HomeMy WebLinkAbout03-1517RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO. _ J S17 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
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, Carlisle, PA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse 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 o en persona
o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las
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 o notificacion y por cualquier
queja o alivio que es pedido en la peticion do demanda. Usted puede perder dinero o sus
propiedades o otros derechos importanates para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO
TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about assessable
facilities and reasonable accommodations available to disable individuals having business
before the Court, please contact our office. All arrangements must be made at least 72
hours prior to any hearing or business before the Court. You must attend the scheduled
conference or hearing.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR SECTION 3301(d)
AND 3301 (a)(6) OF THE DIVORCE CODE
AND NOW, comes the above Plaintiff, Renee P.J. Cronin, by and through her
attorney, Marianne E. Rudebusch, Esquire, and seeks to obtain a decree in divorce from the
above-named Defendant, upon the grounds hereinafter set forth:
1. The Plaintiff, Renee P.J. Cronin, is an adult individual who resides at 406
Cherokee Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. The Defendant, George W. Cronin, III, is an adult individual whose last known
mailing address is 800 Bretz Drive, Harrisburg, Pennsylvania, 17222.
3. The Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint.
4.
5.
The Plaintiff and Defendant were married on 10/11/86.
Plaintiff avers that there are two minor children to the parties.
6. The Plaintiff and Defendant are both citizens of the United States of America.
7. There have been no prior actions in divorce between the parties.
8. The Plaintiff and Defendant are not members of the Armed Services of the
United States or any of its allies.
9. Plaintiff has been advised of the availability of counseling and that she may
have the right to request that the Court require the parties to participate in counseling.
10. The causes of action and sections of Divorce Code under which Plaintiff is
proceeding are:
A. Section 3301(c). The marriage of the parties is irretrievably
broken. After ninety (90) days have elapsed from the date of the
service of this Complaint, Plaintiff intends to file an Affidavit
consenting to a divorce. Plaintiff believes that Defendant may
also file such an Affidavit.
B. Section 3301(d). The marriage of the parties is irretrievably
broken. The Plaintiff and Defendant separated on 3/14/03.
C. Section 3301(a)(6). The Plaintiff avers as the grounds on which the
action is based that the Defendant has offered such indignities to the
person of the injured and innocent spouse, namely Plaintiff, as to render
her condition intolerable and life burdensome. This action in divorce
is not collusive.
COUNTI
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
11. Plaintiff hereby incorporates by reference all of the averments contained in
paragraphs 1 through 10 of this Complaint.
12. Plaintiff and Defendant are the owners of real estate, motor vehicles, bank
accounts, insurance policies, pensions, retirement benefits and other personal property
acquired during the marriage which is subject to equitable distribution by this Court.
13. Plaintiff and Defendant have been unable to agree as to an equitable division
of said property as of the date of the filing of this Complaint.
14. Plaintiff requests this Court to equitably distribute the parties' marital property.
COUNT II
CLAIM FOR ALIMONY PENDENTE LITE
UNDER SECTION 3702 OF THE DIVORCE CODE
15. Plaintiff hereby incorporates by reference all of the averments contained in
paragraphs 1 through 14 of this Complaint.
16. Plaintiff does not have sufficient funds to support herself during the pendency
of this action.
17. Defendant is well able to pay support to Plaintiff.
18. Plaintiff requests this Court to grant her alimony pendente lite.
COUNT III
CLAIM FOR COUNSEL FEES, COSTS AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
19. Plaintiff hereby incorporates by reference all the averments contained in
paragraphs 1 through 18 of this Complaint.
20. Plaintiff does not have sufficient funds to pay the counsel fees, costs and
expenses incidental to this action.
21. Defendant is well able to pay Plaintiff's counsel fees, costs and expenses
incidental to this matter.
22. Plaintiff requests this Court to grant her counsel fees, costs and expenses
incidental to this action.
COUNTIV
CLAIM FOR ALIMONY
UNDER SECTION 3701 OF THE DIVORCE CODE
23. Plaintiff hereby incorporates by reference all of the averments contained in
paragraphs 1 through 22 of this Complaint.
24. Plaintiff does not have a sufficient source of income or earning capacity at the
present time to maintain the standard of living enjoyed by the parties during their marriage.
25. Defendant does have a sufficient source of income and earning capacity to aid
Plaintiff in maintaining the standard of living enjoyed by the parties during their marriage.
COUNT V
CUSTODY
26. Plaintiff hereby incorporates by reference all of the averments contained in
paragraphs 1 through 25 of this Complaint.
27. Plaintiff seeks primary physical custody of the following children:
Name Date of Birth Age
Melissa L. Cronin 1/22/86 17
David M. Cronin 2/1/89 14
28. The best interest and permanent welfare of the children will be served by
granting the relief requested because:
a. The Plaintiff has been the primary care giver of the children and has
provided the children with consistent and loving care.
b. Plaintiff is willing and able to continue to provide proper care and
supervision to the children.
C. Plaintiff can provide a stable and loving environment to the children.
29. Plaintiff has not participated as a party or witness or in another capacity in
other litigation concerning the custody of the children in this or another Court, nor does she
know of a person nor a party to the proceedings who has physical custody of the children or
claims to have custody or visitation rights with the children.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree:
a. dissolving the marriage between the Plaintiff and Defendant; and
b. equitably distributing all property owned by the parties hereto; and
c. directing the Defendant to pay alimony pendente lite to Plaintiff; and
d. directing the Defendant to pay Plaintiff's counsel fees and expenses incidental
to this divorce action; and
e. granting alimony to Plaintiff; and
f. to grant primary physical custody of the parties minor children to the Plaintiff
with liberal partial physical custody to the Defendant; and
g. for such further relief as the Court may determine to be equitable and just.
Respectfully Submitted,
/Wcha ftv\" e, ? - &CL
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Id. No. 63522
Dated: J-2,7--0 3
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
VERIFICATION
Upon my personal knowledge, information, and belief, I, Renee P. J. Cronin, hereby
verify that the facts averred and statements made in the foregoing are true and correct.
I understand that false statements or averments therein made will subject me to the
criminal penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: n cuw y) a-?' ?' Loo3
Renee P.J. Croni
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RENEE P.J. CRONIN : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
NO. 03-1517 Civil term
GEORGE W. CRONIN, III,
Defendant CIVIL ACTION - LAW
IN DIVORCE
ANSWER TO COMPLAINT IN DIVORCE UNDER
SECTION 3301 (c) OR SECTION 3301 (d)
AND 3301 (a) (6) OF THE DIVORCE CODE
AND NOW, comes the above defendant, George W. Cronin, who files this Answer to
Plaintiff's Complaint in Divorce, and in support thereof, avers the following:
1. Admitted.
2. Denied. The current mailing address has been reported to the Cumberland
County Office of Domestic Relations and due to Plaintiff's past actions the defendant seeks to
keep the address restricted from the Plaintiff.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10. Admitted.
(A). Admitted
(B). Admitted with clarification. The Defendant asserts the separation
date is 01/14/03 whereas the Defendant was living separate and apart from the Plaintiff
beginning 01/14/03.
(C). Denied. The defendant avers as the grounds on which the action is
based that the Plaintiff has offered such indignities to the person of the injured and innocent
spouse, namely the defendant, as to render his condition intolerable and life burdensome.
COUNT 1
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
11. The defendant hereby incorporates by references all of the averments
contained in paragraphs 1 through 10 of this answer.
12. Admitted.
13. Denied. The Plaintiff and the Defendant have reached agreement on the
distribution of real estate, motor vehicles, bank accounts, insurance policies, and other
personal property. As such the agreement precludes any Court ordered settlement.
14. Denied. The Defendant and Plaintiff seeks to relieve the Court of the burden of
property distribution.
COUNT II
CLAIM FOR ALIMONY PENDENTE LITE
UNDER SECTION 3702 OF THE DIVORCE CODE
15. The defendant hereby incorporates by references all of the averments
contained in paragraphs 1 through 14 of this answer.
16. Denied. The Plaintiff does indeed have sufficient means to support herself and
does not require financial support during the pendency of this action.
17. Denied.
18. Denied. The Defendant requests the Court deny application for alimony
pendente lite.
COUNT III
CLAIM FOR COUNSEL FEES, COSTS, AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
19. Defendant hereby incorporates by reference all the averments contained in
paragraphs 1 through 18 of this answer.
20. Denied.
21. Denied. The Defendant avers the action brought by the Plaintiff is self-initiated
and as such the Plaintiff assumes responsibility for fees, costs and expenses incidental to
this matter.
22. Denied. The Defendant requests the Court deny the Plaintiff's motion for
payment of legal counsel by the Defendant.
COUNT IV
CLAIM FOR ALIMONY
UNDER SECTION 3701 OF THE DIVORCE CODE
23. Defendant hereby incorporates by reference all the averments contained in
paragraphs 1 through 22 of this answer.
24. Denied. The Plaintiff enjoys a well paying job based on annual salary
supplemented by large financial rewards such as sales commission, and compensation
commensurate with performance and experience. The Plaintiff's potential earnings exceed
those of the Defendant. Further, the Defendant is currently sharing expenses as requested
by the Plaintiff and to the Plaintiffs satisfaction.
25. Denied. The Plaintiff has a well paying job and receives compensation based
on sales commission, providing product training, as well as compensation commensurate
with performance and experience. The Plaintiffs potential earnings exceed those of the
Defendant.. The Defendant is currently sharing expenses as requested by the Plaintiff to the
Plaintiffs satisfaction.
COUNT V
CUSTODY
26. Defendant hereby incorporates by reference all the averments contained in
paragraphs 1 through 22 of this answer.
27. Admitted
28. Admitted
29. Admitted
WHEREFORE, Defendant respectfully requests this Honorable Court to enter a
Decree:
a. dissolving the marriage between the Plaintiff and the Defendant
b. denying court ordered distribution of property as settlement has been reached
regarding property distribution
c. denying the motion for alimony pendente lite
d. denying the motion for the payment of counsel fees and expenses incidental to
this divorce action.
e. Denying alimony
f. Granting primary physical custody of the parties minor children to the Plaintiff
with liberal partial physical custody to the Defendant
Res
Dated:
George
RENEE P.J. CRONIN
Plaintiff
VS.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. 03-1517 Civil term
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I verify that the facts contained in the above pleading are true and correct to the best
of my knowledge, information and belief. I understand that the facts herein are verified
subject to the penalties for unsworn falsification to authorities under Crimes Code, Section
4904 (18 Pa.C.S. §4904).
Date: yZ l`D3
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
INVENTORY
UNDER RULE 1920.33
Plaintiff, Renee P.J. Cronin, 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.
Plaintiff verifies that the statements made in this inventory are true and
correct. Plaintiff understands that false statements herein are made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Date: 5 ?e OY
By: l (?uYt.
Renee P.J. Cronin
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.
(XX) 1. Real Property
(XX) 2. Motor Vehicles
(XX) 3. Stocks, bonds, securities and options
( ) 4. Certificates of Deposit
(XX) 5. Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit box(s)
( ) 8. Trusts
(XX) 9. Life insurance policies (indicate face value, cash
surrender value and current beneficiaries)
( ) 10. Annuities
( ) 11. 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
claim/award
( ) 17. Profit sharing plans
( ) 18. Pension plans (indicate employee contribution and date plan vests)
(XX) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
(XX) 24. Debts due, including loans, mortgages held
(XX) 25. Household furnishings and personalty (include as a total category
and attach itemized list if distribution of such assets is in dispute)
(XX) 26. Other
MARITAL PROPERTY
PLAINTIFF LISTS ALL MARITAL PROPERTY I314 WHICH EITHER OR BOTH
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AS OF THE DATE OF THE SEPARATION OF THE PARTIES:
ITEM NUMBER DESCRIPTION NAMES OF
OF PROPERTY ALL OWNERS
1 406 Cherokee Drive Renee P.J. Cronin
Mechanicsburg, PA George W. Cronin, III
2. 2003 Toyota Corolla Renee P.J. Cronin
2. 1998 Honda Accord Renee P.J. Cronin
George W. Cronin, III
2. Honda Motorcycle George W. Cronin, III
3. Stocks Renee P.J. Cronin
George W. Cronin, III
3. U.S. Savings Bonds Renee P.J. Cronin
George W. Cronin, III
Melissa L. Cronin
David M. Cronin
5. PSECU Credit Union Renee P.J. Cronin
Acct. No. 8009222780
5. Navy Federal Credit Union
Acct. No. 570114732 George W. Cronin, III
9. Life Insurance Policy with George W. Cronin, III
Knight of Columbus
9. TAP Account George W. Cronin, III
19. Deferred Compensation Plan George W. Cronin, III
19. PA State Police Retirement Plan George W. Cronin, III
19. IRA/Retirement Plan Renee P.J. Cronin
25.
Household goods and furnishings
Renee P.J. Cronin
George W. Cronin, III
26. 2002 IRS tax refund Renee P.J. Cronin
George W. Cronin, III
NON-MARITAL PROPERTY
PLAINTIFF LISTS ALL PROPERTY IN WHICH A SPOUSE HAS A LEGAL OR
EQUITABLE INTEREST WHICH IS CLAIMED TO BE EXCLUDED FROM MARITAL
PROPERTY:
ITEM NUMBER
OF PROPERTY
]REASON FOR
EXCLUSION
25 End tables and coffee table Purchased with inheritance from
in family room Plaintiffs father
25. Diningroom furniture - table, Gifts from Plaintiffs mother
chairs, buffet, china cabinet
25. Livingroom furniture - couch, Gifts from Plaintiffs mother
two chairs, end tables, coffee
table, curio cabinet and contents,
mirror and pictures
25. Guestroom furniture - bed, dresser Gifts from Plaintiffs mother
night stand and shelf
25. Cabinet in office Gift from Plaintiffs mother
PROPERTY TRANSFERRED
PLAINTIFF LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAD A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AND WHICH HAS BEEN TRANSFERRED WITHIN THE PRECEDING
THREE YEARS:
ITEM DESCRIPTION DATE OF CONSIDER- PERSON TO
NUMBER OF PROPERTY TRANSFER ATION WHOM
TRANSFERRED
LIABILITIES
PLAINTIFF LISTS ALL LIABILITIES OF EITHER OR BOTH SPOUSES ALONE OR
WITH ANY PERSON AS OF THE DATE OF SEPARATION:
ITEM
NUMBER
24.
