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Home My WebLink About00-06060IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS PATRICK J. SULLIVAN, III, a/k/a • , Defendant DECREE IN DIVORCE No. 2000-6060 KIMBERLY A. SULLIVAN, 2005 AND NOW, mll4 ty IT IS ORDERED AND KIMBERLY A. SULLIVAN DECREED THAT AND PATRICK T. SULLIVAN, 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; NONE PROTHONOTARY ?? ?? KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, (also known as Patrick T. Sullivan, III) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-6060 CIVIL TERM 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). 2. Date and manner of service of the Complaint: Sheriff's service on 13 September 2000 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 12 May 2005 by Defendant: 12 May 2005 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the 4. Related claims pending: None 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 12 May 2005, filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 12 May 2005, filed contemporaneously herewith. Date: trl fl'1 a, 2 7S By mu I L. Ande Atto ey for Plaintiff n __ cri ..r' 47 3f `t7 i ? ??? _?... L.. t'o _ =? , . ".`,= ? C7 yr` F ,. ? -^: ? ,„,_ --C ?? ii 'R. KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- 1,00,0 LL? 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 J KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- 6060 C;?f7' - IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, KIMBERLY A. SULLIVAN, by his/her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: The Plaintiff is KIMBERLY A. SULLIVAN, an adult individual who currently resides at 5 San Juan Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is PATRICK J. SULLIVAN, III, an adult individual who currently resides at 330 South 3155 Street in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residence of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 29 September 1995 in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 - IRRETRIEVABLE BREAKDOWN B. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. Date: 01" KIMBER A. S LLIVAN S`amukl L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 5 September 2000 and served upon the Defendant on or about 13 September 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. 1 consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ZI2?0 S Date KIMB LY A. ULLIVAN YJ :?10 , KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK,,;. SULLIVAN, III, "r, Defendant 14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 5 September 2000 and served upon the Defendant on or about 13 September 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on Defendant. 3. 1 consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ? oS Date - PATRICK/. SULLI AN, III r, Q c°rg r C ? C3 KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. S ?2 OS Date KIMB LY A. ULLIVAN Q ? l"d1 ?Tj ? rv r ' ad? _-q _ CD V KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK,d: SULLIVAN, III, -r, Defendant 4W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (2/OS Date P ATRICK/. SULL T. f& AN, III N a C?D .._L I SHERIFF'S RETURN - REGULAR CASE NO: 2000-06060 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SULLIVAN KIMBERLY A VS SULLIVAN PATRICK J III J. MICHAEL ICKES Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon SULLIVAN PATRICK J III the DEFENDANT , at 0015:20 HOURS, on the 13th day of September, 2000 at 330 SOUTH 31ST STREET CAMP HILL, PA 17011 by handing to TRACEY CARPER (ADULT RESIDENT) a true and attested copy of COMPLAINT - DIVORCE together with NOTI and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 service 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this d/oF day of dz- y? A. D. rothonotary So Answers: woo- 000-0 OQ? R. Ts Kline 09/14/2000 -? SAMUEL ANDES By. Lk L Deputy-Sheriff- KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE ORDER a AND NOW this day of 2002, upon consideration of Plaintiff's Motion to Compel, it appearing that Defendant has made no response to Plaintiff's Request for Production of Documents and Things for a period in + sp«.a -rb excess of three months, Defendant is hereby ordered and directed to pFCdus644044ems iless? Plaintiff's Request for Production of Documents and Things, to Plaintiff's counsel at his office, within 2.0 days of service of this order. BY THE COURT, • ,41 J. Distribution: Samuel L. Andes, Esquire (Attorney for Plaintiff) P.O. Box 168, Lemoyne, PA 17043 Patrick J. Sullivan, III ro se 9 330 South 31 st Street, Camp Hill, PA 17011 Ib,IrF'Y i02,1111--! ? , i . PENNSYC?IANIA KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE ORDER AND NOW this day of , 2002, upon consideration of Plaintiff's Motion to Compel, a conference is scheduled before the undersigned, to be held in Court Room of the Cumberland County Courthouse in Carlisle, Pennsylvania, at o'clock m. on the day of , 2002. BY THE COURT, J. Distribution: Samuel L. Andes, Esquire (Attorney for Plaintiff) P.O. Box 168, Lemoyne, PA 17043 Patrick J. Sullivan, III ro se 330 South 31' Street, Camp Hill, PA 17011 KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE MOTION TO COMPEL AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and moves the court to compel Defendant to produce documents, based upon the following: 1. The Petitioner herein is the Plaintiff, Kimberly A. Sullivan an adult individual who resides at 817 Allenview Drive in Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Respondent herein is the Defendant, Patrick J. Sullivan, III, who is not represented by an attorney in this matter and whose address is 330 South 31't Street in Camp Hill, Cumberland County, Pennsylvania 17011. 3. On 6 March 2002, Plaintiff served upon Defendant a Request for Production of Documents and Things. A copy of the Request, with a certificate of service, is attached hereto and marked as Exhibit A. 4. Since service of the Request for Production, Defendant has filed no objections to the Request, has provided none of the documents requested in the Request, and has not responded in any way to Plaintiff's Request for Production. 5. Plaintiff needs the information and documents requested from Defendant in order to properly resolve this case and to prepare it for settlement or litigation. 6. Defendant's refusal to cooperate and to produce the information described in Plaintiff's Request for Production has caused Defendant to incur legal fees which would not otherwise have been necessary. At this point she anticipates the fees she will incur to obtain this information to be at least $500.00. WHEREFORE, Plaintiff moves this court to enter an order to compel Defendant to produce the documents and other things described in Plaintiff's Request for Production and, if Defendant fails to produce them in accordance with this court's order, to impose such sanctions, including attorneys fees, as the court deems appropriate. Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Motion to Compel upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Patrick T. Sullivan 330 South 31" Street Camp Hill, PA 17011 Date: 24 June 2002 Sa I L. Andes Attorney for Plaintiff KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS TO: Patrick J. Sullivan, III 330 South 31' Street Camp Hill, PA 17011 You are requested, in accordance with Pa. R.C.P. 4009, to deliver to the office of the undersigned at 525 North 12th Street, Lemoyne, Pennsylvania, or otherwise make arrangements reasonably satisfactory to the undersigned, for his inspection or examination, copies of the following documents, articles, and things, within thirty (30) days of the date of this Request. For purposes of this Request, all computer records and information available on computer records or within computer programs, should be included within the Request for Production. That is, this Request is not limited to documents or "hard copies" of records, but should include computer records, tapes, disks, and other media as well as paper documents. 1. A copy of the Deed to your property at 330 South 31st Street in Camp Hill, Cumberland County, Pennsylvania, and any other real estate in which you own or claim an interest or have owned or claimed an interest at any time since 29 September 1995. 2. Copies of all appraisals of any real estate in which you own or claim an interest which you have from 29 September 1995 to the present. 3. Copies of all notices of assessment or other documents describing the assessed value from any real estate you own or in which you own an interest now or at any time after 29 September 1995. 4. Documents showing the balance owed on any mortgage against your real estate at 330 South 31 s` Street in Camp Hill or any other real estate in which you own or claim an interest, for the following dates, or the dates closest to them for which such information is available: A. 29 September 1995. B. Any date on which you refinanced any of the debts secured by such mortgage or mortgages. C. 30 June 2000. 5. Copies of documents confirming the balance in any deferred compensation account, or similar tax-deferred benefit of your employment with the Commonwealth of Pennsylvania, for the following dates: A. 29 September 1995. B. 30 June 2000. C. 31 December 2001. 6. Copies of the statement of account for your pension benefits with the State Employees Retirement System for the following dates: A. Year end 1995. B. Year end 2000. C. Year end 2001. 7. Statements from any investment account, stock portfolio, mutual fund, or other investment asset which you own, individually or jointly with any other person or entity, specifically including statements from an account with Waterhouse Securities, for the following dates: A. 29 September 1995. B. The date the account was first opened or first placed in your name. C. 30 June 2000. D. 31 December 2001. 8. Copies of all bills of sales, receipts, motor vehicle titles, or other documents which will confirm all motor vehicles and items of construction equipment which you purchased, acquired, or used in your construction business from 29 September 1995 to the present. 9. Copies of documents relating to and describing the sale of a motor vehicle owned by your wife that was sold during the marriage which we believe to be a 1991 Honda automobile. 10. Copies of your check registry or other documents which will reflect what was done with the proceeds of the sale of the automobile described in the foregoing request. 11. Copies of the following documents relating to any Harley Davidson motorcycle, or other motorcycle or similar motor vehicle, owned by you during the marriage: A. A copy of the title and the original documents issued when you purchased the vehicle. B. Copies of loan documents after you borrowed money for the purchase of the vehicle or used the vehicle as security for any loan. C. A statement showing the balance owed on any loan against the vehicle as of 30 June 2000. D. A copy of any appraisal or other document reflecting the value of the motorcycle. 12. Copies of documents describing your interest in a sail boat or similar recreational boat, trailer, motor, and related items of equipment and any debt owed against that. Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing Request for Production of Documents and Things upon the Defendant herein by regular mail, postage prepaid, addressed as follows: Patrick T. Sullivan 330 South 31" Street Camp Hill, PA 17011 Date: 6 March 2002 181 sa1'Yuj-d 9 . Samuel L. Andes Attorney for Plaintiff c, - ?-?? a ?? - ? ='?- -_ -a .?r ?? i f -:`yi? . - r -, r ?T? .-.:? l C?i:J ?! /'" ? ill ( ?? 6 j _? ? "? - . L}3 G KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE PRAECIPE Please withdraw all economic claims filed in this matter by the Defendant, including any claims filed for equitable distribution, alimony, alimony pendente lite, or counsel fees and expenses. Date: ? ? ;ghn F. King ttorney for Defend nt Supreme Court ID # 600 North Second Street Harrisburg, PA 17101 c r ?' ?. ?' _„r-y r I--? ....- - .? y .e.3 l ? L? ? ?? ? ? 1 .?? C C ? = 7, ?? , . , -4 ? ?? KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE PRAECIPE Please withdraw all economic claims filed in this matter by the Plaintiff, including any claims filed for equitable distribution, alimony, alimony pendente lite, or counsel fees and expenses. Date: ?i 20b? Sa I L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12'h Street Lemoyne, PA 17043 r ` 0 - s ? p KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE ENTRY OF APPEARANCE Kindly enter my appearance on behalf of the Defendant, Patrick J. Sullivan, III, in the above-captioned matter. Respectfully submitted, FRIEDMAN & KING, P.C. ?U Date: Jon King, E quire t Second S reet 60 Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 CD ca p 3 T G? '? `r C7 Commonwealth of Pennsylvania APR 2 0 2004 County of Cumberland, ss: KIMBERLY A. SULLIVAN, ) In the Court of Common Pleas of Plaintiff ) Cumberland County, Pennsylvania 1 VS. ) No. 2000-6060 CIVIL TERM PATRICK J. SULLIVAN, III, ) Defendant ) Motion for Appointment of Master KIMBERLY A. SULLIVAN, Plaintiff moves the court to appoint a Master with respect to the following claims: ( 1 Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite and in support of the motion states: (XX) Distribution of Property ( ) Support ( 1 Counsel Fees ( ) Costs and Expenses 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared in the action by his attorney, John F. King, Esquire. 3. The statutory ground(s) for divorce are: Distribution of Property 4. Check the applicable paragraph(s). ( 1 The action is not contested. ( 1 An agreement has been reached with respect to the following claims: ( ) The action is contested with respect to the following claims: 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 days. 7. Additional information, if any, relevant to the motion: (9 coT Date L. Andes J Attorney for Plaintiff /J AND NOW, 0 2004, e-0 Z( -&1 664 , Esquire, is appointed Maste wit respect to the following claims: Distribution of Property BY THE. pi. FILED-O FIGS OF THE MOTHoNoTAF?Y 2004 APR 27 Aid 10- (5 CUME :jt v; r-, ? is , ,UNTY I EIdI?VS?7.11 mm,,A ki ", V Q "y- ? a- cli - = '' ate, .u!aw? s ?:r..?:..p 4 .?} .afN<-xsptmw^',:.?'??1'e'mNk3? rnrs?Fle ? KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE INVENTORY OF PATRICK.L SULLIVAN, III John F. King, Esquire, on behalf of the Defendant, 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. John F. King, Esquire verifies that upon information from Defendant the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. The Defendant is presently outside of the jurisdiction of this Court, and will file a supplemental Verification upon return. ASSETS OF THE PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (XX) (XX) (XX) 1. 2. 3. 4. 5. 6. 7. 8. 9. Real Property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment termination benefits-severance pay, worker's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of assets is in dispute) Other 10. 11. 12. 13. 14. 15. ) 16. ( ) 17. (XX) 18. (XX) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (XX) 24. (XX) 25. ) 26. MARITAL PROPERTY Defendant 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 this action was commenced: Item Description Names of Number of Property All Owners 1. Increase in value of Marital Patrick J. Sullivan, III Residence during marriage (Property deeded in Located at 330 S. 3 V Street Defendant solely) Camp Hill, PA 17011 2. Motor Boat Patrick J. Sullivan, III 17' open bow Chris Craft and Kimberly A. Sullivan 3. Water skis (3 sets) Patrick J. Sullivan, III and Kimberly A. Sullivan 4. Husband's retirement plan Patrick J. Sullivan, III Commonwealth of PA (Portion acquired during Marriage) 5. Wife's 401(k) Kimberly A. Sullivan (Portion acquired during Marriage) 6. Wife's IRA Kimberly A. Sullivan (Portion acquired during Marriage) 7. Wife's retirement plan Kimberly A. Sullivan Pinnacle Health (Portion acquired during Marriage) 8. Furniture and other Patrick J. Sullivan, III Household personalty and Kimberly A. Sullivan 9. 1997 Suburban motor vehicle Patrick J. Sullivan, III (Purchased used) 10. 1988 Chevrolet Dump Truck Patrick J. Sullivan, III (Purchased used) 11. Motorcycle Patrick J. Sullivan, III (Purchased used) NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Description Reason for Number of Property Exclusion 1. Various personalty Owned pre-marriage 2. Real Property Owned pre-marriage 330 S. 31" Street Camp Hill, PA 17011 3. Husband's retirement Portion acquired Outside marriage 4. Wife's retirement Portion acquired Outside marriage 5. Wife's IRA Portion acquired Outside marriage 6. Wife's 401(k) Portion acquired Outside marriage PROPERTY TRANSFERRED Item Description Date of Consider- Number of Prope tv Transfer ation Person to Whom Transferred N/A LIABILITIES Item Description Names of Names of Number of Property All Creditors All Debtors 1. Primary mortgage on marital National City Patrick J. Sullivan III residence Mortgage , 2. Real estate equity loan PSECU Patrick J. Sullivan, III and Kimberly A. Sullivan 3. Personal service loan PSECU Patrick J. Sullivan, III and Kimberly A. Sullivan k/p: divorce\psullivan. inv KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on May 25, 2004, I served a copy of the within Inventory of Patrick J. Sullivan, III, by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Samuel L. Andes, Esquire 525 North Twelfth Street P. O. Box 168 Lemoyne, PA 17043 P.C. ja N. SecondS et house Suite . Box 984 isburg, PA 17108 (717) 236-8000 F = 7 C) r-n i9 O -< KIMBERLY A. SULLIVAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-6060 Civil PATRICK J. SULLIVAN, III, : CIVIL ACTION - LAW Defendant : DIVORCE PRAECIPE Please substitute the attached Verification for the Verification filed with the Inventory of Patrick J. Sullivan, III. Date: ? i k/p:divorce\psullivan.pra Respectfully submitted, VERIFICATION I, Patrick J. Sullivan, III, hereby acknowledge that I am the Defendant in the foregoing action; that I read the foregoing Inventory; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 1)?414JIJL-)Zt- PatrickT Sullivan, Dated-. (A& 4eA ( ) A KIMBERLY A. SULLIVAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-6060 Civil PATRICK J. SULLIVAN, III, : CIVIL ACTION - LAW Defendant : DIVORCE CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on November 1, 2004, I served a copy of the attached Praecipe substituting the Verification, by Hand Delivery, addressed as follows: E. Robert Elicker, 11, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Street P. 0. Box 168 Lemoyne, PA 17043 N. Second Street P nthouse Suite 0. Box 984 C Harrisburg, PA 171( (717) 236-8000 t CZ q r, 3?!sri ? mr 7J J? I KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE DEFENDANT'S PRE-TRIAL STATEMENT Defendant, by his attorney, John F. King, Esquire, files this Pre-Trial Statement in accordance with Pa. R.C.P. 1920.33(b). 1. ASSETS. Attached hereto and marked as Exhibit "A" is a list of the Marital and Non-Marital Assets as known to Defendant. 2. EXPERT WITNESSES. At this time, Defendant intends to call the following expert witnesses to testify on his behalf at any hearing: A. Real estate appraiser to testify as to the increase in value of Husband's real estate at 330 S. 315` Street in Camp Hill. Defendant reserves the right to call such additional experts as may be necessary, depending upon the witnesses the Plaintiff will call. 3. FACT WITNESSES. At the present time, Defendant intends to call himself as a fact witness. The Defendant will give general testimony regarding the value of assets and further information regarding marital versus non-marital property, and finally information regarding debt. The Defendant also intends to call his mother, who will testify as to ownership of the TD Waterhouse securities account. 4. EXHIBITS. At this time, Defendant intends to offer into evidence the following exhibits (collectively attached as Defendant's Exhibit "B"): A. Real estate equity loan documents. B. Primary mortgage documents. C. Boat valuation. D. Payroll statement. E. SERS Statement of account. F. Chevrolet Suburban valuation. G. Real Estate Appraisal - date of marriage. 5. INCOME. Attached hereto as Exhibit "C" is a copy of Defendant's pay statement for period ending 8/13/04. Defendant's current gross income is approximately $56,500.00 annual, and approximately current net income is $36,400.00 annual. 6. PENSION VALUE. Attached hereto is a copy of the Defendant's 2000 Statement of Account from the Pennsylvania State Employee Retirement System. 7. DEBTS. Please see Defendant's Exhibit "D". 8. PROPOSED RESOLUTION. A 50150 distribution of marital assets by way of a combination of cash distribution and Qualified Domestic Relations Order. Respectfully submitted, Date:nA;t",,at? 60 N. Second St Pe thouse Suite Fl7r .Bo x 984 isburg, PA 17108 ) 236-8000 k/p:divorce\psullivan.pretrial VERIFICATION I, Patrick J. Sullivan, III, hereby acknowledge that I am the Defendant in the foregoing action; that I have read the foregoing Defendant's Pre-Trial Statement; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Patrick?' Sullivaff , III Dated: MARITAL PROPERTY DATE OF MARITAL ASSET VALUE VALUE PORTION N/A 1. Marital residence Appraisal pending Current 330 S. 31" Street Camp Hill, PA 2. Husband's SERS Unknown N/A Retirement Acct 3. Wife's Tax Unknown Deferred Annuity with Travelers Ins. 4. Husband's 1997 $4,260.00 Chevrolet Suburban 5. Husband's 1984 $3,000.00 Harley Davidson motorcycle 6. Husband's 1/3 $2,200.00 interest in sail boat and trailer NOTE: 1/3 interest sold - 6/2000 7. 1987 Chris Craft Unknown 17' motor boat in Plaintiff s possession 8. Household Negligible furnishings 9. Water skis, tube, $400.00 Wakeboard 10. Wife's 401(k) Unknown 11. Wife's IRA Unknown 12. Wife's Ret. Plan Unknown present sale date 2002 as ordered by Court (support action) present N/A Date of Separation Current Appraised I' mtg $85,076.00 (DOS) Value 2nd mtg $34,626.00 (DOS) $135,000.00 approx. 