++++++++++++++++++++ 't' + + + + EXHIBIT "B" PROTHONOTARY " , I " 'J ... I ... . ~. VERIFICATION The foregoing Petition is based upon information which has been gathered by my counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this veri fication. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties'L I!!:l (U.4-- <- Larty L. Hkman I " , I '"', " 'J " .., '. ,.'. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Carol J. Lindsay, Esquire SAIDIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, P A 17013 Susan M. Kadel, Esquire P.O. Box 650 Hershey, P A 17033 MARTSON DEARDORFF WILLIAMS & OTTO B~~(4-t9 ~ 'cia D. Eckenroad Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: November 14, 2005 ...., C.:::::] e-:-:::> ';;-,,1' G~' CJ ~n .-\ f~;J '.--' ~~~. "-I't \:~-) , ..:;,',-n ":~.\ ~1.'; ~ -::' .:~ - . " '. " KELLI S. HARMAN, Plainti ff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 0- v. NO. 03-1077 CIVIL ACTION - LAW LARRY 1. HARMAN, DefendantlPetitioner IN DIVORCE RULE TO SHOW CAUSE AND NOW, this~ day of lJ~, 3005, upon consideration of the Petition to Enforce Postnuptial Agreement and for Breach of Contract, a Rule is entered upon Respondent, Kelli S. Harman, to show cause, if any there be, why the relief requested in said Petition should not be granted. Rule returnable~ days from service. /' B~EC O~R~ . /0 . ;/( , J. cc: Attorney for Petitioner Jennifer 1. Spears, Esquire "" I j1d3-0S ~ .~ jY; Attorney for Respondent Carol J. Lindsay, Esquire ~~. L'I , h,... ('\ (' -1-' ~ 1,1 ~:' _.:: ,(., , :,., -1"',. {,~ Atll/lC-i :U~ ~O f \flLES\DAT AF1LE\GelleraJ\CulTflll\J 1196, l.cosl Created IVt/05438PM Revised \211105438PM Jennifer 1. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff KELLI S. HARMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CNIL ACTION - LAW LARRY 1. HARMAN, Defendant IN DNORCE CERTIFICATE OF SERVICE I, Jennifer 1. Spears, Esquire, of Martson Deardorff Williarns & Otto, hereby certify that a copy of the Rule to Show Cause dated November 22,2005, was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Kelli S. Harman 5455 Bonnyrigg Court Mechanicsburg, P A 17050 By Jenniti Ten E st igh Street Carlisle, P A 17013 (717) 243-3341 Dated: December I, 2005 c' ..,:' (,';.\ ,,:.; F :\FllES\DA T AFllE\General\Current\11796.1.ruleabsoJute Created: 9/20/04 0:06PM Revised: 12128/05 3:17PM Jennifer L. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE PETITION TO MAKE RULE ABSOLUTE 1. Petitioner/Defendant is Larry L. Hannan, the fonner husband in the above-captioned divorce action. 2. Respondent/Plaintiffis Kelli S. Hannan, fonner wife in the above-captioned divorce matter. 3. On or about November 16, 2005, Petitioner filed a Petition to Enforce Postnuptial Agreement and for Breach of Contract. 4. On November 22,2005, the Honorable Edgar B. Bayley issued a Rule directing the Plaintiff to show cause within twenty (20) days from service why the Court should not grant Defendant's Motion. 5. Said Rule to Show Cause was served on Plaintiff by first class mail on December 1, 2005. 