DESCRIPTION
OF PROPERTY
Mortgage on marital home
NAMES OF
ALL CREDITORS
NAMES OF ALL
DEBTORS
24.
National City Mortgage
Home Equity Line of Credit National City Mortgage
24. Braces for Melissa Cronin
24. Electric bill
24. Sewer & Trash bill
Peoples Heritage
PP&L
Hampden Township
Renee P.J. Cronin
George W. Cronin, III
Renee P.J. Cronin
George W. Cronin, III
Renee P.J. Cronin
George W . Cronin, III
Renee P.J. Cronin
George W . Cronin, III
Renee P.J. Cronin
George W. Cronin, III
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RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-1517
GEORGE W. CRONIN, III,: CIVIL ACTION - LAW
Defendant : IN DIVORCE
INCOME AND EXPENSE STATEMENT
UNDER RULE 1920.31
I hereby file the Statement of Income 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. 4904, relating to unsworn falsification to authorities.
Date: sl1 iol0u
Renee P.J. Cronin
INCOME AND EXPENSE STATEMENT
OF
RENEE P.J. CRONIN
INCOME
Employer: Capital Computer Systems, Inc.
Address: 406 Second Street, New Cumberland, PA 17070
Type of Work: System Analysts and Trainer
Payroll Number:
Pay Period (Weekly, Bi-weekly, etc.): Bi-weekly
Gross Pay Per Pay Period: $ 1,923.08
Itemized Payroll Deductions:
Federal Withholding $ 244.00
Social Security $ 119.23
Local Wage Tax $ 19.23
State Income Tax $ 59.04
Unemployment $ 1.73
Medicare Tax $ 27.89
Retirement (401K) $
Savings Bonds $
Credit Union $
Life Insurance $
Health Insurance $
Pension Contribution $
Net Pay Per Pay Period $ 1,451.96
OTHER INCOME:
MONTHLY ANNUAL
Interest $ $
(C.D. & Mun. Bonds)
Dividends $ $
Pension $ $
Annuity $ $
Social Security $ $
Rents $ $
Royalties $ $
Expense Account $ 300.00 $ 3,600.00
Unemployment Comp. $ $
Workmen's Comp. $ $
Child Support $ 1,015.38 $ 12,184.56
Alimony/Spousal Support $ $
Total $ 1,315.38 $ 15,784.56
TOTAL INCOME: $ 4,458.87 $ 53,506.48
EXPENSES
MONTHLY ANNUAL
HOME:
Mortgage/Rent $ 1,289.87 $ 15,478.44
Home Equity Loan $ 100.00 $ 1,200.00
Maintenance & Lawn $ 25.00 $ 300.00
Utilities:
Electric $ 250.00 $ 3,000.00
Gas $ $
Oil $ $
Sewer $ 35.00 $ 420.00
Telephone $ 45.00 $ 540.00
Cell phone (kids) $ 120.00 $ 1,440.00
Water $ $
Refuse City $ $
EMPLOYMENT:
Public Transportation $ $
Lunch $ 100.00 $ 1,200.00
TAXES:
Real Estate $ 179.44 $ 2,153.28
Personal Property $ $
INSURANCE:
Homeowners
Automobile(s)
Life
Accident
Health
Other
AUTOMOBILES:
Payments (Plaintiff's car)
Fuel (all vehicles)
Repairs and Service
MEDICAL:
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special needs
(Glasses, braces,
Orthopedic devices, etc.)
$ 40.58 $ 487.00
$ 165.00 $ 1,980.00
$ 329?14 $ 3,952.08
$ 150.00 $ 1,800.00
$ 100.00 $ 1,200.00
$ 45.00 $ 540.00
$ 50.00 $ 600.00
$ 6.00 $ 72.00
$ 100.00 $ 1,200.00
EDUCATION
Private School $ $
Parochial School $ $
College $ 20.00 $ 240.00
Religious $ $
PERSONAL:
Clothing $ 200.00 $ 2,400.00
Food $ 400.00 $ 4,800.00
Barber/Hairdresser $ 100.00 $ 1,200.00
Credit Payments $ $
Credit Card $ 100.00 $ 1,200.00
Charge Accounts $ $
Memberships $ 26.25 $ 315.00
LOANS
Credit Union $ $
MISCELLANEOUS:
Child CareBabysitting $ $
Papers/Books/Magazines $ 30.00 $ 360.00
Entertainment $ 50.00 $ 600.00
Pay T.V. $ 38.00 $ 456.00
Vacation $ 83.33 $ 1,000.00
Gifts $ 100.00 $ 1,200.00
Legal Fees $ 100.00 $ 1,200.00
Charitable Contributions $ 176.16 $ 2,114.00
Other $ $
Tax Preparation $ 14.58 $ 175.00
TOTAL EXPENSES $ 49568.55 $ 54,822.60
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RENEE P.J. CRONIN, : IN THE COURT OF COMA
Plaintiff : CUMBERLAND COUNTY,
V. NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
on 4!2103.
2. The marriage ofPlaintiff and Defendant is irretrievably
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
Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and
PLEAS
NSYLVANIA
Code was filed
and ninety (90)
of Notice of
I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S
relating to unsworn falsification to authorities.
Section 4904
Date: LI-1 ` 0
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:
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
IN THE COURT OF COMD
CUMBERLAND COUNTY,
NO. 03-1517
CIVIL ACTION - LAW
IN DIVORCE
1. I consent to the entry of a Final Decree of Divorce
2. I understand that I may lose rights concerning alimony,
lawyer's fees or expenses if I do not claim them before a divorce is
3. I understand that I will not be divorced until a divorce
Court and that a copy of the decree will be sent to me immediately
Prothonotary.
I verify that the statements made in this Affidavit are true and
PLEAS
notice.
ANIA
of property,
is entered by the
it is filed with the
I understand
that false statements herein are made subject to the penalties of 18 Pa. CIS. §4904, relating
to unsworn falsification to authorities.
Date: 0 `l
III
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1517
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Marianne E. Rudebusch, Esquire, attorney for Plaintiff, certifies that:
1. A notice of intent to serve the subpoena with a copy of the subpoena attached
thereto was mailed or delivered to each party at least twenty days prior to the
date on which the subpoena is sought to be served.
2. A copy of the notice of intent, including the proposed subpoena, is attached to
this certificate.
3. No objection to the subpoena has been received.
The subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
i
12 ?G?? e , K ,eti? t I-A,
Date Counsel for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
RENEE P.J. CRONIN,
Plaintiff
. File No. 03-1517 -- CIVIL
V.
GEORGE W. CRONIN, III
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Commonwealth of PA Deferred Compensation Plan
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things:
The documents set forth on the attached
Exhibit 1
at 4711 Locust Lane, fflarrisburg, ?K 17109
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Marianne E. Rudebusch, Esq.
ADDRESS: 4711 Locust Lane
Harrisburg, PA 17109
TELEPHONE: 717-657-0632
SUPREME COURT ID # 6 3 5 2 2
ATTORNEY FOR: Plaintiff
Date:
Seal of the Court
BY THE COURT:
Prothonotary, Civil Division
Deputy
Cronin v. Cronin
The following documents and records on George W. Cronin, III (SS #570-11-4732)
1. Statement as of 3/14/03
2. Statement as of 1111105
3. History of this account from 3/14/03 until 11/1/05
4. Contributions made by employee from 3/14/03 until 1111105
5. Contributions made by the employer from 3/14/03 until 1111105
"Document" and "record" refer to an contemplate all written, recorded, or graphic
information, whether preserved in writing, on magnetic tape, by electronic means, in
photographic form, on microfilm or microfiche, computer disc, DVD, or by any other means
of information retrieval or storage.
EXHIBIT I
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1517
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AMENDED PRETRIAL STATEMENT
On behalf of the Plaintiff, Renee P.J. Cronin, in the above-captioned action,
Marianne E. Rudebusch, Esquire does hereby file the following amended pre-trial
statement for consideration of the Court:
1. MARITAL ASSETS
a. Marital Residence
b. Defendant's PA State Police Retirement
C. U.S. Savings Bonds
$ 51,462.00 equity
$ 379,783.00
$ 16,050.00 (already
divided between the parties
d
d.
e.
f.
9.
h.
i.
Defendant's Deferred Compensation Acct. $ 51,715.00
?p ?ptX?
Stocks" 0?`'•? 9s` ___-- $ 7,000.00
PSECU Acct. # 800922278 $ 5,000.00
Navy Fed. Credit Union Acct. 570114732 $ 200.00
K of C Life Insurance $ 25,000.00
2003 Toyota Corolla $ -0-
j. 1998 Honda Accord ( in Defendant's possession) $ ?
k. Honda Motorcycle (in Defendant's possession) $ ?
2. MARITAL OBLIGATIONS
a. Mortgage on Marital Home $ 153,473.00
b. Home Equity Line of Credit $ 18,785.00
C. Mastercard X9445 $ 9,542.00
d. Visa $ 7,762.00
e. SUNOCO Credit Card $ ?
f. Defendant's Student Loan $ ?
g. Chase Bank loan on 2003 Corolla (current balance) $ 4,300.00
3. EXPERT WITNESSES
The names and addresses of each expert whom the Plaintiff intends to call at trial
includes the following:
Actuary from Conrad Siegel, Inc.
2
4. WITNESSES
Name and address of each witness Plaintiff intends to call at trial includes the
following:
Renee Cronin, Plaintiff
406 Cherokee Drive
Mechanicsburg, PA 17050
George Cronin, Defendant
5. EXHIBITS
A list of all exhibits which the Plaintiff intends to offer into evidence which have
been attached hereto:
a. Plaintiff's Inventory & Appraisement Statement
b. Husband's Pension Valuation dated June 14, 2006
C. List of U.S. Savings Bonds
d. Appraisal of marital residence dated September 2, 2005
e. Mortgage statement for National City Mortgage dated June 21, 2006.
f. Home Equity statement for National City Mortgage dated June 8, 2006.
g. Defendant's Deferred Compensation Plan Statement dated 3/31/03.
h. Compilation of interest earned on Defendant's Deferred Compensation Plan
since date of separation.
i. Account Statement for Mastercard Account
3
j. Account History for Visa Account
k. Plaintiff reserves the right to provide additional exhibits at a later date
6. PROPOSED RESOLUTION OF ISSUES:
The value of the marital assets is approximately $527,240. To affect economic
justice between the parties, a 60140 division is appropriate, with 60% of the assets
($316,344.00) accorded to Wife as follows:
a. Wife shall receive the marital residence at 406 Cherokee Drive,
Mechanicsburg, PA and shall assume full responsibility for the two existing
joint mortgages, totaling approximately $172,258.00 and shall hold
harmless and indemnify Husband fall all costs and expenses arising from
this property. Equity value to Wife - approximately $51,462.00 (after
deducting 6% of the cost of a sale). Wife also received the $15,000.00 cash
out from the home equity loan immediately prior to the date of separation.
Husband shall transfer the property to Wife within five (5) business days of
the issuance of a Decree in Divorce. Wife shall list the property for sale no
later than August 15, 2007 and shall satisfy the joint mortgage/Home Equity
Loan with National City Mortgage at the time of the sale. All proceeds
from a sale shall solely belong to Wife.
b. Wife will retain her IRA accounts, bank accounts and the stocks, totaling
approximately $10,000.00. Husband and Wife agreed to use $5,000.00 of
4
the initial $15,000.00 for their daughter's tuition. Husband alone disbursed
$1,500.00 to the parties' daughter as a graduation gift from him without
Wife's knowledge or consent.
C. Husband will convey to Wife the full marital value of his Deferred
Compensation Plan - $51,715.00 via a DRO. Such DRO shall be prepared
by Husband's counsel within 30 days from the date of the issuance of a
Decree in Divorce.
d. Husband will be responsible for all debts in his name alone, including but
not limited to: PSECU Visa, Sunoco, Navy Federal Credit Union,
Mastercard, and his student loan. Because the Visa account was used by
both parties, Husband shall receive a credit of $3,506.00 ($3,881.00 less
$375.00, which is Wife's share of the 2002 tax refund that Defendant
retained).
e. Husband shall transfer $192,167.00 from his State Police Retirement Plan
to Wife via a DRO. Such DRO shall be prepared by Husband's counsel
within 30 days from the date of the issuance of a Decree in Divorce.
£ Subject to any encumbrances, Husband will retain ownership of the 1998
Honda and the Honda motorcycle and Wife will retain ownership of the
2003 Toyota Corolla.
g. Alimony to Wife in the amount of $800.00 per month for an indefinite
period of time subject to Wife's cohabitation, remarriage or death of either
5
party. Husband shall maintain life insurance in the amount of $100,000.00
designating Wife as the irrevokable beneficiary for as long as he has a
support obligation to her.
Respectfully submitted,
Marianne E. Rudebusch, Esq.
Attorney I.D. No. 63522
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Dated: ao v !0
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EXHIBIT ?
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03-1517
CIVIL ACTION - LAW
IN DIVORCE
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INVENTORY
UNDER RULE 1920.33 y
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Plaintiff, Renee P.J. Cronin, 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.
Plaintiff verifies that the statements made in this inventory are true and
correct. Plaintiff understands that false statements herein are made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities.
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Date: 4D)XV-1
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By
Renee P.J. Cronin
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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.
(XX) 1. Real Property
(XX) 2. Motor Vehicles
(XX) 3. Stocks, bonds, securities and options
( ) 4. Certificates of Deposit
(XX) 5. Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit box(s)
( ) S. Trusts
(XX) 9. Life insurance policies (indicate face value, cash
surrender value and current beneficiaries)
( ) 10. Annuities
( ) 11. 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
claim/award
r.