29% None (portion earned during marriage) 100% None 100% 100% 100% 100% 100% 100% LIENS None None None None None None N/A 100% Unknown N/A 100% Unknown N/A 100% Unknown NON-MARITAL PROPERTY REASON DATE OF FOR ASSET VALUE VALUATION EXCLUSION 1. TD Waterhouse $65,000.00 Date of Separation The securities in this Securities Account Acct. are solely owned by Husband's mother 2. Defendant's equity $135,000.00 Date of Marriage Written Pre-Marital in residence at Agreement between 330 S. 31" Street parties, and appraisal Camp Hill (on date of marriage) 3. Wife's Pre-Marital Unknown N/A Owned pre-marriage portion of tax deferred annuity with Travelers Insurance 4. Each parties' Negligible N/A Owned by each party pre-marital furniture prior to date of marriage 5. Wife's pre-marital Unknown N/A Earned pre-marriage portion of 401(k) 6. Wife's pre-marital Unknown N/A Earned pre-marriage portion of IRA 7. Wife's pre-marital Unknown N/A Earned pre-marriage portion of retirement plan 8. Husband's pre-marita l Unknown N/A Earned pre-marriage portion of retirement plan LIENS None ls`mtg. $85,076. (DOS) 2nd mtg. $34;626. (DOS) N/A None Unknown Unknown Unknown None August 27, 2004 Patrick Sullivan 330 S 31st Street Camp Hill, PA 17011 Account # 0196547128 DEAR Patrick Sullivan: The balances on your loans as of June 2000 are as follows: Personal Service Loan (LI) $237.22 June 20,2000 Visa Loan (L9) $3990.15 June 26, 2000 Real Estate Equity Loan (1,50) $34,626.62 June 1, 2000 If you have any questions, you may reach us between 7 a.m. to 5 p.m. Monday through Friday or between 8 a.m. to noon on Saturdays. Call 234-8484 in Harrisburg or call our toll-free number (800) 237-7328. When you come to the menu prompt, enter 5 and then enter 5 again. One of our Member Service Representatives will be glad to assist. Sincerely, CIU ita Austin Member Service Advisor Member Services PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • (717) 234-8484 • (800) 237-7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 - (717) 777-2100 (TDD) • (800) 472-1967 (TDD) Web Address: www.psecu.com Savings federally Insured up to $100,000 by the National Credit Union Administration SPOUSAL WAIVER AND AFFIDAVIT ? fl I I, ?/ ?1 M (? P'Y .? ?1I Sl ),va- I , being first duly sworn, make the following affidavit for the pur ose of inducing Penn nia tate Employees Credit Union (the "Credit Union's to make a loan to my spouse, 157 ? ! ,J `?? individually or as a paner with others, secured by a mortgage lien upon real estate located in ?° r , 10- County, Pennsylvania, by documents bearing even date herewith, without my joinder in any of the loan documents. 1. I consent and agree to the loan transaction referred to herein, after full disclosure to me of its terms. 2. 1 hereby knowingly and willingly waive any right or interest that I might have in the real estate identified in the mortgage, whether In statute, common law, or otherwise, and subordinate any such right or interest to the lien of the Credit-Union's mortgage. 3. 1 acknowledge that the loan transaction is to be entered into good faith by the parties thereto, and that the Credit Union will give value in connection therewith to the full extent of the loan proceeds which have been committed to be loaned. 4. 1 hereby acknowledge that: a) but for this waiver the Credit Union would not have made a loan to my spouse; b) the Credit Union has changed its position in reliance on this waiver. Check the appropriate box: V There is not action in divorce or annulment, nor any other type of matrimonial lawsuit or other legal action relating to marital status pending between me and my spouse. ? There is action in divorce or annulment, or another type of matrimonial lawsuit or other legal action relating to marital status pending between me and my spouse. IN WITNES WH REOF, I have hereunto set my hand and seal on this Mp day of? _sa9G0, "intending to be I gaily bound hereby. e 2rhnatdre Sworn and Subscribe before a thi ?_day Y?l Z60 Notary Public My commission expires: NOTARIAL SEAL GAO. P. STRICKLER, Nptary Public Camp HD, Cumberland County My Commission Expires Feb. 3, 2003 rrrr- rrrrrrrr MNCP MCP mom CJ1UlNCP O O O O O O O O 0000 0 0 0 0 0 0 0 0 0 N W A 0 W V W CO O 0 0 ,666 0 0 0 O ? N N N N N N N N N N 0000000000 N N N N N N N N N N N O O N N 00 00 N N -1 -1 -1 -1 -1 -1 -1 --1 -1 1 -1 -1 OI N 01 N N N N N N N C7 7 7 7 7 7 7 7? 7 7? MME-y+.-y+.-yi?-Nw -Nip M-yy. -Nn y. fD fD N N N (D (D CD N N (D N O O O O O O O O O O O O N N N N N N N N N N N N 7 7 7? 7>> 7 7 7? 3 T T T T T T T T -0 T T T N N N N d N fU N N< [U < 33333 3 33 3333 m m m m m m m m m m m m N_ N_ _N N N N N N N N N N A CII V W O? W CI1 N V N W W 0 0 O N N N N N N N W CA OD CO W CND co i? N_ ??? N N N N N N 0 0 0 0 0 0 O W W CJI W N O W V CT A N V 0 fil 0 A. W IV m O .IA 0 W W W -? A M V W A - OOO O O O O O O O O O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Cl) Cl) W co N N N N N N' N N O OOO (O COOOO W W W N W V W O W 0 ' W 0 O 0 OD 0 CA W W 0 O V V -4 A W - CO O)O AO) W A V CD V N'm Uf O(O NO 'o 'm MMO W -+V 0 V C 000 T T T T T T T T T T T T 0 0 0 0 0 0 0 0 0 0 0 0 3 3 3 3 3 3 3 3 3 3 3 3 cn cn cn co co cn cn cn 0cn co co S S S S S S S S S S S S N N fU N ID N N N N N N N fD fD N lD CD N N N N N fD N A A A OA A A A A? OA A A b ?ryN ICI n y C9 ro m as 0 ?-n 0-2002 12:24 Pg* li. PATRICK T SULLIVAN 330 S 31ST ST CAMP HILL PA 17011-5211308 P. 02/02 Page 6 Page 6 A Payment of 162.17 is due on 07/12/00 YTA Finance Charge: Year to Date 213.11 __=====rrc=cc====ccv===cxe.x cccv.......eve=rmcve==ecc..eeeeevq __________ ___________ Se ..r5 www ANNUAL PERCENTAGE RATE 8.500% *** Periodic Rate (Monthly) 0.70833.* Post Eff Description Principal *FIN CEG* Balance 0601 ID 50 REAL ESTATE EQUITY LOAN Beginning Balance 34813.97 0601 Payments Transfer From Share 04 187.35- 246.60 34626.62 0630 Ending Balance 34626.62 A Payment of 433.95 is due on 07/01/00 YTD Finance Charge: Year to Date 584.18 veveeeeevarcxveee..eevee e.v ecv___eeee_eeem_..aa=c=ee=====ccer_..e_n=====s=e=vevva aaee Total Dividend YTD: Year to Date 60.69 T6tal YTD Finance Charge, Year t6 Date 1200.07 TOTAL P.02 (THIS IS NEITHER A CONTRACT NOR A COMMITMENT TO LEND) LENDER OR LENDER'S AGENT: Pennsylvania State Employees Credit Union Preliminary ® Final P.O. Box 67013 DATE: March 21, 2000 Harrisburg, PA 17106-7013 LOANNO.: 2861 Type of Loan: Fixed BORROWERS: Patrick T. Sullivan 00M, ADDRESS: 330 South 31st Street CITY/STATE/ZIP: Camp Hill, PA 17011-5211 PROPERTY: 330 South 31st Street Camp Hill, PA 17011-5211 ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments To. coet of your credit as a The dollar amount the credit will The am0utn of credit provided The amount you will have yearly mi.. coat you. to you or an your beacon. paid niter you have made all peymenh as scheduled. $39 910.39 $ 52 073.92 PAYMENT SCHEDULE: VARIABLE RATE FEATURE: Thia loan has a Variable Rate Posture, Vuisdak Rate Disclosures have been provided to you earlier. SECURITY: Yuu are givinga ucuruy inter.ae in the property located az: 330 South 31st Street, Camp Hillr PA 17011-5211 ASSUMPTION: Someone buying this property ® 0amr01 aeeuma the n:nrainiag balance due under original rand" terms Q may eemate, subject to lender's cooditima, the renmining balance due udder original nmugnge (arm, FILING /RECORDING FEES: $ 0.00 PROPERTY INSURANCE: ®Praprrty hazard imuranee in We amount of $ 120, 600.00 with a m0ngngeo.1.... to the lender is s squired condition efthis loam Borrower may pumhaae this insurance from any insurance company acceptable to the lender. LATE CHARGES: Ifyourpayment is more Iherr .l5 days late, you will he charged a late charge of 5,0 % of the overdue payment. PREPAYMENT: Iflyoupay off your loan early, you or ay ou L 0 will not have to pay a penalty. 0 nmy 5D ill not be cnlid.d to a rofund nfpmt cliffs lisonce cbmg.. See your contract documents for any additional information regarding non-payment, default, required repayment in full before scheduled date, and prepayment refunds and penalties. a means estimate Coot/ Patrick T. Sullivan BORROWER/DATE BORROWER/DATE BORROWER/DATE BORROWER/DATE ®'-780189011 VMP MORTGAGE FORMS-18 0 016 21-7 2P1 Paso l or2 5196 1999 CBF Systems, Inc. The contents of this form In whole or 10 part era protected wMer the eopyli9N laws of the United Shred. DEMAND FEATURE: ® This loan does not have a Demand Pasture. [::] This loan has a Demand Feature as follows:' DEFOUTION OF TRUTH-IN-LENDING TERMS ANNUAL PERCENTAGE RATE This is not the Note rate for which the borrower applied. The Annual Percentage Rate (APR) is the cost of the loan in percentage terms taking into account various loan charges of which interest is only one such charge. Other charges which are used in calculation of the Annual Percentage Rate are Private Mortgage Insurance or FHA Mortgage Insurance Premium (when applicable) and Prepaid Finance Charges (loan discount, origination fees, prepaid interest and other credit costs). The APR is calculated by spreading these charges over the life of the loan which results in a rate higher than the interest rate shown on your Mortgage/Deed of Trust Note. If interest was the only Finance Charge, then the interest rate and the Annual Percentage Rate would be the same. PREPAID FINANCE CHARGES Prepaid Finance Charges are certain charges made in connection with the loan and which must be paid upon the close of the loan. These charges are defined by the Federal Reserve Board in Regulation Z and the charges must be paid by the borrower. Non-Inclusive examples of such charges are: Loan origination fee, "Points" or Discount, Private Mortgage Insurance or FHA Mortgage Insurance, Tax Service Fee. Some loan charges are specifically excluded from the Prepaid Finance Charge such as appraisal fees and credit report fees. PrepaidFinance Charges are totaled and then subtracted from the Loan Amount (the face amount of the Deed of Trust/Mortgage Note). The net figure is the Amount Financed as explained below. The amount of interest, prepaid finance charge and certain insurance premiums (if any) which the borrower will be expected to pay over the life of the loan. AMOUNT FINANCED f The Amount Financed is the loan amount applied for less the prepaid finance charges. Prepaid finance charges can be found on the Good Faith Estimate/Settlement Statement (HUD-1 or IA). For example if the borrower's note is for $100,000 and the Prepaid Finance Charges total $5,OM, the Amount Financed would be $95,00. The Amount Financed is the figure on which the Annual Percentage Rate is based. TOTAL OF PAYMENTS This figure represents the total of all payments made toward principal, interest and mortgage insurance (if applicable) over the life of the loan. PAYMENT SCHEDULE The dollar figures in the Payment Schedule represent principal, interest, plus Private Mortgage Insurance (if applicable) over the life of the loan. These figures will not reflect taxes and insurance escrows or any temporary buydown payments contributed by the seller. t0 -780 Jason page 2 of 2 C`.^arl..w?nnt Ct?Yn monY U.S. Department of Hauling -504 I9710 form HUD-tA (2194) VMP MORTGAGE FORMS-19001621']291 ref. RE$PA V / CITY MORTGAGE C 1620 ,N, OH 45401-1820 J W.NATIO N ALCITYMO RTGAGEE.COM NATIONAL CITY MORTGAGE FEDERAL IDENTIFICATION NO. 31-0856949 '. -- -- sox r 5565.73 a PAIO ON PURCHASE OF I BOX 2 ANC PAL RESIDENCE- 0,00 IND OF OVERPAID BOX 3 .INTEREST 0.00 ;L ESTATE TAXES.,: BOX 4' 1864.98 " "- ",. -ARDINSURANCE-i 1 70.00 /FHA INSURANCE:[ i `+0.00 ONAL'ASSESSMENTSI - 0.00 - .-OTHER ... 0.00 NDS TO BORROWER n-nn DATE 1106 2/07 3/16 3/20 4/03 4/07 5/15 6/08 7/17 7/17 8110 8/14 9/11 10/16 11/07 12108 NO. 1545-0901 deductible b? - ar.u ?llVy 1141 ua luny ' You on The Information In boxes 1, 2, and 3 Is Income tax a your Federal return. Limitations based Important tax information R and Is being on the cost and value of the secured furnished to the Internal Revenue Service. property may apply. In addition, you It you are required to file a return. ion a may only deduct an amount of negligence penally or other sanction may mortgage interest rest to the e extent be Impaled on you if the IRS deter S determines incurred by you, ritually paid that an underpayment of tax results by by you, , and not reimbursed by by because you overstated ated a deduction for another person. this mortgage interest or for these points or because you did not report this refund - SEE REVERSE SIDE FOR of interest on your return_ - TAXPAYER INSTRUCTIONS PROPERTY ADDRESS 330 S 31ST STREET CAMP HILL PA 17011 ACCOUNT NUMBER TAX IDENTIFICATION NUMBER 8597088 169-54-7128 LOAN TYPE.. CONVENTIONAL MORTGAGE. 1;'?p,•, PAYER'S / BORROWER'S NAME, ADDRESS, CITY, STATE, ZIP CODE 1022190 AV "AUTO T3 0 0120 17011 tue?0?wt??nuu'?wAlefe?eu?e?wlOue?AuOle ??ue?n?el PATRICK T SULLIVAN III 330 S 31ST ST CAMP HILL PA 17011-5211 PLEASE REMEMBER TO FILE FOR HOMESTEAD EXEMPTION WITH YOUR TAXING AUTHORITY IF YOU ARE ELIGIBLE. DESCR Beginning PAYMENT PAYMENT LATE CHARG PAYMENT CITY TAX D PAYMENT PAYMENT PAYMENT PAYMENT PRINCIPAL I PAYMENT SCHOOL TAX PAYMENT PAYMENT PAYMENT PAYMENT TRANSACTION HISTORY PTION DUE TRANSACTION PRINCIPAL INTEREST, ESCROW ESCROW PRINCIPAL OTHER DATE AMOUNT AMOUNT AMOUNT AMOUNT BALANCE BALANCE 3alance 710.00 85714.68 1/00 722.63 89.72 464.29 168.52 878.62 85624.96 2100 710.77 90.21 4153.80 156.76 1035.38 85534.75 ASSESS 3/00 1035.38 85534.75 27.70- 3/00 -738.47 90.70 463.31 156.76 1192.14 85444.05 27.70 :SB 4/00 519.17- 519.17- 672.97 85444.05 4/00 710.77 91.19 462.82 156.76 829.73 85352.86 5/00 710.77 91.68 462.33 156.76 986.49 85261.18 6100 710.77 92.18 461.83 156.76 1143.25 85169.00 7100 710.77 92.68 461.33 156.76 1300.01 85076.32 INLY PMT 8100 27.70 27.70 1300.01 85048.62 8100 ,710.77 93.33 460.68 156.76 1456.77 84955.29 OISE 8/00 1345.81- 1345.81- 110.96 84955.29 9/00 710.77 93.84 460.17 156.76 267.72 84861.45 10100 710.77 94.34 459.67 156.76 424.48 84767.11 11/00 710.77 94.85 459.16 156.76 681.24 84672.26 12/00 710.77 95.37 I 458.64 156.76 738.00 84576.89 *** G 16 *** I4901-721 INTEGRA MORTGAGE COMPANY LOAN HISTORY Y-T-O IMU 209 CRT 068 INUS S54967906 T13 12/29/95 PAGE 73539 x 330 S 31ST ST ?OFO CAMP HILL PR 17011 0000 IST MTGE PAIN 2NO MT 70,437.70 & PRIN ESU SAL RES .00 672.22 T ESC SU .00 SPENSE AGO DAL .00 .00 REPL-FES--HUD-M LC INT VE DUE DATE HUD PRT OF M .00 .00 .00 .00 01-01-96 .00 17 5 g g OUE SHORT AMT 0 37.9G1 211 .00 .00 .00 102.83 .00 g .00 0 .00 0' .00 0 -,.00 679.06 .OS00000 1 1 1ST ORIG MTG 2ND 73.0 0 DAIS MTG 0 PRIMDAL 71.19 BEG INT IND CRP FLAG MTGR 7.17 169 54 SSN DEF INT DAL PRIOR YR PoD INT PPO INT IND OPM ORS 7128 0.00 0 00 0 0 ASSUM-DT XFER-DEED FHA-SEC/HUM LIP PAYOFF FC-TRK-SW YE-ACO-RPT/DATE Y/03_IB-92 SALE-ID EXEMPT PLGD-LN PMT-OPT CALL-METH FLOC BNKRPCY CH/DT 1098-DET-HIST -POINTS-PD-BY-BORR POINTS-PD-RPTG-YR SUPPRESS-MICR-STMT DI-NOT-RPT-YE REASONABLE-CRUSE RI-HDR-SW 1ST DUE DT - JOE W-H SW / -H / .00 BALANCE .00 IORE W-H N F SW / / W-4 BALANCE UUNSTR CO NO PURGE FES B .00 .00 DUE PROC TP 1 gDpA?TE?WpDA?TE TR NO - gM4 RECEIVED L P PAID RINCIPAL I BA1L1ANNCCE?7 Z F MTHEST ESCROW PAID PAID __ESCRUW ADVANCE STATUS bl"lub UKLMNLU uTRVr-= BALANCE BALANCE AMOUNT BALANCE INT-BAL. AMOUNTS OCT I 1 1-0312 685.93 ? 3I3 4 .14.Gb 15528 Aloii S .00 .88 . 08 -7 01-03-95 L 14.0 AA 02-95 01-30 1 72 1 685.93 61.41 71074.76 474.24 150.28 BATCH 720 ED179EQ 0820itl 858.69 .00. .00 .00 .00 1 0 03-SS 03-10 1 72 1 685.93 61.82 71012.94 473.93 150.28 9N hA BATCH 718 EDIT-= 372496 1008 97 .00 .00 .00 .00 1 3-i0=95L 14.81 RR 7 B 0 EOIT-SEO 12 713 TCH 04 93 3-31 3 2 1 04-95 09-05 1 7 7 1 GHEG 23 68585.93 .93 3Sa5 62.23 70950.71 5.27 973.42 150.28 -553.rEE 00 3r 703.98 .06 .00 .00 .00 1 04-OS-95 L 05-95 05-03 1 72-1_ 685.93 62.65 70888.06 " 473.00 _ 150.28 BATCH 716 EDIT-SED 416819 854.26 .00 .00 .00 .00 1 ? - 14.70 RR 4 ED 799% - 06-95 6-05 1 /2 1 68S.93 63.06 70925.00 4,12.SS 150.28 . J 1004.54 OD 06-05-95 L 14.77 RR - - 07-95.07-05 1 72 1 685.93 63.48 • 70761.52 472.17 150.28 UAICH 70,1 EDIT39.O 247185 1154.82 .00 ..00 .00 .00 1 07-05-95 L 08-95 08-02 1 72 -1 685.93 63.91 70697.61 471.74 150.28 BATCH 708 EDIT-SED 623916 .00 .00 .00 .00 1305.10 . OU-02-95 14.74 RA BATCH 718 EDIT-SEO 146332 *** H 16 *** 14901-721 INTEGRA MORTGAGE 'COMPANY LOAN-NO ICONT'D) LOAN HISTORY Y-T-D INU 209 CRT 068 INUx 554957906 T13 1229/95 PAGE 73540 x U 08-95 08-07 3 14 1 CHECK x265614 09_25 09-05 1 72 1 685 93 64.33- 70633.28 471.32 1234.00- 71.10 150.28 221.38 PAYEE CD 3704108015 ' 00 .00 .00 .00- I - - 09-05-05 14.73 AA BATCH 708 EDIT-SEO 568813 47 .b i655??SA i ee 1 15%.93- 54.7b ii b652 YSiS E8 371.66 .06? 6? 1 10-04-95 L 9.7 - 11-95 11-06 1 72 1 605.93 65.19 70503.33 470.46 150.26 521.94 ESIT$E6Ui9A5 BATCH I9 .00 .00 .00 .00 3 11-06-951 12-95 12-04 1 72 1 685.93 65.83 70437.70 470.02 150.28 672.22 BATCH 709 EDIT-SEO 363212 .00 .00 .00 .00 -1 12-04-9s T 14.69 AA BATCH 727 DIT- D 787949 RED-BY TOTALS 81231.16 5,668.33 759.47 1. 803.36 .00 - 177.14 OTHER AMOUNT CODES: _P HAL _ -PAID POOI - -P 9 - /. - _ _ OF RESTRICTED C=235-FEE I=A-H-PD NcRDURNCE-EFF-DATE T S:CR-LIFE-RMT W_SUBPENSE DIDEFERRED-INT-SAL. AB=SUB-CODE AJ=DEf-INT-ADJ-FLAG AK=ADU-AMT-RECD AL=TRAN SOURCE RM=IOC-SPEC-INT-PD AN=NDN-AEC-CORP-ADU AP=DATE-STAMP AD=TIME- R= FEE CODES: NADAguides.com - New Car Prices, Used Car Values Page 1 of 3 Used Values: Result Next Steps • Free Finance Quote • Free Insurance Quote • Free Credit Report Boats and Personal Watercraft 1987 CHRIS-CRAFT 17BR CAVALIER September 1, 2004 Low Retail l Base Price $2,240 • DMV Forms Options • Donate Your Boat Power Boat: CANVAS Boat Cover - 15 ft. thru 19 ft.: Bow Cover: P. a Price Bridge Enclosure: Guide Cockpit Cover: Power Boat: ELECTRONICS Depth Sounder: Power Boat: ENTERTAINMENT Stereo - am/fm cassette When shopping for a boat, personal watercraft, outboard motor or boat trailer, be w/4 speakers: TOTAL Boat Specifications $70 $125 $1,325 $160 $80 $130 $4,130 @ print this page Average Retail $2,760 $85 $150 $1,575 $190 $95 $155 $5,010 Length: 17' Model Name/Description: 17BR CAVALIER Boat Type: / Stern Drive Power Boat ?? B V http://www.nadaguides.com/Values/ValueReport.asp?UserED=5b 194465-ffi2-4fd9-8a65-e4... 9/1/2004 ( 1-Category _ I 12 - Make & Year] I 3 - Model I I 4 -_Oprions ._, ..I 0 5 - Used Values I NADAguides.com - New Car Prices, Used Car Values prepared. Subscribe to a N.A.D.A.price guide for all your vehicle valuation needs. Don't leave home without it... Buy a Guide Todd Hull Material: Fiberglass Beam: 61911 Engine: 1 140 HP Gasoline Net Weight: 1,450 Notes (*)INCLUDES THE VALUE OF THE OUTBOARD MOTOR AND TRAILER. (**)INCLUDES THE VALUE OF THE TRAILER. (***)INCLUDES THE VALUE OF THE OUTBOARD MOTOR. N/A DUE TO LIMITED RESALE ACTIVITY. Next Steps Need a new Pickup Truck or SUV to haul your Boat or Personal Watercraft? Before you buy Check your credit and get a Free Finance Quote. Obtain a Free Insurance Quote. Sell your boat through Boattrader.com and get the most money for your craft. Value Explanations Low Retail Value - A low retail valued boat will show excessive wear and tear either cosmetically and/or mechanically. This boat will require cosmetic or mechanical work and may or may not be in running order. The buyer can expect to invest in cosmetic and/or mechanical work. Low retail vessels usually are not found on a dealer's lot. Average Retail Value - An average retail valued boat should be in good condition with no visible damage or defects. This boat will show moderate wear and tear and will be in sound running condition. The buyer might need to invest in either minor cosmetic or mechanical work. Note: Vessels in exceptional condition can be worth a significantly higher value than the Average Retail Price shown. Select Another Category Page 2 of 3 http://www.nadaguides.conVValuesNalueReport.asp?UserlD=5b 194465-ff82-4fd9-8a65-e4... 