6. To date, Plaintiff has failed to file an Answer or respond to the Rule. 7. The undersigned has been infonned by Carol J. Lindsay, Esq uire and Susan M. Kadel, Esquire that they are not authorized to represent Plaintiff in this matter. WHEREFORE, the Defendant asks that this Honorable Court enter an Order making the Rule absolute and directing Plaintiff to pay to Defendant the sum of $20,000.00 within sixty (60) days of the date of this Order; and to pay all of Defendant's attorney's fees and costs for preparation ofthis Petition, within twenty (20) days of their submission to Plaintiff. Respectfully submitted by, MARTS71E 1/ ,'I ORFF WILLIAMS & OTTO By 1/] Dated: December 28, 2005 lIe fer. Spears, Esquire Att me s for Plaintiff CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition to Make Rule Absolute was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Kelli S. Harman 5455 Bonnyrigg Court Mechanicsburg, P A 17050 Carol J. Lindsay, Esquire SAIDIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, P A 17013 Susan M. Kadel, Esquire P.O. Box 650 Hershey, P A 17033 MARTS ON DEARDORFF WILLIAMS & OTTO By l i\ ~C (,1~f' alJ~(i.CLCI Melissa A. Scholly . Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: 12/28/05 C., .' (~ ~::0 (;;:~:) ,;,/1 C.:1 r't"j C) 1~-..) OJ o -'11 ..., i-~ ;TI '_I~ Y' ~~), c:-~ CD , tt t Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 1.0. No. 87445 10 E. High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DNORCE ORDER AND NOW, this $'0 day of ~~ , 1-C.1'~~ it is ORDERED and DECREED that: (a) Respondent has breached the contract between the parties memorialized as their Postnuptial Agreement of June 7, 2004; Respondent is to pay to Petitioner the sum of$20,000.00 within sixty (60) days ofthe ~~~~de~ .s.u....A- f1:: ~Jl.. ~ &'It:L..-\TJ f~ R~~l'ulld"lll;3 Ie J3BoO' all gfPetitioner's attorney's fees and costs for preparation of (b) "7' (c) \~(, (1 this Petition.widJiu lwt;uly (:20) day" vftftCll !...:bmissieH to Re~1'511d""l~ ,r I , J. / Distribution: JenniferL. Spears, Esquire, 10 East High Street, Carlisle, PA 17013 ~.~ /-03.0<- Kelli S. Hannan, Plaintiff/Respondent, 5455 Bonnyrigg Court, Mechanicsburg, P A 17050 9-., > ti"~ -Cd' I" ~ li.IC: !J'~;{:'; (~) E:~, 01:'." ~uL'_ -J G:~U ;J..; 1-'- l.L C) tf) N ~";- 6: o (\-) ,U 2:5 ~, D c;::,. <--J , FIFILES\DA T AFILEIGeneral\Currenll 11796.lcol.lnselfees Created 1/26/05 1141AM Revised I/Ili06 1033AM MARTSON DEARDORFF WILLIAMS & OTTO Jennifer L. Spears, Esquire Attorney ID No. 87445 10 E. High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CNIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DNORCE DEFENDANT'S CLAIM FOR COUNSEL FEES. COSTS AND EXPENSES The following is a list of Defendant' s attorney's fees and costs associated with the enforcement of the Divorce Decree in the above-captioned case, and Defendant's Petition for Contempt of same by Plaintiff: DATE DESCRIPTION TIME RATE AMOUNT 9/28/05 Phone call with client re: enforcement of .8 190 $152.00 Postnuptial Agreement re: $20,000 payment to be made to Husband. Prepare Petition to Enforce Postnuptial Agreement. 10/17/05 Phone call with client re: money owed .2 190 $38.00 per equitable distribution in Postnuptial Agreement. 11 /9/05 Phone call with client. Revise Petition to .3 190 $57.00 Enforce Postnuptial Agreement. 11/14/05 Costs- Certified Mail, Restricted $8.84 Delivery of Petition. 11/14/05 Revise Petition to Enforce Postnuptial .4 45 $18.00 Agreement; Prepare for filing; (paralegal) correspondence to opposing counsel with Petition. 11/28/05 Receipt of Rule to Show Cause. Letters .3 190 $57.00 to client and Kelli Harman with same. 11/29/05 Phone call with client re: status of .3 190 $57.00 Petition to Enforce Postnuptial Agreement. 12/1/05 Prepare correspondence to Ms .3 45 $13.50 Harman; Prepare Certificate of Service; (paralegal) Prepare correspondence to client. 