( ) 17. Profit sharing plans
( ) 18. Pension plans (indicate employee contribution and date plan vests)
(XX) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
(XX) 24. Debts due, including loans, mortgages held
(XX) 25. Household furnishings and personalty (include as a total category
and attach itemized list if distribution of such assets is in dispute)
(XX) 26. Other
MARITAL PROPERTY
PLAINTIFF LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AS OF THE DATE OF THE SEPARATION OF THE PARTIES:
ITEM NUMBER DESCRIPTION NAMES OF
OF PROPERTY ALL OWNERS
1 406 Cherokee Drive Renee P.J. Cronin
Mechanicsburg, PA George W. Cronin, III
2. 2003 Toyota Corolla Renee P.J. Cronin
2. 1998 Honda Accord Renee P.J. Cronin
George W. Cronin, III
2. Honda Motorcycle George W. Cronin, III
3. Stocks Renee P.J. Cronin
George W. Cronin, III
3. U.S. Savings Bonds Renee P.J. Cronin
George W. Cronin, III
Melissa L. Cronin
David M. Cronin
5. PSECU Credit Union Renee P.J. Cronin
Acct. No. 8009222780
5. Navy Federal Credit Union
Acct. No. 570114732 George W. Cronin, III
9. Life Insurance Policy with George W. Cronin, III
Knight of Columbus
9. TAP Account George W. Cronin, III
19. Deferred Compensation Plan George W. Cronin, III
19. PA State Police Retirement Plan George W. Cronin, III
M
25.
IRA/Retirement Plan
Household goods and furnishings
Renee P.J. Cronin
Renee P.J. Cronin
George W. Cronin, III
26. 2002 IRS tax refund Renee P.J. Cronin
George W. Cronin, III
NON-MARITAL PROPERTY
PLAINTIFF LISTS ALL PROPERTY IN WHICH A SPOUSE HAS A LEGAL OR
EQUITABLE INTEREST WHICH IS CLAIMED TO BE EXCLUDED FROM MARITAL
PROPERTY:
ITEM NUMBER DESCRIPTION REASON FOR
OF PROPERTY EXCLUSION
25 End tables and coffee table Purchased with inheritance from
in family room Plaintiffs father
25. Diningroom furniture - table, Gifts from Plaintiffs mother
chairs, buffet, china cabinet
25. Livingroom furniture - couch, Gifts from Plaintiffs mother
two chairs, end tables, coffee
table, curio cabinet and contents,
mirror and pictures
25.
Guestroom furniture - bed, dresser Gifts from Plaintiffs mother
night stand and shelf
25. Cabinet in office Gift from Plaintiffs mother
t
PROPERTY TRANSFERRED
PLAINTIFF LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAD A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AND WHICH HAS BEEN TRANSFERRED WITHIN THE PRECEDING
THREE YEARS:
ITEM DESCRIPTION DATE OF CONSIDER- PERSON TO
NUMBER OF PROPERTY TRANSFER ATION WHOM
TRANSFERRED
LIABILITIES
PLAINTIFF LISTS ALL LIABILITIES OF EITHER OR BOTH SPOUSES ALONE OR
WITH ANY PERSON AS OF THE DATE OF SEPARATION:
ITEM
NUMBER
24.
24.
24.
24.
DESCRIPTION NAMES OF
OF PROPERTY ALL CREDITORS
Mortgage on marital home National City Mortgage
Home Equity Line of Credit National City Mortgage
Braces for Melissa Cronin Peoples Heritage
Electric bill
PP&L
24. Sewer & Trash bill Hampden Township
NAMES OF ALL
DEBTORS
Renee P.J. Cronin
George W. Cronin, III
Renee P.J. Cronin
George W. Cronin, III
Renee P.J. Cronin
George W. Cronin, III.
Renee P.J. Cronin
George W. Cronin, III
Renee P.J. Cronin
George W. Cronin, III
EXHIBIT B
Conrad Siegel
A C T U A R I E S
The Employee Benefits Company
Conrad M. Siegel, F.S.A.
Harry M. Water, Jr., F.S.A.
Clyde E. Gingrich, F.S.A.
Eart L Mummers, M.AA.A.
Robed J. Dolan, A.S.A.
David F. Stirling, A.S.A.
Robert J. Mrazik, F.SA.
David H. IOlliek, F.S.A.
Jeffrey S. Myers, F.S.A.
Thomas L Zimmerman, F.S.A.
Glenn A. Hater, F.S.A.
Kevin A. Erb, F.S.A.
Frank S. Rhodes, F.S.A., A.CA.S.
Holly A. Ross, F.S.A.
Joel M. Leymaister, CEBS
Mark A. Bonsall, F.S.A.
John W. Jeffrey, F.S.A.
Derdse M. Polin, F.S.A.
Thomas W. Reece, A.S.A.
Jonathan D. Cramer, A.S.A
John D. Vargo, F.S.A.
Robed M. Glus, A.S.A.
Bruce A. Sol, CEBS
Laura V. Hess, A.S.A.
Vicki L Delligatd
June 14, 2006
-501 Corporate Circle • P.O. Box 5900 • Harrlsburg, PA 17110-0900
"9- 1 Phone t717) 652-5633
Fax t717) 540-9106
www.conradslegel.com
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
Re: Cronin v. Cronin
Dear Ms. Rudebusch:
You provided the following information concerning George W. Cronin:
1. Date of birth -April 5, 1961.
2. Date married - October 11, 1986.
3. Date separated - March 14, 2003.
4. Data provided by the State Employees' Retirement System as follows:
a. Years of service -19.33 (Class A-50) as of December 31, 2004.
b. Contributions plus interest - $70,653 as of December 31, 2004.
c. Retirement covered earnings:
Year Amount
2002 $72,277
2003 $76,699
2004 $75,569
Currently, George W. Cronin is 45 years of age (age nearest birthday).
George W. Cronin is a State policeman covered under the State Employees'
Retirement System. Currently, he has completed more than 20 years of service
and he is eligible to retire on a pension of 50% of his highest year's pay. If he
retires after completing at least 25 years of service, his pension would be 75% of
his highest year's pay.
Conrad Siegel
A C T U A R I E S
Marianne E. Rudebusch, Esquire
June 14, 2006
Page 2
The following table shows the pension benefit for retirement now and at age 49 (after 25 years
of service), the present value of such benefits, the coverture fraction and the present value of
the pension earned during the marriage:
Pension
Retirement Benefit
Present Value
Present Value Coverture Pension Earned
Pension Benefit Fraction During Marriage
Now Maximum single life
annuity of $3,149
Refund of contributions
plus interest &
maximum single life
annuity of $2,816
Age 49 (After Maximum single life
25 Years of annuity of $4,723
Service)
Refund of contributions
plus interest &
maximum single life
annuity of $4,307
$558,093 .79 $440,893
$573,863 .79 $453,352
$646,894 .66 $426,950
$660,135 .66 $435,689
Since the pension benefit takes into account both service before the date of marriage and after
the date of separation, it is necessary to multiply the present value of the pension benefit by a
"coverture fraction" in order to determine the present value of the pension earned during the
marriage. The coverture fraction is .79 (16.42 divided by 20.78) for retirement now and .66
(16.42 divided by 25.00) for retirement at age 49.
It is my understanding that George W. Cronin 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 his
earnings as a police officer and taking into account an appropriate "coverture fraction," the
estimated Social Security attributable to the marriage to start at age 62 is $886 per month for
retirement now and $800 per month for retirement at age 49.
The following table shows the pension benefit for retirement now and at age 49, the present
value of the pension earned during the marriage, the present value of the Social Security Offset
and the net present value:
Conrad Siegel
A C T U A R I E S
Marianne E. Rudebusch, Esquire
June 14, 2006
Page 3
Pension
Retirement Benefit
Now Maximum single life
annuity of $3,149
Refund of contributions
plus interest &
maximum single life
annuity of $2,816
Age 49 (After Maximum single life
25 Years of annuity of $4,723
Service)
Refund of contributions
plus interest &
maximum single life
annuity of $4,307
Present
Present Value Value
Pension Earned Social Net
During Marriage Security Present Value
$440,893 $61,110 $379,783
$453,352 $61,110 $392,242
$426,950 $55,178 $371,772
$435,689 $55,178 $380,511
The Social Security benefit increases in accordance with the Consumer Price Index. The
calculation of the present value of the Social Security benefit takes into account an assumption
that the Consumer Price Index would increase at the rate of 3.0% per year. The Consumer
Price Index increased on the average at the rate of 4.39% 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 value computations have been based upon the assumptions promulgated by the
Pension Benefit Guaranty Corporation for annuity valuations except mortality was not taken
into account before retirement. The interest rate is 6.2% per year for 20 years followed by
4.75% per year. The mortality is in accordance with the 1994 Group Annuity Basic Table for
males with Projection Scale AA to 2016.
With best regards,
Yours sincerely,
Harry . Leister, Jr., F.S.A.
Cons ting Actuary
Yours sincerely,
Jonathan D. Cramer, A.S.A.
Consulting Actuary
HML:JDC:kad
EXHIBIT C
R.:ug. 01 03 09:27a Reneb :inin 1719.- 009
Primary Name Seconda ry Name Date Amount Series ID #
George W . Cronin September-89 $100 .00 EE C211017549EE
George W . Cronin October-89 $100 .00 EE C226699406EE
George W . Cronin November-89 $100 .00 EE C226715095EE
George W . Cronin December-89 $100 .00 EE C226730609EE
George W . Cronin January-90 $100 .00 EE C226746132EE
George W . Cronin February-90 $100 .00 EE C266761473EE
George W . Cronin March-90 $100 .00 EE C225776667EE
George W . Cronin April-90 $100 .00 EE C242897937EE
George W . Cronin May-90 $100 .00 EE C242912984EE
George W. Cronin June-90 $100. 00 EE C242928115EE
George W. Cronin July-90 $100 .00 EE C242941781 EE
George W. Cronin Renee PJ Cronin April-92 $100. 00 EE C342754588EE
George W. Cronin Renee PJ Cronin May-92 $100. 00 EE C342772976EE
George W. Cronin Renee PJ Cronin June-92 $100. 00 EE C342794729EE
George W. Cronin Renee PJ Cronin July-92 $100. 00 EE C342805020EE
George W. Cronin Renee PJ Cronin July-92 $100. 00 EE C360854992EE
George W. Cronin Renee PJ Cronin August-92 $100. 00 EE C360892D22EE
George W. Cronin Renee PJ Cronin September-92 $100. 00 EE C360917047EE
George W. Cronin Renee PJ Cronin October-92 $100. 00 EE C367461182EE
George W. Cronin Renee PJ Cronin November-92 $100. 00 EE C367487150EE
George W. Cronin Renee PJ Cronin December-92 $100. 00 EE C367511419EE
George W. Cronin Renee PJ Cronin January-93 $100. 00 EE C394625079EE
George W. Cronin Renee PJ Cronin February-93 $100. 00 EE C394648795EE
George W. Cronin Renee PJ Cronin March-93 $100. 00 EE C394675456EE
George W. Cronin Renee PJ Cronin April-93 $100. 00 EE C410664788EE
George W. Cronin Renee PJ Cronin May-93 $100. 00 EE C410690626EE
George W. Cronin Renee PJ Cronin June-93 $100. 00 EE C410714997EE
George W. Cronin Renee PJ Cronin July-93 $100. 00 EE C410739598EE
George W. Cronin Renee PJ Cronin July-93 $100. 00 EE C425514424EE
George W. Cronin Renee PJ Cronin September-93 $100. 00 EE C425565917EE
George W. Cronin Renee PJ Cronin October-93 $100. 00 EE C437833035EE
George W. Cronin Renee PJ Cronin November-93 $100. 00 EE C437857302EE
George W. Cronin Renee PJ Cronin December-93 $100. 00 EE C437883916EE
George W. Cronin Renee PJ Cronin January-94 $100. 00 EE C437908865EE
George W. Cronin Renee PJ Cronin February-94 $100. 00 EE C437934775EE
George W. Cronin Renee PJ Cronin March-94 $100. 00 EE C437958518EE
George W. Cronin Renee PJ Cronin April-94 $100. 00 EE C437984864EE
George W. Cronin Renee PJ Cronin May-94 $100. 00 EE C457497227EE
George W. Cronin Renee PJ Cronin June-94 $100. 00 EE C467522444EE
George W. Cronin Renee PJ Cronin July-94 $100. 00 EE C46754604BEE
George W. Cronin Renee PJ Cronin July-94 $100. 00 EE C467570807EE
George W. Cronin Renee PJ Cronin August-94 $100. 00 EE C467595856EE
George W. Cronin Renee PJ Cronin September-94 $100. 00 EE C485878861EE
George W. Cronin Renee PJ Cronin October-94 $100. 00 EE C485903210EE
George W. Cronin Renee PJ Cronin November-94 $100. 00 EE C485930194EE
George W. Cronin Renee PJ Cronin December-94 $100. 00 EE C495172205EE
George W. Cronin Renee Pi Cronin January-95 $100. 00 EE C495198657EE
George W. Cronin Renee PJ Cronin February-95 $100. 00 EE C495223425EE
George W. Cronin Renee PJ Cronin March-95 $100. 00 EE C495249011EE
George W. Cronin Renee PJ Cronin April-95 $100. 00 EE C515409892EE
p.3
Fiug 0,1 03 09:27a Renee inin 1717,., Jos
George W. Cronin Renee PJ Cronin May-95 $100.00 EE C515435676EE
George W. Cronin Renee PJ Cronin June-95 $100.00 EE C515458731 EE
George W. Cronin Renee PJ Cronin June-95 $100.00 EE C515482970EE
George W. Cronin Renee PJ Cronin July-95 $100.00 EE C527322536EE
George W. Cronin Renee PJ Cronin August-95 $100.00 EE C527347769EE
George W. Cronin Renee PJ Cronin September-95 $100.00 EE C527372440EE
George W. Cronin Renee PJ Cronin October-95 $100.00 EE C527397441 EE
George W. Cronin Renee PJ Cronin November-95 $100.00 EE C510541930EE
George W. Cronin Renee PJ Cronin December-95 $100.00 EE C510566744EE
George W. Cronin Renee PJ Cronin January-96 $100.00 EE C510590578EE
George W. Cronin Renee PJ Cronin February-96 $100.00 EE C539959579EE
George W. Cronin Renee PJ Cronin March-96 $100.00 EE C539982411 EE
George W. Cronin Renee PJ Cronin April-96 $100.00 EE C559646295EE
George W. Cronin Renee PJ Cronin May-96 $100.00 EE C559669275EE
George W. Cronin Renee PJ Cronin May-96 $100.00 EE C559692111EE
George W. Cronin Renee PJ Cronin June-96 $100.00 EE C559714341 EE
George W. Cronin Renee PJ Cronin July-96 $100.00 EE C559736571EE
George W. Cronin Renee PJ Cronin August-96 $100.00 EE C559758544EE
George W. Cronin Renee PJ Cronin September-96 $100.00 EE C574247260EE
George W. Cronin Renee PJ Cronin October-96 $100.00 EE C574269325EE
George W. Cronin Renee PJ Cronin November-96 $100.00 EE C574292391 EE
George W. Cronin Renee PJ Cronin December-96 $100.D0 EE C574314450EE
