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Home My WebLink About01-0616 FX . . .. . .. . . . ;f. Of.:tl:li '" :f. . . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY STATE OF REBOCCA L. CHANDLER . . VERSUS . THOMAS M. CHANDLER AND NOW, DECREED THAT PENNA. No. 2001-616 DECREE IN DIVORCE D~ 1'7 ~ / t: 3" A. ~ . ,~ , IT IS ORDERED AND REBECCA L. CHANDLER , PLAINTIFF, AND THOMAS M. CHANDLER , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. . . The Marital Settlement Aqreement is incorporated, but not merged, with the Decree in Divorce. B PROTHONOTARY ATTEST: . . . . . .. . .. . J. :Ii "';I: iF. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ " - ~ ; I "~~_.-_1;;- . . t REBECCA L. CHANDLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. S. 2001 01 - ("Ib CIO:( ( L~ CIVIL ACTION DIVORCE THOMAS M. CHANDLER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief or property or other rights important to you, including custody or visitation of your children. When the ground for the' divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE 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 11 E. I1~gl, Otr",,,,!:: ~ 1.IbWy /.J(.)~ Carlisle, PA 17013 I (717) 249-3166 . . 1 REBECCA L. CHANDLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01- ~/," S. 2001 THOMAS M. CHANDLER, Defendant CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(0) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Rebecca L. Chandler, who resides at 1116 Apple Drive, Mechanicsburg, Cumberland County, pennsylvania, 17055. 2. Defendant is Thomas M. Chandler, who resides at 412 S. High Street, Apt. A, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 29, 1996, in Ft. Washington, Pennsylvania. 5. Plaintiff avers that there is one child born of this marriage, namely Christopher, born December 16, 1996. 6. The parties have been living separate and apart since on or about May 21, 2000, a date prior to the filing of this complaint. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Nei ther of the parties in this action is presently a member of the Armed Forces on active duty. . ~,,- "~ < . " , . 9. Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 11. Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Dated: ,1.2 q J 6 I By: Robert B. MacIntyre, Attorney for Plaintiff 6000 Linglestown Road P.O. Box 6656 Harrisburg, PA 17112 (717) 652-9485 1.D. # 36817 -01 ,--" = - ~', ~-, -- , '. -, .- '-~---'" ' r -~:"'_<'__i -- -.'--'"-,",,,. . --:;,:~~: -~'-< '-,~j~,-i:,...-- , ~ VERIFICATION I, '~€ e r_~ Cf>{J./J(j I-u-- , VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 1 UNDERSTAND THAT THE STATEMENTS THEREIN ARE MADE SUBJECT TO THE PENALTIES OF 1 8 P A. C. S. S 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Ik,M... ~fRA- (3) ~ p:_"rD-C'I~FiCE -C' ',', ~"'~'r'''1 '0' T^'RY Ui ~:',_ f'c, ",,)11-",j\;l it\! 01 .lnN 30 PH 2: 14 CUMB[F:i../J~[) COUNTY PENNSYLVANIA 1/7S. SO c .f'. co- SM- \$ /PO" S-O - PeL 4.f--fy ~ :2Cfpr Q:i:L /6f.. Cff-? '~""f REBECCA L. CHANDLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA VS. : NO. 2001-616 [ . . THOMAS M. CHANDLER, DEFENDANT : CIVIL ACTION -DIVORCE PRAF;CIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Thomas M. Chandler. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: March itL, 2001 e 6 Esquire Counselfor D nda PA 1.0. # 64~8 5021 East Trindle Road Suite 100 Mechanicsburg PA 17050 (717) 796-1930 liM1'" "'*jll~>ljj~l;;i@L4&l;ilitW~~Pii.';i\f~;';'ilf...,i,.;j'""*:Ji;;',;J<i~,,,,,,m~~,i€,,,'1tliJ#,>"--,!i/!:i;g!M.t~-__'1i ~ ~~ ........ ,-~ I~ ~ ,_ , .~ ' . -'l!!liJlii!ll~'''-~ -y"~,J..'M1'''''"4. ,. ", , -~ () fi j~ , ,S;: 6 ~, 0 };O ~ t,,!,~";~~ilIi' o ~ ::0 I Co ;g ~ -. 01, - ~~ .' I Q '/'. ::;:1 'h'i~'tJ '~t'< ;''"[1 :dq 0..-:, ~';. 0:rJ :z:o 0"'" ~ --< ~ . -:.~~~..~-;;:-:----~ - , , ~ . , REBECCA 1. CHANDLER, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-616 THOMAS M. CHANDLER, Defendant CIVIL ACTION - DIVORCE M'FIDA "'IT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was fried on January 30, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint 3. I consent to the entry of a final decree of divorce after service of the notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Cf If} t/ot ~AX~ Rebecca 1. Chandler, PLAINTIFF ~'~'i - o. , -' ~ 1I,""~_,;;;, , , REBECCA 1. CHANDLER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-616 THOMAS M. CHANDLER, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE I. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: q It/ /0/ J!Jk~,X ~d6A Rebecca L. Chandler, PLAINTIFF ~ OF ;" " :--.r+:Ol:~JiY r~ , '.J! OCT ~5 PIl r I::: 5: CLHv~,c~;':;-" -' ,. P5ZJI~JS\;i~:f.,~J'r~'~~I~N1Y .....,,\\ili, r,:; ,~ " ," ... ""'""i;, . . REBECCA 1. CHANDLER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-616 THOMAS M. CHANDLER, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE I. I consent to the entry of a frnal decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if] do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein ar~ made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: q-'}d- 01 ~.M~~ Thomas M. Chandler, DEFENDANT fiU:l)--(jiYlCF (;r: "i :,:::Y\"I,r;,';'T',f\Y' I ,'__' l -, . , , ,~- ~ .;;,.J f',j~ ~ 0\ SEP28 Pr\ 3: \3 C" UI',,'BH.'<' ,,"-Ii< 1"'1.)'\1 IN1V " ......,!1...",J';.J V iJ II PENNSY0J:\N!i\ j I I I I ~ ,; ':~ '1: ~ . :'1 ~I ~ ift :i ~I I I I ~ il1 , ;,' ~ ,;;-;.-_J__ "'" ,,-,,-,-_-I. 11~~,""i,;;; I . . .. REBECCA 1. CHANDLER, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-616 THOMAS M. CHANDLER, Defendant CNIL ACTION - LAW AFFIDAVIT OF SERVICE I, Robert B. MacIntyre, Esquire, hereby certifY that a true and correct copy of the Complaint was served upon the Defendant by the United States Postal Service, certified mail, restricted delivery, return receipt requested, on February 9, 2001 (green card attached as Exhibit "A") addressed as follows: Thomas Chandler 412 S. High Street, Apt. A Mechanicsburg, PA 17055 /7 "-" / // '"...-/ / .-'// / filED-\)'r\-'\C'}c- OF t~'\::C\T:":.!~1\!C)TAHY ~ 0\ SEP 28 Pr'l 3: 13 CUMBE8U'ND COllNTY . PENNSYLWINii\ . ~ '""'._..w I... _-i'~~~ - . + . fl1 ;;T I"'- IIEClIAIIICS8lJR& PA 17055 ru fl1 Postage $ to.55 CJ r'i Certifie<:lFee f1.90 ru ru Return Receipt Fee .1.50 CJ (Endorsement Required) CJ Restricted Delivery Fee U.20 t:l (Endorsement Required) <::I Total Postage & Fees <::I "'" fl1 ..... ..... t:l I"'- -- . Complete ilems 1: 2, and 3. Also c;mplele ilem 41f Reslrlcted Delivery is desired. . Print your name and address on the reverse so Ihal we can relurn Ihe card 10 you. . Attach this card to the back of the mailpiece, or on the "front if space permits. 