9/1/2004 RGILITY CENTER Fax:7177050967 Oct 27 '04 1147 P.02 L';MFLU Y bb FA Y J 1 A I t jIVMIN I Patrick T Sulllvan III Organizational Unit Name: TR Mun Srvs CDC Code: 0008888 330 S. 31St5tteet BIU: B3 Group: 09 Level: 08 Camp Hill, PA 17011 f^VVT Marital Status: S Nil. Fxemotions / Allowances: 00 GROSS EARNINGS YEAR TO DATE 88,468.25 NET PAY THIS PAY_ PENNSYLVANIA STATE EMPL GU 713.47 TOTAL NET 713.4r EARNINGS HOURS RATE AMOUNT Normal working hours 75.00 29.02 2,176.90 DEDUCTIONS THIS PAY YTD Federal YUrmhoKfing Tax 368.27 5,446.16 TX EE Social Sewrily Tax 134 94 2,385.03 Tx EE Medicare Tax 31.50 557.77 State Wilhhelding-Pennsylvanls 50•32 1,181.00 Local Wage Tax-Camp Hill eoreu9h 43.53 492.54 TX EE Unemployment Tax 196 34.52 Gamish: AllmonylSupport 654.92 11,790,56 Series EE BoMi 25,00 450.00 State Emp Rat 136.03 2,404.29 REIMBURSEMENTS THIS PAY YTD TOTAL EARNINGS i SERVICECREDrr 17 YR 21 PP EMPLOYER PAID BENEFITS - THIS PAY TX ER Social Security Tax 134.94 TX ER Medicare Tax 31.55 ER Basic Life 419 Slate Emp Ref 31.12 _ Annut-Unt Mdtl Hospital 204.60 ER Workers Camp Benefit 46.39 PR Capital Blue Cross 270.00 FWT Taxable Gross: 2.040.47 SENIORITY INFORMATION QuMatassvnnr 6.00 0.60 0-00 Accryal This PP 5.78 3.75 0.00 Absence Repoded This PP 0.00 0,00 0.00 Adjustment 325.57 409,47 17.00 Ouola Tills Slmnl 331,35 41322 17,00 ACCRUAL RATE: UAL 7.70 % SICK 9.00% - Comaet your IOOaI Human ResOurdes Office if you nave any questions regarding the conlentahd diMbU0on Oryour Employee Pay Statement For: PATRICK T SULLIVAN Your statement contains three sections: SECTION I: BASIC DATA SECTION II: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 2000 SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT II SECTION I: BASIC DATA B Personal Data Social Security Number: 169-54-7126 Sex: MALE Birtb Date: 28-DEC-1960 Coverage Type: PULL Contribution Rate: 5.00% Counseling Center: - HARRISBURG Normal Retirement Date: 28-DEC-2020 Final Average Salary: $38,951.21 2000 Retirement Covered Earnings: $39 , s 12.62 Total SSI Non-Covered Earnings: Joint Coverage Conversion Amount: Mandatory Debt: Service Credit as of Dec. 31, 2000* Class Years of Service Class Years of Service A-60 13.0000 TOTAL SERVICE 13.0000 Account Balance Regular Contributions SSI Contributions Dec. 31, 1999, Balance $24,110.78 Contributions - $1 990.66 Lump Sum Payment Arrears Payment Credited Interest $1,003.94 YTD Adjustment*** Dec. 31, 2000, Balance $27,105.38 TOTAL DEDUCTIONS $27,105.38 Arrears Balance as of Dec. 31, 2000 Regular SSI Taxable Breakdown of Your Account**** Taxable Contributions $21,208.19 Pre 87 Non-Taxable Contributions Post 86 Non-Taxable Contributions Credited Interest (Taxable) $5,897.19 Dec. 31, 2000, Balance $27,105.38 K M SULLIVAN I M J SULLIVAM *If you are eligible to purchase creditable state and/or non- state . service, contact your Retirement Counselor for information on purchasing service. All requests to purchase service must be filed while you are an active, contributing member. ** Information filed on a Nomination of Beneficiary (J es) form Ware 1993 or since Dec. 31, 2000, or involving special circumstances (such as the designation ofan estate or trust as your beneficiary) may not appear. maximum of 10 beneficiaries may be shown here; however, you may have more beneficiaries in your retirement record. Keep your beneficiary nomination current. You may change your beneficiary nomination at any time by fling a new Nomination of Beneficiary(ies) form with SEAS. Forms are available from your agency Personnel Office or your regional SEAS Retirement Counseling Center Please contact us if you do not want your beneficiary(ies) listed on future Statements. ***YTD (Year-To-Date) Adjustments reflect corrections to your account for which you already have received notification. ****SERS is a defined benefit plan under Internal Revenue Service Code Section 401 (a). SPECIAL CONDITIONS The following Special conditions apply to your benefit estimates or estimates were not calculated: If you received projected estimates last year, they may be lower this year because your Retirement Covered Earnings are lower this year. SECTION II: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 2000 .IS section provides an estimate of your Monthly Pension ly if you have at least 10 years of credited service or you ve reached your Normal Retirement Date and have at least -ee years of credited service. Maximum Single Life Annuity (MSLA) onthly Pension 1266.95 ;cumulated Deductions $27.105.39 Option 1 onthly Pension $261.60 esent Value $60.714.62 Option 4 (Adjusted for withdrawal of Accumulated Deductions) ljusted MSLA Monthly Pension $147.77 ljusted Option 1 Monthly Pension $144.91 1justed Present Value Under option 1 $33,609.24 Disability Retirement onthly Pension (if you qualify) $11 051.98 Death in State Service $80.714.62 IMPORTANT INFORMATION • Benefit Estimates are provided for: • Maximum Single Life Annuity (also known as Full etirement Allowance) - Monthly Pension payment ade to you for life; beneficiary(ies) receive(s) ccumulated Deductions, less Monthly Pension iyments you received and any lump sum you received ider Option 4. • Option 1 - Monthly Pension payment made to you it life; beneficiary(ies) receive(s) Present Value, less lonthly Pension payments you received and any lump im you received under Option 4. • Option 4 - At retirement, you may withdraw an nount equal to all or any part of your Accumulated eductions. You may elect to receive this withdrawal in i to four installments. If you elect this option, you must so elect a Monthly Pension payment plan. • Disability Retirement - You must have at least five ,ars of credited service (except State Police and iforcement Officer-category employees, who have no inimum service requirement) and be certified by SERS odiral Fvaminare ac nhvcirally nr mAntalh, inranahla W your Accumulated Deductions if you take Disability Retirement. • Death in State Service - If you are vested and die while an active employee, it will be assumed you retired under Option 1 the day before your death. The Present Value of your annuity will be payable to your beneficiary(ies). If you are not vested, your Accumulated Deductions will be payable to your beneficiary(ies). 0 Benefit Estimates assume: • Your future earnings will be the same as in 2000. • You continue in your present class of service as a full-time employee. Retirement tables and factors remain the same as those in use on December 31, 2000. • Any Arrears Balance will be paid (exception - those members who are currently vestees or in a furlough status). • Your earnings will not exceed the federal Social CPrllrlt\/ tavnml ivaaa haen after,)nnn SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT DATE This section provides Monthly Pension estimates, projected to your Normal Retirement Date, f you have at least 10 years of credited service. Estimates are provided for the same options as listed under Section H. Normal Retirement Date: -28-DEC-2020 Maximum Single Life Annuity (MSLA Monthly Pension $2,251.07 Accumulated Deductions $119,788.60 Option 1 Monthly Pension $2,043.81 Present Value $304,737;767d Option 4 (Adjusted for withdrawal of Accumulated Deductions) Adjusted MSLA Monthly Pension $1,490.92 Adjusted Option 1 Monthly Pension $1,363.65 Adjusted Present Value Under Option 1 $234,948.16 Kelley Blue Book - Trade-In Pricing Report - Chevrolet, Suburban OWE BOOK TRADE-11 VALUE Pennsylvania • October 27, 2004 1997 Chevrolet Suburban 1500 Sport Utility See Local Lis in aDf This Car ?a List Your Car For Sale Online Buy a New Car Free Record Check Auto Loans from 3.65% APR Engine: V8 5.7 Liter Trans: Automatic Drive: 4 Wheel Drive Mileage: 150,000 Equipment Air Conditioning Power Steering Power Windows Power Door Locks Tilt Wheel Cruise Control AM/FM Stereo Cassette Single Compact Disc Dual Front Air Bags Insurance Quote Payment Calculator ABS (4-Wheel) Leather Third Seat Consumer Rated Condition: Fair "Fair" condition means that the vehicle has some mechanical or cosmetic defects and needs servicing but is still in reasonable running condition. This vehicle has a clean title history_ , the paint, body and/or Interior need work performed by a professional. The tires may need to be replaced. There may be some repairable rust damage. Trade-In Value List Your Car For Sale Online $4,260 Trade-in Value is what consumers can expect to receive from a dealer for a trade-in vehicle assuming an accurate appraisal of condition. This value will likely be less than the Private Party Value because the reselling dealer incurs the cost of safety inspections, reconditioning and other costs of doing business. Sat-i Pnvat Pe arty Vase Get Invoice & MSRP on New Cars Page 1 of 1 http://www.kbb.com/kb/ki.dll/kw.kc.ur?kbb.PA;334205;PA043& 17104;+t&278;... 10/27/2004 J.H. Troup Inc.; Appraisers ur n. a xxx Aaaress 1G/1 t]FBarIRL B=. FH 171U 1717 939-8380 Location Urban X 6uburbar. Rural Prerbnirrent Sirroe fan6y housing Resent land tree % land use edrs6le Built up ? Over 75% . ? 25-75% El Under 25% PRICE if (000) AGE (yre) One family loll ? Not likely ? likely Growth rate ? Rapid X? Stable ? Slaw Owner 90 Law 10 2-4 family ? In process : " Property values X? Increasing ? Stable ? Declining ? Tenant 150 Hi fi 45+ Multi-family To: : ii Demand/supply El Shortage - X? In balance [] Over supply X? Vacant (0.5%) m Predominant Commercial Marketin time Under 3 mos. F X1 mos. 11 Over 6 mos. Vacant (over 5%) 120 20-25 ' Note: Iraro and the mdal canpasipan of dte rwlghbartroad are not appreLsai fanws. . ' `Q ; Neighborhood boundaries and characteristics: the rzreista of tie area Of Canto Rill ever of 32nd Stmt betxem Qastrsm and Didraxsan Streets. rzeigbboalcod Factors that affect the marketability of the properties in the neighborhood (proximity to employment and amenities, employment stability, appeal to market, etc.l: 'lie sujbioct is located in a xesidatial arras arriong es of similar sty1e and nedret appeal. Rees in the area are maintained and omuIoid. All rmvertiaces, axe easily accessible to the suiblect, . Market conditions in the subject neighborhood (including support for the above conclusions related to the trend of property values, demand/supply, and marketing time ... such as data an competitive properties for sale in the neighborhood, description of the prevalence of sales and financing concessions, etc.): Fzxipes of this st:yle and area sell well uithatt seller ?mssims. Tr2ext st are not prevalent at this tyre with ornatioal rates urder 9%. fi Project Information for PUDs (If applicablel.-Is the developer/builder In control of the Home Owners' Association (HOAR Yes No ' Approximate total number of units in the subject project N/A Approximate total number of units for sale in the subject project , Describe common elements and recreational facilities: <f Dimensions 120' x 120' Topography 7sgnmc. 1rae1 Site Area .33 A tms Carrier Lot El Yes El No Size Average of area Specific zoning classification and description Residaltial Shape PgmG,. Re r. Zoning compliance ? Legal ? Legal nonconforming IGrandlathered use) ? Illegal ? No zoning Drainage Appsara Ad to ' Highest & best use as improved I] Present use ? Other use lexplain) V{eW Sjburloan/hv Utilities Public Other Off-site Type Public Private Landscaping of Area W::. Improvements Driveway surface, Asphalt Electricity X? 100 App Street Asphalt %? ? Apparent Easements NTe 200a Gas X? Curb/Gutter "mnete x? ? Water I] Sidewalk ? ? FEMA Special Flood Hazard Area ? Yes x? No Sanitary Sewer X? Street lights ? ? FEMA Zone C Map Date 12 ll al Storm Sewer X Alley FEMA Ma No. 420357 0001 B Comments(appri ent adverse easements, encroachments, special assessments, slide areas, illegal or legal nonconforming zoning, use, etc.): Mrere are no aot)allaoll adveCSe else eats or acxmdnmt,. The Mitiec ,,Cs rat to lie in a FEM rps' ed flood era. S,pi <'> GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION BASEMENT INSULATION No. of Units 1 Foundation c e tze Bloc Slab Na Area Sq. Ft. 1,092 Roof ? ' `. No. of Stories 1.5 Exterior Walls Frans Crawl Space Fb % Finished 0 Ceiling Avexale ? Type(Det./Att.) Detached Roof Surface ampasitim ]Basement Rai Ceiling Joist Walls Average ? Design (Style) Caps and Gutters & Dwnspts yes Sump Pump tQ7 Walls PlascalrY Floor Nile :Uif:: Wietirci Window Type coulole Hmci Dampness rb e d. Floor ( to None Age (Yrs.) 43 Storm/Screens yes Settlement No Evidence Outside Entry No unknown ? $: Effective Are lyre.) 15 Manufactured Housebb Infestation rib eridmce RY!:: ROOMS Fo er Living Dinin Kitchen Den Famil Rm. Rec. Rm. Bedrooms # Baths Laundr Other Area S .Ft. <X*j: Basement 1 092 Level 1 x 1 1 1 2 1 1 268 rL,, Level2 t 1 503 Finished area above grade contains: 6 Rooms: 3 Bedrooms): 2 Baths ; 1 7r2 Square Feet of Gross Livin Area Ia!:! INTERIOR Materials/Condition HEATING KITCHEN EQUIP. ATTIC AMENITIES CAR STORAGE h Floors N? le:, gx/ Type Refrigerator ® None ? Fireplace(s) #Stme ? Nor,2? Walls /' Plaster F?intal Fuel Oil Range/Oven El Stairs ? Patio ? Garage . x of cars Trim/Finish Hood Pain Condition Arerane Disposal ? Drop Stair X eck ? Attached 1+ Bath Floor (promo Tile Avexa COOLING Dishwasher ? Scuttle Q Porch ? Detached Bath Wainscot genic Tile AveGl Central Yea Fan/Hood ? Floor ? Fence ? Built-In >3 Doors Hood Clearlpmerage I Other too Microwave ? Heated ? Pool ? Carport Condition Washer/Dryer Finished Driveway Additional features (special energy efficient items, Condition of the improvements, depreciation (physical, functional, and external), repairs needed, quality of construction, remodeling/additions, etc.: Adverse environmental conditions (such as, but not limited to, hazardous wastes, toxic substances, etc.) present in the improvements, on the site, or in the immediate vicinity of the subject property: rb adverse Hrvinmmtal vadit' chs¢verl at the t' of inexz=ion. Freddie Mac Form 70 6-93 MCS, Richardson, TX 75081 (214) 699-7783 Page 1 at 2 Fannie Mae Form Property Description UNIFORM RESIDENTIAL APPRAISAL REPORT File No. 5502024 J.H. Troup Inc., Appraisers UNIFORM RESIDENTIAL APPRAISAL REPORT File No. S502a24 ESTIMATED SITE VALUE ........................ _ $ 40 000 Comments on Cost Approach (such as source of cost ESTIMATED REPRODUCTION COST-NEW OF IMPROVEMENTS: estimate, site value, square foot calculation and for HUD, Dwelling 1.772 Sq. Ft. @ $ 47.35 = $ 83.904 VA, and FmHA, the estimated remaining economic life of >Ua aaParan: 1,268 Sq. Ft. @ S 12.30 = 15,596 the property): 11411: Built-ins. Fixplace. etc = 5,760 ' Garage /Carport 352 Sq. Ft. @ S 12.50 = 4.400 Sese Attached BteLd, Total Estimated Cost New ..... = $ 109.660 Physical Functional External The Marshall & sift Omt Handooo1c ves used as an aid in Less 15 $ 0 a o-rutincr the a'aL approach utilizing quitliLy. Depreciation 16 449 = $ 16.449 Depreciated Value of Improvements ................. = $ 93,2111 "As-is" Value of Site Improvements = $ 3 500 INDICATED VALUE BY COST APPROACH = $ 136 711 ITEM SUBJECT COMPARABLE NO. 1 COMPARABLE NO. 2 COMPARABLE NO. 3 330 South 31st Sheet ll8 N. 30th Street 4!1 Q>mtxy Club Road 859 Country Cb Fred Address Center Hill Carp Hill Carro, Hill Hill Proximio to Sub'e of .5 Mile 1 Mile 1.5 Miles `i Sales Price 5 N/A 9 D6,000 `s 3 140 000 'f. $ 136,900 .1 Price/Gross Liv. Area 3 / 3 103.11 / " if 73.22 3 91.63 / Date and/ar Inspectim Stab REprirt hVS/S1FH Repart NHS/SM Report 1 Verification Sources Public Reds Public Records Public Records Public Reds VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION +I-IS Adjustment DESCRIPTION +I-IS Ad in unit DESCRIPTION +1-IS Adjustment Sales or Financing Qnv,mtional Qrn is al ?nantieal ': concessions Nre I r viu 66 D.O.M. 2 D.O.M. Date of Sale/Time " 8/3/ 94 8 B 94 9 30 99 ' Location In e Sulourbsr/Averacke e suburbar/Aversecie LeaseholdlFee Simple Fee S' le Fee S' le - Fee S' le Fee Simple ". Site 120' x 120' ('artier 55' x 120' 69' x 155' 90' x 215' e View Residential Pesidestial Aura Residential Residential Design antl Appeal Similar Similar Similar Quality of Construction Prarre/Average Bri -1,500 Srick/Aerscas -1,500 ffiidc & Frame/Arvietratria -1,500 A e 43 46 55 43 .:: Condition Averace e Aver Averacva n>r Above Grade Total Btlrms Baths Total Btlrms Baths Total Btlrms Baths Total Btlrms Baths B Roam Count x 6 3 2 7 9 2 7 3 1.5 500 8 4 3 -1,000 Gross Living Area Qs 1.772 So. Ft. 1,319 SO. Ft. +3 DDO 1,912 5 . FL -1,500 1.494 So. Ft. +2,500 Basement & Finished Bull Baskerent: Pull Basement Rsll HaSelatt Bill Basement Raoms Below Grade Dpfin:shei Family Rmn -2,500 Fani1' Frrm -2,500 Unfinished gc: Functional Utility 4Q.j Heetin /COObn O?0N CP. CA /CA QL "??" Etter Efficient Items Storm units similar Similar i;!i Gara a/Car ort 1i 1 Car None 1,500 1 000 2 Car -1 000 l Porch, Patio, Deck, Q i Average Similar Similar Fire loca(s). etc 1 Store, Fireplace 1 Brick Fireplace F' lace Brick -1 000 2 Rr+rr F' lace -1 000 :0: Fence. Pool, etc. W Avexacle Similar similar . Net Ad. Irate[) x -F - 3 500 + x - 3 -5 000 + x - It -2 000 :i Adjusted Sales Price Net$ <i U.4 :? i? ..... 3 5 i' 'NGG$ ?, $. { of Comparable LyrS$ ;:.1 b, ! $ 136 500 c •: $ 135,000 3 134 900 Comments on Sales Comparison (including the subject property's compatibility to the neighborhood, etc.l: All sales are close) tl?sactims. All Sales are considered aV indicators of value and iseichted equally in the final ramcilat:im. ITEM SUBJECT COMPARABLE NO. 1 COMPARABLE NO. 2 COMPARABLE NO. 3 Date. Price and Data Deed 13x Asses:stent Office Tax Assessment Office Tax Assesstest Office 3 Source for prior sales Public Records Rjblic Revvrds Public Records Public Records within year of appraisal Analysis of any current agreement of sale, option, or listing of the subject property and analysis of any prior sales of subject and comparables within one year of the date of appraisal: [Sorg IGw t .... :3di11: INDICATED VALUE BY SALES COMPARISON APPROACH .............................................. $ 135 coo - INDICATED VALUE BY INCOME APPROACH (if Applicable) Estimated Market Rent 5 iMo. x Gross Rent Multi lien PIA = $ The appraisal Is made X "as is" subject to the repairs, alterations, inspections or contlitlon5 listed below subject in completion per plans and specifications. Conditions of Appraisal :'The tibliect: is appraised in its resaa: miditim. RsYmnercl %cod infestatim o=itiEiacim. Final Reconciliation The purpose of this appraisal is to estimate the market value of the real property that is the subject of this report, based on the above conditions and the certification, contingent and limiting conditions, and market value definition that are stated in the attached Freddie Mac Form 43911'annie Mae Form 10048 (Revised 6/93 1. I IWE) ESTIMATE THE MARKET VALUE, AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OF THIS REPORT, AS OF F.ebcuary 27, 1995 (WHICH IS THE DATE OF INSPECTION AND THE EFFECTIVE DATE OF THIS REPORT) TO BE $ 135.000. APPRAISER; SUPERVISORY APPRAISER (ONLY IF REQUIRED) .i? X? Did ? Did Not Signature % /I a Signature Name Gary G Trv w'Assistant Appraieen, Name Jahn H. TruuioIII PA- RL 000001 L Inspect Property Date Report Signed February 27, 1995 Date Report Signed Pebmary 27, 1995 State Certification # N/A State State Certification # RL 000001 L State PA TX 750111 11141 699-7783 Page RGILITY CENTER Fax:7177050967 Oct 27 '04 11:47 P.02 LMYLU Y bh VA Y J I A I 1'1Y1V iN t Personnel No. 00027663 Transportation Period Ending 0 611 3/2 0 0 4 Pay Date 08/27_12004 PatricK Y Sullivan III Organintlonal Unit Name: TR Mun SNS CDC Code: 0008888 33o S. 31St street B/U: 53 Group: 09 Level: 08 Camp Hill, PA 17011 FWT Marital Status: S No. Exemptions / Allowances: 00 GROSS EARNINGS YEAR TO GATE NET PAY PENNSYLVANIA STATE EMPL OU $8,468.25 I EARNINGS HOURS RATE AMOUNT THIS PAY Normal working hours 75.00 29.02 2,176.50 71$,47 713.47 DEDUCTIONS THIS PAY YTD Federal Wimholging Tax 36627 0,4.06.16 TX EE Social Smo rityTex 134 94 2,395.03 TX EE Medicare Tax 31.5e 567.79 State Withholding-Pennsylvania 60,82 1,181.00 Local Wage Tax-Camp Hill Borough 43.53 492.64 Tx EE Unemployment Tax 1.95 34.52 Garnish: Alimony/Support 954.92 11,788,56 Series EE BOms 26,00 450.00 State Emp Ret 13e.o3 2,40A,29 THIS PAY YTD EMPLOYER PAW BENEFITS THIS PAY TX ER Social Security Tax 134.94 TXER MCglcwe Tax 31.55 ER Basic We 4.79 State Emp Ret 31,12 _ Annuitant Mad H0300l 204.60 ER Workers Camp Senalrt 48.39 PR Capital Blue Cross 270.00 FNrr Taxable Gran: 2,040.47 TOTAL EARNINGS 2,176.50 SERVICE CREVIT 17 YR 21 PP SENIORITY INFORMATION ABSENCE ACTIVITY ANNUAL SICK PERSONAL 'L70ola'CaR. =rIn9- 0.00 0.00 9.00 Accrual This PP 5.78 3.75 0.00 Absence Reported This PP 0.00 0,00 0.00 Adjustment 325.57 409A7 17.00 OWIa TONS Stmt 331.35 413.22 17.00 ACCRUAL RATE: ANNUAL 7.70 V. SICK 5.00 % Contactyour lpol Human Resources Offica if you nave any gaesnonS regarding the conlemand atsQibution of your Employee Pay Statement DEBTS DATE INITIAL DEBT DOS VALUE INCURRED AMOUNT $85,169.00 1990 $90,000.00 (mortgage) $34,626.00 3/2000 $34,910.00 (home equity loan) $3,990.00 Revolving Visa loan PAYMENTS POST-SEPARATION $710.77 monthly $433.95 monthly k/p:divorce\psullivan.exh KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, HI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on October 28, 2004, I served a copy of the within Defendant's Pre-Trial Statement, by UPS Overnight, addressed as follows: E. Robert Elicker, H, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Street P. 0. Box 168 Lemoyne, PA 17043 .C N. Second Street thouse Suite 0. Box 984 rrisburg. PA 17108 (717) c-> ? i; r; 4°`' ° nzr z'? '?i ??_ ? ?-? t 1,3 ?? r_ N ={ KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, 111, Defendant RECEIVED APR 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this //' day of 2005, based upon the stipulation of the parties which is attached hereto, we hereby order and decree as follows: 1. The Defendant, Patrick T. Sullivan, III, incorrectly identified in the caption in this matter as "Patrick J. Sullivan, 111" (hereinafter "Husband") shall pay to the Plaintiff, Kimberly A. Sullivan (hereinafter "Wife") the sum of Thirty-Four Thousand ($34,000.00) Dollars before 5:00 p.m. on Friday, 6 May 2005. The payment shall be made by a certified check or by a check from his attorney delivered to Wife's attorney by that time. In the event that Husband fails to make such payment, the funds now held in escrow by his attorney, as described in the attached Stipulation, shall be immediately paid and delivered to Wife's attorney on noon the next business day and Wife shall be entitled to enforce the payment of the balance owed of Twenty-Eight Thousand ('$28,000.00) Dollars under all provisions of the law of Pennsylvania, specifically including the provisions of the Divorce Code, and Husband shall be responsible to pay all fees, costs, and expenses incurred by Wife in her efforts to collect said debt. Notwithstanding the foregoing, if Husband pays to Wife the total sum of Twenty-Eight Thousand ($28,000.00) Dollars by 5:00 p.m. on May 6, 2005, such payment shall satisfy his obligation to make a cash payment to Wife under this Paragraph and Wife shall accept the total payment of Twenty-Eight Thousand ($28,000.00) Dollars as satisfaction of Husband's obligation to make cash payment to her under this Order. 