George W. Cronin Renee PJ Cronin January-97 $100.00 EE C574336137EE
George W Cronin Renee PJ Cronin February-97 $100.00 EE C593997435EE
George W. Cronin Renee PJ Cronin March-97 $100.00 EE C607869046EE
George W. Cronin Renee PJ Cronin April-97 $100.00 EE C607879737EE
George W. Cronin Renee PJ Cronin May-97 $100.00 EE C607900247EE
George W. Cronin Renee PJ Cronin May-97 $100.00 EE C607920071EE
George W. Cronin Renee PJ Cronin June-97 $100.00 EE C607940554EE
George W. Cronin Renee PJ Cronin July-97 $100.00 EE C607959766EE
George W. Cronin Renee PJ Cronin August-97 $100.00 EE C611515795EE
George W. Cronin Renee PJ Cronin September-97 $100.00 EE C611535384EE
George W. Cronin Renee PJ Cronin October-97 $100.00 EE C611555487EE
George W. Cronin Renee PJ Cronin November-97 $100.00 EE C611574793EE
George W. Cronin Renee PJ Cronin December-97 $100.00 EE C622442572EE
George W. Cronin Renee Pi Cronin January-98 $100.00 EE C622461890EE
George W. Cronin Renee PJ Cronin February-98 $100.00 EE C622480882EE
George W. Cronin Renee PJ Cronin March-98 5100,00 EE 0622499161 EE
George W. Cronin Renee PJ Cronin April-98 $100.00 EE C637102046EE
George W. Cronin Renee PJ Cronin May-98 $100.00 EE C637119827EE
George W. Cronin Renee PJ Cronin May-98 $100.00 EE C637138298EE
George W. Cronin Renee PJ Cronin June-98 $100.00 EE C637155475EE
George W. Cronin Renee PJ Cronin July-98 $100.00 EE C637173019EE
George W. Cronin Renee Pi Cronin August-98 $100.00 EE C645246528EE
George W. Cronin Renee PJ Cronin September-98 $100.00 EE C645264388EE
George W. Cronin Renee PJ Cronin October-98 $100.00 EE C645281885EE
George W. Cronin Renee PJ Cronin December-98 $100.00 EE C645316928EE
George W. Cronin Renee PJ Cronin January-99 $100.00 EE C654094769EE
George W. Cronin Renee PJ Cronin February-99 $100.00 EE C654111361 EE
George W. Cronin Renee PJ Cronin March-99 $100.00 EE C654128749EE
George W. Cronin Renee PJ Cronin April-99 $100.00 EE 0671153751 EE
p.4
Aug •01 03 09:27a Renee u nin
George W. Cronin
George W. Cronin
George W. Cronin
George W. Cronin
George W. Cronin
George W. Cronin
Renee PJ Cronin
Renee PJ Cronin
Renee PJ Cronin
Renee PJ Cronin
Renee PJ Cronin
Renee PJ Cronin
April-99
May-99
June-99
July-99
August-99
September-99
171771 ;09
$100.00 EE C654144808EE
$100.00 EE C671169631EE
$100.00 EE C671185838EE
$100.00 EE C671201227EE
$100.00 EE C671216351 EE
$100.00 EE C579182630EE
P.5
r_
EXHIBIT D
OCT-28-2005 08:31AM FROM-MANCKE WAGN, MHA
+717-234-7080 {l T-665 P.002 F-282
APPRAISAL REPORT
406 CHEROkaE DRIVE
CAMP HILL, PENNSYLVANIA
PREPARED FOR
GEORGE W CRONIN
BY
LARRY E.FOOTE
DIVERSIFIED APPRAISAL SERVICES
35 EAST HIGH STREET, SUITE 101
CARLISLE, PENNSYLVANIA
17013-3052
(717) 249-2755
apam
` OCT-28-2005 09:31AM FROM-MANCKE WAG? PREHA +717-234-7080 T-805 P. 003/019 F-282
SUMMARY OF IMPORTANT FACTS AND CONCLUSIONS
LOCATION:
1'A.X YAKCEL NUMBER:
IMPROVEMENTS:
PROPERTY RIGHTS:
406 Cherokee Drive
Camp Hill, Pennsylvania
10-19-1600-257
Two-story detached single-family dwelling.
Fee simple interest.
OWNERSHIP HISTORY: The subject property is owned by George W. and Renee
P.J. Cronin, The property was purchased on August 7,
1997 for a reported consideration of $1.00 and ownership
transferred on Deed Book 162, Page 632.
SCOPE OF THE ASSIGNMENT: The scope of the assignment included an analysis of the
subject's area, an inspection of the subject property, an
estimation of the property's highest and best use,
consideration of all three approaches to value, and the
application of those relevant to the valuation of the
subject.
OBJECTIVE: To estimate the market value of the subject property as
unencumbered.
EFFECTIVE DATE: September 2, 2005.
HIGHEST AND BEST USE. Continued use as a singlc-family residence:.
COST APPROACH: N.A.
SALES APPROACH: $238,000
INCOME APPROACH: N.A.
FINAL VALUE CONCLUSION: $238,000
2
OCT-28-2005 09:31AM FROM-MANCKE 'NAGKL- 4PREHA
+717-234-7080 7-665 P. 004/019 F-262
APPRAISAL CERTIFICATION
I hereby certify that upon application for valuation by:
GEORGE W. CRONIN
the undersigned personally inspected the following described property:
All that certain piece or parcel of land, with the improvements thereon erected, situate
in Hampden Township, Cumberland County, Pennsylvania, bounded and described as follows,
Beginning at a point on the eastern line of Cherokee Drive at the dividing line between
Lots 15 and 16, Block "N", said point also being 328.85 feet measured in a northerly direction
from the northern line of Sioux Drive; thence along the Eastern line of Cherokee Drive by a
curve to the right having a radius of 765.00 feet an arc distance of 112.00 feet to a point at the
dividing line between lots 16 and 17, Block "N"; thence along the dividing line between lots 16
and 17. Block "N", North 77 degrees 06 minutes 20 seconds T'ast a. distance, of 9R 94 feet. to a
point on the Western line of Lot 9, Block 'N'; thence along the dividing line between lots 16
and 9, Block "N", South 14 degrees 36 minutes 22 seconds East a distance of 97.83 feet to a
point at the dividing line between Lots 9, 10, 15 and 16, Block "N", thence along the dividing
line between Lots 15 and 16, Block "N" South 68 degrees 43 minutes 00 seconds West a
distance of 94.69 feet to a point on the Eastern line of Cherokee Drive said puint being the
place of beginning.
To the best of my knowledge and belief the statements contained in this report are true
and correct, and that neither the employment to make this appraisal nor the compensation is
contingent upon the value reported, and that in my opinion the Market Value as of September
2, 2005 is:
TWO HUNDRED THIRTY-EIGHT THOUSAND DOLLARS
$238,000
The property was appraised as a whole, subject to the contingent atd liluituig ouuditioets
outlined herein.
Larry ` t. Foote
Certified General Appraiser
GA-000014-L
•OCT-28-2005 09:32AM FROM-MANCKE WAG PREHA +717-2$4-7080 T-665 P.005/019 F-282
INTENDED USE OF THE APPRAISAL
The intended use of this appraisal is to estimate the Market Value of the subject
property as of September 2, 2005.
Market Value is defined as the most probable price which a property should bring in a
competitive and open market under all conditions requisite to a fair sale, the buyer and seller,
each acting prudently, knowledgeably and assuming the price is not affected by undue
stimulus. Implicit 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:
a. Buyer and seller are typically motivated,
b. Both parries are well informed or well advised, and each acting in what
he considers his own best interest.
c. A reasonable time is allowed for exposure in the open market.
d. Payment is made in semis of cash in U.S. dollars or in terms of financial
arrangements comparable thereto.
e. The price represents the normal consideration for the property sold
unaffected by special or creative financing or sales concessions granted
by anyone associated with the sale.
Source: Office of the Comptroller of the Currency, 12 CPI §34.42(f).
HIGHEST AND BEST USE
Highest and Best Use is defined by the Appraisal Terminology and Handbook,
published by the Appraisal Institute, as "the most profitable likely use to which a property can
be put". l he opinion of such use may be based on the highest and most profitable continuous
use to which the property is adapted and needed, or likely to be in demand, in the reasonable
near future.
However, elements affecting value that depend upon events or a combination of
occurrences which, while within the realm of possibility, are not fairly shown to be reasonably
probable, should be excluded from consideration. Also, if the intended use is dependent on an
uncertain act of another person, the intention cannot be considered.
Based on the above definition and after seeing the site, neighborhood, and area, it is my
opinion that the present use of the subject is its Highest and Best Use.
4
OCT-28-2005 09:33AM FROM-MANCNE WAG( 4PREHA
9
SITE DATA
ADDRESS: 10-19-I600-253
TOWNSHIP: Hampden
COUNTY: Cumberland
+717-234-7080 ` T-665 P.006/019 F-282
STATE. Pennsylvania
LOT SIZE: 112' x 98.94'
SEWERS: Public utility.
WATER: Public utility.
LANDSCAPING: Typical for the area, with a sodded lawn, trees and shrubs.
DETRIMENTAL INFLUENCES
None. Pride of ownership is evident throughout the neighborhood.
DESCRErTION OF I11IFROVEMENTS
GENERAL DESCRIPTION: Two-story detached single-family dwelling containing approx-
imately 2,254 square feet of gross living area above grade with a two-car attached garage.
CONDITION: Exterior: Average
Interior: Average
ROOMS: First Floor: Living room, dining room, kitchen, family room, one-balf
Bathroom with laundry hookups.
Second Floor: Four bedrooms and two full bathrooms.
Basement: Full, approximately ninety percent finished into two
bedrooms and a full bathroom. Floor coverings are of
carpet, walls are of drywall and ceilings are of suspended
acoustical the blocks.
EXTERIOR: Foundation: Poured concrete.
Walls: Vinyl siding.
Sash: Vinyl-clad thermopanes with screens.
Gutters. Aluminum, painted.
Roof: Gable, with shingles.
5
OCT-28-2005 09:33AM FROM-MANCKE WAG( PREHA +717-234-7090 `
INTERIOR, PRINCIPAL ROOMS: Flooring: Carpot
Walls: Drywall
Ceilings: Drywall
Trim: Wood, painted.
KITCHEN: Cabinets: Oak, natural finish.
Counters: Formica
Walls: Drywall, painted and papered.
Flooring: Vinyl
Sink: Double-bowl, stainless steel,
BAT14RCX)A0: Flooring-. Parkay wood or carpet.
Walls: Drywall, painted and papered.
Bathtub: Built-in, with shower or shower stall,
Lavatory: Vanity.
Water closet Two-piece.
Medicine cabinet: Wall-mounted.
CONSTRUCTION: Joists: Wood
Beams: Steel
Columns: Steel
Plumbing: Copper and plastic.
HEATING- Electric heat pump.
COOLING: Central air conditioning.
HOT WATER: Electric, 50-gallon.
ELECTRIC: Circuit breaker system, 200-ampere.
T-665 P.007/019 F-282
OTHER: There is a brick woodbuming fireplace in the family room and there are
paddle fans in three of the bedrooms. Attached to the front of the dwelling is a covered porch
and attached to the rear of the dwelling is a concrete patio.
GENERAL CONDITION: All improvements are considered to be in average condition on the
interior and on the exterior, with the exception of damaged vinyl siding on the front of the
dwelling. Mechanical systems appear to be adequate and functioning properly.
• OCT-28-2005 09:34AM FROM-MANCKE WAGN. PREHA
+717-234-7080 T-665 P.008/019 F-282
I THE APPRAISAL PROCESS
I
Three approaches to value are generally included in an appraisal report. These
techniques include the cost approach, sales comparison approach, and income approach to
value.
The cost approach to value is based on the assumption that the reproduction cost of a
building plus land value, tends to set the upper limit to value. A key assumption is that a newly
constructed building would have advantages over the existing building, therefore an evaluation
focuses upon disadvantages or deficiencies (depreciation) of the existing building compared to
a new facility. Due to the age of the subject improvements, the cost approach is considered to
be inappropriate and has, therefore, not been included in the development of this appraisal
report.
The sales comparison approach to value assumes that under normal conditions, a given
number of parties acting intelligently and voluntarily, tend to set a pattern from which value
can be estimated. Application of this approach relies on a comparison of the subject with a
sufficient number of recent transactions of comparable properties in the market, based on a
common unit, such as price per square foot of building area.
The income approach concerns itself with present worth of the future potential benefits
of a property. The initial estimate involves the net income, which a fully informed person is
justified in assuming the property will produce during its remaining useful life. This estimated
net income is then capitalized into a value estimate, based upon the level of risk as compared
with that of a similar type and class. Since homes similar to the subject are not typically
utilized as income-producing investment properties, the income approach to value is considered
to be inappropriate and has, therefore, not been included in the development of this appraisal
report.
•OCT-28-2005 09:34AM FROM-MANCKE WAGN. PREHA +717-234-7080 T-655 P.009/019 F-2B2
SALES COMPARISON APPROACH
In arriving at this conclusion of the value of the subject property, the appraiser made a
survey of properties that have sold in the area of the subject property.
Consideration was given and adjustments were made on each comparable sale as to
liArrC Uf Sale, aiZU, JUCaliUU, as well a5 all. ether factory that might ait"oot value. A rcaumo of
some of the sales considered by the appraiser is as follows:
SALE NO. 1:
Location:
Date of Sale:
Sale Price:
Size:
Unit Price:
416 Huron Drive, Camp Hill
May 19, 2005.
$238,000
2,225 square feet.
$106.97 per square foot.
SALE NO. 2:
Location: 405 Hopi Drive, Camp Hill.
Date of Sale: May 25, 2005.
Sale Price: $239,900
Size: 2,256 square feet.
Unit Price: $106.34 per square foot.