1. Article Addres~ to: Ihomos ChJnd ley Lfl ~ S. #iQh S-h<fIpli meChoJ'iCn>lA~ fA I1D55 . - -'" - 3. Service ~jfjed Express Mail tJ Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes , 2,' Article Number !9?prlrom service labeQ , I D '3 :l I q. 3 7tJ Cf,qv. :-rOo ooo~, ,Q1, "j 0<- · PSiFo';" 3811, jJlf 1999 .: · "Dod,l.Jtic Fle\.lrn Receipt Exhibit "A" 102596-GO-M-0952 ' r !Il 1 ; 1 ~ I I ;I,t ,. t . _._",",,_=~"_,~:::-=;,",7b~~."_.;;;".=='_';;;;'-';;"~~;;:=:--==--===<"_=--=~' .$ -_J' '-, :'-:'1iVT( C' !:~ ,'"' .- ,'" .' [.": ..~: i ....~. CUMBEHu\r-iD COUN1Y PENNSYLVANiA . . ~^ ~ -~- ~.., ". .., ,=",. "''''._'','~' '," . ,-." ~~- ,-. --, ~ ~,,-,.' -/,<,C"".-~ ," - '.'--.'lii'j REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 THOMAS M. CHANDLER, Respondent : CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the within Petition to Enforce Property Settlement Agreement, a hearing is hereby scheduled for the day of , 2002, at o'clock .m. in Court Room No. , of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: J. , "~ ""'0'-'''''' ,-" .'- "'O}:__,j REBECCA L. CHANDLER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-0616 CIVIL TERM THOMAS M. CHANDLER, Defendant CIVIL ACTION - LAW IN RE: CONTEMPT ORDER OF COURT AND NOW, this 17th day of June, 2004, it appearing to the Court that the Defendant has violated our prior order directing him to make all payments due on the loan to M&T Bank in connection with the 1996 Ford Windstar, he is adjudicated to be in contempt. He is directed to appear for sentence on Thursday, July 22, 2004, at 11:30 a.m. Edward E. Guido, J. John J. Connelly, Jr., Esquire For the Plaintiff .~ ~ (, .JJ.M 9-. Thomas Chandler Defendant, Pro se Sheriff .j~'I" I,j- I j ;',. '( Court Administrator ,I I ( .' l srs l' "~I -,-, "'~, . 'I" , . . .. ,H'< ~,~"<,,- ~ -"~ ' f\LED-OfRCE OF 1\1E PH01nOf~OTI,p.y 2nU4 JUN 22 Pi'l 3: \ Z CUrv~:~;'L~;>,Lt",~- ~-'" 'j i,:,()U0yr-, F"c,\'~><~)'(lY;\N\A ,..e -'c.'-' .~{'j'l!1_~_'Jffi'l!!:l.W~ >~lll~r 3'''~''''. -- ,--"-",,,- ." ~, ._,,=',,-, _'-:__1: -'-'","",0..'_"-- -'JIiilli.'l'" REBECCA L. CHANDLER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-0616 CIVIL TERM THOMAS M. CHANDLER, Defendant CIVIL ACTION - LAW IN RE: AMENDMENT TO 6/17/04 CONTEMPT ORDER ORDER OF COURT AND NOW, this 25th day of June, 2004, the Order of Court in the above-captioned matter dated June 17, 2004, is amended to include the following: A portion of the Defendant's sentence will be a requirement that he pay Petitioner's counsel fees in the amount of $825.00. In all other respects, the Order shall remain the same. John J. Connelly, Jr., Esquire For the Plaintiff Sheriff ~-dJl~,/ ~ ~ ~..2f.D'f C}-, Thomas Chandler Defendant, Pro se Court Administrator ~-~I/~ srs . 11 i :~~"'~"F'" "0 "'^'>;"',_' c' .".' FILED--DFFICE OF THE F110TH:~ir\!CrG\RY nOnt ''''J ^" ltiu I JU,\ dJ 1H1IO: J9 Jl.>ny , .1\ G,"""" ,,'" "'" ,""" ",.."",,"1 '''' ,,,,,.~,,,..Ojffi~~," "~~T"~~"':" ,:,_,::!~IL,:~,,_~ "'Jr.J!. ~~--"-'--~ .. .-J!""i ~TI JJJJ ,.1-. J- -~4' j'-~ ~. "-<- y~ "'-r MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this Sfhday of ~, 2000, by and between REBECCA L. CHANDLER, hereinafter referred to as "Wife", and THOMAS M. CHANDLER, hereinafter referred to as "Husband". WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on June 29, 1996. There is one child born of this marriage, said child being Christopher, born December 16, 1996. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; the settling of all matters relating to the children of the parties including custody, visitation and support; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. f'eE~t,m-(r'S I '1'23 t, ~ l.-1L'1" . , , " NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable considerations, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows; 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed a condonation on the part of either party hereto of any act or acts on the part of the other party which have occurred prior to or which may occur subsequent to the date hereof. 2. EFFECT OF DIVORCE DECREE. The parties agree that, unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the parties hereto that this Agreement shall create contractual rights and obligations entirely independent of any Court Order and that this Agreement may be enforced by contract remedies in addition to any other 2 ",~ '_c ., _~ , , ....- ~ . ,~- - '..,~., -H '" remedies which may be available pursuant to the terms of this Agreement or otherwise under law or equity. 3 . AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The parties agree that the terms of this Agreement shall be incorporated, but not merged, into any divorce decree which may be entered with respect to them. The parties further agree that the CoUrt of Common Pleas which may enter such divorce decree shall retain continuing jurisdiction over the parties and the subject matter of the Agreement for the purpose of enforcement of any of the provisions thereof. 4. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to Wife by her attorney, Robert B. MacIntyre, Esquire. Wife acknowledges that she has received independent legal advice from counsel of her selection. Husband acknowledges that he has been advised of his right to seek independent legal counsel and that he has fully and voluntarily waived that right. The parties acknowledge that they 3 , . fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable; that it is being entered into freely and voluntarily, after having received such advice and with such knowledge; that execution of this Agreement is not the result of any duress or undue influence; and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full and complete disclosure of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. Each party agrees that he and she shall not, at any future time, raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. 6. PERSONAL RIGHTS. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession ot employment which to him or her may seem advisable. 4 , , - , , ',- ,~, '. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell, by any means or in any manner whatsoever, with him or her. 7. SUBSEQUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent co-habitation or resumption of marital relations, unless the parties otherwise specifically agree in writing. 8. MU~UAL RELEASES. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature or wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a 5 , , '. surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relation or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 6 - ~~J. , I ,,- 1V' , . 9. BANK ACCOUNTS AND RETIREMENT ACCOUNTS. Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that these accounts and plans shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title or interest they may have in the other parties' account. 10. PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have divided their tangible personal property, including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. (See Exhibit A for partial allocation). The parties do hereby specifically waive, release, renounce and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties further agree that the following items shall be shared by the parties: lawnmower, blower, hedge trimmer, "sawzall", weed trimmer and edger. The parties further agree to share equally in any repair expenses for the shared items. 7 . oj, '. 11. AFTER-ACQUIRED PERSONAL PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 12. ~ ESTATE. Husband and Wife are the owners of a house located at 1116 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania. Wife shall assume full responsibility for the payment of the mortgage, taxes, utilities and maintenance. Husband agrees to execute a deed to transfer his interest in said property to Wife on or within 3 months after February 1, 2003. If both parties agree, husband may transfer his interest prior to February 1, 2003. If the property is sold prior the the execution of a deed of transfer, husband shall not be liable for any settlement costs, nor shall he share in the proceeds of sale. Further, Husband agrees not to enter the home, nor to remove items from the home, or otherwise attempt to exert any control of the use or renovation of the home. 13. AUTOMOBILES. The parties are the owners of various automobiles. Wife shall be the sole and separate owner of any vehicle titled in her name and/or in her possession at the execution of this agreement. Husband shall be the sole and 8 '....... I> ,-I, -" "ii!flllMii. , . separate owner of a van titled in both his and her names and in his possession at the execution of this agreement. Each party agrees to execute all documents necessary to implement this paragraph. Husband shall be solely responsible for the payment of the loan on the vehicle in his possession and shall indemnify and hold wife harmless for the repayment of said loan. 14. CURRENT LrAB,ILITIES. Wife shall be solely responsible for payment of the mortgage, utilities, taxes and insurance on the house at 1116 Apple Drive. Further, Wife shall be responsible for all individual bills which she has incurred since the date of separation. Husband shall be responsible for all individual bills which he has incurred since the date of separation. 15. WAIVER OF ALIMONY PENDENTE LITE AND PAYMENT OF LEGAL FEES. Each party hereby waives any right to alimony pendente lite and the payment of legal fees. 16 . RELEASE OF SUPPORT - ACKNOWLEDGEMENT OF ADIilQUACY. The parties herein acknowledge that, by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support or 9 0-""''"'''"'' , J,' ., ~'~- -if';- maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 17. CUSTODY AND VISITATION. Husband and Wife shall have shared legal custody of the parties' child. Wife shall have primary physical custody. Husband shall have liberal periods of partial physical custody, not less than every other weekend from 5:30 pm on Friday until 6:00 pm on Sunday. Wife shall be responsible for transporting the child no farther than 25 miles from child's current residence. Husband shall be responsible fro remaining transportation. 18. CHILD SUPPORT. Husband agrees to pay $80.00 per week directly to Wife. If not paid, Wife will file a formal complaint for child support with the applicable Court. The parties agree that this amount shall be reviewed every February and July. This review will consist of providing pay stubs for the previous six month period to determine the current applicable rate of support. Husband agrees that no expenses shall be deducted from the weekly sum for out-of-pocket expenditures. Husband further agrees to pay one-half of any uninsured medical and dental expenses, as well as one-half of any child care costs. Any further support shall be as agreed by the parties or, if applicable, the Court. 10 . , - ~I , " .oh="_ , .- 19. MUTU~ CONSENT DIVORCE. The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counselling, and that they both consent to the entry of a decree in divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (herein referred to as the Code). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of The Code. Upon request, to the extent permitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 20. W"AlUU\NTY AS TO EXISTING OBLIGATIONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligations for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for 11 .~ ..-- ; -,' t~ , .' necessities, except for the obligations arising out of this ~greement. 21. WARRANTY AS TO FUTURE OBLIGATIONS. Wife and Husband each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 22. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 23. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 12 I , , ~ ,.,- . 'L , .. 24. LAWS OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 25. AGREEMENT BINDING HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 26. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 27. NO ~IVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 13 \ .' , I ~~ ~ . 28. ENFORCEMENT OF AGREEMENT. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her. 29. SEVERABILITY. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall, in no way, void or alter the remaining obligations of the parties. 30. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement, nor shall they affect its meaning, construction or effect. 14 . ;,'0' . -> IN WITNESS WHEREOF, the parties hereto have set their hands and seal the day and year first above written. :~>~' ;t / C&n~ ~~,,'F' . ~, - II _ REBECCA L. CHANDLER ~~-, ~'Q -Ill ~~ 'THO AS M. CHANDLER 15 ,;;;;jL ;. " 1:","", ".,: t~'-'~'. _1-. , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. On this, the 54 , 2000, /~tf"6( ~ day of before me a Notary Public of the Commonwealth of Pennsylvania personally appeared REBECCA L. CHANDLER, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~, Notary Publlc NOTARIAL SEAL MICHAEL R. CARANCI. Notary Public Camp Hili Boro. CUmb8rland County ! My Commission Expires June 15. 2002 I.. ______.,' 16 ~ ~ -J" ~ . . COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND On this, ~1;T the ~ day of ~.P~8~ , 2000, before me, a Notary Public for the Commonwealth of Pennsylvania, personally appeared THOMAS M. CHANDLER, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~~/? No ary PubllC NOTARIAL SEAL MICHAEL R. CARANCI, Notary Public Camp Hill Boro. Cumberland Coun~ My Commlsslo!!~lres June 15, ?