12/28/05 Prepare and file Petition to Make Rule .9 190 $171.00 Absolute in enforcement of Postnuptial matter. Letters to client and Kelli Harman serving same. 1/6/06 Receipt of Order of Court on Petition to .4 190 $76.00 Enforce Postnuptial Agreement. Letters to client and Kelli Harman with same. 1/9/06 Review client's bills and Preparation of .8 190 $152.00 this Claim for Counsel Fees, Costs and Expenses. TOTAL: $800.34 MARTSON DEARDORFF WILLIAMS & OTTO 'Ii I'} rlf/J By J elIDi r . Spears, Esquire 10 E 't High Street Carlisle, P A 17013 (717) 243-3341 Date: January 11, 2006 Attorneys for Defendant/Petitioner " CERTIFICATE OF SERVICE I, TriciaD. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Defendant's Claim for Counsel Fees, Costs and Expenses was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Kelli S. Hannan 5455 Bonnyrigg Court Mechanicsburg, P A 17050 MARTSON DEARDORFF WILLIAMS & OTTO aD. Eckenro;lcl n East High Street Carlisle, P A 17013 (717) 243-3341 {J G J(t21c0cl Dated: January 11, 2006 C) (~_. ;::-, C) -n :.-J ;,1 Ce) (:::J C.) ,. KELLI S. HARMAN, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LARRY L. HARMAN, DEFENDANT/PETITIONER 03-1077 CIVIL TERM ORDER OF COURT AND NOW, this f.!] day of January, 2006, as a follow-up to the order of December 30, 2005, Kelli S. Harman is ordered to pay Larry L. Harman within 30 days of this date, $250 toward his counsel fees. ~nifer L. Spears, Esquire For Larry L. Harman v1<elli S. Harman, Pro se 5455 Bonnyrigg Court Mechanicsburg, PA 17050 ---. :sal I ' '" 'i-y~ t~.~~~J' '. ~~ .yOle c\ .\ ') ,. \ \) : i. \ 1.1'; L i!';.'r ),i d 7 " :,\-H. ~':J 'J _, Jennifer L. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff KELLI S. HARMAN, Respondent/Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Petitioner/Defendant IN CUSTODY TO: KELLY S. HARMAN, PLAINTIFF NOTICE OF ENTRY OF JUDGMENT You are hereby notified that on the -.3J.d/.idayof ~'" , ,~ / ,2006, the following Judgment was entered against you in the above-captioned action: Respondent failed to pay to Petitioner the sum of$20,000.00 within sixty (60) days of the Order dated December 30,2005, and the sum of $250.00 to Petitioner within thirty (30) days of the Order dated January 17,2006. Date:11.~ 31 .1 ('CG , Or (;I. hu ;'(" Prot onotary 1\j2( KU.7i , a I hereby certify that the name and address of the proper person to receive this Notice under Pa. R. Civ. P. 236 is: Ms. Kelli S. Harman 555 Bonnyrigg Court Mechanicsburg, P A 17050 ...... . F ;\FILES\DA T AFllE\GeneraJ\Current\ 11796.1.pra 1 Created: 912QI04 O:Q6PM Revised: 3/29/06 3:54PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLI S. HARMAN, Respondent/Plaintiff v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Petitioner/Defendant IN CUSTODY PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: Enterjudgment in the above captioned action in favor of Defendant and against Plaintiffin the amount of$20,000.00 and $250.00 pursuant to the Orders ofthis Court dated December30, 2005, and January 17, 2006, respectively, plus interest and costs of suit, as well as attorney's fees pursuant to the Postnuptial Agreement filed to this docket for failure to comply with the attached Orders signed by the Honorable Edgar B. Bayley. MARTSON DEARDORFF WILLIAMS & OTTO By Jenn' 10 East igh Street Carlisle, P A 17013 (717) 243-3341 Date: ~'B)\0\0 Attorneys for Plaintiff Jennifer L. Spears, Esquire 'vIARTSOl\; DEARDORFF WILLIAMS & OTTO LD. l'io. 87445 10 E. High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLI S. HARMAN, PlaintifCRespondent v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE ORDER AND NOW, this -.l!L dayof IJu'pMAJ;/L/ , .J~t -: , itisORDERED and DECREED