SALE NO. 3:
Location:
Date of Sale:
Sale Price:
Size:
Unit Price:
413 Hopi Drive, Camp Hill,
January 14, 2005,
$270,000
2,404 square feet.
$112.31 per square foot.
The appraiser, in addition to the sales listed, also considered several additional sales in
arriving at his final opinion of value. On the Sales Comparison Analysis form that follows this
page are dollar adjustments reflecting market reaction to those items of significant variation
between the subject and comparable properties. If a significant item in the comparable
property is superior to, or more favorable than, the subject property, a minus (-) adjustment is
made, thus reducing the indicated value of the subject; if a significant item in the comparable is
inferior to, or less favorable than, the subject property, a plus (+) adjustment is made, thus
increasing the indicated value of the subject.
After making all of the necessary adjustments, it is the appraiser's considered opinion
that the indicated value of the subject property by the Sales Comparison Approach is $238,000.
8
OCT-28-2005 08'35AM FROM-MANCKE WAGR. oPREHA
+717-234-7080 ( T-665 P.010/018 F-282
SALES COMPARISON ANALYSIS
ITEM SUBJECT COMPARABLE #1 COMPAF.ABLB 92 COMPAFABLE #7
Address
Proximity to Subject
Sale Price
Priw/Sq. Ft. GLA 40G Clrttokx I)riw
Camp Hi11
N.A.
N.A. 416 Huron Drive
Camp Hill
One Rock.
$238,000
$106.97 405 Hopi Drive
Cutup Hill
Roar yard teaches the subjwt's yard.
$239.900
$106.34 413 Hopi F)tive
Comp YEll
225 foci 6vm the subject.
$270,000
'S02.31
Data Source
ADJUSTM N'r5 Iaepectica
DP.SCR[PTION Cn atbouse records
DESCRWrION $ Adjust. Courthouse & Central Penn IALS
DESCRIPCION S Adjust. Cotuthousc records
DBSCRIPTION $ Adjust.
Sales or inancing
Coacessions
None
Nona
None
Dote of Sale /Time Aa of 9-2-05 5.19.05 5-25-05 1.1.05
Location Average Similar Similar Similar
Sim / view 112' x 98.94' 100' x 100' 96.85' x 100' 90'X 185' -5,000
Design and Appeal Two-storydatached Similar Similar Similar
Constractinn Vmyl ardm* Vinyl siding Brick & vinyl siding -3,000 Vinyl siding
Age 20 yours 19 ycarr 20 years 20 years
Condition Average Slar Similar similar
Above Grade Tot, Bed. Bath Tot. Bad. Buth Tot. Bud. Bath Tot Bed. Both
Room Count 8 4 2f 8 4 2'/a 8 4 2%s 9 4 3A x,000
Gross Living Aura 2.54 square feet 2,229 equaro feet 2,256 square fat 2,404 square feet -7,900
Bwarrionr &Finished
Rovms Below Grade Full basement, 900/9
finished
Similar
Similar
similar
Functionaludli Awry Similar Similar Sunilar
Heetin / Ccoling Heat
pump Hear Heat purrip Heat
Gma L / C Two.car sarap, Two-car am c. Twocar gangs. Twocar ge,
Porches, Patios
Pools, etc.
Porch patio.
Porch, wood deck
Porch wood A.
Porch, wood deck.
Spacial Energy
EMl iupl Anus I 'typical for the
real 'ca.
Sinukr
Suuilar
Similar
F' laces Fi lace F' lace Fir ace Fi law
Other (og, kitohm
equip; remodeling)
Net Adi? total)
Lrdlwted Value
of Sub'ect
Built-ins.
$4TW4r
A-
238,000
Similar
-3,000
236.900
Similar
-16,500
253.500
FINAL INDICATED VALUE OF SUBJECT PROPERTY? $238,000
9
•OCT-28-2005 09MAM FROM-MANCKE WAGN. ,PREHA +717-234-7080 T-665 P.011/019 F-282
CORRELATION
Correlation may be defined as "the bringing together of parts in a proper relationship."
The parts of this appraisal report are the following approaches to value your appraiser used:
Value Indicated by Cost Approach N.A.
Value Indicated by Sales Comparison Approach $238,000
Value Indicated by Income Approach N.A.
These approaches are representative of the market value of the subject property. I have
carefully reexamined each step in each method, and I believe the conclusions accurately reflect
the attitude of typical purchasers of this type property in this neighborhood. It is my belief that
this reexamination has confirmed the original conclusions.
The Cost Approach will result in an excellent estimate if all elements are figured
accurately, because no prudent person will pay more for a property than the cost to produce a
hub56tutc property with oquol dc5irability and utility. Purchasers of the type of dwrtlittg
typical of the subject property are more concerned with amenities than with hypothetical
replacement of the property. Due to the age of the subject improvements, the Cost Approach is
considered to be inappropriate and has not been included in this appraisal report.
The Sales Comparison Approach was based on several recent sales of properties similar
to that of the subject, all of which are located in the same general area. The adjusted sales
prices are most consistent under comparison. This approach is the most reliable because it
reflects the reactions of typical buyers and sellers in the market.
The Income Approach is most applicable to income producing properties or properties
that are primarily utilized for income producing purposes. Purchasers of income producing
properties are willing to pay no more for a particular property than the net operating income
will support. Since the majority of properties similar to the subject are not utilized for income
producing purposes, this approach to value has not been included in this appraisal report.
Therefore, as a result of this appraisal and analysis, it is this appraiser's considered
judgment and opinion that the Market Value of the subject property, as of September 2, 2005,
is:
TWO HUNDRED THIRTY-EIGHT THOUSAND DOLLARS
$238,000
10
OCT-29-2005 09:36AM FROM-MAHCKE WAGN .. MEHA
+717-234-7080 l T-665 P.012/019 F-282
UNDERLYLNG ASSUMPTIONS AND LIMITING
CONDITIONS SUBJECT TO THIS APPRAISAL
1. I assume no responsibility for matters legal in nature, nor do I render any npininn ac to
the title, which is assumed to be marketable. The property is appraised as though under
responsible ownership.
2. The legal description used herein is correct.
3. I have made no survey of the property, and the boundaries are taken from records
believed to be reliable.
4. I assume that there are no hidden or unapparent conditions of the property, subsoil or
structures which would render it more or less valuable. I assume no responsibility for
such conditions or for engineering which might be required to discover such factors.
5. The information, estimates, and opinions furnished to me and contained in this report
were obtained from sources considered reliable and believed to be true and correct.
.However, no responsibility for accuracy can be assumed by me.
6. This report is to be used in its entirety and only for the purpose for which it was
rendered.
7. Neither all nor any part of the contents of this report (especially any conclusions as to
value, the identity of the appraiser or the firm with which he is connected) sball be
reproduced, published, or disseminated to the public through advertising media, public
relations media, news media, sales media, or any other public means of communication,
without the prior written consent and approval of the appraiser.
8. This appraisal was prepared for the exclusive use of the client identified in this appraisal
teport. The iuforuiatiou and opinions contaiued ill this appraisal set forth the
appraiser's best judgment in light of the information available at the time of the
preparation of this report. Any use of this appraisal by any other person or entity, or
any reliance or decisions based on this appraisal are the sole responsibility and at the
sole risk of the third party. The appraiser accepts no responsibility for damages
suffered by any third party as a result of reliance on or decisions made or actions taken
based on this report.
it
'OCT-28-2005 09:37AM
FROM-MANCKE WAGN6 sPREHA
+717-234-7080
CERTIFICATE OF APPRAISAL
Your appraiser hereby certifies that:
1. The statements of fact contained in this report are true and correct.
T-665 P 013/016 F-262
2. The reported analyses, opinions, and conclusions are limited only by the reported
assumptions and limiting conditions, and are my personal, impartial, and unbiased
protessional analyses, opinions, and conclusions.
3. 1 have no present of prospective interest in the property that is the subject of this report,
and no personal interest with respect to the parties involved.
4. 1 have no bias with respect to the property that is the subject of this report or to the
parties involved with this assignment.
5. My pnLragrmPnt in this assignment was not contingent upon developing or reporting
predetermined results.
6. My compensation for completing this assignment is not contingent upon the
development or reporting of a predetermined value or direction in value that favors the
cause of the client, the amount of the value opinion, the attainment of a stipulated result,
or the occurrence of a subsequent event directly related to the intended use of this
appraisal.
7. To the best of my knowledge and belief, the statements of fact contained in this
appraisal report, upon which the analyses, opinions, and conclusions expressed herein
are based, are true and wiicvl.
I 8. This appraisal report sets forth all of the limiting conditions (imposed by the terms of
my assignment or by the undersigned) affecting the analyses, opinions, and conclusions
contained in this report.
9. This appraisal report has been made in conformity with the Uniform Standards of
Profcaoional Appraisal Practice adopted by the Appraisal Standards Bnard of the
Appraisal Foundation, and is subject to the requirements of the Code of Professional
Ethics and Standards of Professional Conduct of the National Association of Realtors
Appraisal Section.
12
OCT-28-2005 09:37AM FROM-MANCKE WAi MENA +717-234-70801 T-665 P.014/019 F-282
10, No one other than the undersigned prepared the analyses, conclusions, and
opinions concerning real estate that are set forth in this appraisal report.
Larry E. Foote
Certified General Appraiser
GA-000014-L
13
OCT-28-2005 09:38AM FROM-MANCKE WAG( PREHA +717-134-70801 T-665 P.015/019 F-282
PMACY NOTICE
Pursuant to the Gramm-Leach-Billey Act of 1999, effective July 1, 2001, appraisers,
along with all providers of personal financial services are now required by federal law to
inform their clients of the policies of the firm with regard to the privacy of client nonpublic
personal information. As professionals, we understand that your privacy is very important to
you and are pleased to provide you with this information.
in MC'011 of Ny fvr.^.:i.-^.b •_•YprA?Sd1S tl e^tayselleeLwhat.i. 1C314V in RS..` p7x?lliR ...............
personal information" about you. This information is used to facilitate the services that we
provide to you and may include the information provided to us by you directly or received by
us from others with your authorization.
We do not disclose any nonpublic personal information obtained in the course of our
engagement with our clients to nonaffiliated third parties, except as necessary or as required by
law. By way of example, a necessary disclosure would be to our independent contractors, and
in certain situations, to unrelated third party consultants who need to know that information to
assist us in providing appraisal services to you. All of our independent contractors and any
third party consultants we engage are informed that any information they see as part of an
appraisal assignment is to be maintained in strict confidence within the firm. A disclosure
required by law would be a disclosure by us that is ordered by a court of competent jurisdiction
with regard to a legal action to which you are a party.
We will retain records relating to professional services that we have provided to you for
a reasonable time so that we are better able to assist you with your needs. In order to protect
your nonpublic personal information from unauthorized access by third parties, we maintain
physical, electronic and procedural safeguards that comply with our professional standards to
insure the security and integrity of your information.
14
r_
OCT-28-2005 08:38AM FROM-MANCKE WAGNLn SPREHA
+717-234-7080
LARRY E. FOOTE
REAL ESTATE APPRAISER
T-665 P.016/018 F-282
EXPERIENCE:
1979-Present: Chief Appraiser, Diversified Appraisal Services, Carlisle, Pa.
Principal Broker, LaRue Development Company, Carlisle, Pa.
1976-1,979: Associate Broker, Colonial Realty, Carlisle, Pa.
1972-1976: Realtor Associate, Jack Gaugben Realtor, Carlisle, Pa.
Appraisal experience included undeveloped land, farms, buildiug lcuv, single-flimily dwellings, mobile
home parks, medical centers, nursing homes, motels, apartment buildings and complexes, office
buildings, service stations, veterinary clinics, rehabilitation centers, retail buildings, daycare centers,
warehouses, and manufacturing facilities.
EDUCATION:
Bachelor of Business Administration, Pennsylvania State University, 1976.
Associate Bachelor of Business Administration, Harrisburg Area Community
College, 1974.
Diploma, Carlisle Senior High School, 1965.
Certificate, Pennsylvania Realtors Institute, GRI I, GRI II, GRI III.
Certificate, Realtors National Marketing Institute, Cl 101, Cl 102, Cl 103, CI 104,
Cl 105.
Standards of Professional Practice, American Institute of Real Estate Appraisers.
Real Estate Appraisal Principles, American Institute of Real Estate Appraisers.
Residential Valuation, American Institute of Real Estate Appraisers.
Appraisal Procedures, Appraisal Institute.
Principles of Income Property Appraising, Appraisal Institute.
Case Studies in Real Estate Valuation, Appraisal Institute.
Report Writing and Valuation Analysis, Appraisal Institute.
PROFESSIONAL ,LICENSES:
General Appraiser #GA-000014-L, Commonwealth of Pennsylvania,
Real Estate Broker 4RB-029729-A, Commonwealth of Pennsylvania
PROFESSIONAL DESIGNATIONS:
GRI: Graduate of the Pennsylvania Realtors Institute, awarded by the Pennsyl-
vania Association of Realtors.
CRS: Certified Residential Specialist, awarded by the Realtors National Market-
ing Institute of the National Association of Realtors.
CCIM: Certified Commercial Investment Member, awarded by the Realtors
National Marketing Institute of the National Association of Realtors.
PROFESSIONAL ORGANIZATION AFFILTATIONSI
National Association of Realtors Appraisal Section.
Carlisle Association of Realtors.
Pennsylvania. Association of Realtors.
National Association of Realtors.
Raulture National Marketing rnxtrute.
15
OCT-29-2005 09:39AM FROM-MANCKE WAGNt.. SPREHA
PAST CLIENTS:
Borough of Carlisle
Keystone Financial Mortgage
Cornerstone Federal Credit Union
Pennsylvania State Bank
Commerce Bank
Cumberland-Perry Association for Retarded Citizens
Carlisle Suburban Authority
Members V Federal Credit Union
Pennsylvania National Bank
Evans Financial Corporation
Greenawalt & Company, CPA
Smith's Transfer Corporation
Carlisle Department of Parki and Recreation
Executive Relocation Services
Carlisle Area School District
Messiah Homes, Incorporated
ERA Eastern Regional Services
Pennsylvania Turnpike Commission
Chase Home Mortgage Corporation
Defense Activities Federal Credit Union
Pennsylvania State Employees Credit TJninn
PNC Mortgage Corporation
F&M Trust Company
National City Mortgage Corporutim
Washington Mutual Horne Loans, Inc.