~n. 17 TransUnion - Dispute Online Page I of2 TransUnkM'L Dispute Online Thank you for submitting your dispute. The information you submitted appears at the bottom of this page. We received your request and will investigate the information that you have disputed by contacting the data furnisher with a request to verify the information's accuracy. Upon verification, the data furnisher will then advise TransUnion LLC of any changes that are necessary. The investigation will be concluded within 30 days and, upon conclusion, you will receive an updated copy of your TransUnion LLC credit report reflecting the results of our investigation. Should you need to contact our office with questions. you should have your TransUnion file identification number available so that we may assist you. You will find your file identification number in the upper right hand corner of your TransUnion LLC credit report. Please allow time for our staff to process your request. If you have questions, our telephone representatives are available Monday through Friday. 8:30 a.m. to 4:30 p.m.. In your time zone, excluding major holidays at 1-800-916- 8800. We have received the following dispute information. Please print this page for your records. e' Dispute Details Personal Information: Name: SSN: Date of Birth: Home Phone Number: Employer's Name: Rebecca Lynn Chandler 198503535 12/17/1965 (717) 795-0190 Morneau Sobeco Current Address: Address: 1116 Apple Drive Mechanicsburg, Pennsylvania, 17055 P. +t tiane~'.s. EXHIBIT 2- '1';2;'02 L-i<:-T Previous Address: Address: Credit Report File Number: https://www.transunion.com/Personal/DisputeProcess.asp 11/02/200 I _.~ ~~ ~ ~ .~ .......... TransUnion - Dispute Online .~. . File Number: 106292483 Personal Information Corrections: 1. Previous Address: I have never resided at 412 S. High Street, A 1, Mechanicsburg, PA 17055 Disputes: 1. National City Mortgage, account 4330616956: Other: This was not included in the bankruptcy. 2. First USA Bank, account 4417125881271880: Other: I believe this was only not paid when it was included in the bankruptcy. 3. PNC Bank, account 1103047606124139: This account is closed. 4. McCaughan Mortgage, account 66779: This account is closed. 5, McCaughan Mortgage. account 69729: This account is closed. 6. Bankamerica, account 6396356175969001: This account is closed. 7. First Florida Bank, account 400156175969001: This account is closed. 8. Burdin. account 1581472732: This is not my account. 9. Chevron, account 7380476940: This is not my account. Comments: - no comments have been entered -- - https://www.transunion.com/Personal/DisputeProcess.asp Page 2 of2 11/02/200 I ,. .-,-- , '""-~ '. ~w ~ ~, I Trans Union Consumer Credit Score Name: CHANDLER, REBECCA, L Address: 1116APPLEDR MECHANICSBURG, P A 17055 File Number: 106292483 Date of Credit Score: 10/03/2001 About your credit score: A credit score is a computer generated mathematical calculation of the information which appears in a credit report. It represents your credit worthiness as a number or a numerical value. The credit score is based on data about your credit history and payment behavior. Credit scores are used to assist a lender in determining the level of risk associated with granting you a loan, credit limit, and 1 or rate of interest. Credit scores can change over time, depending on how your credit history and payment behavior changes and how well you manage your credit obligations. Since, the credit score is based on information in your credit history, it is important that you review the credit report that is being furnished with this document to make sure it is complete and accurate. The credit score, displayed below, is created by Trans Union. A higher credit score means a lower likelihood of delinquency in the .next two years on a new account. The credit score is presented with up to four key factors. These factors will print in the' order of importance as to the reasons your credit score is not higher. Please note that this credit score may be different than a credit score used by a lending institution. The credit industry uses many different types of credit scores. For more information, visit www.transunion.com. Factor 1: Months since most recent serious delinquency is too short: Your credit report reflects a delinquent payment history. Making prompt payments over time may improve your credit score. Factor 2: Too many derogatory accounts or public records: Your credit report reflects one or more accounts with a derogatory payment rating or a public record such as a civil judgement, bankruptcy or tax lien. Factor 3: Too many active accounts with a balance: Your credit report reflects several accounts with balances, which has a negative impact on your credit score. Factor 4: Average balance of bankcard accounts is too high: High balances on these accounts have a negative impact on your credit score. Lowering your balances on these accounts may improve your credit score. 11004 72993 7/12 lii1TilOOM~i'-"Ui?Iill1lj'ilil0;.;i"i",,"",,\i,.g~l@m..~Sl!~'''''-'Si!1l'.tiIF~l~i:ff~~<hl,0li1liiiir~ ~.""~,,,,-,~ '1ItI1~Q".~"~rl""1" t-:i;l- '"""tliIil~~;"r -~" b.. ". ~ 1 Credit Scoring Questions and Answers: . How are Credit Scores used? A Credit Score is one of the primary tools a lender uses when determining whether or not to grant you credit and if so, how much credit and at what interest rate. Lenders also typically consider other information in addition to your credit report, such as income, employment, or their previous credit experience with you. Taken together, this factual information provides credit grantors with a fair representation of the risk in lending money to you. . Does every consumer have a Credit Score? No. For a score to be calculated, your credit report must contain at least one account which is commonly referred to as a trade line. If this information is missing, then Trans Union cannot accurately report a score. In addition, a credit score will not be calculated if one or more of the following has occurred; a trade line has a notation which references a person associated with the account as deceased or the social security number on the credit report is a match on the Social Security Administration's "Death Claim Index". . How is my Credit Score calculated? The Trans Union credit scoring model is based on many interrelated characteristics of credit information, Numerical weights are placed on different aspects of your credit report and a mathematical formula is used to arrive at a final credit score. There are many different credit score models used in the credit industry which consider different variables for different types of credit. The credit score characteristics may be generally summarized in to six categories: Maiutaiuiug Credit - considers how you are paying your accounts. Total Balances - considers how much money you currently owe. Credit Experience - considers how long your accounts have been open. Credit Mix - considers the different types of credit you use. Utilization of Credit - considers the amount of credit you use in relation to the amount you have available. Credit Applications - considers how often and how recently you have applied for credit. . How often does my