that: (a) Respondent has breached the contract between the parties memorialized as their Postnuptial Agreement of June 7, 2004; Respondent is to pay to Petitioner the sum of$20,OOO.00 within sixty (60) days ofthe date ofthis Order; and . R~f2t~~~~iti~'SC.tt~;~ee~;~d0c~~r~r';~~Jtion of this Petition, within tv.enty (20) days e>ftLeir stlbmissian to Resl'anclent. (b) /' . fer)' BY THE COURT, ,()1] ,'. I~ I edt'" /1 l'ok,;! ~ , J. Distribution: Jennifer L. Spears, Esquire, 10 East High Street, Carlisle, PA 17013 Kelli S. Harman, Plaintiff/Respondent, 5455 Bonnyrigg Court, Mechanicsburg, P A 17050 T?Ur: C.oPY FTiC:'i' m::cc:") 1/1 TNlJIOO;ov ";.f'W,,;! I i~ii :.r:i" ""';~.' ,',.,1Q WI ,_,_ v ,..c.;;:... -..I ....,. >(i(j ~ ~ 011 ..~!:,j CM( ;;J [;';;:!Jsie, P"... j r.~ J'o :::'-AJV UtA..Q,.u,'14u.... JtJc.;' ').,/' '- a...~~ ~;'.h I - { . ProihC(lt:mr~ KELLI S. HARMAN, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. LARRY L. HARMAN, DEFENDANT/PETITIONER 03-1077 CIVIL TERM ORDER OF COURT AND NOW, this f.!] day of January, 2006, as a follow-up to the order of December 30, 2005, Kelli S. Harman is ordered to pay Larry L. Harman within 30 days of this date, $250 toward his counsel fees. By the Court, ./ ---. Jennifer L. Spears, Esquire For Larry L. Harman Kelli S. Harman, Pro se 5455 Bonnyrigg Court Mechanicsburg, PA 17050 :sal , .I '/ ,/ ,~/ I; \..; 11 / '" , ./) , i I :.j,:: ..! I ' ei, J . ;"\ j (' . ',I' \, '('1,1 I 1/ \'" . f I I", " __' '~_~ __ --.../, - "_.' "'. 1'1 ),/ Ii I ) I . CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Kelli S. Harman 555 Bonnyrigg Court Mechanicsburg, P A 17050 MARTS ON DEARDORFF WILLIAMS & OTTO tf2!/}JAJ iJfl&UuJ ricia D. Eckenr'oa<'f f . Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated::O?{!(fA 3q d. 671& ( ? ~\ r \ , "-< ? \ > r c ~ J.: ,,~ (-0., (" v rv< ~ ....:" ... ,'" '<. ( ,;- ).. --I ~ '1-' c-. <' ""':...:. ;:c- '(0 i' ~u 9r -~.~ ,~ "" .p r: o ~ v """,, , r:) -~ !::....."-. n :",) , -" "':. .....-.: ~ CI' jC\ ~"\ :=:1,"L ',1 ii-~-"" c.) - _.:'") -'" ~,' \ \ ~-- ... ~ -.. ~ .', \.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , ... CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION vs. Confessed Judgment Other File No. 03-1077 Amount Due $20.000.00 Interest $ 183.08 Atty's Comm $ 250.00 Costs * *to be completed by Sheriff Caption: KELLY S. HARMAN, Plaintiff/Respondent LARRY L. HARMAN, Defendant/Petitioner TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) All personal property of Respondent located at 555 Bonnyrigg Court, Mechanicsburg,PA County, All property of Plaintiff in the possession of Sovereign Bank. 17 West High Street, Carlisle, PA, all bank accounts including No. 2471703321, Routing No. 231372387 owned by Plaintiff in the name of The Harman Agency. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All propertv of Plaintiff in the ossession of Soverei n Bank, 17 W. Hi h St, Carlisle, PA,including \I '" bank account No. 2471703321, Routing No. 231372387 owne Ain the name of The Harman Agency. and all other property of the defendant(s) in the possession, custody or 'control of the said garnishee(s). o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date May 24, 2006 Signature: Print Name: Address: Esquire 10 E High Street Carlisle, PA 17013 Attorney for: Defendant/lPetJtioner Telephone: 717-241-3341 Supreme Court 10 No.: 87445 ( over) ~ 0 r-..::. = 0 w ~ c ':::;:' -q 0"'\ (:J ~ ~-'. ::!Ii: :e ~ \j' ~ -{J ~ "1 ~ m;22 1f- ~ -:: V) 8 0 ~ 6 N -oDJ 0.