Prudential Relocation Services
Lender's Choice
Market Intelligence, Incorporated
United Telephone Employees Federal Credit Union
Cumberland County Commissioners
Allstate Enterprises Mortgage Corporation
Dickinson College
PPG Industries, Incorporated
Gettysburg College
Redevelopment Authority of Cumberland County
Record Data Appraisal Services, Incorporated
First United Federal Savings Association
Fulton Bank
United States Marshall Service
GMAC Mortgage Corporation
Orrstown Bank
Letterkermy Federal Credit Union
BancPlus Mortgage Corporation
Coldwell Banker Relocation Services, Incorporated
Ca t" Dewcylvania Savings Bank
Mellon Bank
Provident Home Mortgage Corporation
Drovers Bank
+717-234-7080 ? T-665 P.017/019 F-262
American Home Bank
Trans Union
M&T Mortgage Corporation
Cody Financial Mortgage Services
Waypoint Bank
Northwest Savings Bank
Blue Ball National Bank
Adams County National Bank
Countrywide Home Loans
Aarrow Mortgage
Various law funs and individuals
16
OCT-28-2005 09:39AM FROM-MANCKE WAGNER SPREHA
+717-234-7080 T-665 P.018/019 F-282
PHOTOGRAPHS OF THE SUBJECT IMPROVEMENTS
17
7
OCT-28-2005 09:40AM FROM-WANCKE WAGNER SPREHA
f
+717-234-7080
T-665 P.019/019 F-282
18
EXHIBIT E
Loan Information for Loan Number 1886868 Wednesday, June 21, 2006
Loan Number: 1886868
Borrower Name: George W Cronin Co-Borrower Name: Renee P J Cronin
BorrowerSSN/TIN: 570-11-4732 Co-Borrower SSN/TIN: 210-56-6718
Contact Information
Home Phone: (717) 763-8859 Other Phone: (717) 763-8859
Mailing Address: 406 CHEROKEE DRIVEDONOTCHANGE
MECHANICSBURG,PA
17050 Property Address: 406 CHEROKEE DR
MECHANICBURG,PA
17055
*Borrower email: reneecronin@comcast.net *Co-Borrower email:
renee(acaoitolcom.com
If mailing address or telephone numbers are incorrect, please click here to update.
All other information, please send us an email.
* Your email address will be added to our database as a means of contacting you
and may be used to contact you about information concerning your mortgage loan
with National City Mortgage Co.
General Loan Information
Current Principal
Balance: $153,473.96 Loan Type: Conventional
Fixed Rate
Loan Origination Date: 02/08/2003 Current Interest Rate: 6.37500%
First Payment Due Date: 04/01/2003 Original Loan Amount: $160,000.00
Maturity Date: 03/2033 Payment Method: Coupons
Payment Information
Scheduled Payment Breakdown: Last Payment Breakdown:
Next Payment Due: 07/01/2006 Date Payment Received: 06/16/2006
Principal & Interest: $998.20 Principal: $181.90
Hazard Insurance: $47.75 Interest: $816.30
City Tax: $38.58 Escrow: $251.70
Other Tax: $155.77 Fees/Late Charge: $17.36
Shortage: $9.60 Addt'I. Principal: $0.00
Total Scheduled Payment: $1,249.90
Year-To-Date-Totals
Principal: $1,077.10 Property Taxes: $500.28
Interest: $4,912.10 Hazard Insurance: $535.00
r
EXHIBIT F
NWo WCft
_v
W07180 PO BOX ""I
OLEVEIAND orl"11!0148981
448929b12036C397001678519000026256
New Balance Minimum Payment Due Date
18,785.19 262.56 07/03106
Account number 4469 2981 2016 0397
Amount Enclosed $ _
Address change? Call Customer Service Numberbelow.
PLEASE MAKE CHECK PAYA8LE TO: ?GEEORG1E'WI CRONIN 11160
NATIONAL CITY RENEEPJ CRONIN
P.O. BOX 6956176 408 CHEROKEE DR
LOUISVILLE, KY 40285.8176 MECHANIGSBURG PA 17050-2509
lJ,rlil+.+.ddl++h+l+l„l1,+++,I!!.nl?ilrlmltll.rl.ril! Inalk1+LIIIInIIJdLI,,,I,I,LIdi++II+I+III,+?,II+,.6111
5444811' 45000X100801: 9 298 Z 20160397111 001
"'° Af;p1Rz. Previous Total Balance
$18,785.01
Paymenta/Gredits $150.00
Account numwr 4489 2981 2018 68ST Cash Advance/Credit Card $0.00
credit Limit $19,980.00 Cash AdvanoslCheok $0.00
Available Credit $1,164:00 Finance Charges $150.18
Days In-Silang Cycle 31 Other Charges. $0.00
Statement closing Data 06108818 New Total Balance $18,78519
Past Due Balance $112.38
A FWWALN'RAVINI R70,i VA LIM 040701116R.
1FrOVNAVIIlWAL1SAVV018rE80, PLEASEMOr
TNEAMOWPA9rOUL
Reference Number Description Amount
7448 SWS19M0YL :PAYMENT THANK YOU KALAMAZOO MI t50.000R
`FINANCECHAR6E' 150.18
FAVANt::b CBABG$$ $1.TMMARY
RATETYPE MORNLY CO fXtj?ANNUAL
f a FIN ANC .. .... AVERAGE
PERIODIC SAT E
m RATE CHA DAILY BAFANOE
Current Cash AdvanowlCrediCard .813% 9:78% $0.00: $0.00
Current Cash Advanae/Check .813% 9.75% $150.18 $18,472.63
BLENDEDANNUAL PERCENTAGE RATE: 9.7$%
1lNLE9&07HERWIBE:STATED AJ30M` 0S RAIEMAY WARY..
Ct9BTOMER SERVICE: 1-8" 112"M
11,0011111640110* PO BOX 1SM4I CCLUTASUS Off 4321644
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TRANSAGT[UN3
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Date Date
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EXHIBIT H
CALCULATIONS FOR INCREASE
IN DEFENDANT'S DEFERRED COMPENSATION PLAN
Interest from August 2003 to December 2003
6.36% average = $2,608 + 12 months = $217.30 per month x 5 = $1,087.00
+41,000.00
$42,087.00
Interest from January 2004 to December 2004
8.2% average 42,087.00
+ 3,451.00
45,538.00
Interest from January 2005 to December 2005
8.83% average $45,538.00
+ 4.022.00
49,559.00
Interest from January 2006 to June 2006
8.7% average = $4,312.00 - 12 months = $359.00 per month x 6 = $2,156
$49,559.00
+ 2.156.00
$ 51,715.00
EXHIBIT I
ACCOUNT SUMMARY as of Wed, 19 Mar 200318:55:51
Your Access Number it 77613$
Note: You have enabled all of your accounts for the rest of this session.
CHECKING
Account Number Description Name Balance
0123335705 Sharechek GEORGE W CRONIN $0.00
SAVINGS
Account Number Description Name Balance
0123335002 Share Savings GEORGE W CRONIN $228.59
0123335101 Share Savings DAVID MATTHEW CRONIN $282.20
0123335200 Share Savings MELISSA L CRONIN $415.98
LOANS/ MORTGAGE
Account Number Description Name Balance
No accounts of this type
CREDIT CARDS
Account Number Description Name Balance
MOOOOOOOOOOC9445 MasterCard GEORGE W CRONIN $9,542.00
ACCOIINT DETAILS: xxxxxxxxxxxx9445 MASTERCARD STAN-oARD
Balance: $9,542.00
Credit Limit: $9,700.00
Available Credit: $158.00
Minimum Payment Due: $0.00
Next Due Date: 04/08/03
Last Statement Balance: $9,542.00
Last Statement Date: 03/14/03
Last Payment Amount: $250.00
Last Payment Date: 03/03/03
YTD Interest Paid: $252.52
Effective Annual Percentage Rate: 12.25%
Note: The difference between the Credit Limit and the Balance may not equal the Available Balance due to
unposted charge authorizations.
Tran Date Post Date Reference Number Description Amount
03/14 03/14 PURCHASE *FINAN $1.78
03/14 03/14 PURCHASE *FINAN $93.81
03/03 03/03 75422853062021125461082 MAIL REMITTANCE $250,00-
ECEIVE
02/26 02/27 78432863057000803270971 CB *APR SATI RE 609-77 NJ $26.00
02/21 02/24 70548073053389405641673 BORDERS BOOKS&M $43.49
CHICAG IL
02/21 02/24 70410193053568445002738 IHRC-CHICAGO 2 CHICAG $75.00
02/21 RC-CHICAGO 1 CHICAG
02/24 70410193053568445001052 H $28
90
H .
02/20 02/24 93410193052915624295091 UNITED 0161 ATLANT GA $271.50
02/20 PEDIA SVC/DLV 800-36
02/21 88541863052004118138271 EX $5
00
?, .
02/16 02/20 70434253050206732736406 MOTHER HUBBARD $20
00
CHICAG IL .
02/16 02/18 70541863049072007076856 HYATT HOTELS F& $29
24
CHICAG IL .
02/16 02/18 80417343049640493945215 O'CALLAGHANS CHICAG $15.50
02116 02/17 70541863048072019354961 RUTH'S CHRIS CH CHICAG $49
35
.
02/16 02/17 70541863048072019354821 RUTH'S CHRIS CH CHICAG $332
06
.
02/14 02/17 80536063047242422100624 KCLINGER'S PUBL $28.00
ETTERS PA
02/14 02/17 70499673046683055810653 BATH & BODY WOR r $15.90
WHITEH PA
DOWNLOAD QIF:
From Date: 02!14!03 To Date: 03114103
r For Money® and Quicken® 2000, 99 or 98 (Release 4)
r For Quicken 98®, Release 3,or earlier
Transaction history is available for downloading to popular financial management software
such as Quicken® and Money® from all or part of the current and previous statement
cycles only. If you request transactions outside of this date range, nothing will be displayed
or downloaded for the unavailable dates.
EXHIBIT J
Account History
Below are up to 15 of the most recent transactions for this share or loan within the past 3 months. To see all of this
month's transactions, or to see history for other months, please click on the history button.
Account: VISA LOAN (1-09)
Histoy'
Effective Transaction Description Principal Interest Late Fee Balance Check/Misc
Date
PURCHASE VISA TRANSACTION
3/20/2003 GIANT FOOD STORES #005 MECHANICSBURG PA $28.85 $0.00 $0.00 $7,761.72
DATE 03/19/03 24610432E23226SMD 5411
PURCHASE VISA TRANSACTION
3/20/2003 WINE & SPIRITS 2106 MECHANICSBURG PA DATE $13.24 $0.00 $0.00 $7,732.87
03/19/03 24435652F02VR25T0 5921
2/2812003 INSURANCE SINGLE LIFE02/03 $5.39 $0.00 $0.00 $7,719.63
2/24/2003 PAYMENT HOME BANKING TRANSFER FROM _$155.00 $0.00 $0.00 $7,714.24
SHARE 04
2/23/2003 PAYMENT HOME BANKING TRANSFER $35.62 $64.38 $0.00 $7,869.24
FROM CRONIN,GEORGE W 1570XXXXXX SHARE 04
PURCHASE VISA TRANSACTION
2/21/2003 THE HOME DEPOT 4120 MECHANICSBURG PA $61.23 $0.00 $0.00 $7,904.86
DATE 02/19/03 24610431 K09FABXQD 5200
PURCHASE VISA TRANSACTION
2/20/2003 PIERCE FLORIST N HOLLYWOOD CA DATE 02118/03 $28.15 $0.00 $0.00 $7,843.63
24455011HBW3WRZJN 5992
PURCHASE VISA TRANSACTION
2/17/2003 THE HOME DEPOT 4120 MECHANICSBURG PA $90.73 $0.00 $0.00 $7,815.48
DATE 02/15103 24610431 F09FQZBOT 5200
PURCHASE VISA TRANSACTION
2/14/2003 CLASSMATES ONLINE CLASSMATES.CO WA DATE $36.00 $0.00 $0.00 $7,724.75
02/12/03 24478231QME84WL04 8699
PURCHASE VISA TRANSACTION
2/14/2003 KCLINGER'S TAVERN HANOVER PA DATE 02113103 $31.25 $0.00 $0.00 $7,688.75
24224431D7FM56MAR 5812
PURCHASE VISA TRANSACTION
2/10/2003 PALUMBO PIZZA MECHANICSBURG PA DATE $7.42 $0.00 $0.00 $7,657.50
02/08/03 24266571960LLYF7W 5812
1/31/2003 INSURANCE SINGLE LIFE01103 $5.35 $0.00 $0.00 $7,650.08
1/27/2003 PAYMENT HOME BANKING TRANSFER FROM _$100.00 $0.00 $0.00 $7,644.73
SHARE 04
1/12/2003 PAYMENT HOME BANKING TRANSFER FROM
$200.00
$0.00
$0.00
$7,744.73
SHARE04
PURCHASE VISA TRANSACTION
1110/2003 TEXACO INC 91002678454 DENVER PA DATE $10.01 $0.00 $0.00 $7,944.73
01/08/03 246921609008LPB4P 5542
Back to Top
Account History
Below are up to 15 of the most recent transactions for this share or loan within the past 3 months. To see all of this
month's transactions, or to see history for other months, please click on the history button.