Credit Score change? Your credit file is continually updated with new information from your creditors. The Trans Union credit score is calculated based on the current information contained in the credit file at the time the credit score is requested, Therefore, every time a credit file is requested, the credit score may be different because the information in your credit report continually changes. . How do inquiries impact my Credit Score? A common misperception is that inquiries will always negatively impact a credit score. Typically, the presence of inquiries on the credit file has only a small impact on the credit score. Inquiries have less impact than delinquencies, balances owed, and the length of time you have used credit. Inquiries will usually have a larger impact on the credit score for consumers who have a limited credit history. . How can I improve my Credit Score? First, it is important to review your credit report for accuracy. In addition, maintaining a good credit standing and continuing to exhibit responsible credit behavior are the most effective means of presenting a positive picture of your credit worthiness. Improving one's credit standing or credit score is not a one time only fix, but more of a change in how you view and handle credit over time. For more information on credit scoring, visit our web site at www.transunion.com 11004 72994 8/12 " ,-, ~" ,~". '~"-'/ -,~- ".~ '~-- I~ -",,",,-,,"-, , L" L ~...." ~ , I ':'; .,.~ P.O. BOX 1000 CHESTER, PA 19022 YOUR PAGE DATE TRANS UNION 1 OF 6 THIS REPORT FILE NUMBER: 106292483 PR I NTED: 10/03/2001 RETURN SERVICE REQUESTED SOCIAL SECURITY NUMBER: 198-50-3535 BIRTH DATE: 12/1965 YOU HAVE BEEN IN OUR FILES SINCE: 04/1985 AKA: VEACH,REBECCA,L PHONE: 795-0190 CONSUMER REPORT FOR: ***** CHANDLER, REBECCA, L 1116 APPLE DR MECHANICSBURG, PA 17055 FORMER ADDRESSES REPORtED: 412 S HIGH ST AI, MECHANICSBURG, PA 17055 1405 ROOSEVELT AV, LEHIGH ACRES, FL 33972 EMPLOYMENT DATA REPORTED: MORNOSEVICO DATE REPORTED: 10/2001 YOUR CREDIT INFORMATION THE FDLLOWING ITEMS OBTAINED FROM PUBLIC RECORDS APPEAR ON YOUR REPORT. YOU MAY BE REQUIRED TO EXPLAIN PUBLIC RECORD ITEMS TO POTENTIAL CREDITORS. ANY BANK- RUPTCY INFORMATION WILL REMAIN ON YOUR REPORT FOR 10 YEARS FROM THE DATE OF FILING. UNPAID TAX LIENS MAY GENERALLY BE REPORTED FOR AN INDEFINITE PERlnD OF TIME DEPENDING ON YOUR STATE OF RESIDENCE. PAID TAX LIENS MAY BE REPORTED FOR 7 YEARS FROM DATE OF PAYMENT. ALL OTHER PUBL I C RECORD I NFORMAT I ON, I NCLUD I NG DISCHARGED CHAPTER 13 BANKRUPTCY AND ANY ACCOUNTS CONTAINING ADVERSE INFORMATIDN REMAIN FOR 7 YEARS. ALL OTHER PUBLIC RECORD INFORMATION INCLUDING DISCHARGED CHAPTER 13 BANKRUPTCY, MAY BE REPORTED FOR 7 YEARS. DOCKET #99000004409 FEDERAL DISTRICT CHAPTER 7 BANKRUPTCY DISCHARGED PLAINTIFF ATTORNEY: THOMAS D GOULD ENTERED: 10/1999 ASSETS: $0 PAID: 01/2000 L1AB: $0 THE FOLLOWING ACCOUNTS CONTAIN INFORMATION WHICH SOME CREDITORS MAY CONSIDER TO BE ADVERSE. ADVERSE' ACCOUNT INFORMATION MAY GENERALLY BE REPORTED FOR 7 YEARS FROM THE DATE OF THE FIRST DELINQUENCY, DEPENDING ON YOUR STATE OF RESIDENCE. THE ADVERSE INFORMATION IN THESE ACCOUNTS HAS BEEN PRINTED IN >BRACKETS< FOR YOUR CONVENIENCE, TO HELP YOU UNDERSTAND YOUR REPORT. THEY ARE NOT BRACKETED THIS WAY FOR CREDITORS. (NOTE: THE ACCOUNT # MAY BE SCRAMBLED BY THE CREDITOR FOR YOUR PROTECTION). 11004 72987 1/12 ~1~f,u~J!'&j$i.o~>&;"~,'~~Jt4i%i@j:~i"""';-iMi"~'",'~^"1i,r"'bL:'!J!\~_,c;;,,1JII1.~;\.MM\WlI~i -'t:ir!i;r''';'''-~:w.rJ>>~lh~!w;''j-''"'-' " - REPORT ON CHANDLER, REBECCA, L SOCIAL SECURITY NUMBER: 198-50-3535 PAGE 2 OF 6 TRANS UNION FILE NUMBER: 106292483 ALLFIRST # 20000000060768 INSTALLMENT ACCOUNT AUTOMOBILE UPDATED 09/2001 BALANCE: $10192 JOINT ACCOUNT OPENED 08/1999 MOST OWED: $14535 PAY TERMS: 66 MONTHLY $279 1996 FORD WINDSTAR STATUS AS OF 09/2001: PAID OR PAYING AS AGREED >IN PRIOR 26 MONTHS FROM LAST UPDATE 3 TIMES 30 DAYS LATE< NTL CITY MTG # 4330616956 MORTGAGE ACCOUNT >INCLUDED IN BANKRUPTCY< FHA REAL ESTATE MORTGAGE UPDATED 09/2001 BALANCE: $113741 JOINT ACCOUNT OPENED 03/1999 MOST OWED: $116800 PAY TERMS: 360 MONTHLY $1005 STATUS AS OF 09/2001: PAID OR PAYING AS AGREED IN PRIOR 30 MONTHS FROM LAST UPDATE NEVER LATE # 5491130145784187 UNVL BK NA >INCLUDED IN BANKRUPTCY< UPDATED 07/2001 BALANCE: OPENED 04/1999 CLOSED 11/2000 STATUS AS OF 11/2000: UNRATED IN PRIOR 18 MONTHS FROM DATE CLOSED $0 REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT CREDIT LIMIT: $8000 NEVER LATE FST USA BK B >INCLUDED IN BANKRUPTCY< UPDATED 03/2000 BALANCE: OPENED 01/1998 MOST OWED: PAID OFF 09/1999 STATUS AS OF 09/1999: UNRATED >IN PRIOR 21 MONTHS FROM DATE PAID 4 TIMES 90 DAYS, 1 TIME 60 DAYS, 1 TIME 30 DAYS LATE< >MAXIMUM DELINQUENCY OF 90+ DAYS OCCURRED IN 07/1999< # 4417125881271880 $0 $14371 REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT CREDIT LIMIT: $14000 THE FOLLOWING ACCOUNTS ARE REPORTED WITH NO ADVERSE INFORMATION REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT PAY TERMS: MINIMUM $70 CREDIT LIMIT: $2400 STATUS AS OF 09/2001: PAID OR PAYING AS AGREED IN PRIOR 11 MONTHS FROM LAST UPDATE NEVER LATE PROVIDIAN # 4361450900660004 UPDATE D OPENED 09/2001 10/2000 $2318 $2318 BALANCE: MOST OWED: CAPITAL 1 BK # 5291151759629064 REVOLVING ACCOUNT CREDIT CARD UPDATED 09/2001 BALANCE: $956 INDIVIDUAL ACCOUNT OPENED 08/2000 MOST OWED: $1111 PAY TERMS: MINIMUM $28 STATUS AS OF 09/2001: PAID OR PAYING AS AGREED IN PRIOR 13 MONTHS FROM LAST UPDATE NEVER LATE S~"',,~~, c_ y_ '",,""'"'~~Y ... _ '" , .,,~ ' ~,-,",I I 11004 72988 2/12 llli,' ~""'~. R~PORT ON CHANDLER, REBECCA, L SOCIAL SECURITY NUMBER: 198-50-3535 ~'" L. " , PAGE 3 OF 6 TRANS UNION FILE NUMBER: 106292483 FST USA BK B # 4325150305637798 ACCOUNT CLOSED BY CONSUMER UPDATED 09/2001 BALANCE: OPENED 12/1988 MOST OWED: PAID OFF 11/1997 STATUS AS OF 11/1997: PAID OR PAYING AS IN PRIOR 24 MONTHS FROM DATE PAID NEVER $0 $9653 # 11030476061~4139 ED 08/2001 OPENED 06/1995 PAID OFF 08/1996 STATUS AS OF 08/1996: PAID OR PAYING AS IN PRIOR 9 MONTHS FROM DATE PAID NEVER BALANCE: MOST OWED: $0 $500 REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT AGREED LATE LINE OF CREDIT ACCOUNT LINE OF CREDIT PARTICIPANT ON ACCOUNT CREDIT LIMIT: $500 AGREED LATE WACH BKCRD # 4325150305637798 REVOLVING ACCOUNT ACCOUNT CLOSED BY CONSUMER CREDIT CARD UPDATED' 07/2001 BALANCE: $0 INDIVIDUAL ACCOUNT OPENED 12/1988 MOST OWED: $9653 CREDIT LIMIT: $0 CLOSED 05/1993 STATUS AS OF 05/1993: PAID OR PAYING AS AGREED DAUPHIN DEP # 19850353500001 INSTALLMENT ACCOUNT ACCOUNT CLOSED BY CONSUMER STUDENT LOAN UPDATED 04/2001 BALANCE: $0 INDIVIDUAL ACCOUNT OPENED 02/2000 MOST OWED: $450 PAY TERMS: MONTHLY $50 CLOSED 02/2001 STATUS AS OF 02/2001: PAID OR PAYING AS AGREED IN PRIOR 11 MONTHS FROM DATE CLOSED NEVER LATE SOANB/FBUG # 6004665210121524 REVOLVING ACCOUNT ACCOUNT CLOSED BY CONSUMER CHARGE ACCOUNT UPDATED OS/2000 BALANCE: $0 INDIVIDUAL ACCOUNT OPENED 04/1993 MOST OWED: $0 CREDIT LIMIT: $500 STATUS AS OF OS/2000: PAID OR PAYING AS AGREED IN PRIOR 24 MONTHS FROM LAST UPDATE NEVER LATE HRS COMPUSA # 7738304431743 ACCOUNT CLOSED BY CONSUMER UPDATED 03/2000 BALANCE: OPENED 10/1996 MOST OWED: CLOSED 08/1998 STATUS AS OF 08/1998: PAID OR PAYING AS AGREED IN PRIOR 36 MONTHS FROM DATE CLOSED NEVER LATE $0 $2462 REVOLVING ACCOUNT COMBINED CREDIT PLAN JOINT ACCOUNT CREDIT LIMIT: $4000 FST USA BK B # 4417128652132257 ACCOUNT CLOSED BY CONSUMER UPDATED 07/1999 BALANCE: OPENED 05/1997 MOST OWED: CLOSED 01/1998 STATUS AS OF 01/1998: PAID OR PAYING AS AGREED IN PRIOR 10 MONTHS FROM DATE CLOSED NEVER LATE $0 $9000 REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT CREDIT LIMIT: $9000 11004 72989 3/12 -" _: ! ~Mb#IJijif'<j;jillil!li;;j,j;,!liI!