2. The distribution and division of the parties' other marital assets, and the waiver of other claims by the parties, as set out in the attached Stipulation, are hereby approved and are incorporated into this Order. FILED-OFFICE OF THEE PROTHONOTARY 2005 APR I I PM 3: 16 L?, :' , Ira {_ OUNTY PEiNNSYLVANIIiA rte. 3. Upon Wife's receipt of the cash payments due pursuant to this Order, and upon the presentation of the appropriate documents to this court, we will enter a final decree in divorce between the parties. Distribution: Xmuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12"' Street, P.O. Box 168, Lemoyne, PA 17043 ,,,,.AMn F. King, Esquire (Attorney for Defendant) /600 North Second Street, 5`h Floor, P.O. Box 984, Harrisburg, PA 17108 V' BY THE COURT, - rte' KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant STIPULATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE AND NOW come the above-named parties, with their attorneys, and stipulate and agree as follows: 1. The Defendant, Patrick T. Sullivan, III, incorrectly identified in the caption in this matter as "Patrick J. Sullivan, III" (hereinafter "Husband") shall pay to the Plaintiff, Kimberly A. Sullivan (hereinafter "Wife") the sum of Thirty-Four Thousand ($34,000.00) Dollars before 5:00 p.m. on Friday, 6 May 2005. The payment shall be made by a certified check or by a check from his attorney delivered to Wife's attorney by that time. In the event that Husband fails to make such payment, the funds now held in escrow by his attorney, as described in the attached Stipulation, shall be immediately paid and delivered to Wife's attorney on noon the next business day and Wife shall be entitled to enforce the payment of the balance owed of Twenty-Eight Thousand (*$28,000.00) Dollars under all provisions of the law of Pennsylvania, specifically including the provisions of the Divorce Code, and Husband shall be responsible to pay all fees, costs, and expenses incurred by Wife in her efforts to collect said debt. Notwithstanding the foregoing, if Husband pays to Wife the total sum of Twenty-Eight Thousand ($28,000.00) Dollars by 5:00 p.m. on May 6, 2005, such payment shall satisfy his obligation to make a cash payment to Wife under this Paragraph and Wife shall accept the total payment of Twenty-Eight Thousand ($28,000.00) Dollars as satisfaction of Husband's obligation to make cash payment to her under this Order. 2. Husband and his counsel, John F. King, Esquire, represent and acknowledge that Husband has deposited with Mr. King the sum of Six Thousand ($6,000.00) Dollars, which funds are currently held in Mr. King's firm's escrow account. Husband and Mr. King ti - LI _ acknowledge that such funds shall be held and distributed strictly in accordance with this Stipulation and the Order to be entered pursuant to this Stipulation. 3. The parties have agreed upon the distribution and division of all of their marital assets. Husband shall retain all of those assets currently in his possession or titled or held in his name (including, without limitation, his residence at 330 South 3152 Street in Camp Hill, his benefits within the Pennsylvania State Employees Retirement System, his interest in an investment account he holds with his mother with TD Waterhouse Company and a 1997 Chevrolet Suburban automobile) and Wife hereby waives and releases any claims to or interest in such assets. 4. The parties have agreed upon the distribution and division of all of their marital assets. Wife shall retain all of those assets currently in her possession or titled or held in her name (including, without limitation, Wife's 401 (k) Plan accrued while she was employed with Pinnacle Health, Wife's Pinnacle Health pension benefits, and a 1987 17-foot Chris-Craft boat with trailer) and Husband hereby waives and releases any claims to or interest in such assets. 5. Husband represents to Wife that the debts which encumber his residence at 330 South 3155 Street in Camp Hill are in his name alone and that Wife has no liability on those debts. Each of the parties represents that there are no other debts or obligations created by either of the parties for which the other party may be liable and each of the parties agrees to pay and satisfy, in accordance with their terms, any debts or obligations currently owed by them individually and indemnify and save the other harmless from any loss, cost, or expense, including reasonable, attorney's fees, which may result from their failure to pay and satisfy such debts and obligations. 6. Effective upon Husband's payment to Wife as required by: Paragraph 1 hereof, each of the parties hereby waives any further claims against the other party arising out of their marriage or the Pennsylvania Divorce Code, including, without limitation, any claims for alimony, alimony pendente lite, or counsel fees and expenses. 7. In the event that either party breaches this agreement or fails to perform their obligations hereunder, they shall be responsible to pay any attorneys fees or other costs reasonably incurred by the other party in enforcing their rights hereunder. I - 8. The parties agree that the Order attached to this Stipulation shall be entered by the Court of Common Pleas of Cumberland County to adopt and enforce this agreement between the parties. They further agree that the terms and provisions of this agreement shall not merge with any subsequent divorce decree entered between them. IN WITNESS WHEREOF the parties and their counsel have set their hands and seals this --DC day of 2005. /,, &. , ?, J,, u, , Kimberly #. Sullivan air uel L. Andes Attorney for Plaintiff 1111'`'' _, n cm N O ° ? co T a? I-N . i KIMBERLY A. SULLIVAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, III, : Defendant IN DIVORCE ORDER OF COURT AND NOW, this /3'?h day of , 2005, the economic claims raised in the proceedings having been resolved in accordance with a stipulation dated April 7, 2005, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. cc: /amuel L. Andes Attorney for Plaintiff V1, ohn F. King Attorney for Defendant J ?e?Oy ba"?3 BY THE COURT, Gebr E. H ffer, J. FILE [} C'`rFIGE OF THE PRTI'r;O NOTARY 2005 APR 13 A ,10.07 lrl P?PJ 'WIN f KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant STIPULATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE AND NOW come the above-named parties, with their attorneys, and stipulate and agree as follows: 1. The Defendant, Patrick T. Sullivan, III, incorrectly identified in the caption in this matter as "Patrick J. Sullivan, 111" (hereinafter "Husband") shall pay to the Plaintiff, Kimberly A. Sullivan (hereinafter "Wife") the sum of Thirty-Four Thousand ($34,000.00) Dollars before 5:00 p.m. on Friday, 6 May 2005. The payment shall be made by a certified check or by a check from his attorney delivered to Wife's attorney by that time. In the event that Husband fails to make such payment, the funds now held in escrow by his attorney, as described in the attached Stipulation, shall be immediately paid and delivered to Wife's attorney on noon the next business day and Wife shall be entitled to enforce the payment of the balance owed of Twenty-Eight Thousand (*$28,000.00) Dollars under all provisions of the law of Pennsylvania, specifically including the provisions of the Divorce Code, and Husband shall be responsible to pay all. fees, costs, and expenses incurred by Wife in her efforts to collect said .debt. Notwithstanding the foregoing, if Husband pays to Wife the total sum of Twenty-Eight Thousand ($28,000.00) Dollars by 5:00 p.m. on May 6, 2005, such payment shall satisfy his obligation to make a cash payment to Wife under this Paragraph and Wife shall accept the total payment of Twenty-Eight Thousand ($28,000.00) Dollars as satisfaction of Husband's obligation to make cash payment to her under this Order. 2. Husband and his counsel, John F. King, Esquire, represent and acknowledge that Husband has deposited with Mr. King the sum of Six Thousand ($6,000.00) Dollars, which funds are currently held in Mr. King's firm's escrow account. Husband and Mr: King t N T acknowledge that such funds shall be held and distributed: strictly in accordance with this Stipulation and the Order to be entered pursuant to this Stipulation. 3. The parties have agreed upon the distribution and division of all of their marital assets. Husband shall retain all of those assets currently in his possession or titled or held in his name (including, without limitation, his residence at 330 South 31st Street in Camp Hill, his benefits within the Pennsylvania State Employees Retirement System, his interest in an investment account he holds with his mother with TD Waterhouse Company and a 1997 Chevrolet Suburban automobile) and Wife hereby waives and releases any claims to or interest in such assets. 4. The parties have agreed upon the distribution and division of all of their marital assets. Wife shall retain all of those assets currently in her possession or titled or held in her name (including, without limitation, Wife's 401 (k) Plan accrued while she was employed with Pinnacle Health, Wife's Pinnacle Health pension benefits, and a 1987 17-foot Chris-Craft boat with trailer) and Husband hereby waives and releases any claims to or interest in such assets. 5. Husband represents to Wife that the debts which encumber his residence at 330 South 31" Street in Camp Hill are in his name alone and that Wife has no liability on those debts. Each of the parties represents that there are no other debts or obligations created by either of the parties for which the other party may be liable and each of the parties agrees to pay and satisfy, in accordance with their terms, any debts or obligations currently owed by them individually and indemnify and save the other harmless from any loss, cost, or expense, including reasonable: attorney's fees, which may resultfrom their failure to pay and satisfy such debts and obligations. 6. Effective upon Husband's payment to Wife as required by Paragraph 1 hereof, each of the parties hereby waives any further claims against the other party arising out of their marriage or the Pennsylvania Divorce Code, including, without limitation, any claims for alimony, alimony pendente lite, or counsel fees and expenses. 7. In the event that either party breaches this agreement or fails to perform their obligations. hereunder, they shall be responsible to pay any attorneys fees or other costs reasonably incurred by the other parry in enforcing their rights hereunder. A y 8. The parties agree that the Order attached to this Stipulation shall be entered by the Court of Common Pleas of Cumberland County to adopt and enforce this agreement between the parties. They further agree that the terms and provisions of this agreement shall not merge with any subsequent divorce decree entered between them. IN WITNESS WHEREOF the parties and their counsel have set their hands and seals this day of lpd; 2005. J 4-?, ?, Z, -- K mberly . Sulliv n Patrick,Y Su ?leh uel L. Andes ?- rolmey F. King Attorney for Plaintiff for I KIMBERLY A. SULLIVAN V. PATRICK J. SULLIVAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00 - 6060 IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Kimberly A. Sullivan Samuel L. Andes Patrick J. Sullivan John F. King Plaintiff Counsel for Plaintiff Defendant Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 24th day of February 2005 at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, George E. Hoffer, President Judge Date of Order and Notice: 113104 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 KIMBERLY A. SULLIVAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Samuel L. Andes John F. King , Attorney for Plaintiff , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 1st day of November, 2004, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 8/31/04 E. Robert Elicker, II Divorce Master KIMBERLY A. SULLIVAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND PARTIES TO: Samuel L. Andes Kimberly A. Sullivan Counsel for Plaintiff Plaintiff John F. King Patrick J. Sullivan Counsel for Defendant Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 29th day of November 2004, at 2:00 p.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: 11/1/04 E. Robert Elicker, II Divorce Master RRIEDMAN & KING, P. C. ATTOENEYs AT LAW 600 N. SECOND ST. FIFTH FLOOR P.O. Box 984 HARI? SHUHO, PENNSYLVANIA 17108 (717) 230-8000 TEL COFIEE NO. (717) 236-8080 friedmamndldng@hotmail.com RICHARD S. FBIEDMAN JOHN F. KING July 28, 2004 E. Robert Elicker, II, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: Please be advised that Mr. King is out of the country until August 2, 2004, and will respond when he returns. Very truly yours, Barbara E. Palmer, Secretary BEP/bep:corresaf\elicker2.ltr cc: Patrick Sullivan Samuel L. Andes, Esquire L M KIMBERLY A. SULLIVAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, Defendant IN DIVORCE MEMORANDUM THE MASTER: Today is Friday, December 17 2004. This is the date set for a conference with counsel and the parties. Both of the parties are present but not in the hearing room at this time and both counsel are present and in the hearing room. After discussion with counsel, it has been determined that there is a matter of discovery which needs to be addressed in order to allow the Plaintiff to adequately satisfy herself that the information that has been provided is accurate. Mr. Andes is going to place on the record what information he is going to ask Mr. Sullivan to produce and then the Master will indicate a time frame in which this information should be provided and made available to wife's attorney. Mr. Andes. MR. ANDES: We have spent an hour and a half here, Mr. King and myself, and we have gone over assets and exchanged a lot of documents -- and we exchanged documents beforehand -- and we have identified three types of documents that we need yet. I will say that many of these I 1 requested in formal discovery in 2002, and I am not blaming Mr. King, I am blaming Mr. Sullivan, but they have not been produced. These are the documents that we have identified that both counsel require. Statements from the TD Waterhouse account that Mr. Sullivan holds jointly with his mother from the inception of that account in May of 1997 through December 2000. Copies of cancelled checks or other documents that will verify Mr. Sullivan's mother's contributions or depoaits into the TD Waterhouse account. An appraisal of the residence owned by Mr. Sullivan as of June of 2000. Statements from Mr. Sullivan's account at PSECU for the period from March through July of 2000 which we believe will verify what expenditures were made from the home equity loan that he took out. THE MASTER: Mr. King, do you have any comments? Do you understand the request that Mr. Andes is making or do you have any statements you want to make with regard to the information requested? MR. KING: I understand the request that is being made and I would ask the Master if he would allow for a period of time with an end date of January 15, 2005, in order for my client to provide the documents being 2 requested. THE MASTER: Mr. Sullivan, through his counsel, is directed to provide the information that Mr. Andes has requested by January 15, 2005. In the event that this information is not provided in a timely way as indicated, Mr. Sullivan faces the potential of having to pay counsel fees and costs for his failure to timely produce the documents that are necessary to further complete the discovery settlement possibilities in this case. MR. ANDES: Because of the time that has passed since I first attempted to obtain this information in formal discovery, I would like also to reserve the right to come back if we do not have this by January 15, 2005, and ask that if Mr. Sullivan does not produce them, that he be foreclosed or precluded from offering any testimony about, for example, the TD Waterhouse account or the home equity loan that would contradict our position which is the home equity loan is not a marital debt and that the TD Waterhouse account, as least half of that, is marital property. I am not asking you to rule on that now but I am asking you to indicate that you would at least receive that kind of argument if the information is not produced. THE MASTER: It is understood. We would certainly allow you to raise that argument at the time, in the event that the information is not provided. Thank you, 3 counsel. MR. ANDES: Thank you. MR. KING: Thank you. cc: Samuel L. Andes Attorney for Plaintiff John F. King Attorney for Defendant SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPRO (717) 761-5361 Fe 24 January 2005 (717) 761-3L35 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Kimberly A. Sullivan vs. Patrick J. Sullivan, N No. 2000-6060 Civil Term in Divorce Dear Mr. Elicker: I represent Mrs. Sullivan. Mr. Sullivan is represented by John King, Esquire. You have scheduled a hearing in this matter for 24 February 2005. We are working on a settlement which we think will come to pass, but we are not going to be able to get that in placejay:'the time set for the hearing. I spoke with your office on Friday and understand that you have 31 March 2005 available to hold this hearing. I spoke with Mr. King and both of us have agreed to postpone the hearing and conduct it on 31 March 2005 if we have not settled the case by that time. If that is satisfactory with you, please issue a notice of the hearing for 31 March 2005. Mr. King and I will notify you as soon as possible if we settle the case prior to that date. Sincerely, Ses amh cc: John F. King, Esquire. Kimberly A: Sullivan:. KIMBERLY A. SULLIVAN V. PATRICK J. SULLIVAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00 - 6060 IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Kimberly A. Sullivan Samuel L. Andes Patrick J. Sullivan John F. King , Plaintiff , Counsel for Plaintiff , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 12th day of 2005 at 9.00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, George E. Hoffer, President Judge Date of Order and Notice: 2/1/05 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET, CARLISLE, PA 17013 TELEPHONE (717) 249-3166 i r KIMBERLY A. SULLIVAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Monday, November 1, 2004 Present for the Plaintiff, Kimberly A. Sullivan, is attorney Samuel L. Andes, and present for the Defendant, Patrick J. Sullivan, is attorney John F. King. A divorce complaint was filed on September 5, 2000, raising grounds for divorce of irretrievable of the marriage. Counsel have indicated that the parties will sign affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code. The parties separated in June 2000. There was one child born of the marriage, Sarah E. Sullivan, born February 29, 1996. The child resides with the wife. Economic claims raised in the complaint are equitable distribution, alimony, alimony pendente lite and counsel fees and expense. Mr. Andes indicated that there may be testimony regarding marital misconduct if his client decides to pursue the alimony claim. He will advise Mr. King if we have to have a hearing in this case at least a month prior to the hearing whether or not the alimony claim is going to be contested and who his witnesses will be with respect to marital misconduct. Wife is 38 years of age and resides at 5 San Juan Drive, Mechanicsburg, Pennsylvania, with the daughter. She is an RN and works for Capital Blue Cross. Her net income every two weeks is $1,429.86. She is receiving child support in the amount of $750.00 per month which is based on an order of $683.00 per month plus $67.00 per month on the arrearages. Wife has not raised any health issues. Husband is 43 years of age and resides at 330 South 31st Street, Camp Hill, Pennsylvania. There has been some question about whether anyone is living with him and that will not really be important unless we get into an 1 alimony issue. Husband has a Bachelors degree and is an analyst with Penn Dot with the Commonwealth of Pennsylvania. His net annual income as shown on the pretrial statement is $36,400.00. Mr. King indicated that he will clarify on the record how that number was determined or if that number should be reviewed. Husband has not raised any health issues. Husband had real estate prior to the marriage at 330 South 31st Street, Camp Hill, Pennsylvania, and counsel are going to determine the increase in value and include in that review and computation the debt against the property which is a mortgage and a home equity loan. We are waiting on an appraisal that Mr. King has ordered and he will provide the results of that appraisal to Mr. Andes so counsel can do the computations. I am going to let counsel address the matter of the vehicles on the record, as well as the boats which the parties had during the marriage, namely a motor boat and a sail boat. Husband is a participant in the SERS with the Commonwealth of Pennsylvania. There is some question about whether wife had any retirement benefits accruing during her time with employment with PinnacleHealth during the marriage. Counsel are also going to address the issue with respect to the Waterhouse Securities account. The Master has been advised that with regard to the household tangible personal property apparently the parties have received what each is satisfied will be a distribution of that property. The marital debt consists of the mortgage and the home equity loan. Mr. King will address on the record during his remarks a revolving Visa loan through PSECU. Mr. Andes, would you like to make some comments on the record? MR. ANDES: Yes. I am going to provide Mr. King with a copy of the appraisal of Mr. Sullivan's pension done by Harry Leister and hope we can stipulate to that. I am going to provide him with documents 2 I showing the balance in my client's tax deferred annuity with the Travelers Insurance Company, both the date of marriage and the date of separation, and hopefully we can stipulate on the increase in value during the marriage of that asset. I am going to check with my client to see if she had any other retirement benefits. I am not aware of any but I will check with her and it may well be that she had something from her employment with PinnacleHealth. I will check with my client about signing a consent. I will talk with her about whether she wants to pursue a claim for alimony and if so we will notify Mr. King of any evidence or any need for a hearing regarding marital misconduct. Mr. King is going to provide me with the latest appraisal of the real estate, the value of the dump truck. I am going to try to come up with the information to support the value of the Chriscraft boat that my client has in her possession. There is a substantial dispute about a TD Waterhouse account that is in the joint names of Mr. Sullivan