- 0 0 ..:::- ='-J ~~; C) 0 c; 0 -0 ;~~~ """'- ..... ~ :J:: ~ ... l' 0} , I (..,) (jlf1 ~ .. ~ \ ... .r-- ::n u.; '"' ... ::- ~ a -< " ~ ( ,~ " .. .. .:t:- ... ""' - -- (- WRIT OF EXECUTION and/or ATTACHMENT - NO 03-1077 Civil CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LARRY L. HARMAN, Defendant (s) From KELLY S. HARMAN, 555 BONNYRIGG COURT, MECHANlCSBURG, PA (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF RESPONDENT LOCATED AT 555 BONNYRIGG COURT, MECHANICSBURG, P A . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ALL PROPERTY OF PLAINTIFF IN THE POSSESSION OF SOVEREIGN BANK, 17 W. HIGH ST., CARLISLE, P A INCLUDING BANK ACCOUNT NO. 2471703321, ROUTING NO. 231372387 OWNED BY KELLY HARMAN IN THE NAME OF THE HARMAN AGENCY. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $20,000.00 Interest $183.08 Arty's Comm % Arty Paid $36.00 Plaintiff Paid Date: MAY 24, 2006 L.L. $.50 Due Prothy $1.00 Other Costs $250.00 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JENNIFER L. SPEARS, ESQUIRE Address: 10 E HIGH STREET CARLISLE, P A 17013 Attorney for: DEFENDANT Telephone: 717-243-3341 Supreme Court ID No. 87445 4p:\FILES\DA TAFILE\GeneraJ\CUlTent\ 1 1796.I.atlinll Created: 5/19/06 9:54AM Revised: 6/19/06 4:21PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant/Petitioner Larry L. Harman KELLI S. HARMAN, PlaintifDRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE Al1stDer,s -Iv AMENDED INTERROGATORIES IN ATTACHMENT TO: SOVEREIGN BANK, Garnishee, 17 West High Street, Carlisle, Pennsylvania You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. I. At the time you were served or at any subsequent time did you owe the Respondent any money or were you liable to the Respondent on any negotiable or other written instrument, or did the Respondent claim that you owed the Respondent any money or were liable to the Respondent for any reason? No 2. At the time you were served or at any subsequent time was there in your possession, custody or control orin the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Respondent? Yes- See Attached 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Respondent or in which Respondent held or claimed any interest? No 4. At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the Respondent had an interest? No 5. At any time before or after you were served did the Respondent transfer or deliver any property to you or to any person or place pursuant to your direction or consent, and if so, what was the consideration therefor? No , 6. At anytime after you were served, did you pay, transfer or deliver any money orproperty to the Respondent or to any person or place pursuant to the Respondent's direction or otherwise discharge any claim of the Respondent against you? No MARTS ON DEARDORFF WILLIAMS & OTTO By / J e i r . Spears, Esquire 10 Ea t igh Street Carlisle, P A 17013 (717) 243-3341 ,?() Date: June l'9, 2006 Attorneys for Petitioner ANSWER TO INTERROGATORIES Account # 2471703321 Balance: $19,749.13 Account Holder: Kelli S. Harman d.b.a. MilleniafThe Harman Agency c/o Gift & Associates P.O. Box 567 Mechanicsburg, P A 17055-0567 Account # 2334029903 Balance: $50.51 Account Holder: Kelli S. Harman Trevor Lee Harmon 4202 Carlisle Pike, Suite 228 Mechanicsburg, P A 17055-3079 VERIFICATION I, Timothy J. Cooney, OAG Team Leader of Sovereign Bank, hereby verifY that the information contained in the foregoing Answers to Interrogatories in Attachment are 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. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: Timothy 1. Cooney OAG Team Leader o c 2f~:: , 7'" ,-"', .