~JiM~l!%'n''''f1_1'><;,,,,,,,''\i,;,~,,,jMj'!~16'&;1ii!~'~'''~~riW ....,.~..- 'iilJlM1t~"~"_ --~I!il.l!llliil!-m.lilM"." ~I 'Hliillili"~'~~~~- REPORT ON CHANDLER, REBECCA, L SOCIAL SECURITY NUMBER: 198-50-3535 PAGE 4 OF 6 TRANS UN I ON FILE NUMBER: 106292483 CAPITAL 1 BK # 4388641436625896 ACCOUNT CLOSED BY CONSUMER UPDATED 12/1998 BALANCE: OPENED 10/1997 MOST OWED: CLOSED 12/1998 STATUS AS OF 12/1998: PAID OR PAYING AS AGREED IN PRIOR 15 MONTHS FROM DATE CLOSED NEVER LATE GMAC CLOSED UPDATED 05/1998 OPENED 06/1996 CLOSED 05/1998 STATUS AS OF 05/1998: PAID OR PAYING AS AGREED JJLtRlOR 23 MONTHS FROM DATE CLOSED NEVER LATE --- ' -~ 0~CAUGHA MTG l' -- UPDATED 11/1997 I OPENED 03/1993 CLOSED 02/1995 I STATUS AS OF 02/1995: PAID OR PAYING AS AGREED I IN PRIOR 3 MONTHS FROM DATE CLOSED NEVER LATE M WARD/MBGA # 05091345226 ACCOUNT CLOSED BY CONSUMER UPDATED 12/1996 BALANCE: OPENED 09/1993 MOST OWED: CLOSED 11/1993 STATUS AS OF 11/1993: PAID OR PAYING AS AGREED ..----.-...----.------..... //~~-NKAIIER I CA ) ./ ------- ""/~ .---- . .'---~-- # 20314850481 BALANCE: MOST OWED: # 69729 BALANCE: MOST OWED: $0 $9202 $0 $6823 $0 $65186 $0 $780 # 6396356175969001 UPDATED 03/1994 OPENED 10/1992 PAID OFF 03/1994 "SIE~_S AS OF 03/1994: PAID OR BALANCE: MOST OWED: $0 $2759 PAYING AS BURDIN/FDSB # 1581472732 UPDATED 02/1994 BALANCE: $0 OP,EN"ED 01/1991 MOST OWED: $0 STATUS AS OF 02/1994: PAID OR PAYING AS I \. f , , \ , F ST FLA BANK UPDATED 02/1993 OpENED 10/1992 '- # 400156175969001 MOST OWED: $2759 ~IH,US AS OF 02/1993: PAID OR PAYING AS I ~( MCCAUGHA MTG # 66779 UPDATED 02/1993 BALANCE: OPENED 10/1990 MOST OWED: STATUS AS OF 02/1993: PAID OR <._..,~ ""=.- $64541 $65497 PAYING AS REVOLVING ACCOUNT CREDIT CARD JOINT ACCOUNT INSTALLMENT ACCOUNT LEASE INDIVIDUAL ACCOUNT PAY TERMS: 23 MONTHLY $284 MORTGAGE ACCOUNT FHA LOAN PARTICIPANT ON ACCOUNT PAY TERMS: 30 MONTHLY REVOLVING ACCOUNT INDIVIDUAL ACCOUNT CREDIT LIMIT: $0 INSTALLMENT ACCOUNT AUTOMOBILE JOINT ACCOUNT PAY TERMS: 24 MONTHLY $129 86 MERC 2MEBP95F6GX607536 AGREED REVOLVING ACCOUNT INDIVIDUAL ACCOUNT CREDIT LIMIT: AGREED $500 INSTALLMENT ACCOUNT JOINT ACCOUNT PAY TERMS: 24 MONTHLY $129 86 MERC 2MEBP95F6GX607536 AGREED MORTGAGE ACCOUNT FHA LOAN PARTICIPANT ON ACCOUNT PAY TERMS: 360 MONTHLY AGREED $651 11004 72990 4/12 .. ~~"';~I"........... ,_ R~PORT ON CHANDLER, REBECCA, l SOCIAL SECURITY NUMBER: 198-50-3535 "" ,~ <ri.~',," ~ -1 , ! PAGE 5 OF 6 TRANS UNION FilE NUMBER: 106292483 SEARS # 653942580784 ACCOUNT CLOSED BY CONSUMER UPDATED 09/2001 BALANCE: OPENED 06/1999 MOST OWED: CLOSED 06/2000 STATUS AS OF 06/2000: UNRATED IN PRIOR 18 MONTHS FROM DATE CLOSED CHEVRON UPDA - NE D STATUS # 7380476940 REVOLVING ACCOUNT 01/1993 PARTICIPANT ON ACCOUNT 03/1990 MDST OWED: $269 AS OF 01/1993: PAID OR PAYING AS AGREED REVOLVING ACCOUNT CHARGE ACCOUNT $0 AUTHORIZED ACCOUNT $0 CREDIT liMIT: $2200 NEVER lATE FST USA BK B # 4246171023919405 ACCOUNT CLOSED BY CONSUMER UPDATED 02/2000 BALANCE: OPENED 07/1998 MOST OWED: STATUS AS OF 02/2000: UNRATED IN PRIOR 19 MONTHS FROM lAST UPDATE NEVER $0 $4500 FST USA BANK # 4417128591504434 CLOSED UPDATED 01/1997 BALANCE: $0 OPENED 08/1996 CLOSED 08/1996 STATUS AS OF 08/1996: UNRATED DISCOVER FIN # 6011002456510528 ACCOUNT CLOSED BY CONSUMER UPDATED 12/1995 BALANCE: OPENED 10/1987 MOST OWED: CLOSED 04/1994 STATUS AS OF 04/1994: UNRATED $0 $118 REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT CREDIT liMIT: $4500 lATE REVOLVING ACCOUNT CREDIT CARD INDIVIDUAL ACCOUNT REVOLVING ACCOUNT CREDIT CARD JOINT ACCOUNT THE FOllOWING COMPANIES HAVE RECEIVED YOUR CREDIT REPORT. THEIR INQUIRIES REMAIN ON YOUR CREDIT REPORT FOR TWO YEARS. (NOTE: "TU CONSUMER DISCLOSURE" INQUIRIES ARE NOT VIEWED BY CREDITORS). DATE 10/03/2001 09/27/2001 03/05/2001 10/13/2000 SUBSCRIBER NAME TU CONSUMER DISCLOSURE WAYPOINT BANK CINGUlAR FUSA SUBSCRIBER NAME FIRST CONSUMERS NATIONAL CAPITAL ONE BANK UNITRIN FIRST PREMIER THE COMPANIES liSTED BELOW RECEIVED YOUR NAME, ADDRESS AND OTHER liMITED INFORMATION ABOUT YOU SO THEY COULD MAKE A FIRM OFFER OF CREDIT OR INSURANCE. THEY DID NOT RECEIVE YOUR FUll CREDIT REPORT, AND THESE INQUIRIES ARE NOT SEEN BY ANYONE BUT YOU. DATE 01/2001 03/2001 04/2001 02/2001 SUBSCRIBER NAME CAPITAL ONE BANK FIRST CONSUMERS NATIONAL FIRST CONSUMERS NATIONAL GREAT AMERICAN INSURANCE I NQU I RY TYPE INDIVIDUAL INDIVIDUAL INDIVIDUAl INDIVIDUAl DATE OS/2001 02/2001 11/2000 01/2001 11004 72991 5/12 L ~".' '~~k~~;ffi;lMil"rIL~h\*~mw~~tilit",~jZt<-~;h'?"..>0:Hb~';,F(';'~'b"'dt.~iL"ili;W.M::.~~" ..~~=~-<~.~':iilNM_J~lff>'t' ~,..' :!l!SI~' ~.'tIl!Ifi1J -~' ~~ REPORT ON CHANDLER, REBECCA, L SOCIAL SECURITY NUMBER: 198-50-3535 P AG E 6 OF 6 TRANS UNION FILE NUMBER: 106292483 09/2000 01/2001 09/2000 BAY AREA BUSINESS COUNCI FIRST PREMIER FIRST PREMIER 10/2000 09/2000 CAPITAL ONE BANK FIRST CONSUMERS NATIONAL THE COMPANIES LISTED BELOW OBTAINED INFORMATION FROM YOUR CONSUMER REPORT FOR THE PURPOSE OF AN ACCOUNT REVIEW OR OTHER BUSINESS TRANSACTION WITH YOU. THESE INQUIRIES ARE NOT DISPLAYED TO ANYONE BUT YOU AND WILL NOT AFFECT ANY CREDITOR'S DECISION OR ANY SCORE. DATE 08/2001 04/2001 01/2001 01/2001 11/2000 12/2000 11/2000 10/2000 09/2000 08/2000 07/2000 03/2000 02/2000 02/2000 01/2000 12/19,99 11/1999 10Jl9* ~~ SUBSCRIBER NAME PNC NATIONAL BANK PNC NATIONAL BANK PNC NATIONAL BANK CAPITAL ONE BANK UNIVERSAL BANK NA CAPITAL ONE BANK PNC NATIONAL BANK CAPITAL ONE BANK CAPITAL ONE BANK PNC NATIONAL BANK UNIVERSAL BANK NA UNIVERSAL BANK NA PNC NATIONAL BANK UNIVERSAL BANK NA FUSA/BKl A/M UNIVERSAL BANK NA PNC NATIONAL BANK UNIVERSAL BANK NA FUSA/BKl A/M IF YOU BELIEVE ANY OF THE INFORMATION IN YOUR CREDIT REPORT IS INCORRECT, PLEASE LET US KNOW. FOR YOUR CONVENIENCE, AN INVESTIGATION FORM IS INCLUDED. PLEASE COMPLETE IT AND MAIL TO: TRANS UNION CONSUMER RELATIONS P.O. BOX 2000 CHESTER, PA 19022-2000 1-800-916-8800 OUR BUSINESS HOURS IN YOUR TIME ZONE ARE: 8:30 A.M. TO 4:30 P.M. EXCEPT MAJOR HOLIDAYS. MONDAY THRU FRIDAY FOR ADDITIONAL CONSUMER INFORMATION OR TO DISPUTE YOUR CREDIT REPORT ONLINE VISIT THE PERSONAL SOLUTIONS PAGE AT WWW.TRANSUNION.COM :<",-~.,'"' ..r _,"_m, ~ 11004 72992 6/12 ~.IW'_~"'='... . '_'n'~,I.N. ~.