Account: MONEYHANDLER (SO4)
History'
Date Transaction Description Amount Balance Check/Misc
WITHDRAWAL #38291210
3/22/2003 POS 1886 WAL-WAL941753MECHANI1886 -$39.13 $38.61
PAWAL WA
DEPOSIT SST TRANSFER
3/22/2003 FROM CRONIN,GEORGE W 1570XXXXXX $50.00 $77.74
SHARE 04
WITHDRAWAL #PS007871
3122/2003 POS 6558 CARLISLE -$22.51 $27.74
PIKEMECHANICSBUR PASHEET
DEPOSIT HOME BANKING TRANSFER
3/22/2003 FROM CRONIN,GEORGE W 9002XXXXXX $40.00 $50.25
SHARE 04
WITHDRAWAL SST TRANSFER
3/19/2003 TO CRONIN,GEORGE W 1570XXXXXX -$40.00 $10.25
SHARE 04
WITHDRAWAL AT ATM #00002248/TQ2575
3/18/2003 ATM #1 CREDITUNION PLHARRISBURG -$60.00 $50.25
PA
DEPOSIT SST TRANSFER
3118/2003 FROM CRONIN,GEORGE W 1570XXXXXX $100.00 $110.25
SHARE 04
WITHDRAWAL AT ATM #000000181TR3519
3116/2003 ATM 10 SKYPORT ROAD -$20.00 $10.25
MECHANICSBURGPA
WITHDRAWAL ATM FEE
3/16/2003 ATM 10 SKYPORT ROAD -$0.25 $30.25
MECHANICSBURGPA
ATM INQ 10 SKYPORT ROAD
3/15/2003 MECHANICSBURGPA
3/15/2003 WITHDRAWAL AT ATM #00006146/TQ2794 -$60.00 $30.50
ATM 350 NEWBERRY COMMOETTERS PA
WITHDRAWAL #PS007668
3/15/2003 POS 750 N POTTSTOWN PIEXTON -$10.00 $90.50
PAWAWA #085
DEPOSIT SST TRANSFER
3/15/2003 FROM CRONIN,GEORGE W 1570XXXXXX $80.00 $100.50
SHARE 04
WITHDRAWAL #PS007375
3/15/2003 POS 6558 CARLISLE -$18.13 $20.50
PIKEMECHANICSBUR PASHEET
3/14/2003
I WITHDRAWAL AT ATM #000086381748201 -$61.50 $38.63
ATM 1130 CARLISLE RD CAMP HILL PA
V
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this day of 2006, I, Katherine A. Frey,
secretary to Marianne E. Rudebusch, Esquire, Attorney for the Plaintiff, hereby certify that
a copy of the within document has been served, by hand delivery to the following addressee:
P. Richard Wagner, Esquire
Mancke, Wagner, Hershey & Tully
2233 North Front Street
Harrisburg, PA 17110
Attorney for Defendant
By: i"':?
a h rine A. Frey
RENEE P.J. CRONIN,
Plaintiff
V.
GEORGE W. CRONIN, III,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03-1517
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on 4/2/03.
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.
Section 4904 relating to unworn falsification to authorities.
'
Date: 02-t#-O) )
Renil? P.J. C nin
7 C? tJ
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RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 43301(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.
§4904, relating to unsworn falsification to authorities.
Date: a- (P -o 7 (;LA Do, a 'D.
Ren a P.J. Cro 'n
?
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RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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. §4904, relating
to unsworn falsification to authorities.
Date: 9-40 -07
C IC
Y V _k `
v. `0 \
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on 4/2/03.
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. Section 4904
relating to unsworn falsification to authorities.
Date: d' ` (o -0-?
George W. Wonin, III
? ? ?_ ??
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA
V. : NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE
Marianne E. Rudebusch, Esquire, being duly sworn according to law, deposes and
says that she is an attorney at law duly authorized to practice in the Commonwealth of
Pennsylvania, and that on the 4th day of April 2003, she did serve upon, George W.
Cronin, III, Defendant in the foregoing case, a true and correct copy of the Complaint in
Divorce by sending a copy by First Class Mail, postage pre-paid, certified/ restricted delivery
to the Defendant. The "Green Card" is attached to this Affidavit of Service.
! n
Said copy of the Complaint was duly endorsed with notice to Defendant to appear and
answer within twenty (20) days from the date of service or the matter would proceed without
him.
Sworn to and subscribed
before e this day
of , 2007.
Notary Public tapii
Ury By: AW?ta?•?
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Id. No. 63522
¦ Complete items 1, 2, and 3. Also complete
iteM 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
George W. Cronin, III
c/o 8000 Bretz Drive
Harrisburg, PA 17112 f
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A.
- 0 Agent
B.Aaceived by (F5n'nted Name)
D. Is delivery address different from item 1? ? Yes
If YES, enter delivery address below: 0 No
3. ice Type
Kertified Mail 0 Express Mail
0 Registered 0 Return Receipt for Merchandise
4. Restricted
2. Article Numbe ?001 1140 0001 4024 8 616
(Transfer from
PS Form 3811, August 2001 Domestic Return Receipt
102595-02-M-1035
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
MOTION TO REVOKE THE
APPOINTMENT OF SPECIAL MASTER
AND NOW, comes the Plaintiff, Renee P.J. Cronin, by and through her attorney,
Marianne E. Rudebusch, Esquire, and respectfully requests the Court to revoke the
appointment of E. Robert Elicker, II, Esquire, Master, for the reasons hereinafter set forth:
I . On or about April 26,, 2004, E. Robert Elicker, II, Esquire was appointed by the
Court to serve as Master in the above captioned divorce action.
2. An agreement has been reached between the parties, settling all economic
claims pertaining to the divorce action.
3. P. Richard Wagner, Esquire, attorney for Defendant, concurs with this Motion.
WHEREFORE, Plaintiff respectfully requests that this Court revoke the appointment
of E. Robert Elicker, II, Esquire as Master in this matter.
Respectfully Submitted,
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Id. No. 63 522
Dated:
S 4.
MAR 0 5 2007
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ORDER OF COURT
AND NOW, this day of , 2007, upon consideration of
the attached Motion to Revoke the Appointment of Special Master, it is hereby ORDERED
and DECREED that the appointment of E. Robert Elicker, Esquire, as Special Master is
hereby revoked.
BY THE COURT;
Distribution: /anne E. Rudebusch, Esq., 4711 Locust Lane, Hbg., PA, 17109
Richard Wagner, Esq., 2233 North Front Street, Hbg., PA 17110
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT is made and entered into between GEORGE W.
CRONIN, 111 and RENEE P.J. CRONIN, hereinafter referred to as Husband and
Wife. The parties were married on 10/11/86 and there are two children born of
their marriage, to wit, Melissa L. Cronin, born 1/22/86 and David M. Cronin, born
2/1/89.
As a consequence of disputes and unhappy differences, the parties have
separated. The parties desire to confirm their separation and make
arrangements in connection therewith, including the settlement of their property
rights, custody, support, and all other rights and obligations arising out of the
marriage relationship.
It is therefore agreed:
1. CONSIDERATION
The consideration for this Agreement is the mutual promises and
agreement herein contained.
2. SEPARATION AND NONINTERFERENCE
A. It will 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 ray m o
time to time choose or deem fit.
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B. Each party shall be free from interference, authority and control,
direct or indirect, by the other, as fully as if he or she were single and unmarried.
Neither shall bother the other or compel or endeavor to compel the other to
cohabit or dwell with him or her.
3. MUTUAL RELEASE
Subject to the provisions of this Agreement, each party has released and
discharged, and by this Agreement does for himself or herself, and 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 ever had or now has
against the other, except any or all cause or causes of action for divorce.
4. FULL DISCLOSURE
The provisions of this Agreement and their legal effect are fully understood
by each party to this Agreement, 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. Husband and Wife each
represent and warrant to the other that he or she has made a full and complete
disclosure to the other of all assets of any nature whatsoever in which such party
has an interest, of the sources and amount of the income of such party of every
type whatsoever, and of all other facts relating to the subject matter of this
agreement. Wife represents that she is represented by Marianne E. Rudebusch,
Esquire in reaching this Agreement, and Husband represents that he is
represented by P. Richard Wagner, Esquire, in reaching this Agreement. Both
parties represent that the terms of this Agreement have been fully explained to
them by their respective counsel.
S. EQUITABLE DIVISION
By this Agreement, the parties have previously agreed to a division of their
marital property and exchanges have subsequently been finalized. The division
was not intended by the parties to constitute in any way a sale or exchange of
assets.
6. SUBSEQUENT DIVORCE
A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically
understood and agreed by and between the parties hereto and each of the said
parties does hereby warrant and represent to the other that the execution and
delivery of this Agreement is not predicated upon nor made subject to any
agreement for institution, prosecution, defense, or for the non-prosecution or
non-defense of any action for divorce; provided, however, that nothing contained
in this Agreement shall prevent or preclude either of the parties hereto from
commencing, instituting or prosecuting any action or actions for divorce, either
absolute or otherwise, upon just, legal and proper grounds; nor to prevent either
party from defending any such action which has been, may or shall be instituted
by the other party, or from making any just or proper defense thereto. It is
warranted, covenanted and represented by Husband and Wife, each to the other,
that this Agreement is lawful and enforceable and this warranty, covenant and
representation is made for the specific purpose of inducing Husband and Wife to
execute the Agreement. Husband and Wife each knowingly and understandingly
hereby waives any and all possible claims that this Agreement is, for any reason,
illegal or for any reason whatsoever, unenforceable in whole or in part. Husband
and Wife each do hereby warrant, covenant and agree that, in any possible
event, he and she are and shall forever be stopped from asserting any illegality
or unenforceability as to all or any part of this Agreement.
B. ENTRY AS PART OF DECREE - It is the intention of the parties that
the Agreement shall survive any action for divorce which may be instituted or
prosecuted by either party and no order, judgment or decree of divorce,
temporary, final or permanent, shall affect or modify the financial terms of this
Agreement. This Agreement shall be incorporated in but shall not merge into any
such judgment or decree of final divorce, but shall be incorporated for the
purposes of enforcement only.
C. MUTUAL CONSENT DIVORCE - The parties agree and
acknowledge that their marriage is irretrievably broken, that they do not desire
marital counseling, and that they both consent to the entry of a decree in divorce
pursuant to 23 Pa.C.S.A. Section 3301(c). Accordingly, both parties agree to
forthwith execute such consents, affidavits, or other documents and to direct their
respective attorneys to forthwith file such consents, affidavits, or other
documents as may be necessary to promptly proceed to obtain a divorce
pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent
permitted by law and the applicable Rules of Civil Procedure, the named
defendant in such divorce action shall execute any waivers of notice or other
waivers necessary to expedite such divorce.
7. DIVISION OF PERSONAL PROPERTY
The parties agree to divide all Stocks, Mutual Funds and Orrstown
Bank Stock balances at a time mutually agreed upon, not to exceed 6 months
from the date of execution of this agreement. The division shall be 60% to
Husband and 40% to Wife; taxes on the proceeds shall be 60% to Husband and
40% to Wife. The Ford Motor Company stock of 100 shares each will be
designated for Melissa & David and will not be sold and Husband will manage
the account(s) on their behalf until each are capable of assuming responsibility.
Husband agrees to communicate with Wife for all transaction modifications until
time of party distribution.
The parties agree that all U.S. Savings Bonds and the funds in the TAP
shall be designated for their children's post high school education. The parties
shall jointly make decisions concerning these funds and neither party shall
capriciously withhold his/her consent or signature for the use of the funds for the
children's education. Both parties shall provide documentation to each other for
any monies withdrawn.
The parties agree that both children have accounts at the Navy Federal
Credit Union and PSECU and that the balances in these accounts shall remain
the property of the children. Both parties agree not to make any claims on the
Knights of Columbus life insurance monies which are designated for the children.
Husband shall continue to make the premium on these policies and the children
shall be irrevocable beneficiaries of these policies.
8. DIVISION OF MOTOR VEHICLES
With respect to the motor vehicles owned by one or both of the parties,
they agree as follows:
Husband: 1998 Honda - subject to all encumbrances
Honda motorcycle - subject to all encumbrances
Wife: 2003 Toyota Corolla - subject to all encumbrances
The titles to the said motor vehicles shall be executed by the parties, if
appropriate, for effectuating transfer as herein provided, at any time thereafter,
as mutually agreed at a undetermined date.
9. DISPOSITION OF PROPERTY
From and after the date of the signing of this Agreement, both parties shall
have complete freedom of disposition as to his/her separate property and any
property which is in their possession or control pursuant to this Agreement and
may mortgage, sell, grant, convey or otherwise encumber or dispose of such
property, whether real or personal, whether such property was acquired before,
during or after marriage, and neither Husband nor Wife need join in, consent to,
or acknowledge any deed, mortgage, or other instrument of the other pertaining
to such disposition of property. Wife shall take the originals of family photos and
video tapes to be copied at a shared expense of both parties.
10. DIVISION OF REAL PROPERTY
Husband and Wife hereby agree and acknowledge that they own certain
real property located at 406 Cherokee Drive, Mechanicsburg, Pennsylvania, as
tenants by the entireties.
Husband hereby agrees to convey all his right, title and interest in said
property to Wife. Husband agrees to execute a deed or other instrument of
conveyance necessary to effectuate this transfer at the time of the execution of
this document.
The parties acknowledge that there are two existing mortgages against this
property held by National City in the total amount of approximately $174,000.00.
Wife shall hold Husband harmless and indemnify him from liability for this
obligation and other obligations arising from this property.
Wife agrees to obtain financing of these obligations in her name alone
within one year of the date of the signing of this Agreement.
11. PAYMENT OF SPECIFIED OBLIGATIONS
The parties agree that the following constitute joint marital obligations
which shall be paid by the following person:
A. WIFE - All debts in her name alone
All medical balances incurred by her after submission to
and payment from Husband's health insurance for
future services while Wife is covered under Husband's
policy.
B. HUSBAND - All debts in his name alone, including but not limited
to:
PSECU Visa: Balance
Navy Federal Credit Union
MasterCard
Student Loan(s)
12. LEGAL FEES
Each party shall pay his or her own attorneys fees.
13. ALIMONY
Both parties acknowledge and agree that the provisions of this Agreement
providing for equitable distribution of marital property are fair, adequate and
satisfactory to them and are accepted by them in lieu of and in full and final
settlement and satisfaction of any claims or demands that either may now or
hereafter have against the other for support, maintenance, alimony pendente lite
or alimony. Husband and Wife further, voluntarily and intelligently, waive and
relinquish any right to seek from the other any payment for support,
maintenance, alimony pendente lite or alimony.
14. DEFERRED COMPENSATION AND RETIREMENT PENSION PROGRAM
The parties agree that Wife shall receive a total of $70,000.00 from
the Husband's Deferred Compensation Plan with the Commonwealth of
Pennsylvania. Payment of $35,000.00 will be made within 30 days of the
execution of this agreement transferring the funds to wife. Husband agrees to
pay the remaining balance ($35,000.00) to Wife within 30 days after date of
Husband's retirement with his current employer.
A QDRO shall be prepared by Husband's attorney within 30 days of the
execution of this agreement transferring the funds to wife.