and his mother. Mr. King is going to provide me with some documents or some verification that all of the money in that account was contributed by the mother and also some explanation of how it is that the account is in both names. If it does not belong to Mr. Sullivan, at least in 3 part, the increase in value should not be considered. There is a dispute about the value of the Suburban relative to the home equity loan because the Suburban was purchased -- it was about three years old and it was purchased in the earlier part of 2000, before the parties separated, for $15,000.00 and that purchase price was paid, we understand, with the home equity loan. If we are going to consider the home equity loan, I think it is only fair that we value that vehicle at its purchase price or at least its value at or near the time of separation. Hopefully Mr. King and I can resolve those matters. THE MASTER: Mr. King. MR. KING: The appraisal that has been discussed today has been ordered from Mr. Troup, the same appraiser that appraised the home shortly before the marriage in 1995 and I hope to have a copy of that appraisal by the end of the week which I will get over to Mr. Andes. When Mr. Andes referred to any other retirement accounts owned by wife, he specifically is going to inquire with her as to whether she had any 401(k), IRA, explore whether she was a member of any retirement plan such as a defined benefit plan or defined contribution plan during the course of the marriage. I want to, for the, record, indicate that I misrepresented one of the exhibits in the pretrial statement 4 i i and that is the exhibit for the boat. I believe that when I put this packet together I was thinking that the boat valuation exhibit referred to my client's sail boat when in fact, as Mr. Andes pointed out prior to us going on the record, this is actually a valuation from the NADA guide that my client had performed for the 1987 Chriscraft which was retained by wife. And in addition to the numbers from the NADA guide for the valuation of the boat plus the equipment on the boat, he also placed a value that he came up with himself for the trailer. So those two pages are in Exhibit B and I will send something in writing to Mr. Elicker and Mr. Andes just indicating that this is actually an exhibit that we are presenting for purposes of valuing the motor boat. As far as the sail boat goes, I was able to confirm with my client that he received as a financial benefit for his one-third interest $1,500.00 but he had actually sold that interest for a greater amount and he is going to confirm what that number was and then I will share that with Mr. Andes to see if we can reach an agreement as to what the marital one-third interest of that sail boat value should be for the purposes of this proceeding. Regarding the TD Waterhouse account, I have requested that my client regather the documentation that he had previously had, which he has now lost, which will try to establish the fact that husband's mother provided the sole 5 monies for the investments there and perhaps I will ask for some sort of a statement from mother explaining why her son's name was added on to that account which our position up to this point has been it was so that son would have the ability to make investment decisions on behalf of his mother. I believe that's all I have. THE MASTER: A conference is scheduled for Monday, November 29, 2004, at 2:00 p.m. Counsel are requested to bring along to the conference spreadsheets to show the values of assets which they believe are correct so we can identify areas of agreement and areas of dispute. Also, we are going to schedule a hearing in this matter in the event the case is not settled on the 29th of, November, for Thursday, February 24, 2005, at 9:00 a.m. Notices will be sent to counsel and the parties. cc: Samuel L. Andes Attorney for Plaintiff John F. King Attorney for Defendant NOTE: Mr. King should provide verification of husband's net monthly income after a recomputation. He should also provide documentation regarding the revolving VISA loan account with PSECU. 6 KIMBERLY A. SULLIVAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN,III, Defendant IN DIVORCE RESCHEDULED CONFERENCE WITH COUNSEL AND THE PARTIES TO: Samuel L. Andes Counsel for Plaintiff Kimberly A. Sullivan Plaintiff John F. King , Counsel for Defendant Patrick J. Sullivan, III , Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 17th day of December 2004, at 2:30 p.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II November 17, 2004 Divorce Master SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 166 LEMOYNE, PENNSYLVANIA 17043 TRu PROs (717) 761-5361 Fd (717) 761-1435 16 November 2004 E. Robert Elicker, 11 Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE. Kimberly A. Sullivan vs. Patrick J. Sullivan, /// No. 2000-6060 Civil Term In Divorce Dear Mr. Elicker: You have scheduled a settlement conference in the above case for 2:00 p.m. on 29 November 2004. 1 am scheduled to appear before Judge Bayley at a hearing that "'afternoon at 1:30 p.m. in a matter which I thought had been resolved. However; my optimism in 't'hat case was premature and I expect we may have a hearing that will last most of that afternoon. I would suggest we move the conference back an hour and try to start at 3:00 p.m., but I do not believe that will give counsel and the parties adequate time to have any useful negotiations. Accordingly, I request that you reschedule the conference for sometime in December so that we will have adequate time to make the conference meaningful. You have scheduled the hearing in February and I think a settlement conference in mid December will give us time to accomplish everything we can. Sincerely, L. Andes 2 -N amh cc: John F. King, Esquire Kimberly A. Sullivan SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761-5361 8 April 2005 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE.- Kimberly A. Sullivan vs. Patrick ?. Sullivan, No. 2000-6060 C/v/l Term In Divorce Dear Mr. Elicker: PAX (717) 761-1635 You have a hearing scheduled in the above case for Tuesday, 12 April 2005. The parties just signed a stipulation which resolves all of the economic issues in the case. I will be filing a motion with the court within the next week or two to have an order entered to confirm the stipulation. In the meantime, I write to request that the hearing be canceled and that you take whatever steps are necessary to have your appointment as Master vacated so that we can conclude the divorce. Sincerely, Ce L. Andes amh / Enclosure cc: John F. King, Esquire Kimberly A. Sullivan IN THE COURT OF COMMON PLEAS OF KIMBERLY A.SULLIVAN CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. NO. CIVIL 19 00 - 6060 IN DIVORCE PATRICK J. SULLIVAN Defendant STATUS SHEET DATE: n ACTIVITIES: An . ? n ? ,,-°j;d mom(, {2?/11,D IA A'l /hA VV 6, An i r( ,< <- r' KIMBERLY A. SULLIVAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, III,: Defendant IN DIVORCE TO: Samuel L. Andes John F. King , Attorney for Plaintiff , Attorney for Defendant DATE: Thursday, May 6, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. Iof AID 0_1 KIMBERLY A. SULLIVAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-6060 Civil PATRICK J. SULLIVAN, III, : CIVIL ACTION - LAW Defendant : DIVORCE DEFENDANT'S PRE-TRIAL STATEMENT Defendant, by his attorney, John F. King, Esquire, files this Pre-Trial Statement in accordance with Pa. R.C.P. 1920.33(b). 1. ASSETS. Attached hereto and marked as Exhibit "A" is a list of the Marital and Non-Marital Assets as known to Defendant. 2. EXPERT WITNESSES. At this time, Defendant intends to call the following expert witnesses to testify on his behalf at any hearing: A. Real estate appraiser to testify as to the increase in value of Husband's real estate at 330 S. 3131 Street in Camp Hill. Defendant reserves the right to call such additional experts as may be necessary, depending upon the witnesses the Plaintiff will call. 3. FACT WITNESSES. At the present time, Defendant intends to call himself as a fact witness. The Defendant will give general testimony regarding the value of assets and further information regarding marital versus non-marital property, and finally information regarding debt. The Defendant also intends to call his mother, who will testify as to ownership of the TD Waterhouse securities account. 4. EXHIBITS. At this time, Defendant intends to offer into evidence the following exhibits (collectively attached as Defendant's Exhibit "B"): A. Real estate equity loan documents. B. Primary mortgage documents. C. Boat valuation. D. Payroll statement. E. SERS Statement of account. F. Chevrolet Suburban valuation. G. Real Estate Appraisal - date of marriage. 5. INCOME. Attached hereto as Exhibit "C" is a copy of Defendant's pay statement for period ending 8/13/04. Defendant's current gross income is approximately $56,500.00 annual, and approximately current net income is $36,400.00 annual. 6. PENSION VALUE. Attached hereto is a copy of the Defendant's 2000 Statement of Account from the Pennsylvania State Employee Retirement System. 7. DEBTS. Please see Defendant's Exhibit "D". 8. PROPOSED RESOLUTION. A 50150 distribution of marital assets by way of a combination of cash distribution and Qualified Domestic Relations Order. Respectfully submitted, Date: 7045_. 60q N. Second StrW Pedthouse Suite Pp. . Box 984 risburg, PA 17108 17)236-8000 k/p:divorce\psullivan.pretrial VERIFICATION I, Patrick J. Sullivan, III, hereby acknowledge that I am the Defendant in the foregoing action; that I have read the foregoing Defendant's Pre-Trial Statement; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to.authorities. Patrick J. Sullivan, III Dated: MARITAL PROPERTY ASSET VALUE DATE OF VALUE MARITAL PORTION LIENS 1. Marital residence Appraisal pending Current Appraised 1 s` mtg $85,076.00 (DOS) 330 S. 31" Street Value 2"a mtg $34,626.00 (DOS) Camp Hill, PA $135,000.00 2. Husband's SERS Unknown N/A approx. 29% None Retirement Acct (portion earned during marriage) 3. Wife's Tax Unknown N/A 100% None Deferred Annuity with Travelers Ins. 4. Husband's 1997 $4,260.00 Chevrolet Suburban 5. Husband's 1984 x$3,000.00 Harley Davidson motorcycle 6. Husband's 1/3 $2,200.00 interest in sail boat and trailer NOTE: 1/3 interest sold - 6/2000 7. 1987 Chris Craft Unknown 17' motor boat in Plaintiff's possession 8. Household Negligible furnishings 9. Water skis, tube, $400.00 Wakeboard 10. Wife's 401(k) Unknown 11. Wife's IRA Unknown 11 Wife's Ret. Plan Unknown present 100% None sale date 2002 100% None as ordered by Court (support action) present 100% None N/A 100% None Date of Separation 100% None Current 100% None N/A 100% Unknown N/A 100% Unknown N/A 100% Unknown NON MARITAL PROPERTY REASON DATE OF FOR ASSET VALUE VALUATION EXCLUSION 1. TD Waterhouse $65,000.00 Securities Account 2. Defendant's equity $135,000.00 in residence at 330 S. 31" Street Camp Hill (on date of marriage) 3. Wife's Pre-Marital Unknown portion of tax deferred annuity with Travelers Insurance Date of Separation The securities in this Acct. are solely owned by Husband's mother Date of Marriage Written Pre-Marital Agreement between parties, and appraisal N/A Owned pre-marriage 4. Each parties' Negligible pre-marital furniture 5. Wife's pre-marital Unknown portion of 401(k) 6. Wife's pre-marital Unknown portion of IRA 7. Wife's pre-marital Unknown portion of retirement plan 8. Husband's pre-marital Unknown portion of retirement plan N/A Owned by each party prior to date of marriage N/A Earned pre-marriage N/A Earned pre-marriage N/A Earned pre-marriage N/A Earned pre-marriage LIENS None 1" mtg. $85,076. (DOS) 2"d mtg. $34,626. (DOS) N/A None Unknown Unknown Unknown None Patrick Sullivan 330 S 31st Street Camp Hill, PA 17011 Account # 0196547128 DEAR Patrick Sullivan: The balances on your loans as of June 2000 are as follows: Personal Service Loan (Ll) $237.22 June 20,2000 Visa Loan (L9) $3990.15 June 26, 2000 Real Estate Equity Loan (L50) $34,626.62 ^ s. June 1, 2000 If you have any questions, you may reach us between 7 a.m. to 5 p.m. Monday through Friday or between 8 a.m. to noon on Saturdays. Call 234-8484 in Harrisburg or call our toll-free number (800) 237-7328. When you come to the menu prompt, enter 5 and then enter 5 again. One of our Member Service Representatives will be glad to assist. Sincerely, ita Austin Member Service Advisor Member Services PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 - (717) 234-8484 - (800) 237-7326 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • (717) 777-2100 (TDD) • (800) 472-1967 (TDD; Web Address: www.psecu.com Savings federally Insured up to $100,000 by the National credit Union Administration SPOUSAL WAIVER AND AFFIDAVIT 1, 1 ?lJy1?? t''yfl:I Ivis? , being first duly sworn, make the following affidavit for the pur ose of inducing Pennyvania tate Employees Credit Union (the "Credit Union") to make a loan to my spouse,??r .?? individually or as a pa ner with others, secured by a mortgage lien upon real estate located in e rA vvs?Q4 County, Pennsylvania, by documents bearing even date herewith, without my joinder in any of the loan documents. 1. I consent and agree to the loan transaction referred to herein, after full disciosure to me of its terms. 2. 1 hereby knowingly and willingly waive any right or interest that I might have in the real estate identified in the mortgage, whether in statute, common law, or otherwise, and subordinate any such right or interest to the lien of the Credit-Union's mortgage. 3. 1 acknowledge that the loan transaction is to be entered into good faith by the parties thereto, and that the Credit Union will give value in connection therewith to the full extent of the loan proceeds which have been committed to be loaned. 4. 1 hereby acknowledge that: a) but for this waiver the Credit Union would not have made a loan to my spouse; b) the Credit Union has changed its position in reliance on this waiver. Check the appropriate box: V There is not action in divorce or annulment, nor any other type of matrimonial lawsuit or other legal action relating to marital status pending between me and my spouse. Q There is action in divorce or annulment, or another type of matrimonial lawsuit or other legal action relating to marital status pending between me and my spouse. IN WITNES WH REOF, I have hereunto set my hand and seal on this /? L htending to be i Bally bound hereby. Aa? day of fit'/Lf; } A ( gnat re Sworn and Subscribe, before a thi day of 'C Notary Public My commission expires NOTARIAL SEAL GAIL P. STRiCKLER, Notary public Camp HHI, Cumberland County My Commission Expires Feb. 3, 2003 w 0 on c? a H d rh? M E U a 000000000000 m m m m m m m m m m? m rrrrtrrrtrrr 0 0 0 0 0 0 0 0 0 0 0 0 ? ?. U ?. LL LL LL LL LL LL LL LL LL LL LL LL t?fJOON?O?ha00? W ? V ?OM(00 Woo or, wo (M O M O N'?t I,- 0 r M 0 M O M M M M M M O O O O O N N .N N N N N N M M M M 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 0 d"M 1-M Vq MMMM d'OfONM V'Ol0 rf0 rim N V lO pl M CN ?cOMO O O O O O r r r r N N N N N N N N N N N N It M M M r'd'I-N0M d' l00) N 0 O O M M M N r?N r 0 M M l O M O M 1? 0 V N N N N N N N N N N N N C C C C C C C C C C U) N N Q1 0 N 0 OI N 01 0 0 U7 N E E E E E E E E E E E E m w m m m m m m m m m m aaaaaan.LL aaaLL c c c c c c c c c c c c m 0 J m J m J J m 0 0 0 0 J m N 0 J J J N N N N N N N N N N N N N f?q N N N N f?q N N N N N C L L C C L C C C C L C N E N E N N W N 2 E 2 2 P -I-E-FFF1-" F- F?- F- NNN N N N N N N N N N 0 0 0 0 0 0 0 0 0 0 0 0 000000000000 N N N N N N N N N N N N r r O r r r r r 0 0 0? o 0 0 0 0 0 0 0 - r 0 rN r0 0 0 0 0 0 0 0 0 000000000000 J J J J J J J J J J J J ,6-2002 12:24 PE PATRICK T SULLIVAN 330 S 31ST ST CAMP HILL PA 17011-5211308 Page 6 2 :1 „ I. "? :YEr2W ' Page 6 A Payment of 162.17 is due on 07/12/00 YTD Finance Charge: Year to Date 213.11 a?We nqW¢ ? ? tb 4rLC Rai *** ANNUAL PERCENTAGE RATE 0.500% *** Periodic Rate (Monthly) 0.708331k Past Eff Description Principal *FIN CHG* Balance 0601 ID se REAL ESTATE EQUITY LOAN Beginning Balance 34813.97 0601 Payments Transfer From Share 04 187.35- 246.60 34626.62 0630 Ending Balance 34626.62 A Payment of 433.95 is due on 07/01/00 YTD Finance Charge: Year to Date 584.18 =cec....aae__eeeeeee===?voe_¢_=_=ccee.cvcccaac=a==e.ecce--cote n_ee==vee==vee;.caue Total Dividend YTD: Year to Date 60.69 Total YTD Finance charge, Year to Date 1200.07 P. 02/02 TnT01 P R? TRUTH-IN-LENDING DISCLOSURE STATEMENT (THIS IS NEITHER A CONTRACT NOR A COMMITMENT TO LEND) C.86(DER OR LENDER'S AGENT: Preliminary ?X{Final dit U i on n Pennsylvania State Employees Cre P.O. Be. 67013 DATE: March 21, 2000 Harrisburg, PA 17106-7013 LOANNO.: 2861 Type of Loan: Fixed BORROWERS: Patrick T. Sullivan ?y n ???V ADDRESS: 330 South 31st Street CITY/STATE/ZIP: Camp Hill, PA 17011-5211 PROPERTY: 33D South 31st Street Camp Hill, PA 17011-5211 ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments The cost of your credit as a The dollar coronas, the credit will The amount of cedit provided The mrtou[u yon will have yearly rate, cost you, 1 m,.m.r.n your bchniL P°id nOcr you hove nmdc all payment as xehcdutcd. 9499% $17,163.59 ,134 910.34 352 073.92 PAYMENT SCHEDULE: NUMB 1Etl1' ?:ttMOUNMOi'JN7Y)1° r"SUUCx :1JIIM1)ER OP': AM01?N I"OIY. 4VIIDN PAYA7LNT5 ARE DOIi ?VIILNI'A,YMLNT$ .,. « ? ,.ft,KMTSN;fST :i-?NTS. L 433 87 :. 04/01/10 Montfily DEMAND FEATURE: ELI This loan does not have ° Demand Feawre. This loan bas a Demand Feature as follows:' VARIABLE RATE FEATURE: ® This teen has. Variable Rata Fame, Variable Rate Disclosures Lave been provided to you earlier. SECURITY: Yon am giving p accurity irtemst in Ilu prop.rty locatul at 330 South 31st Street, Camp Hill, PA 17011-5211 ASSUMPTION: Sorrcenebuying dais propetty ®canna assume the rmnaining lplanpe due under original mortgage tenna nay aaaum., uubjmt t. lendce'e eotid'uiort+:. the rmlainirtg balance dm uvular origitat mettgage woos. FILING / RECORDING FEES: S0- 00 --^?7 PROPERTY INSURANCE: [OPr.pettylrcudimucuneei.tba maum.f1i 120,600.00 wi0amongngpe dauuadre lener is a roquircd condition of this lo an. Borrower nay purebaae this insurance foam any inaureact company acacpnble to the lender- r Hmand inaumnec Elis x is not ovvilnble throw h the lender at pn estiirawd cost aC for n year lean. LATE CHARGES: Ifyour payment I. more than 15 days late. yon will be charged a lam charge of 5.0 % of the overdue psymeM. PREPAYMENT: may f?'1 will nos, lava m pay a pcanity, LJ Inay will not be crualcd to a refned.(part of the tine....hnrgc. See your convect documents for any additional information regarding non-payment, default. required repayment in full before scheduled date, and prepayment refunds and penalties. a ..an. estimate VW. heceby acknowledge readirg and meeivinS a complain copy of this diseloslm- T. Sullivan BORROWER/DATE BORROWER I DATE BORROWER / DATE BORROWER/DATE (Q -750 !eao'l N omcmG.GE Few's-innole2'. :2Pr Pupal e!2 Wes Q 1999 eeF Syetema, Inc The conhnb c! thla form in wFOla ar In par[ ore pretaaetl untlar [M1e copYdpM1[ nwa pl the United 5[nlm. DEFINITION OF TRUTH-IN-LENDING TERMS ANNUAL PERCENTAGE RATE This is not the Note rate for which the borrower applied. The Annual Percentage Rate (APR) is the cost of the loan in percentage terms taking into account various loan charges of which interest is only one such charge. Other charges which are used in calculation of the Annual Percentage Rate W Private Mortgage Insurance or FHA Mortgage Insurance Premium (when applicable) and Prepaid Finance Charges (loan discount, origination fees, prepaid interest and other credit costs). The APR is calculated by spreading these charges over the life of the loan which results in a rate higher than the interest rate shown on your Mortgage/Deed of Trust Note. If interest was the only Finance Charge, then the interest rate and the Annual Percentage Rate would be the same. PREPAID FINANCE CHARGES Prepaid Finance Charges are certain charges made in connection with the loan and which must be paid upon the close of the loan. These charges are defined by the Federal Reserve Board in Regulation Z and the charges must be paid by the borrower. Non-Inclusive examples of such charges are: Loan origination fee, "Points" or Discount, Private Mortgage Insurance or FHA Mortgage Insurance, Tex Service Pee. Some loan charges are specifically excluded from the Prepaid Finance Charge such as appraisal fees and credit report fees. Prepaid' Finance Charges are totaled and then subtracted from the Loan Amount (the face amount of the Deed of Trust/Mortgage Note). The net figure is the Amount Financed as explained below. The amount of interest, prepaid finance charge and certain insurance premiums (if any) which the borrower will be expected to pay over the life of the loan. AMOUNT FINANCED The Amount Financed is the loan amount applied for less the prepaid finance charges. Prepaid finance charges can he found on the Good Faith Betimato/Settlement Statement (HUD-1 or 1A). For example if the borrower's note is for $100,000 and the Prepaid Finance Charges total $5,000, the Amount Financed would be $95,000. The Amount Financed is the figure on which the Annual Pementage Rate is based. TOTAL OF PAYMENTS This figure represents the total of all payments made toward principal, interest and mortgage insurance (if applicable) over the life of the loan. PAYMENTSCHEDULE The dollar figures in the Payment Schedule represent principal, interest, plus Private Mortgage Insurance (if applicable) over the life of the loan. These figures will not reflect taxes and insurance escrows or any temporary buydown payments contributed by the seller. -780 199o11 yap 2.12 Ionian: Settlement. Statement U.S. Department of Housing ...... floos wR6ou[ Sellers and Urban Development OMB Approval No. 2502-0491 Name & Address of Borrower. Name & Address of Lender: Patrick T. Sullivan Pennsylvania State Eroployees Credit Union P.O. Sox 67013 / 330 South 31st Street Hazrisburq, PA 