~,. ~_..-~~;"~J,.~_ , " "' _ --;;J~ .iI., ., -, " -,,-....'.,""'-' [1 A Summary of Your Rights Under the Fair Credit Reporting Act The federal Fair Credit Reporting Act (FCRA) is designed to promote accuracy, fairness, and privacy of information in the files of every "consumer reporting agency" (CRA). Most CRAs are credit bureaus that gather and sell information about you -- such as if you pay your bills on time or have filed bankruptcy -- to creditors, employers, landlords, and other businesses. You can find the complete text of the FCRA, 15 U.S.C.~~1681-168Iu, at the Federal Trade Commission's web site (http://www.ftc.gov) The FCRA gives you specific rights, as outlined below. You may have additional rights under state law. You may contact a state or local consumer protection agency or a state attorney general to learn those rights. . You must be told ifinformation in your file has been used against you. Anyone who uses information from a CRA to take action against you -- such as denying an application for credit, insurance, or employment -- must tell you, and give you the name, address, and phone number of the CRA that provided the consumer report. . You can find ont what is in your file. At your request, a CRA must give you the information in your file, and a list of everyone who has requested it recently. There is no charge for the report if a person has taken action against you because of infor- mation supplied by the CRA, if you request the report within 60 days of receiving notice of the action. You also are entitled to one free report every twelve months upon request if you certifY that (I) you are unemployed and plan to seek employment within 60 days, (2) you are on welfare, or (3) your report is inaccurate due to fraud. Otherwise, a CRA may charge you up to eight dollars and fifty cents ($8.50). . You can dispute inaccurate information with the CRA. If you tell a CRA that your file contains inaccurate information, the eRA must investigate.the items (usually within 30 days) by presenting to its information source all relevant evidence you sub- mit, unless your dispute is frivolous. The source must review your evidence and report its findings to the CRA. (The source also must advi3e national CRAs -- to which it has provided the data -- of any error.) The CRA must give you a written report of the investigation, and a copy of your report if the investigation results in any change. If the CRA's investigation does not resolve the dispute, you may add a brief statement to your file. The CRA must normally include a summary of your statement in future reports. If an item is deleted or a dispute statement is filed, you may ask that anyone who has recently received your report be notified of the change. . Inaccurate information must be corrected or deleted. A CRA must remove or cor- rect inaccurate or unverified information from its files, usually within 30 days after you dispute it. However, the CRA is not required to remove accurate data from your file unless it is outdated (as described below) or cannot be verified. If your dispute results in any change to your report, the CRA cannot reinsert into your file a disputed item unless the information source verifies its accuracy and completeness. In addition, the CRA must give you a written notice telling you it has reinserted the item. The notice must include the name, address and phone number of the information source. . You can dispute inaccurate items with the source of the information. If you tell anyone -- such as a creditor who reports to a CRA -- that you dispute an item, they may not then report the information to a CRA without including a notice of your dispute. In addition, once you've notified the source of the error in writing, it may not continue to report the information if it is, in fact, an error. 11004 72995 9/12 ~'llih>tl.UI!,gH.~,h""';W;"bk"",il0~!1L';;;..%""",0b>;"",.&':,,;!, "'-' _,,,<,,~,,,~,"-.iy,, .",'>-"K'"f;~< ,ldd';,~MiiM~~~~~~~il!!~~,",,~~~Iiit\jU[.lij' "" '.' ~i ...! . Outdated information may not be reported. In most cases, a CRA may not report negative information that is more than seven years old; ten years for bankruptcies. . Access to your file is limited. A CRA may provide information about you only to people with a need recognized by the FCRA -- usually to consider an application with a creditor, insurer, employer, landlord, or other business. . Your consent is required for reports that are provided to employers, or reports that contain medical information. A CRA may not give out information about you to your employer, or prospective employer, without your written consent. A CRA may not report medical information about you to creditors, insurers, or employers without your permission. . You may choose to exclude your name from CRA lists for unsolicited credit and insurance offers. Creditors and insurers may use file information as the basis for sending you unsolicited offers of credit or insurance. Such offers must include a toll- free phone number for you to call if you want your name and address removed from future lists. If you call, you must be kept off the lists for two years. If you request, complete, and return the CRA form provided for this purpose, you must be taken off the lists indefinitely. . You may seek damages from violators. If a CRA, a user or (in some cases) a pro- vider of CRA data, violates the FCRA, you may sue them in state or federal court. The FCRA gives several different federal agencies authority to enforce the FCRA: FOR QUESTIONS OR CONCERNS REGARDING: PLEASE CONTACT, CRAs, creditors and others not listed below Federal Trade Commission Consumer Response Center - FCRA Washington, DC 20580 *1-877-FTC-HELP National banks, federal branches/agencies offoreign banks Office oftbe Comptroller ofthe Currency (word "National" or initials "N.A" appear in or after bank's name) Compliance Management, Mail Stop 6.6 Washington, DC 20219 *800.613.6743 Federal Reserve System member banks (except national banks, and federal Federal Reserve Board branches/agencies oftbreign banks) Division of Consumer & Community Affairs Washington, DC 20551 *202A52~3693 Savings associations and federally chartered savings banks Office ofTIuift Supervision (word "Federal" or initials "F.S.B," appear in tederal institution's name) Consumer Programs Washington, DC 20552 *800.842.6929 Federal credit unions National Credit Union Administration (words "Federal Credit Union" appear in institution's name) 1775 Duke Street Alexandria, VA 223 14 *703-518.6360 State-chartered banks that are not members ofthe Federal Reserve System Federal Deposit Insurance Corporation Division of Compliance & Conswner Affairs Washington, DC 20429 *800-934-FDIC Air, surface, or rail common carriers regulated by fonner Civil Aeronautics Department of Transportation Board or hlterstate Connnerce Commission Office of Financial Management Washington, DC 20590 *202.366.1306 Activities subject to the Packers and Stockyards Act, 1921 Department of Agriculture Office of Deputy Administrator ~ GIPSA Washington, DC 20250 *202.720.7051 11004 72996 10/12 ~r '" "- ~ " L I ~ iIDIiIll. ~ , ~ . -.