Wife shall waive all interest in Husband's current PA State Employees System
Pension Program. Wife further agrees to sign a waiver of such when requested by
Husband.
Husband shall waive all interest that he may have in Wife's retirement
benefits accumulated as the result of her employment or any other additional
benefits she may have accrued, including but not limited to her existing IRA with
PSECU.
15, MISCELLANEOUS
All assets, other then mentioned in previous paragraphs, including, but not
limited to, savings accounts, checking accounts, certificates of deposit and life
insurance policies shall be the sole and separate property of the title holder of
said asset.
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.
Until 2002 the parties 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.
16. GENERAL PROVISIONS
A. WARRANTY AS TO EXISTING OBLIGATIONS - Each party
represents that they have not heretofore incurred or contracted for any debt or
liability or obligation for which the estate of the other party may be responsible or
liable except as may be provided for in this Agreement. Each party agrees to
indemnify or hold the other party harmless from and against any and all such
debts, liabilities, or obligations of every kind which may have heretofore been
incurred by them, including those for necessities, except for the obligations
arising out of this Agreement.
B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband
each covenant, warrant, represent and agree that each will now and at all times
hereafter save harmless and keep the other indemnified from all debts, charges,
and liabilities incurred by the other after the execution date of this Agreement,
except as may be otherwise specifically provided for by the terms of this
Agreement and that neither of them shall hereafter incur any liability whatsoever
for which the estate of the other may be liable.
C. SEVERABILITY - 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 his or her obligations under any one or more of the paragraphs herein, with
the exception of the satisfaction of the conditions precedent, shall in no way void
or alter the remaining obligations of the parties.
D. OTHER DOCUMENTATION - Wife and Husband covenant and
agree that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other writings as may
be necessary or desirable for the proper effectuation of this Agreement, and as
their respective counsel shall mutually agree should be so executed in order to
carry out fully and effectively the terms of this Agreement.
E. ENTIRE AGREEMENT - This Agreement contains the entire
understanding of the parties, and there are no representations, warranties,
covenants, or undertakings other than those expressly set forth herein.
F. 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 of any breach hereof or default hereunder shall be
deemed a waiver of any subsequent default of the same or similar nature.
G. MUTUAL COOPERATION - Each party shall, at any time and from
time to time hereafter, take any and all steps and execute, acknowledge, and
deliver to the other party any and all further instruments and/or documents that
the other party may reasonably require for the purpose of giving full force and
effect to the provisions of this Agreement.
H. LAW GOVERNING - This Agreement shall be construed and
governed in accordance with the laws of the Commonwealth of Pennsylvania.
1. BINDING EFFECT - Except as otherwise stated herein, this
Agreement shall be binding and shall inure to the benefit of the parties hereto
and their respective heirs, executors, administrators, successors, and assigns.
J. 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 it be construed as a waiver of strict performance of
any other obligations herein.
K. HEADINGS NOT PART OF AGREEMENT - Any heading preceding
the text of the several paragraphs and subparagraphs hereof are inserted solely
for convenience or reference and shall not constitute a part of this Agreement nor
shall they affect its meaning, construction, or effect.
L. ADDRESS OF PARTIES - Each party shall at all times keep the
other informed of his or her place of residence, and shall promptly notify the other
of any change, giving the address of the new place of residence.
4 F
A
M. WAIVER OF CLAIMS AGAINST ESTATES - Except as herein
otherwise provided, each party may dispose of his or her property in any way,
and each party hereby waives and relinquishes any and all rights he or she may
have or hereafter acquire, under the present or future laws of Pennsylvania or
another jurisdiction, to share in the property or the estate of the other as a result
of the marital relationship, including, without limitation, dower, courtesy, their
statutory equivalents, widow's allowance, homestead rights, right to take in
intestacy, right to take against the will of other, and right to act as administrator or
executor of the other's estate, and each party will, at the request of the other,
execute, acknowledge, and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment
of all such interests, rights and claims.
N. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that either
party breaches any provision of this Agreement, and the other party retains
counsel to assist in enforcing the terms thereof, the parties hereby agree that the
breaching party will pay all reasonable attorneys' fees, court costs, and expenses
incurred by the other party in enforcing the Agreement.
IN WITNESS WHEREOF, and intending to be bound hereby, the parties
,`-
have signed and sealed this Agreement on the day of ,
2001, at Harrisburg, Pennsylvania.
In the presence of:
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WITNESS
SEAL)
(SEAL)
WITNESS RE WE P.J. RONIN
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Plaintiff
RENEE P.J. CRONIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA
V. : NO. 03-1517
GEORGE W. CRONIN, III, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the complaint: Certified/Restricted Delivery;
4/4/03.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section
3301(c) of the Divorce Code: by Plaintiff, 2/6/07 ; by Defendant, 2/6/07 .
1&
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce
Code: N/A.
(2) Date of filing and service of the affidavit upon the respondent: N/A.
4. Related claims pending: All claims were resolved by agreement of the parties
as per the Marriage Settlement Agreement executed by the parties on 1/12/07.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached: N/A.
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: 2/8/07
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: 2/8/07
By: /'.
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Id. No. 63522
Attorney for Plaintiff
Dated: -00- (9
71,
77
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
RENEE P.J. CRONIN
Plaintiff
VERSUS
GEORGE W. CRONIN, III
Defendant
NO. 03-1517
DECREE IN
DIVORCE
AND NOW, 2007 , IT IS ORDERED AND
DECREED THAT Renee P.J. Cronin
AND George W. Cronin, III
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, 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; 00 0?0
The Marriage Settlement Agreement executed by the parties on
1/12/07, and attached hereto, is hereby incorporated, but not
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merged with this Divorce Mecree.
By THE I
ATTEST: 11 J.
PROTHONOTARY
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RENEE P.J. CRONIN, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. NO: 03-1517
CIVIL ACTION - LAW
GEORGE W. CRONIN, III,
IN DIVORCE
Defendant.
QUALIFIED DOMESTIC RELATIONS ORDER
1. PARTIES:
The parties hereto were husband and wife, and a divorce action is in this Court at
the above number. This Court has personal jurisdiction over the parties. The
parties were married on October 11, 1986 and divorced March 20, 2007.
2. PARTICIPANT INFORMATION:
The name, last known address, Social Security number and date of birth of the
Plan "Participant" are:
George W. Cronin, III
411 W. Main Street
Apt. #2
Mechanicsburg, PA 17055
SS # 570-11-4732
DOB: April 5, 1961
3. ALTERNATE PAYEE INFORMATION:
The name, last known address, and Social Security number of the "Alternate Payee" are:
Renee P.J. Cronin
406 Cherokee Drive
Mechanicsburg, PA 17055
SS # 210-56-6718
The Alternate Payee shall have the duty to notify the Plan Administrator in writing of any
changes in mailing address subsequent to the entry of this Order.
4. PLAN NAME:
The name of the Plan to which this Order applies is the Commonwealth of Pennsylvania
Deferred Compensation Program (hereinafter referred to as "Plan").
Any changes in Plan Administrator, Plan Sponsor, or name of the Plan shall not affect
Alternate Payee's rights as stipulated under this Order.
5. EFFECT OF THIS ORDER AS A QUALIFIED DOMESTIC RELATIONS
ORDER:
This Order creates and recognizes the existence of an Alternate Payee's right to receive a
portion of the Participant's benefits payable under an employer-sponsored defined
contribution plan under section 457(b) of the Internal Revenue Code (the "Code").
6. PURSUANT TO STATE DOMESTIC RELATIONS LAW:
This Order is entered pursuant to the authority granted in the applicable domestic
relations laws of the Commonwealth of Pennsylvania.
7. PROVISIONS OF MARITAL PROPERTY RIGHTS:
This Order relates to the provision of marital property rights as a result of the Order of
Divorce between the Participant and the Alternate Payee.
8. AMOUNT OF ALTERNATE PAYEE'S BENEFIT:
This Order assigns to the Alternate Payee an amount equal to Seventy Thousand Dollars
($70,000.00) of the Participant's Total Account Balance under the Plan as of February 12,
2007. Further, such Total Account Balance shall include all amounts maintained under
all of the various accounts and/or sub-accounts established on behalf of the Participant.
Such Total Account Balance shall be determined after the account is reduced by the
outstanding balance of the Participant's account reduction loan(s), if any, as of the
valuation date specified above, such that the Account Balance shall not include the
outstanding balance of any account reduction loan(s) as of the valuation date. The
obligation to repay any Participant Plan loan(s) from and after the date of this Order
remains solely with the Participant. The Alternate Payee's benefit herein awarded shall
be credited with any interest and investment income (or losses) attributable from the
-2-
aforesaid valuation date (or the closest valuation date thereto), until the date of total
distribution to the Alternate Payee.
The Alternate Payee's portion of the benefits described above shall be allocated on a
prorata basis from all of the accounts and/or investment options maintained under the
Plan on behalf of the Participant. Such benefits shall also be segregated and separately
maintained in a nonforfeitable Account(s) established on behalf of the Alternate Payee.
This Account(s) will initially be established in the same fund mix percentages as the
Participant account.
9. COMMENCEMENT DATE AND FORM OF PAYMENT TO ALTERNATE
PAYEE:
If the Alternate Payee so elects, the benefits shall be paid to the Alternate Payee as soon
as administratively feasible following the date this Order is approved as a QDRO by the
Plan Administrator, or at the earliest date permitted under the terms of the Plan or section
414(p) of the Code, if later. Benefits will be payable to the Alternate Payee in any form
or permissible option otherwise available to participants under the terms of the Plan,
except a joint and survivor payment. The Alternate Payee will be responsible for paying
any applicable withdrawal charges imposed under any investment account(s) with respect
to his or her share under the plan.
10. ALTERNATE PAYEE'S RIGHTS AND PRIVILEGES:
On and after the date of this Order is deemed to be a QDRO, but before the Alternate
Payee receives a total distribution under the Plan, the Alternate Payee shall be entitled to
all of the rights and election privileges that are afforded to Plan beneficiaries, including,
but not limited to, the rules regarding the right to designate the Alternate Payee's Estate
as beneficiary for death benefit purposes and the right to direct Plan investment, only to
the extent permitted under the provisions of the Plan.
11. DEATH OF ALTERNATE PAYEE:
In the event of the Alternate Payee's death prior to receiving the full amount of benefits
assigned under this Order and under the benefit option chosen by the Alternate Payee, the
remainder of any unpaid benefits under the terms of this Order shall be paid to the
Alternate Payee's Estate. The Alternate Payee may not designate a beneficiary other than
his or her Estate.
-3-
12. DEATH OF PARTICIPANT:
Should the Participant predecease the Alternate Payee, such Participant's death shall in no
way affect the Alternate Payee's right to the portion of the benefits as stipulated herein.
13. SAVINGS CLAUSE:
This Order is not intended, and shall not be construed in such a manner as to require the
Plan:
a. to provide any type or form of benefits or any option not otherwise
provided under the Plan;
b. to provide increased benefits to the Alternate Payee;
to pay any benefits to the Alternate Payee which are required to be paid to
another alternate payee under another order previously determined to be a
QDRO; or
d. to make any payment or take any action which is inconsistent with any
federal or state law, rule, regulation or applicable judicial decision.
14. CERTIFICATION OF NECESSARY INFORMATION:
All payments made pursuant to this Order shall be conditioned on the certification by the
Alternate Payee and the Participant to the Plan Administrator of such information as the
Plan Administrator may reasonably require from such parties.
15. CONTINUED QUALIFIED STATUS OF ORDER:
It is the intention of the parties that this QDRO continue to qualify as a QDRO under
section 414(p) of the Code, as it may be amended from time to time, and that the Plan
Administrator shall reserve the right to reconfirm the qualified status of the Order at the
time benefits become payable hereunder.
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16. TAX TREATMENT OF DISTRIBUTION MADE UNDER THIS ORDER:
For purposes of sections 402(a)(1) and 72 of the Code, or any successor Code section, any
Alternate Payee who is the spouse or former spouse of the Participant shall be treated as
the distributee of any distribution or payments made to the Alternate Payee under the
terms of this Order, and as such, will be required to pay the appropriate federal income
tax on such distribution.
17. PARTIES RESPONSIBILITIES IN EVENT OF ERROR:
In the event that the Plan inadvertently pays the Participant any benefits that are assigned
to the Alternate Payee pursuant to the terms of this Order, the Participant shall
immediately reimburse the Alternate Payee to the extent that the Participant has received
such benefit payments by paying such amounts directly to the Alternate Payee within ten
(10) days of receipt.
In the event that the Plan inadvertently pays the Alternate Payee any benefits that are to
remain the sole property of the Participant pursuant to the terms of this Order, the
Alternate Payee shall immediately reimburse the Participant to the extent that the
Alternate Payee has received such benefit payments by paying such amounts directly to
the Participant within ten (10) days of receipt.
18. EFFECT OF PLAN TERMINATION:
In the event of a Plan termination, the Alternate Payee shall be entitled to receive his or
her portion of the Participant's benefits as stipulated herein in accordance with the Plan's
termination provisions for participants and beneficiaries.
19. CONTINUED JURISDICTION:
The Court retains jurisdiction over this matter to amend this Order to establish or
maintain its status as a qualified domestic relations order under Code section 414(p), as
amended and the original intent of the parties as stipulated herein. The Court shall also
retain jurisdiction to enter such further orders as are necessary to enforce the assignment
of benefits to the Alternate Payee as set forth herein.
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20. NOTICE OF PENDING RETIREMENT:
In the event that the terms of the Plan require the Alternate Payee to wait until the
Participant's actual date of termination of employment or retirement before becoming
eligible to receive a distribution, then the Participant shall be required to notify the
Alternate Payee, in writing, within ten (10) days following such termination of
employment or retirement. The notice shall be sent via regular first-class mail. For this
purpose, the Alternate Payee shall notify the Participant of any changes in mailing
address.
21. FEE:
A processing fee of $250.00 shall be charged one-half ($125.00) against the Alternate
Payee's account and one-half ($125.00) against the Participant's remaining account. In
the event that the Alternate Payee is awarded 100% of the Participant's account balance
as of the date this Order is processed pursuant to this Order, the entire processing fee shall
be charged to the Alternate Payee's account. If there are not sufficient funds in either
party's account to pay that party's respective share of the fee, the differ ce shall be
charged to the account of the other party. /1
BY THE POURT:
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