17106-7013 330 South 31st Streak Camp Hill, PA 17011-5211 rescission period repaired by la wi . Sorrower(sl Sign.uns(s): 5041¢11.1 form HUD-IA (2194) WPMORTGAGEFC MS-180 01621-7291 ref. RE5PA L CITY MORTGAGE 1820 / jN, OH 45401-1820 'W.NATIONALCITYMORTGAGE.COM NO. ""-"°' uw WIlVubn dW'111111uy MI LU IL 7545-0907 deductible by you on your Fade The Information In boxes 1, 2, and 3 is Income, tax return. Limitation has important tax information and Is being on the cost and value of the secur furnished to the internal Revenue Service. property may apply. In addition, y If you are required to file a return. a may only deduct an amount negligence penally or other sanction may mortgage interest to the extant m Imposed on you 11 the IRS determines was Incurred by you, actually r that an underpayment of tez results pi ODMU4e you overelated a deduction for by you, and not reimbursed this mortgage interest or for these points or another barsDn. because, you did not report this refund SEE REVERSE SmE FOR if If la ly i pERTY ADDRESS 330 S 31ST STREET CAMP HILL PA 17011 PAID Box 2 STATE, ZIP CODE 5565.73 0.00 0.00 1022190 AV "AUTO T3 O 0120 17011 11\Illl\\\I11111\\\1111\11/'\l\\\1\l{Illl\/Ill//11/11\/\1//l/' PATRICK T SULLIVAN III 330 S 31ST ST CAMP HILL PA 17011-6211 NAL DS TO BORROWER -1 - 0.00 - I TRANSACTION HISTORY EFFECTIVE DATE DESCRIPTION DUE DATE TRANSACTION- :.AMOUNT., -PRINCIPAL AMOUNT INTEREST. ` AMOUNT' - ESCROW AMOUNT ESCROW BALANCE PRINCIPAL BALANCE BOTHER Beginning Balance _ 710.00 85714.68 1/06 PAYMENT 1/00 722.63 89,72 464.29 168.62 878.62 85624.96 , 2/07 PAYMENT 2/00 710.77 90.21 463.80 156.76 1035.38 85534.75 3116 LATE CHAR6E ASSESS 3100 - 1035.38 85534.75 27.70- 3/20 PAYMENT 3100 738.47 90,70 463.31 156.76 1192.14 85444.05 27.70 4103 CITY TAX DISB 4100 519.17- 619.17- 672.97 85444.05 4/07 PAYMENT 4/00 710.77 91.19 462.82 156.76 829.73 85352.86 5/15 PAYMENT 5160 710.77 91.68 462.33 156.76 986.49 85261.18 6/08 PAYMENT 8/00 710.77 92.18 461.83 156.76 1143,25 85169.00 7/17 PAYMENT 7/00 710.77 92.68 461.33 156.76 1300.01 85070.32 7/17 PRINCIPAL ONLY PMT 8/00 27.70 27.70 1300.01 85048.62 8110 PAYMENT 8100 710.77 93.33 460.68 156.76 1456.77 84955.29 8/14 SCHOOL TAX DISB 8/00 1345.81- 1345.81- 110.98 84955.29 9/11 PAYMENT 9/00 710.77 93.84 400.17 156.76 267.72 84881.45 10/16 PAYMENT 10/00 710.77 94.34 459.67 166.76 424.48 84767.11 11107 PAYMENT 11100 710.77 94.85 459.16 156.75 581.24 84672.26 12/08 PAYMENT 12/00 710.77 95.37 458.64 156.76 738.00 84576.89 PLEASE REMEMBER TO FILE FOR HOMESTEAD EXEMPTION WITH YOUR TAXING AUTHORITY IF YOU ARE ELIGIBLE. ACCOUNT NUMBER 1 TAX IDENTIFICATION NUMBER 859088 169.54.7128 I *** G 16 *** I4901-721 - INTEGRA.MORTGAGE COMPANY LOAN HISTORY Y-T-D INU 209 CRT 068 INUa 554957906 T13 12/29/95 PAGE 73539 a 330 S 31ST ST WU' CAMP HILL - PA 17011 OOOD IST MIOL PRIM 2N 70,437.70 O MT OE PATH ESC UAL REST ESC 'SU .00 672.22 .00 SPLHt ADU .00 .00 REPL INT DUE DUE DATE HUD PRI OF M .00 .00 • .00 .00 01-01-96 .00 17 5 6 1 151 B 535.65 OUER/SHORT AM 00 T 37.94 2.64 .00 .00 .00 A_ 102.83 .00 &_H---LIFE RISC .00 0 .00 0- .COD -',.00 679.06 .OB00000 1 1 1ST DAIS MTG 73.000 2ND ORIG MTG. 0 PRIM DAL BEG INT IND CAP FLAB MTGR 71.197.17 169 54 SSN DEF INT DAL PRIOR YR P.FO INT PPD INT IND GPM ORG 7128 0.00 0.00 0 0 ASSUM-DT XFER-DEED FHA-SEC/NUM LIP PAYOFF FC-TRK-SW YE-ACC-RPT/DATE Y/03-18-92 SALE-ID EXEMPT PLGD-LH PMT-OPT CALL-METH ELOC BHKRPCY CWDT 1098-DET-HIST POINTS-PD-BY-BORR POINTS-PD-RPTG-YR SUPPRESS-MICR-STMT DI-NOT-RPT-YE REASONABLE-CRUSE RI-HDR-SW 1ST DUE DT _m sw / CRE ULT A MT YID'/%-H .00 W-14 .00 SW / / - ' BALANCE LONSIN CD NO PURGE rLS L .00 .00 DATE DATE TR ' NO - RECEIVED ' PAID BA1L1ANN7CEE1Z kil.6 PAID PAID OTHER CFO BALANCE -BALANSp AMOUNT BALANS& INT-BRA AMO 00 UNTS OCT UMF D1=95-03 Tr2 i 685?S3 61.00 474.151 10.28 ?fGB:41 .oo .00. .oo UGC 01-03-95 L 14-R3 AA 02-95 01-30 1 72 1 685.93 61.41 71074.76 474.24 150.28 856.69 .00. .00 .00 .00 - 1 03-95 03-10 1 72 1 685.93 61.82 71012.94 473.93 150.28 BATCH 718 EDIT-19 372496 1008.97 .00 .00 .00- .00 1 - - 03-10-95 5 FOIEC 324713 14.81 RR ?S m - 04-95 03-31 3 11 04-95 04-05 1 72 1 1 CHECK $123 685.93 98% 62.23 70950.71 5.27- 473.42 150.28 553.10-P irDtI i - 703.98 .00 .00 .00 .00 1 04-05-95 L OS-95 05-03 1 72 1 685.93 62.65 70888.06 _ 473.00 150.28 BATCH 716 EDIT-SEC 416819 1354.26 .00 .00 .00 .00 - - - 05=83- 95T BATCH 714 EDIT-SEC 728243 14.78 AA 06-9505-Ob 72 1 685?93b 3?6-70825.00 4/2.5950 28 100T5 O6-DS-95 L 14.77 RR - 07-95.07-05 1 72 1 685.93 63.48 70761.$2 472.17 150.28- ew EDIT=SEC 247465 1154.82 .00 ..00 .00 .00 1 07-05-95 L DR-99 08-02 1 72 -1 685.93 63.91 70697.61 471.74 150.28 14.76 AA BATCH 708 EDIT-SEO 623916 1305.10 .00 .00 _ _.00_ _ .00_ 1 14.74 RR BATCH 718 EDIT-SED 146332 ***.H 16 *** I4901-721 INTEGRA LOAN-HO (WNT'D) - MORTGAGE COMPANY LOAN HISTORY Y-T-D INU 209 CRT 068 INU# 554957906 T13 12/29/95 - PAGE 73540 a - 08-95 08-07 3 14 1 CHECK #265614 09-SS 09-05 1 72 1 68S.93 64.32 70633.28 471.32 1234.00- 71.10 150.28 721.3a PAYEE CD 370410SOlS .00 ..00 .00 .00 - - - 09-M-95 14.73 All BATCH 708 EDIT-520 568B13 10-95 10-04 1 72-1 685.93- 64-76-rb568.52 470.89 - 150.28 77T .W 00 10-04-95 L 11-95 11-06 1 72 1 685.93 65.19 70503.33 470.46 150.28 521.94 BATCH 773LUIT=MG 019850 .00 .00 .00 .00 1 11-06r95_L- 12-95 12-04 1 72 1 685.93 65.53 70437.70 470:02 150.28 672.22 BATCH 709 EDIT-SED 363212 .00 .00 .00 .00 - 14.69 AA BATCH 727 EDIT-SEO 787949 REO-BY TOTALS 81231.16 759 - 5,6613.33 1, .47 903.36 .00 - 177.14 OTHER AMOUNT CODES: 11R-PEN NTERES -PA E 2-OUE P K3 D- IDE/iOR A E = - C - C=25535-FEE I=A-H-PO _ _ B M=ADVANCE-EFF-ORTE ;_oFgWg H S=CR-IINIFE-RMT , S We SUSPENSE DI-DEFERRED-INT-BAL AB=SUB-CODE AJ=DEF-INT-ADJ-FLAG STRMP AN=NON-AEC-CORP-AOU AR=MTGR AK=ADU-RMT-RECD AL=TRRN-SOURCE AM=IOC-SPEC-INT-PO AN=NON-REC-CORP-AD U AP=DATE-STAMP AO=TIME- -RE(' U 81W-REC-CORP-ADU FEE-?08E6 FfRR0?2=8a 6§ ?£ -- 'RG- . NADAguides.com - New Car Prices, Used Car Values Autos Next Steps • Free Financce Quote • Free Insurance Quote • Free Credit Report • DMV Forms • Donate Your Boat P.Buy a Price Guide When shopping for a boat, personal watercraft, outboard motor or boat trailer be Boats Recreation Vehicles Boats and Personal Watercraft 1987 CHRIS-CRAFT 17BR CAVALIER September 1, 2004 Low Retail I Base Price $2,240 Options Power Boat: CANVAS Boat Cover - 15 ft. thru $70 19 ft.: Bow Cover: $125 Bridge Enclosure: $1,325 Cockpit Cover: $160 Power Boat: ELECTRONICS Depth Sounder: $80 Power Boat: ENTERTAINMENT Stereo - am/fm cassette $130 w/4 speakers: TOTAL $4,130 l??rint this naQe Average Retail $2,760 $85 $150 $1,575 $190 $95 $155 $5,010 Boat Specifications Length: 17' Model Name/Description: 17BR CAVALIER Boat Type: ./ Stern Drive Power Boat Page 1 of 3 Buy a Pr http://www.nadaguides.com/Values/ValueReport.asp?Userlb=5b 194465-i-4fd9-8a65-e4... 9/1/2004 ?! F C- -Y-A l+ 417 1 1- Ca e.LgA 1 12 - Make & Year.] 1 3 --Model I I 4 -Options 1 0 5 - Used Values 0 ................................................................................................ .... ............... ... ............ ...... ......................... Used Values: Result •• NADAguides.com -New Car Prices, Used Car Values prepared. Hull Material: Fiberglass Subscribe to a Beam: 61911 N.A.D.A. price Engine: 1 guide for all your 140 HP vehicle valuation Gasoline needs. Don't Net Weight: 1,450 leave home without it... Buy a Guide Today Notes (*)INCLUDES THE VALUE OF THE OUTBOARD MOTOR AND TRAILER. (**)INCLUDES THE VALUE OF THE TRAILER. (***)INCLUDES THE VALUE OF THE OUTBOARD MOTOR N/A DUE TO LIMITED RESALE ACTIVITY. Neat Steps Need a new Pickup Truck or SUV to haul your Boat or Personal Watercraft? Before you buy Check your credit and get a Free Finance Quote. Obtain a Free Insurance Quote. Sell your boat through Boattrader.com and get the most money for your craft. Value Explanations Low Retail Value - A low retail valued boat will show excessive wear and tear either cosmetically and/or mechanically. This boat will require cosmetic or mechanical work and may or may not be in running order. The buyer can expect to invest in cosmetic and/or mechanical work. Low retail vessels usually are not found on a dealer's lot. Average Retail Value - An average retail valued boat should be in good condition with no visible damage or defects. This boat will show moderate wear and tear and will be in sound running condition. The buyer might need to invest in either minor cosmetic or mechanical work. Note: Vessels in exceptional condition can be worth a significantly higher value than the Average Retail Price shown. .< Select Another Category Page 2 of 3 http://www.nadaguides.com/Values/ValueReport.asp?UserID=5b 194465-ff82-4fd9-8a65-e4... 9/1/2004 RGILITY CENTER Personnel No. 00027 Fax:7177050967 Oct 27 '04 11:47 P.02 L nu Ybh PAY J1 AICMLINI Patrick T Sullivan III Organizational Unit Name: TR Mun Srvs CDC Code: 0008888 330 S. 31St Street BlU: E0 Group: 09 Level: 08 Camp Hill, PA 17011 FWTMatital Status: S No. Exemotions / Allowances: 00 GROSS EARNINGS YEAR TO DATE 98,466.25 NET PAY THIS PAY PENNSYLVANIA STATE EMPL GU 713,47 713.47 DEDUCTIONS THIS PAY YTD Federal Wimholging Tax 388.27 6,448.18 TX EE Social security Tax 134 94 2.385.03 TX V M801cars Tax 31.96 557.79 Stele Wdhholding•Pannsylvania ee.82 1,191.00 Local Wage Tax-Camp H01 Borough 43.53 492.84 TX EE Unemployment Tax 196 34.52 Garnish: Alimony/Support 554.92 11,788.86 Sense EE Bonds 28,00 450.00 State Emp Rat 136.03 2.404,$9 REIMBURSEMENTS THIS PAY YTD EARNINGS HOURS RATE AMOUNT Normal working hours 75.00 29.02 2,176.50 TOTAL EARNINGS EMPLOYER PAID BENEFITS THIS PAY TX ER Sxlal 5eourI1y Tax 134.94 TX ER Medicare Tax 31.56 ER Bask Life 4.79 State Emp Ret 31,12 A ENCE CTIVITY _ Annuitant MW Hospital 20450 ?G - ??"r ER Workers Comp Benefit 49.38 Accrual This PP PR Capital Blue Cleve 270.00 Abse ee Reported This PP Adustment Quota Title Sunni FWT Taxable Grass: 2,040.47 17 YR 21 PP SENIORITY INFORMATION 0.00 0.00 0.05 5.78 3.75 0.00 0.00 0,00 0.001 32557 409.47 17.00 331.35 413.22 17.00 Contact your IQwI Human Resources Office if you have am/ questions regarding the conlem and distfl0u0on Oryeur Employee Pay Statement 2000 STATEMENT ofACCOUNf For. PATRICK T SULLIVAN Your statement contains three sections: SECTION I: BASIC DATA SECTION 11: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 2000 SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT SECTION I: BASIC DATA Personal Data Social Security Number: - 168-54-7128 Sex: - - MALE Birth Date: 28-DEC-1860 Coverage Type: FULL Contr ibution Rate: 5.00% Counseling Center:. - HARRISBURG Normal Retirement Date: 28-DEC-2020 Final Average Salary: $38,951.21 2000 Retirement Covered Earnings: $39,812.62 Total SSI Non-Covered Earnings: Joint Coverage Conversion Amount: Mandatory Debt: Service Credit as of Dec. 31, 2000* Class Years of Service Class Years of Service A-BO 13.0000 TOTAL SERVICE 13.0000 Account Balance Regular Contributions SSI Contributions Dec. 31, 1999, Balance $24.110.78 Contributions $1,990.66 Lump Sum Payments Arrears Payments Credited Interest $1,003.94 YTD Adjustments*** Dec. 31, 2000, Balance $27,105.38 . TOTAL DEDUCTIONS $27,105.38 Arrears Balance as of Dec. 31, 2000 Regular SSI Taxable Breakdown of Your Account**** Taxable Contributions $21,208.19 Pre 87 Non-Taxable Contributions Post 86 Non-Taxable Contributions Credited Interest (Taxable) $5,897.19 Dec. 31, 2000, Balance $27,105.38 ** Vfyou are eligible to purchase creditable state and/or non- state service, contact your Retirement Counselor for information "on purchasing service. All requests to purchase service must be flied while you are an active, contributing member. ** Information filed on a Nomination of Beneficiary(ies) form before 1993 or since Dec. 31, 2000, or involving special circumstances (such as the designation of an estate or trust as your beneficiary) may not appear. 4 maximum of 10 beneficiaries may be shown here, however, you may have more beneficiaries in your retirement record. Keep your beneficiary nomination current. You may change your beneficiary nomination at any time by filing a new Nomination of Beneficiary(les) form with SEAS. Forms are available from your agency Personnel Office or your regional SENS Retirement Counseling Center. Please contact us if you do not want your beneficiary(ies) listed on future Statements. ***YTD (Year-To-Date) Adjustments reflect corrections your account for which you already have recet notification. ****SERS is a defined benefit plan under Internal Revel Service Code Section 401(a). SPECIAL CONDITIONS The following Special conditions apply to your estimates or estimates were not calculated: If you received projected estimates last year, they may be lower thisyear -because your Retirement Covered Earnings are lower this year., SECTION II: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 2000 -is section provides an estimate of your Monthly Pension ly if you have at least 10 years of credited service or you ve reached your Normal Retirement Date and have at least •ee years of credited service. . Maximum Single Life Annuity (MSLA) onthly Pension - - 1266.95 xuwulated Deductions $27.105.38 Option 1 onthly Pension 261.50 esent Value - $60.714.62 Option 4 (Adjusted for withdrawal of Accumulated Deductions) - - Ijusted MSLA Monthly Pension 147.77 ijusted Option I Monthly Pension $144.81 ijusted Present Value Under Option 1 $33 609.24 Disability Retirement onthly Pension (if you qualify) $1,081. s8 Death in State Service $60.714.62 SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT DATE This section provides Monthly Pension estimates, projected to your Normal Retirement Date, fyou have at least 10 years of credited service. Estimates are provided for the same options as listed under Section 11. Normal Retirement Date: 28-DEC-2020 Maximum Single Life Annuity (MSLA) Monthly Pension $2, 251.07 Accumulated Deductions - $119.789.60 Option 1 [Present onthly Pension - $2,043.81 Value $354,.737:76 Option 4 (Adjusted for withdrawal of Accumulated Deductions) Adjusted MSLA Monthly Pension $1,490.92 Adjusted Option I Monthly Pension $1,353.65 Adjusted Present Value Under Option 1 $234,948.16 IMPORTANT INFORMATION • Benefit Estimates are provided for: • Maximum Single Life Annuity (also known as Full etirement Allowance) Monthly Pension payment ade to you for life; benefciary(ies) receive(s) ccumulated Deductions, less Monthly Pension tyments you received and any lump sum you received . ider Option 4. • Option 1 - Monthly Pension payment made to you r life; beneficiary(ies) receive(s) Present Value, less lonthly Pension payments you received and any lump im you received under Option 4. • Option 4 - At retirement, you may withdraw an nount equal to all or any part of your Accumulated eductions. You may elect to receive this withdrawal in ) to four installments. If you elect this option, you must so elect a Monthly Pension payment plan. • Disability Retirement - You must have at least five ears of credited service (except State Police and iforcement Officer-category employees, who have no inimum service requirement) and be certified by SERS a.liral Fvaminore ae nhvciral hr nr mrntally inranahla your Accumulated Deductions if you take Disability Retirement. • Death in State Service - If you are vested and die while an active employee, it will be assumed you retired under Option 1. the day before your death. The Present Value of your annuity will be payable to your beneficiary(ies). If you are not vested, . your Accumulated Deductions will be payable to your beneficiary(ies). • Benefit Estimates assume: • Your future earnings will be the same as in 2000. • You continue in your present class of service as a full-time employee. Retirement tables and factors remain the same as those in use on December 31, 2000. • Any Arrears Balance will be paid (exception - those members who are currently vestees or in a furlough status). • Your earnings will not exceed the federal Social CPmirity favahla xvaan hacn affor In00 Kelley Blue Book - Trade-In Pricing Report - Chevrolet, Suburban BLUE BOOK TRADE-98 VALUE Pennsylvania • October 27, 2004 Equipment Air Conditioning Power Steering Power Windows Power Door Locks Tilt Wheel Cruise Control AM/FM Stereo Cassette Single Compact Disc Dual Front Air Bags ABS (4-Wheel) Leather Third Seat* Consumer Rated Condition: Fair "Fair" condition means that the vehicle has some mechanical or cosmetic defects and needs servicing but Is still in reasonable running condition. This vehicle has a clean title history , the paint, body and/or interior need work performed by a professional. The tires may need to be replaced. There may be some repairable rust damage. Trade-In Value List Your Car For Sale online $4,260 Trade-in Value is what consumers can expect to receive from a dealer for a trade-in vehicle assuming an accurate appraisal of condition. This value will likely be less than the Private Party Value because the reselling dealer incurs the cost of safety inspections, reconditioning and other costs of doing business. Page 1 of 1 http://www.kbb.com/kb/ki.dll/kw.ke.ur?kbb.PA;334205;PA043& 17104;+t&278;... 10/27/2004 4 J.H. Troup Inc.; Appraisers Property Description UNIFORM RESIDENTIAL APPRAISAL REPORT File No. 5502024 G, ::'3f Annraien. TMs v m...... ?_ ....... ..... --- ._ --- ` •+? , 'e[xi Location Urban X Suburban, Henri Predominant famiy housing Presort latlrse% laM USedtorge 1;p:< Sun III Over 76% ? 25-75% ?Under 26% ocoAarw/ a 10001 AGE IVrsl 1 One family 100 X? Not likely ? Likely Growth rate ? Rapid ? Stable ? Slow ? Owner Low 10 r 2-4 family ? In process i; Property values © Increasing ? Stable ? Declining ? Tenant 155 0 Rich 95+ Multi-family To: Demand/supply Shortage X? In balance ? Oversupply ? Vacant 11 '' Predominant " ^' , commercial Marketing time Under 3 mos. x 3-6 mos. Over 6 mos. Vecent lover 5%1 120 20-25 Note: Fae, and firs repel canpasidm of the neigltborlmpd are net apprsLSal factors. Neighborhood boundaries and characteristics: The ,rsI Of tM area of Game Hill east of 32nd Street letV.een Onestazl: and Dickensat Streets. reditfteftod. Facters that affect the marketability of the properties in the neighborhood (proximity to employment and amenities, employment stability. appeal to market, etc.l: 1139 SlIbleCt is located in a reside l area ancher 'es of similar style and neduat aseesel. Hass in the arras ate ma:erta;ro+ and All ocrxioied ?xvesieroes are essil accessible to the snihiect. ys':p Market conditions in the subject neighbprhopd (including support for the above conclusions related to the trend of property values, demand/supply, and marketing time .., such as data on competitive properties for sale In the neighborhood, description of the prevalence of sales and financing concessions, em.): Fnelpecties of this le and area sell tell without seller psi latexes: InLrydoxne are rot prevalent: at this I with o:ntentio al rates tams 9&. Project Informatlm Iw PADS (If applicable(--IS the developer/builder in control of the Home Owners' Association (HOAR Yes No 12;$: G:z Approximate total number of units in the subject project N/A Approximate total number of units for sale in the subject project - Describe common elements and recreational facilities: Dimensions 120' x 120' - Topography 7amac. level Site Area .33 Ayres Corner Lot Elyse ? No Size Aexage of area Specific zoning classification and description Residential Shape Apparel RRactacriculac ,11 Zoning compliance © Legal ? Legal nonconforming Wrandfathered use) ? Illegal ? No zoning Drainage Appears Adequate Highest & best use at Improved X? Present use ? Other use h.PI inn View SlAindemLAverage " Utilities Public Other Off-site Type Public Private Landscaping Averescle, of Area 'lk? Improvements Driveway Surface Asphalt Electricity x? 100 Pro Street Asphalt x? ? Apparent Easements None Arsealysef- Gas x? Curb/Gutter Qn¢ete x? ? Water x? Sidewalk El [I FEMA Special Flood Hazard Area El Yes x?No Sanitary Sewer x? Street lights El El FEMA Zone C Map Date 32/11/81 Storm Sewer X Alley FEMA Ma No. 420357 0001 B '.i Comments(apparent adverse easements, encroachments, special assessments, slide areas, illegal or legal nonconforming zoning, use, etc.): 11e2 ale ro aPParent advez a eaor eentS oY enecoactneltq. 'ect does net to lie in a FEVA des' ten flood ?. appear GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION BASEMENT INSULATION No. of Units 1 Foundation concrete, elm Slab No Area Sq. Ft. 1 B92 Roof ? No. of Stories 1.5 Exterior Walls Erase Crawl Space No % Finished o Ceiling Avea'.)e _ El Type(Det/AttJ Detached Roof Surface ocepeeition ]Basement Fun Ceiling Joist Walls Avexaze ? Design (Style) care, tffi Gutters &Dwnspts Yes Sump Pump Pb Walls Floor Nee ? ' ?11U:, E,asting/Proposed Eclat' Window Type Oahle Dampness ell E..idence Floor Cesar a None ? Age (Yrs.) 43 Storm/Screens Yes E] Settlement th j), idelce Outside Entry No unknown Effective Age lyrs.l ]5 .-.1--vi 14-1 IDFBfitat100 14o Elddene I' ROOMS Foyer Living Dinjn - Kitchen Den Family Rm. Rec. Rm. Bedrooms # Baths Laundr Other Area S .Ft. GG' Basement 1092 `2S Level 1 x 1 1 1 2 1 1,266 Level2 1 1 504 Oi:i %01 Finished area above grade contains 6 ROOMS: 3 Bedroomis - 2 Bath(s): 1,772 S uare Feet of Gross Living Area MENITIES CAR STORA GE INTERIOR I.... lals/eonditlon HEATING KITCHEN EQUIP. ATTIC Floors Nzcl Tile, Type 1? Refrigerator © None replace(s) # sane ?x Nona Walls el„st?r PaintAv Fuel oil Range/Oven [] Stairs tio ? Garage . x of care lu Trim/Finish wgod PPatnted/Ayn Condition Averarfe Disposal x Drop StaEck ? Attached 1+ Bath Floor c_mnc 1Yle Aver, COOLING Dishwasher ? Scuttle orch ? Detapnea J Bath Wainscot CEt-dame Tile/ferRea Central Yes Fan/Hood ? Floor ence ? Bull[-In EEI Doors r/hoecarke Other N7 Microwave ? Heated ool ? Carport Condition Washer/Dryer Finished Drivewa Additional features (special energy efficient items, Condition of the improvements, depreciation (physical, functional, and external), repairs needed. quality of construction, remodeling/additions, Inc.: Adverse environmental conditions (such as, but net limited to, hazardous wastes, toxic substances, etc.