- -L-.T ~J:~:._;. ~ .-.' C:::' -.:.:~ cr' <- <~. N 0" o "n ';t..... [11 r-' -o~, ~.i.'~\~'\~\ ':""~:_ ~X_l ,~\F?\ "D :-< ~ ~. - ~ (,,S-; , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: Kelli S. Harman vs. Larry L. Harman CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Jennifer L. Spears, Esquire Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 Service by certified mail addressed as follows: Kelli S. Harman d.b.a. MillenialThe Harman Agency c/o Gift & Associates P.O. Box 567 Mechanicsburg,Pi\ 17055-0567 Signa of erson Filing Timothy J. Cooney, OAG Team Leader Sovereign Bank MAl MB3-02-10 2 Morrissey Boulevard Boston, MA 02125 June 22, 2006 r' ~ '~ ~ ~ -<" .'-\.--i~ \' -'\'(' ."~\C\ :'2f~\ :,~ s~\ ":.;2: '''i1 -:-L, "'~ (>;. ~~. '1"'. ""';,,. :;;:. .' .- U' ) '" F:\FILES\DA T AFILE\GeneraJ\Current\ 11796.1 ,pra2 Created: 9/20104 0:06PM Revised: 7/6106 4:05PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant/Petitioner Larry L. Harman KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE PRAECIPE FOR JUDGMENT UPON ADMISSION OF GARNISHEE-MONEY JUDGMENT To the Prothonotary: Please enter judgment in favor of the Defendant/Petitioner Larry L. Harman and against the garnishee, Sovereign Bank, in the amount of$19, 799.64, admitted in the Answer to Interrogatories to be in the Garnishee's possession, together with costs and interest. The amount of the judgment of the DefendantlPetitioner Larry L. Harman against the Plaintiff/Respondent Kelli Harman is $20,433.00 plus Sheriff's Costs to be determined. MARTSON DEARDORFF WILLIAMS & OTTO Date: July 6, 2006 By Jennifi . pears, Esquire Ten E s High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorney for Larry L. Harman Defendant/Petitioner , .... CERTIFICATE OF SERVICE I, TriciaD. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Kelli S. Harman 555 Bonnyrigg Court Mechanicsburg, P A 17050 MARTSON DEARDORFF WILLIAMS & OTTO ~Q~ cia D. Eckenroa Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 6, 2006 r<' '::) 1...__i c",c;. ~ ~ ( '-".::-~~ -n '7'I::l ,.:.--' ~ ,- ::? ~ ~ c:: ", e:. r-'" - <::> , d ~ --J - G'- l' <:::> ....J ~-,.~ l" 'P } C> ~ .y:-:- 0"1 ,.. F:\FILES\DA T AFILE\General\CUlTent\ 11796.1.305 1 Created: 9/20/04 0:06PM Revised: 7/6/06 4: 10PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for DefendantlPetitioner Larry L. Harman IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLI S. HARMAN, PlaintifflRespondent v. NO. 03-1077 CIVIL ACTION - LAW LARRY L. HARMAN, DefendantlPetitioner IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Praecipe for Judgment upon Admission ofGamishee - Money Judgment on behalf of Sovereign Bank, and certify that I am autho . ed to do so. 7 -7 - oy Date ...... Sovereign Bank, 17 West High Street, Carlisle, PA 17013 Mailing Address w...... ,.. :=J ~.:.:""'"T -...-2 \~.,'.- ' ( r~ SHERIFF'S RETURN - GARNISHEE CASE NO: 2003-01077 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HARMAN KELLI S VS HARMAN LARRY L And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:16 Hours, on the 2nd day of June , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HARMAN KELLY S , ln the hands, possession, or control of the within named Garnishee SOVEREIGN BANK 17 W. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to RYAN BEAM (CSR) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge So a?~--<~. .00 .00 .00 .00 .00 .00 v 08/04/2006 ~ - /'I.