( present in the improvements, on the site. or in the immediate vicinity of the subject property: Pb edvezve ?^ ,.nwnral ¢editim5 uexa oTeetved at tine tine of im. Form 70 6-93 MCS, Richardson, TX 76081 (214) 699.7783 Page 1 of 2 Fannie Ma. J.H. Troup Inc., Appraisers UNIFORM RESIDENTIAL APPRAISAL REPORT File No. 5502324 ESTIMATED SITE VALUE ........................ = $ 40,000 Comments on Cost Approach (such as source of cast ESTIMATED REPRODUCTION COST-NEW OF IMPROVEMENTS: estimate, site value, square toot calculation and for HUD, Dwelling 1,772 Sq. Ft. @ S 47.35 = $ 83,904 ro' VA, and FmHA, the estimated remaining economic life of ;o:; &isalient 1,268 Sq. Ft. @ $ 12.30 = 15,596 the property): sue;.; [hilt-ins F'irplece etc = 5 760 , . . Gara9el $arport 352 Sq. Ft. @ $ 12.50 = 4.900 Sea Attadled 9retch Total Estimated Cost New ................. = S 109,660 Physical Functional External The Marshall a s.,i.ft Cost: Handbook vas used act an aid in Less >S t 0 o the cost mill li . amium !ia#ij Depreciation 16`9 = $ 16,449 Depreciated Value of Improvements ................. _ $ 93.2111 "As-is" Value of Site Improvements = S 3 500 INDICAT D VALUE BY COST APPROACH ............ _ $ 136 nl ITEM SUBJECT COMPARABLE NO 7 COMPARABLE NO 2 COMPARABLE NO 3 ri . . . 330 Saith 31st Street US N. 30th street 41 Cxartry. Club Road 859 Opuntsy Club ]toad `..' Address Lill Camp Hill Came trill Came Hill Proximit m Sub'so Mile 1 mile 1.5 Miles Sales Price e N A ->'; 8 n6,000 - -%' 8 140 000 "!o. 5 136 900 Price/Gross liv. Area 4 / 4 10311 5 73.22 f? Data and/or inspetip7 Steb Report KS/SIM peport tRS/Shag Rgni't Verification auto.. Public Records public Records public Recods Public Records VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION +14 Adjustment DESCRIPTION +H$ Ad'us vent DESCRIPTION +1-)$ Adjustment Sales or Financing ? CQrv deal a2 Conventional rnualtirsa7. Concessions :. None Yr.. 66 D.O.M. 2 D.O.M. Oat- of SaleTime ` 0/3/94 8 894 9/30/94 Location SlAxtrtoitn/svera?ce Ave>- e Average Leasehold/Fee Simple Fee S' le Fee Simple Fee Simple Fee Simple Site 120' X 120' Cartes 55' x 120' 69' x 155' 90' x 215' View Residential Resid31tia1 Residential Residatial Design antl Appeal Care Cod/plivelexce Similar Similar Similar .' Chalk of C snuction Frame ariclizArate -1,500 B idr Average -1,500 aridc & FYare A -1 500 A e 43 46 55 43 Condition Above Grade Total Btlrms Baths Total Some Baths Total Odrms Baths Total Btlrms Baths V) Room Count 3 6 3 2 7 4 2 7 3 1.5 500 B 4 3 -11000 "'g' :: Gross Livin Area :i::'. 1,772 S q. Ft. 1,319 SO. Ft. +3.000 1.912 S q. Ft. -1,500 1,494 S q. Ft .2 500 ' `Z;i Basement & Firub-tl Pull Baserri Full 2stattenr Full Baserent Fall Basement: Rooms Below Grade Dtfimshed Fanil • Front -2 Soo Family Pool -2 500 [Minisbed , Functional Utility {?;9 i;rft;!i Hearin /QOO in 03f3FW GA FWA/M Cos , f(A GFWM Find Efficient items :S So= Huts Similar Similar Similar I:aili Gare a/Car art 1 (3r CaracIP F}3M 1,500 1 Carport 1,000 2 (3r Ggrage -11000 s : Porch, Patio, Deck, oi 'i Average similar similar similar Fire lece(sl etc. 1 Store F' lea' 1 Brick Fireplace 2 Elrir3c Fireplaroa -1,000 2 Brick rireplivoe -1, me Fence Pool, etc. Averace Similar Similar Similar Net Ad'. (mall + - 3 500 + x - e -5 000 + X - 5 -2 000 Adjusted Sates Price % .. ''- [7et$ ::0 & ;i, '._ NBC' '3 6"! -3l',$ 1 5 of Comparable .:. ? 136 500 : $ 134,900 Comments 0. Sales Comparison (including the subject property's compatibility to the neighborhood, etc.): All sales are elated traoSections. All sales are considered avelege llrlita of Value airs eicilated ecittany in t]Y final rENCilation. } I 1 1 IT M SUBJECT COMPARABLE NO. I COMPARABLE NO. 2 COMPARABLE NO. 3 Dead Ta)c Assessment Office lax Aes?snmt Office Tmc Assesstmt. Office Date, Price and Data Source for prior sales Public Records Public Records Ptb].ic Rets>t$ iablic Records within year of appraisal Analysis of any current agreement of sale, option, of listing of the subject property and analysis of any prior sales of subject and comperables within one year of the date of appraisal: INDICATED VALUE BY SALES COMPARISON APPROACH ......................... . .................... $ 135 coo INDICATED VALUE BY INCOME APPROACH lit Applicable) Estimated Market Rent 5 'Mo. x Gross Rent Multi her N/A = $ The appraisal is made X "as is" subject to the repairs, alterations, inspections or ronditlons listed below subject to completion per plans and specifications. Conditions of Appraisal The siblect appraised its present: edit Recane'd ycW infestationi cartificaticu. Final Reconciliation The purpose of this appraisal is to estimate the market value of the real property that is the subject of this report, based on the above conditions and the certification, contingent and limiting conditions, and market value definition that are stated in the attached Freddie Mac Farm 4391Fannie Mae Form 10048 (Revised 6/93 1. I (WE) ESTIMATE THE MARKET VALUE, AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OF THIS REPORT, AS OF 0 F'elxuary 27. 1995 (WHICH IS THE DATE OF INSPECTION AND THE EFFECTIVE DATE OF THIS REPORT( TO BE $ 135,00 APRNI56A: /' SUPERVISORY APPRAISER (ONLY IF REQUIRED) Signature j /! ( m Signature •_tt X?Did ?Did Not Name Cain. G. 91om; Assistant Appraiser Name JClm H Troup, M PA- RL 000001 L Inspect Property Date Rerun Signed FPlmt`N 27, 1995 Date Report Signed FeMtu^1 27, 1995 State Cenlflcation p N/A State State Certification if RL 000001 L State PA TX 75061 12141 699-7783 Page 2 at 2 Fannie Mae Form 1004 AGILITY CENTER Fax:7177050967 Oct 27 '04 1147 P.02 L'MYLUYbb 1'AY JIAIblKVIN1 Personnel No. 00x27663 Transportation Period Ending 08113/2004 Pay Date 0812712004 Patrick T Sullivan III Organlzallonal Unit Name: TR Mun Srvs CDC Cade: 0008888 330S.31St Street SIU: B3 Group: 09 Level: 06 Camp Hill, PA 17011 FWTMarRal Status: S No. Exemptions / Allowances: 00 GROSS EARNINGS YEAR TO DATE $6,468.25 EARNINGS HOURS RATE AMOUNT Normal working hours 75.00 29.02 2,176.50 NET PAY THIS PAY PENNSYLVANIA STATE EMPL CU 71$,47 TOTAL NET 713.47 DEDUCTIONS THIS PAY YTD Federal Withholding Tax 36827 0,446.16 TX EE Social Security Tax 1340d 2,385.03 TX EE Meaicare Tax 31.5a 567.79 Shale Withholding-Pannsylvanla 58182 1,181.00 Local Wage Tax-Camp Hill Borough 43.53 4g2.64 7X EE Unemployment Yas 196 34.52 Garnish: Allmon/Support 654.92 11,788.56 Series EE Bonds 28,00 450.D0 State Emp Rat 136.03 2.404,29 TOTAL DEDUCTIONS 1 ,48,9.03 25,739.99 ' REIMBURSEMENTS THIS PAY YTD TOTAL EARNINGS 2,176.50 TOTAL REIMBURSEMENTS SERVIC CK T 17 YR 21 PP E CPI EMPLOYER PAID BENEFITS THIS PAY SENIORITY INFORMATION TX ER Social Security Tax 134.94 TX ER MWicafe Tax 31.5a ER 9aslc Ufa 4.79 Slate Emp Pat 31'14 ABSENCE ACTIVITY ANNUAL SICK PERSONAL Annuitant RIM Hospital 204.00 Tl ER Workers Camp Benefit 48.39 p PP 0.00 0.00 0.00 PR CapiW Blue Crass 270.00 5.78 0.00 3.75 0.00 0.00 0.00 Adjustment 375.57 409.47 17.00 OUOta This Stninl 331,35 413,2.2 17.00 ? TOTAL BENEFITS 72S,4o gCCRUAL RATE: ANNUAL 7.70 % SICK 5.00 % s? ? FWTTasable Gyasa: 2,040.47 Contact your local Human Resources Office if you have any questions regarding the whtentand distribution arybur Employee Pay Statement DEBTS DATE INITIAL DEBT DOS VALUE INCURRED AMOUNT $85,169.00 1990 $90,000.00 (mortgage) $34,626.00 3/2000 $34,910.00 (home equity loan) $3,990.00 Revolving Visa loan PAYMENTS POST-SEPARATION $710.77 monthly $433.95 monthly k/p:divorce\psullivan.exh IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-6060 Civil CIVIL ACTION - LAW DIVORCE CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on October 28, 2004, I served a copy of the within Defendant's Pre-Trial Statement, by UPS Overnight, addressed as follows: E. Robert Elicker, II, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Street P. O. Box 168 Lemoyne, PA 17043 N. Second Street thouse Suite 0. Box 984 rrisburg. PA 17108 KIMBERLY A. SULLIVAN, Plaintiff V. PATRICK J. SULLIVAN, III, Defendant (717) FBIEDMAN & KING, P. C. ATTORNEYS AT LAW 600 N. SECOND ST. FIFTH FLooR P.O. Box 984 HARRISBURG. PENNSYLVANIA 17108 (717) 236-8003 TELEC3PIEE No. (717) 230-8080 friedm mndldng@hot=il.com RICHARD S. Fnr=m N JOHN F. xlxo November 22, 2004 E. Robert Elicker, II, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: I was reviewing the transcript from our Pre-Hearing Conference, and pursuant to that I am informing you that the two pages comprising Exhibit B in the Pre-Trial Statement are an exhibit that Mr. Sullivan intends to present relating to valuation of the 1987 Chriscraft Boat which was retained by his wife, along with the trailer. Thank you very much for your attention to this matter. Very truly yours, ,;o F. Kin Y /" I JFK/bp:corresaf\elicker2A.ltr cc: Patrick Sullivan Samuel L.AAndes, Esquire i. RRIEDMAN & KING. P. C. ATTORNEYS AT LAW 800 N. SECOND ST. FIFTH FLOOR P.O. BOX 884 HARRISBURG, PENNSYLVANIA 17108 (717) 238-8000 TELECOPIER NO. (737) 238-8080 Iriedmanandking@hotmail.com RICHARD S. FRIEDMAN May 25, 2004 Josh F. RING Cumberland County Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 In re: Kimberly A. Sullivan v. Patrick J. Sullivan, III No. 2000-6060 Civil Dear sir or madam: Enclosed herewith for filing please find an original and a copy of the Inventory of Patrick J. Sullivan, III. After filing, please return the time stamped copy to me in the enclosed self- addressed stamped envelope. Thank you. Very truly yours, John F. King JFK/bp: corresaflcumbco2.ltr Enclosures cc: Patrick J. Sullivan, III Samuel L. Andes, Esquire E. Robert Elicker, Divorce Master FBIEDMAN & KING, P C. ATTORNEYS AT LAW 600 N. SECOND ST. FIFTH FLOOR P.O. Box 984 HARRISBURG. PENNSYLVANIA 17108 (717) 230-8000 TELECOPIEB NO. (717) 200-8080 friedmanandldng@ho=il.com RICWA D S. FRIEDMAN J°ax F. KING October 28, 2004 UPS OVERNIGHT E. Robert Elicker, 11, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: Enclosed herewith please find a copy of the Defendant's Pre-Trial Statement which I will be filing with the Prothonotary's office on Monday, November 1, 2004. Thank you very much for your attention to this matter. JFK/bp:corresaf\elicker2.ltr Enclosure cc: Patrick Sullivan Samuel L. Andes, Esquire (UPS Overnight) RRIEDMAN & KING, P. C. ATTORNEYS AT LAW 800 N. SECOND ST. FIFTH FLOOR P.O. BOX 984 HARRISBURG, PENNSYLVANIA 17108 (717) 236-6000 TELECOPIEE NO. (717) 236-6080 fded=mndking@hotmeil.com RICHARD S. FHIEDMAN JoHN F. Emu - E. Robert Elicker,11, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 August 19, 2004 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: I ain following up on a telephone conversation that I had with Tracy of your office a couple of weeks ago. During that conversation, she had suggested that I file on behalf of my client a Pre-Trial Statement so that you could schedule a Pre-Hearing Conference and determine at that time whether there was any discovery which needed to be performed. You will recall in this case that the Plaintiff, Mrs. Sullivan, never did file an Inventory. I was in Jamaica the last week of July and I have just been able to leave a message with my client (who is in Washington, D.C.) by way of his cell phone. His work responsibilities have required him to travel recently. I informed Mr. Sullivan he should call for an appointment early next week. I shall submit our Pre-Trial Statement immediately after our meeting.. Thank you very much for your attention to this matter. JFK/bp:corresat\e1icker2.ltr ry truly yours, /O ?Q ` F / J F. Kin cc: Patrick Sullivan Samuel L. Andes, Esquire SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P.O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761-5381 8 June 2004 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Kimberly A. Sullivan vs. Patrick J. Sullivan, N No. 2000-6060 Civil Term in Divorce Dear Mr. Elicker: FAX (717) 761-1435 Enclosed you will find a Pre-Trial Statement which I file on behalf of the Plaintiff in the above matter. I have, this day, sent a copy of this to Mr. Sullivan's attorney so that he can prepare and file his Pre-Trial Statement promptly. Sincerely, C5dQ/? 1/f : W emn Samuel L. Andes amh / Enclosure cc: John F. King, Esquire Kimberly A. Sullivan MAY-24 04 16:29 FRDM:FRIEDMAN 8 KING 2366080 T0:7172407890 PRGE : 03 ? p KIMBERLY A. SULLIVAN, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND CCUNT'Y, PENNSYLV.ANYA vs. NO. 00 - 6060 CIV.T.L PATRICK J. SULLIVAN, III,: Defendant IN DIVORCE TO: Samuel L. Andes John F. King , Attorney for Plaintiff , Attorney for Defendant DATE: Thursday, May 6, 2004 CERTIFICATION OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether, there are any outstanding interrogatories or discovery motions- defendant re5pect.fully requests the Master direct the Plaintiff to :file heT Inventory as required by Pa.. R,I:.P. 1920.33(a), so as to allow Lk:fendant to formulate his Interrogatories and Iik,,quest for Production of Documents. MAY-24 04 16:29 FRDM:FRIEDMRN 8 KING 2368080 TO:7172407890 PRGE:04 (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Defendant, through coiuisel., will serve Interro);at.oi'ieS and Request for PTOiUCti.01). Of :DoCLonc.nts upon Plaintiff irsedi.ate'.ly upon receipt of Plai.ntiff'S Inva*.ntory, S/24/D4 DATE OU SEL FOR PLA ,FNT FF ( ) CO SEL FOR DE E ANT (-XX) NOTE: PRETRIAL DIRECTIVES WILL NOT BE: ISSUED FO.R, THE FIT-INC OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR. OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT 'REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIREC'T'IVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THF.. MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIE"Y THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL S'TATEMENT$ WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. FRIEDMAN & KING, P. C. ATTORNEYS AT LAW 800 N. SECOND ST. FIFTH FLOOR P.O. Box 884 HARRISBURG, PENNSYLVANIA 17108 (717) 838-8000 TELECOPIEE NO. (717) 288-8080 Eriedma ndldng@hotmail.com RICHARD S. FBIEDMAN JOHN F. Klxo May 20, 2004 FAX TRANSMISSION and FOLLOW UP COPY BY MAIL E. Robert Elicker, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: I am in receipt of your Certification of completion of discovery in the above- captioned matter. Please be advised that I will be meeting with my client, Patrick Sullivan, on Monday, May 24, 2004. I will forward the Certification immediately thereafter. Thank you very much for your kind attention to this matter. JFK/bp:corresaflelicker.ltr cc: Patrick Sullivan Samuel L. Andes, Esquire (by fax and mail) MAY-20 Oq 15:18 FROM:FRIEDMRN 8 KING 2368080 TO:7172407890 PRGE:02 F RIEDMAN & KING. P. C. ATTORNEY'S AT LAW ecio N. S'acoND ST. FIrTH: FLOOR P.O. Box 969, .Tf.IARRISDrr,RO. PENNSYLVANIA 17108 X717) B08-R000 Tute(NnPTVV No. )917) 200.0060 fdcdmjwndking%6? m-Tcnm RICHARD S. F.HXPDMAN JOHN F. Rlio May 20, 2004 .PAX TRANSMISSION and FOLLOW UP COPY BY MAIL E. Robert Eticker, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v, Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elic.ker: I am in receipt of your Certification of completion of discovery in the above. captioned matter. Please be advised that I will be meeting with my client,.Patrick Sullivan, on Monday, May 24, 2004. 1 will forward the Certification immediately thereafter. Thank you very much for your kind attention to this matter. b'ety,trulyy©uks, l / Vn 1 Jelin f. King JFK/bp:corresaAelicker,ltr , I l cc: Patrick Sullivan Samuel L. Andes, Esquire (by fax and mail) SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761-5361 12 May 2004 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE.• Kimberly A. Sullivan vs. Patrick J. Sullivan, X No. 2000-6060 Civil Term in Divorce Dear Mr. Elicker: FAX (717) 761-1435 Enclosed is my Discovery Certification in the above case. I have, this day, sent a copy to John F. King, Esquire, who represents the Defendant. Sincerely, I L. Andes amh / Enclosure cc: John F. King, Esquire Kimberly A. Sullivan + J KIMBERLY A. SULLIVAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, III,: Defendant IN DIVORCE TO: Samuel L. Andes John F. King , Attorney for Plaintiff , Attorney for Defendant DATE: Thursday, May 6, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline w nformation is requir at is not complete in orde ire e case for trial and indicate whe e e any outstanding intern ies or discovery mo 1 i r (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Discovery is ccoplete except for information which will be required prior to the hearing to update the value of assets and incomes and expenses of the parties. 5/12/04 DATE r C EL FO PLAIN IFF ( ) COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. MAY-24 04 16:29 FROM:FRIEDMRN & KING 2366060 TO:7172407890 PRGE:02 FRIEDMAN & KING, P. C. ATTORNEYS m, LAW 800 N. SECOND ST. FIFTH FLOOR P.O. Box e84 AA'RRISBU13% PENNSYLVANIA 17100 17»I ean•uooo i r.?.r.Cnv.ren No. Urrl 206,090 hied manandki ngghormad x.m Rimmko S. FRIEDMAN JOHN F. Kiwe) May 24, 2004 FAX TRANSMISSION and FOLLOW UP COPY BY MAIL E. Robert Elicker, Divorce .Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: Enclosed herewith please find the Certification regarding the above captioned matter. JFK/bp: corresaFle.licker2.ltr Enclosure CC; Patrick Sullivan Samuel L. Andcs, Esquire (by fax and mail) x KIMBERLY A. SULLIVAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00 - 6060 CIVIL PATRICK J. SULLIVAN, III,: Defendant IN DIVORCE TO: Samuel L. Andes John F. King , Attorney for Plaintiff , Attorney for Defendant DATE: Thursday, May 6, 2004 CERTIFICATION OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. Defendant respectfully requests the Master direct the Plaintiff to file her Inventory as required by Pa. R.G.P. 1920.33(a), so as to allow Defendant to formulate his Interrogatories and Request for Production of Documents. AA (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Defendant, through counsel, will serve Interrogatories and Request for Production of DocLmients upon Plaintiff immediately upon receipt of Plaintiff's Inventory. 5/24/04 DATE NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. F$IEDMAN & KING, P. C. ATTORNEYS AT LAW 600 N. SECOND ST. FIFTH FLOOR P.O. Box 984 HARRISBURG. PENNSYLVANIA 17108 (717) 238-8000 I LECOPIEE No. (717) 236-8080 friedmanandking@ho=ail.com RICHARD S. FRIEDMAN JOHN F. KING May 24, 2004 I FAX TRANSMISS)[ON and FOLLOW UP COPY BY MAIL E. Robert Elicker, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 i In re: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: Enclosed herewith please find the Certification regarding the above-captioned matter. it JFK/bp: corresaflelicker2.ltr Enclosure cc: Patrick Sullivan Samuel L. Andes, Esquire (by fax and mail) SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 T=PBONH (717) 781-5361 F9 27 August 2004 (717) 751-1435 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE.• Kimberly A. Sullivan vs. Patrick J. Sullivan, A/ No. 2000-6060 Civil Term In Divorce Dear Mr. Elicker: I believe you have been sufficiently patient with Mr. King and with Mr. Sullivan and given them more than adequate additional time to file their pre-trial statement. I believe that, if you will schedule a pre-hearing conference, that may provide the incentive for them to complete the process and get their pre-trial statement filed. I am concerned that, until there is some clear deadline, we will not see that document and the case will simply languish without progress. If you will schedule a pre-trial conference in thirty days or so, that should give Mr. King adequate time to file what he must so the case can proceed. Sincerely, I L. Andes amh cc: John F. King, Esquire Kimberly A. Sullivan s .11RIEDMAN & KING, P. C. ATTORNEYS AT LAW 600 N. SECOND ST. FIFTH FLOOR P.O. Box 984 HARRISBURG, PENNSYLVANIA 17108 (717) 238-8000 T=COPIER NO. (717) 238-8080 friedm ndlang@hotmil.com RICHARD S. FRIEDMAN JOHN F. lrING August 2, 2004 E. Robert Elicker, II, Divorce Master Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 hire: Sullivan v. Sullivan No. 00-6060 Civil in Divorce Dear Mr. Elicker: T am writing in response to correspondence which was directed to you dated July 22, 2004 from Attorney Andes, representing Kimberly A. Sullivan. As your file will indicate, I represent the Defendant in the above-captioned divorce matter, Patrick J. Sullivan, III. I apologize for not writing you earlier, but I just returned from a trip out of the country. Mr. Andes has raised several issues which I would like to take this opportunity to address, as follows: 1. Mr. Andes correctly indicates that you are appointed Master in the above matter, pursuant to Mr. Andes' filing of a "Motion for Appointment of Master" on or about April 19, 2004. 2. Mr. Andes is correct that both parties filed Certifications shortly thereafter. In those Certifications, Mr. Andes certified that discovery is complete as to the claims for which the Master has been appointed (distribution of property). However, contrary to Rule 1920.33, the moving party, Kimberly A. Sullivan, had not filed an Inventory as required by that Rule of Court. I did indicate that deficiency in the Certification that I filed on behalf of my client on or about May 25, 2004. .tee E. Robert Elicker,11, Divorce Master August 2, 2004 Page 2 3. Mr. Andes correctly indicates that he has filed a Pre-Trial Statement. However, Pennsylvania Rule of Civil Procedure 1920.33(b) directs that a Pre-Trial Statement shall be filed within the time required by directive from the Master, or, if none, at least 60 days before the scheduled hearing on the claim for the determination and distribution of property. I do not have in my possession a directive from the Master requiring the filing of a Pre-Trial Statement, nor have I received a hearing notice. As indicated above, the procedures which are laid out in the Pennsylvania Rules of Civil Procedure have not been followed in this case. Although the Defendant, through counsel, has filed his Inventory, none has been filed by the moving parry. After dictation of the above, I was working through my voice messages, and returned a call from Tracy. Pursuant to that call, I will contact my client, and request he come in to prepare a Pre-Trial Statement for filing. Thank you for your attention to these matters. 7FK/bp:corresaf\elicker2.ltr cc: Patrick Sullivan Samuel L. Andes, Esquire JULY 23, 2004 LEFT MESSAGE FOR JOHN KING ASKING THAT EVEN THOUGH THERE WAS NEVER A DIRECTIVE FOR PRETRIALS THAT COULD HE PLEASE FILE A PRETRIAL STATEMENT (MR. ANDES FILED ONE) 50 THAT I COULD SCHEDULE THIS FOR A PRE-HEARING CONFERENCE. il-ld 51pmcc 4cpp ? k ?04? ?Y Lk i SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761-5361 22 July 2004 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Kimberly A. Sullivan vs. Patrick J. Sullivan, N No. 2000-6060 Civil Term in Divorce Dear Mr. Elicker: FAX (717) 761-1435 You were appointed Master in the above matter in May. Both parties filed discovery certifications shortly thereafter and the Defendant, by his attorney, claimed that he would file Interrogatories and Requests for Productions of Documents. To date, the Defendant has not filed any formal discovery requests, although he has filed an Inventory. I filed my pre-trial statement on 6 June 2004. I am afraid that we are never going to advance this case if we wait for Mr. Sullivan and his attorney to file their pre0trial statement or proceed with formal discovery. I think you have enough information before you that you can at least schedule and conduct the pre-hearing conference and we can address at that conference any remaining questions about the assets or information about them. I write to request that you schedule a pre-trial conference at the next available date so this case can proceed. The parties have been separated for more than four years and there is no reason for resolution of the matter to be delayed any longer. Sincerely, I L. Andes amh cc: John F. King, Esquire Kimberly A. Sullivan KIMBERLY A. SULLIVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. PATRICK J. SULLIVAN, III, Defendant CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT Plaintiff by her attorney, Samuel L. Andes, files this Pre-Trial Statement in accordance with Pa. R.C.P. 1920.33(b): 1. ASSETS. Attached hereto and marked as EXHIBIT A is a list of the marital assets as known to Plaintiff. Attached hereto and marked as EXHIBIT B is a list of the non-marital assets as known to Plaintiff. 2. EXPERT WITNESSES. At this time Plaintiff intends to call the following expert witnesses to testify on her behalf at any hearing: A. A pension evaluation expert to testify as to the increase in value of Husband's account within the State Employees Retirement System with the Commonwealth of Pennsylvania. B. A real estate appraiser to testify as to the increase in value of Husband's real estate at 330 South 3155 Street in Camp Hill. Plaintiff reserves the right to call such additional experts as may be necessary depending upon the witnesses the Defendant will call. 3. FACT WITNESSES. At the present time Plaintiff intends to call herself as a fact witness. She reserves the right, however, to call such additional fact witnesses as may be appropriate to respond to Defendant's case. 4. EXHIBITS. At this time Plaintiff plans to offer into evidence the following exhibits: A. An appraisal of Defendant's account within the State Employees Retirement System and its increase in value during the marriage. Page 1 of 6 B. Statements for an account which Husband and his mother hold in their joint names from a time near the date of marriage and a time near the date of final separation. C. Copies of statements and other documents relating to accounts in Husband's name with PSECU. D. Statements showing balances owed on mortgages and other liens against Husband's real estate at various dates including the date of marriage and the date of separation. These documents will also probably include documents relating to refinancing various of these obligations during the marriage. E. Documents relating to Husband's purchase and sale of various motor vehicles, motor cycles, boats, and other tangible assets during the marriage. F. Copies of paycheck stubs, tax returns, bank statements, and various other financial documents which reflect other assets of the parties and their incomes and expenses. 5. INCOME STATEMENT. Attached hereto and marked as EXHIBIT C is Plaintiff's Income and Expense Statement. 6. EXPENSE STATEMENT. Attached hereto and marked as EXHIBIT C is Plaintiff's Income and Expense Statement. 7. PENSION INFORMATION. Defendant is employed by the Commonwealth of Pennsylvania and a participant in SERS. His account within that system increased significantly in value during the marriage and Plaintiff will present a report or, if necessary, live testimony of her expert witness to confirm the increase in value of that account during the marriage. Plaintiff has no pension herself. 8. COUNSEL FEES. Plaintiff is represented by Samuel L. Andes and will present information at the hearing regarding the extent of his services and fees and the costs of his services. 9. PERSONAL PROPERTY. Most of the household furnishings and other tangible personal property used by the parties during the marriage was pre-marital. The few marital items have been divided by the parties and Plaintiff does not expect there to be further testimony about them. 10. MARITAL DEBTS. There are no marital debts of any significance known to Plaintiff. Page 2 of 6 1 1. PROPOSED RESOLUTION OF ECONOMIC ISSUES. Plaintiff proposes that the increase in value of Defendant's SERS pension, Plaintiff's tax deferred savings plan, and Husband's account with Waterhouse Securities be divided so that she receives 55% of those items. If that can be accomplished, she is willing to waive claims for the equitable distribution of the remaining assets. Sa L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 Page 3 of 6 EXHIBIT A MARITAL PROPERTY DATE OF MARITAL AMOUNT ASSET VALUE VALUATION PORTION LIENS OF LIEN Increase in value during the Unknown June 2000 100% Unknown Unknown marriage of Husband's pre- marital real estate and residence at 330 S. 316` Street, Camp Hill, PA Increase in value during the $25,915.00 June 2000 100% Unknown Unknown marriage of Husband's account in SERS Increase in value during the $4,400.00 June 2000 100% No liens marriage of Wife's tax deferred annuity with Travelers Insurance Increase in value in account $65,000.00' June 2000 100% No liens' held by Husband and his mother with Waterhouse Securities Husband's 1997 Chevrolet $15,000.00 June 2000 100% No liens' Suburban automobile Husband's 1984 Harley $10,000.00 June 2000 100% No liens Davidson FLT motorcycle Husband's one-third $5,000.00 June 2000 100% No liens interest in Sail Boat A jointly owned 1987 $2,400.00 June 2000 100% No liens Chriscraft 17 ft motor boat, presently in Plaintiff's possession Household furnishings in Negligible June 2000 100% No liens possession of Plaintiff i Defendant has not produced complete information about this account from which the exact date it was created or the value at the date of separation can be determined. However, from the information which has been provided, it appears that the account had a value at the end of April 1997 of $3,035.00 and a value at the end of June 2000 of $68,640.04. Plaintiff believes that most, if not all, of the contributions to the account during the marriage of the parties were made by Husband and not by his mother. z 3 The purchase price for this vehicle was paid in full from the proceeds of a home equity loan taken against the marital residence by Husband shortly before the parties' final separation. Page 4 of 6 Household furnishings in I Negligible I June 2000 100% No liens possession of Defendant Page 5 of 6 EXHIBIT B NON-MARITAL PROPERTY ASSET VALUE DATE OF REASON FOR LIENS AMOUNT OF LIEN VALUATION EXCLUSION Defendant's equity Unknown September 1995 Husband owned the First mortgage Approximately in his residence at residence prior to $70,000.00 330 S. 31" Street the date of in Camp Hill on the marriage date of marriage Value of Husband's Unknown September 1995 Husband owned the No liens N/A account within account prior to the SFRS prior to date date of marriage of marriage Value of Wife's tax $6,977.83 September 1995 Owned by Wife No liens N/A deferred annuity prior to date of with Travelers marriage Insurance prior to date of marriage Each party's pre- Unknown September 1995 Owned by each No liens N/A marital furniture party prior to date of marriage Page 6 of 6 I KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE PLAINTIFF'S INCOME AND EXPENSE STATEMENT INCOME Plaintiff is employed by Capital Blue Cross and her earnings, and tax and other deductions, from that employment are as follows: Gross Earnings (every two weeks) $2,005.97 Less: Federal Income Tax $311.62 Social Security Tax $136.89 Medicare Tax $37.53 Pennsylvania Income Tax $67.78 Local Income Tax $22.29 Total Taxes $576.11 Total net income every two weeks $1,429.86 Attached hereto and marked as Exhibit A is a copy of a recent paycheck stub confirming that income. EXPENSE Attached hereto and marked as Exhibit B is a listing of Plaintiff's typical average monthly expenses. 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: KIMBERLY A. SULLIVAN var., Kimberly 501 REGULAR 50 PTO HOLIDAY HIPP s.V1 13272.25 EEBHD2 25.00 175.00 2.89 1188.58 EAA .2 1.75 643.79 FITTAX 311.62 3341.64 5589.48 MMBGTX 37.5 349.68 HI 32.01 298.24 PA TAX 67.7 631.46 PAUCEE 2.0 18.62 OASDI 136.89 1275.24 VEHCLE 40.0 240.00 SUSOPT 10.00 SUPIHS 53.76 TOTAL GROSS WAGES 2228.861 20694.10 1 ESP401 HI DML VISION ??o??r2 0 0 PTO EARMED PTO BAL 133.73 906.29 15.15 90.90 5.81 34.86 2074.17 PAID TIME OFF 4.0500 83.10 19662.05 DISABILITY $1421.0 DIRECT DEPOSIT NO. 03/26/2004 ?; Capital BulueCr®ss An Independent Licensee of the Blue Cross and Blue Shield Association ® 2600 Elmerton Ave. Harrisburg, Pa. 17110 EC2482 Kimberly A Sullivan 817 Allenview Drive Mechanicsburg PA 17055 ACCOUNT HUMBER DESCR. og NOWNEGOTIABILE 192522732 HET CHK 1,44221 1.09 EXPENSE STATEMENT WORKSHEET Please complete this document as best you can by listing, the average monthly expense for each item. EXPENSE MONTH HOME Mortgage/Rent 463.84 Electric 117.00 Telephone 70.00 Trash 8.85 Water 24.00 Sewer 25.00 Other 200.00 EMPLOYMENT Lunch 50.00 TAXES Real Estate 101.03 Personal Tax .82 INSURANCE Homeowners 18.33 Automobile 55.00 Dental / Vision 20.96 AUTOMOBILE Payments 283.19 Fuel 80.00 Repairs/Maintenance 20.83 MEDICAL Doctor 4.16 Medicine 8.33 Special Needs (glasses, braces, orthopedic devices) 8.33 EDUCATION Parochial School 166.00 PERSONAL Clothing 75.00 Food 250.00 Barber/Hairdresser 115.83 Credit Payments: Credit Card Charge Account 250.00 Memberships 33.00 MISCELLANEOUS Child Care 83.33 Papers/Books/Magazines 6.00 Entertainment 100.00 Pay TV 67.00 Vacation 83.33 Gifts 12.50 Charitable Contributions 25.00 OTHER Home Owners Association Fee 73.66 Cheer Tyme 50.00 Soccer 12.50 Skiing 33.30 TOTAL EXPENSES $2996.12 ^.f U7 m -J nr c? (P '?".; • Y C " q Y v ? CY) X = Z m ZC? 5D? () Z D c°(l) c m r- D Z o v Ul cn H Z m o A C_ y<v ? 1 (n t w' C V _> W M oA bit ca 64 ?A¦ t• ?jC-CO n6 s pec?a?)in ?() 4 t3 ca,e. pfror 4o ff"?.?, ?dGS _ /Uo? Scnnr?? . 1-1 ?jnys der ! , IPIC? fare are Sca r,??p? ti acknowledge that such funds shall be held and distributed strictly in accordance with this Stipulation and the Order to be entered pursuant to this Stipulation. 3. The parties have agreed upon the distribution and division of all of their marital assets. Husband shall retain all of those assets currently in his possession or titled or held in his name (including, without limitation, his residence at 330 South 315` Street in Camp Hill, his benefits within the Pennsylvania State Employees Retirement System, f is interest in an investment account he holds with his mother with TD Waterhouse Comuany and a 1997 Chevrolet Suburban automobile) and Wife hereby waives and releases ?ny claims to or interest in such assets. 4. The parties have agreed upon the distribution and division of ?li of their marital assets. Wife shall retain all of those assets currently in her possession or titled or held in her name (including, without limitation, Wife's 401 (k) Plan accrued while she was employed with Pinnacle Health, Wife's Pinnacle Health pension benefits, and a 1987 17?foot Chris-Craft boat with trailer) and Husband hereby waives and releases any claims to or in?erest in such assets. 5. Husband represents to Wife that the debts which encumber hislresidence at 330 South 315` Street in Camp Hill are in his name alone and that Wife has no liability on those debts. Each of the parties represents that there are no other debts or obligations created by either of the parties for which the other party may be liable and each of the parties agrees to pay and satisfy, in accordance with their terms, any debts or obligations currently owed by them individually and indemnify and save the other harmless from any loss, cost, or expense, including reasonable attorney's fees, which may result from their failure to?pay and satisfy such debts and obligations. 6. Effective upon Husband's payment to Wife as required by Paragraph 1 hereof, each of the parties hereby waives any further claims against the other party arising out of their i marriage or the Pennsylvania Divorce Code, including, without limitation, any claims for alimony, alimony pendente lite, or counsel fees and expenses. 7. In the event that either party breaches this agreement or fails to perform their obligations hereunder, they shall be responsible to pay any attorneys fees or other costs reasonably incurred by the other party in enforcing their rights hereunder. a 8. The parties agree that the Order attached to this Stipulation shall be entered by the Court of Common Pleas of Cumberland County to adopt and enforce this agreement between the parties. They further agree that the terms and provisions of this agreement shall not merge with any subsequent divorce decree entered between them. IN WITNESS WHEREOF the parties and their counsel have set their hands and seals this ?? day of fif V-) 2005. Kimberly 7 Sulliv n 4Z 4 S uel L. Andes Attorney for Plaintiff Patrick r,Y?. Sul04n, III r 0 F. King iev for N ('_ v . T ? ?? t :: ', _ f 'n ?7 , _' CGS JC7 r: _ 'i, C`J f :fit r -i r.? T:1 -ti ?.? 1-r RECEIVED APR 1 11Q05? L\ KIMBERLY A. SULLIVAN, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW ) NO. 2000-6060 CIVIL TERM PATRICK J. SULLIVAN, III, ) Defendant ) IN DIVORCE ORDER OF COURT AND NOW, this day of '4"P WI 2005, based upon the stipulation of the parties which is attached hereto, we hereby order and decree as follows: 1. The Defendant, Patrick T. Sullivan, III, incorrectly identified in the caption in this matter as "Patrick J. Sullivan, III" (hereinafter "Husband") shall pay to the Plaintiff, Kimberly A. Sullivan (hereinafter "Wife") the sum of Thirty-Four Thousand ($34,000.00) Dollars before 5:00 p.m. on Friday, 6 May 2005. The payment shall be made by a certified check or by a check from his attorney delivered to Wife's attorney by that time. In the event that Husband fails to make such payment, the funds now held in escrow by his attorney, as described in the attached Stipulation, shall be immediately paid and delivered to Wife's attorney on noon the next business day and Wife shall be entitled to enforce the payment of the balance owed of Twenty-Eight Thousand (*$28,000.00) Dollars under all provisions of the law of Pennsylvania, specifically including the provisions of the Divorce Code, and Husband shall be responsible to pay all fees, costs, and expenses incurred by Wife in her efforts to collect said debt. Notwithstanding the foregoing, if Husband pays to Wife the total sum of Twenty-Eight Thousand ($28,000.00) Dollars by 5:00 p.m. on May 6, 2005, such payment shall satisfy his obligation to make a cash payment to Wife under this Paragraph and Wife shall accept the total payment of Twenty-Eight Thousand ($28,000.00) Dollars as satisfaction of Husband's obligation to make cash payment to her under this Order. 2. The distribution and division of the parties' other marital assets, and the waiver of other claims by the parties, as set out in the attached Stipulation, are hereby approved and are incorporated into this Order. 91 .C 14d 1 1 (18V SON n?1+ Of "",)FL, 0: d ?ll4i 20 iii !0-?731V? 3. Upon Wife's receipt of the cash payments due pursuant to this Order, and upon the presentation of the appropriate documents to this court, we will enter a final decree in divorce between the parties. BY THE COURT, Distribution: muel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12`h Street, P.O. Box 168, Lemoyne, PA 17043 ixa ,,.ddfin F. King, Esquire (Attorney for Defendant) 600 North Second Street, 5th Floor, P.O. Box 984, Harrisburg, PA 17108 0q 11 KIMBERLY A. SULLIVAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM PATRICK J. SULLIVAN, III, Defendant TO THE PROTHONOTARY: IN DIVORCE PRAECIPE Please withdraw all economic claims filed in this matter by the Defendant, including any claims filed for equitable distribution, alimony, alimony pendente lite, or counsel fees and expenses. Date: 601 aw--7 n F. King Attorney for Defend t Supreme Court ID # j 600 North Second Street Harrisburg, PA 17101 ?i f._? ?s? (": " ; rt ,r ;- ?ti,a l? 4 7 1 t KIMBERLY A. SULLIVAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM PATRICK J. SULLIVAN, III, Defendant TO THE PROTHONOTARY: IN DIVORCE PRAECIPE Please withdraw all economic claims filed in this matter by the Plaintiff, including any claims filed for equitable distribution, alimony, alimony pendente lite, or counsel fees and expenses. Date: l M---' ?? !-T Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12`" Street Lemoyne, PA 17043 f' ?3 G? _V Y.7 CJ KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK J. SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 5 September 2000 and served upon the Defendant on or about 13 September 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. 1 consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and l participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,?"?t z?o S Date 4v( -,( /; (XZ'1? KIMB LY A. ULLIVAN 1..] r ?} f. .. `?i1 f; „ ? li . - ?? , ??? !. ? C : ` . 'l ? `? ? . -?? KIMBERLY A. SULLIVAN, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM PATRICKXSULLIVAN, Ili, ) Defendant ) IN DIVORCE kt? AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 5 September 2000 and served upon the Defendant on or about 13 September 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. 1 consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that 1 may request the Court to require my spouse and 1 to participate in counseling and, being so advised, do not request that the Court require that my spouse and 1 participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 1 understand that statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. l G S ,/ 1 j 4 Date PATRICK/.. SULLI AN, III ?, ?, -?, t,.,, 4:. `? ,.l _ ?. ?' _ _ _ t",lT .^^ {. ' .4 :? { KIMBERLY A. SULLIVAN, ) Plaintiff ) ) V& ) PATRICK J. SULLIVAN, III, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice, 2. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the court I and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1-Z - Date KIMB ALYA ULLIVAN KIMBERLY A. SULLIVAN, Plaintiff vs. PATRICK/ SULLIVAN, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-6060 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ? 12/o S Date n TRICK/. SU T. P? 'AN, III iJ ( ? _ _,a li ? .? ?t .. .. ? ,?.?) r.'. ?? 1. l ?'L_ ? ?? Lh ? iZ KIMBERLY A. SULLIVAN, Plaintiff VS. PATRICK J. SULLIVAN, III, (also known as Patrick T. Sullivan, III) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-6060 CIVIL TERM 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). 2. Date and manner of service of the Complaint: Sheriff's service on 13 September 2000 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 12 May 2005 by Defendant: 12 May 2005 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 12 May 2005, filed contemporaneously herewith Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 12 May 2005, filed contemporaneously herewith. Date: ?2 fL9 a , By mu I L. Ande Attorney for Plaintiff ?.3 ?? '?1 ?a^ ' ? <: _. ;?; .may ?:. ??:} ?? ?? 1t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS PATRICK J. SULLIVAN, 111, a/k/a PATRICK T. SULLIVA'N, , Defendant DECREE IN DIVORCE No. 2000-6060 KIMBERLY A. SULLIVAN, 2005 AND NOW, ryJLLy ly , IT IS ORDERED AND KIMBERLY A. SULLIVAN DECREED THAT AND PATRICK T. SULLIVAN, 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; NONE BY THE COURT: ATTES 3 J. PROTHONOTARY eo? KIMBERLY A. SULLIVAN : IN THE COURT OF COMMON PLEAS BURKHOLDER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : DOMESTIC RELATIONS SECTION : DOCKET NO. ,09535 S 2000 PATRICK T. SULLIVAN tl(&6 Defendant : PACSES CASE NO. 211102407 PRAECIPE FOR ENTRY OF APPEARANCE TO: CUMBERLAND COUNTY PROTHONOTARY Please enter the appearance of the undersigned as counsel on behalf of Plaintiff, Kimberly A. Sullivan Burkholder, in the above-referenced matter. Respectfully submitted, 4'A - Mark A. Mateya, Esquir Pa. I.D. No. 78931 Attorney for Plaintiff P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Date: CERTIFICATE OF SERVICE I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the foregoing document on the following person(s) by depositing a true and correct copy of the same in the United States Mail, by way of United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: James M Bach Esquire 352 South Sporting Hill Road Mechanicsburg PA 17050 Samuel L Andes Esquire PO Box 168 Lemoyne PA 17043 Dated: &?( 6S L?' A, W? Mark A. Mateya, Esquire PO Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax r.a E J ?- W C sr