()(.. ~ R. Thomas Kline Sheriff of Cumberland County Sworn and Subscribed to day of By before me this A.D FIFlLESIDA T AFILEIGenerallCurrentll1796,l.prasatldrg Created 2/23/05 927AM Revised 11/3/06 0 28PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant/Petitioner Larry L. Harman KELLI S. HARMAN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-1077 CIVIL ACTION - LA W LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment in the above-captioned case satisfied and issue a certificate reflecting the same. DEARDORFF WILLIAMS & OTTO Date: November 3, 2006 By J enn fe L. Spears, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy ofthe foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Cumberland County Sheriff s Department Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO (~fllJ~ cia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: November 3, 2006 :-..:> ~ C:.:J ""i} 0""'" ~ ('> ~\ f' .. ~ ~ I ~ ~ c-, - ~ - ~ ....j ~ r:? '^' 'f.J' '.....) ::eej - C> ~ ~D ...c ....J C;J .-< ~ ---{:. 3- ~ E- 4- C>. ~ It' !i :;:.~ ." "'" '{~~_'i ','- -:.~-' ..., - _.; ~~: ~ Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 400.00 .50 1.00 13.20 40.00 40.00 9.00 .78 /7 522.48 ;/ '7'- Advance Costs: 522.48 Sheriffs Costs: 522.48 $ 000.00 Refunded to Atty on 12/20/06 ,j/t/tJ7 So Answers; ~~ ' ,.~~~ . ~~~ R. Thomas KlIne, Sheriff kf.~Brew!Mbd<</ <:). ~ ..... o ~,j ~ \~A;<.:..""_:::'.'" L J :E d S l A VW qOOl Vd 't\ INilU J U il; ld :jU~Jfl:j .:L:U~3HS 3Hl .:103::31.:1.:10 .;. ",-. . ,is '/0 I.~ Lk. 5,$39 fdu. e:r1t 1875010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1077 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LARRY L. HARMAN, Defendant (s) From KELLY S. HARMAN, 555 BONNYRIGG COURT, MECHANICSBURG, PA (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF RESPONDENT LOCATED AT 555 BONNYRIGG COURT, MECHANICSBURG, PA . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ALL PROPERTY OF PLAINTIFF IN THE POSSESSION OF SOVEREIGN BANK, 17 W. HIGH ST., CARLISLE, P A INCLUDING BANK ACCOUNT NO. 2471703321, ROUTING NO. 231372387 OWNED BY KELLY HARMAN IN THE NAME OF THE HARMAN AGENCY. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $20,000.00 Interest $183.08 Atty's Corom % Atty Paid $36.00 Plaintiff Paid Date: MAY 24,2006 L.L. $.50 Due Prothy $1.00 Other Costs $250.00 c~~s R ~ON~ (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name JENNIFER L. SPEARS, ESQUIRE Address: 10 E IDGH STREET CARLISLE, P A 17013 Attorney for: DEFENDANT Telephone: 717-243-3341 Supreme Court ill No. 87445 " . I.. \FILES\DA TAFllE\Gellt:ral\Cul1'~11l\1179/,) I.prasat:'drg Crl'at~d. :'<!.\;Q5 \.) ~7A!\.1 I{t,'vlsed 11 3,-00 0 ~SP"I Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant/Petitioner Larry L. Harman v. o ,....., ~~ :3 0 < C1'~ 11 ]":) [.~-~~" ~~ -f ,~>.'.;; C) rt-l:n ~ - ' ...~::: f-- 1 ~m :6Cl en :.) fi. -._~ ,-, IN THE COURT OF COMMON PLEAS 6F ;'~j~;0 CUMBERLAND COUNTY, PENN'~YL~~I'<i :::.:J - ::0 ., (....) .-< NO. 03-1077 CIVIL ACTION - LA W ~~~ :: KELLI S. HARMAN, Plaintiff/Respondent LARRY L. HARMAN, Defendant/Petitioner IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment in the above-captioned case satisfied and issue a certificate reflecting the same. Date: November 3, 2006 MARTSO~O:: WILLIAMS & OTTO By ~W Jennifer L. Spears, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 ~ f CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy ofthe foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Cumberland County Sheriff s Department Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO ~.. - iJ~ (By f/'L1 ciaD.Eckenroad -PI Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: November 3, 2006