- ~ To lIispute information on your credit report, please complete this form and return it to Trans Union Consumer Relations. I If any of this information in the box on the left is incorrect or incomplete, write the corrections in the boxes on the right. 11 16 APPLE DR MECHANICSBURG, PA 17055 ~'."I Name: CHANDLER, REBECCA, L other Names(s): VEACH,REBECCA,L Name: Address: Social Security Number: 198-50-3535 Date of Birth: 1211965 Driver's License Number: Telephone Number(s): 795-0190 Employer: MORNOSEVICO :2 Tell us what you disagree with on your credit report. .use the additional space OD the back of this form if necessary. Company Name: Account #: Account #: The reason I disagree: Ell This is not my account Ell I have never paid late Ell This account is in bankruptcy Ell This account is closed Ell I have paid this account in full Ell I paid this before it went to collection or before it was charged off Ell I ...... .,..' . '. ..., /d ' The reason I disagree: Ell This is not my account Ell I have never paid late Ell This account is in bankruptcy Ell This account is closed Ell I have paid this account in full Ell I paid this before it went to collection or before it was charged off ElIlomer: .', . . I Return this form to: TRANS UNION CONSUMER RELATIONS P.O. BOX 2000 CHESTER, PA 19022-2000 Side 1 11004 72997 11/',2 !liiiiil~"llii<MJliliSt!li;ib;'"",Jl,_~~d, ",,,,j;''1{~,,-~~!l&1,,,",,~H~''''i-f>:*'''',f,..~ ,~,^".g-~.!-1i' "tl,-""-"..,""I~hh1!ililll~llil' I r -~ tilJi_]IIIi&'ilI~",,=-~~_l.k.-w.~~JaIIl 1rI iUl ~ ~,~ --!l File Number: 106292483-001 Additional space for :J( Tell us what you disagree with on your credit report. Company Name: Account #: The reason I disagree: Company Name: Account #: The reason I disagree: (:..:::::,;,:':~:::?::: ?:::;::::::::~: ::?::::?::::.::::;'??::::::::;'?:; :~:r'}:,:;:::.:::,::::?:: ;".:.;".:...::..:....:..'::'......:...:.:.:....:..:..::....:..." ':.:.:...:.:..:.........;..:......:::.:;:.::.:::'..... EI This is not my account EI I have never paid late EI This account is in bankruptcy EI This account is closed EI I have paid this account in full EI I paid this before it went to collection or before it was charged off E1I';';.;;"';;';"';.'i;;.';'.I';;;'.;;;:';.;,;.';i'.,:.,,:: ., 1:.0~~]~i:.....':J.:..;.. EI This is not my account EI I have never paid late EI This account is in bankruptcy EI Th is account is closed EI I have paid this account in full EI I paid this before it went to collection or before it was charged off Ell.'..........,.... ,.~;~s~ /1 Company Name: Account #: The reason I disagree: Company Name: Account #: The reason I disagree: EI This is not my account EI I have never paid late EI This account is in bankruptcy EI This account is closed EI I have paid this account in full EI I paid this before it went to collection or before it was charged off Ell EI This is not my account EI I have never paid late EI This account is in bankruptcy EI This account is closed EI I have paid this account in full EI I paid this before it went to collection or before it was charged off E1r..;';';.;';"';,.,"";',.;,.,',..,;';,.,;; ""'I~~wI . 4., Optional: Write any additional comments. For example, tell us if you have any corrections to your previous address or previous employer. Additional Comments: . - , ." "" ~. Side 2 .~ ~- ''"~,~. .~~, ~~._=~ ~",J ~ 11004 72998 12/12 " I, ",-;~.- >' "--" James, Smith, Durkin and Connelly LLP P. O. Box 650 Hershey, PA 17033 TAX ID# 25-1584038 Phone: (717) 533-3280 Fax:(717) 533-2795 Rebecca 1. Chandler 1116 Apple Drive Mechanicsburg, P A 17055 Attention: File#: Inv #: Jul 02, 2002 02-5173 75775 PROFESSIONAL SERVICES RENDERED: HOURS AMOUNT LAWYER Jun-20-02 Review memo, letter and Property Settlement Agreement. Meeting with John Connelly to discuss case. Place call to client. Preparation of fee letter. 1.40 210.00 CLK Jun-21-02 Phone call to client regarding fee letter. 0.10 15.00 CLK Totals 1.50 $225.00 Jun-25-02 Credit Card Payment - 500.00 Total Fees, Disbursements $0.00 Previous Balance Previous Payments Balance Now Due o Recent Fees and Disbursements may not be entered on your account and, if not, will be subsequently billed. Statement reflects previous month's information. Payments received after the last day of the month will be reflected on the next statement. Please include your file # on your payment. Thank You. 2> ,/-2. 'D2- L-IL (' i--.. "'l "",;::::., V't..-O" 1-/, ,1.'.-l!iH~fi,~iil~~~I1l\1""iW~;t;f""i"-c~:ii:~,;;".~~ 'UlrIlIillillliillL ~-, t;~~~c.~' iJi:.'J. James Smith Durkin & Connelly, LLP Trailer Report -i-1ir.... <""'" Date Printed: Report ID: Report Description: Printed By: 09/23/2002 GLIOlO.246 General Ledger Trial Balance RAR "'$ange(s) Selected: Account Number [8009 - 8009] Journal Entry Date [08/27/2002.09/30/20021 Sort(s) Selected: Sub Total Level (Ascending) Account Number (Ascending) Sub Account Number (Ascending) JE Date (Ascending) Journal Number (Ascending) Option(s) Selected: Profit Center: * ALL Show Details: True Page Break on Account Number: False , ,. -""" ~-...,""'-~.- ",~ ,..".=" ;'t ~ ^ < ',-- ~-',,- ,-I: --J t~ c4 James, Smith, Durkin and Connelly LLP P. O. Box 650 Hershey, P A 17033 TAX ID# 25-1584038 Phone: (717)533-3280 Fax:(717) 533-2795 Rebecca 1. Chandler 1116 Apple Drive Mechanicsburg, P A 17055 Attention: File#: Inv #: Aug 20, 2002 02-5173 78342 .--------------------____________________________________________________________________________________________..____________________M_______________ PROFESSIONAL SERVICES RENDERED: Jul-31-02 Draft petition. Phone call with client. HOURS AMOUNT LAWYER 0.80 120.00 CLK 0.40 60.00 CLK 0.10 15.00 CLK 0.10 15.00 CLK 0.10 15.00 CLK 0.20 30.00 CLK 0.10 25.00 JJCJ 0.20 30.00 CLK 0.10 15.00 CLK 0.20 30.00 CLK 0.20 30.00 CLK 0.50 75.00 CLK Jun-24-02 Reviewed letter. Wrote letter. Jul-01-02 Review revisions and make corrections. Phone call with client re: letter revisions. Jul-03-02 Phone call to client. Jul-04-02 Phone call to Tom Chandler. Phone call from Tom Chandler. Jul-05-02 Phone call from Tom. Jul-08-02 Discussion with client regarding Tom's conversation with me. Phone call to client. Received message from Tom. Phone call to client. Phone call to Tom. Jul-26.02 Phone call from client re: petition. Travel to meet client to sign verification. Meeting with client and return to office. , ' - " M Invoice #: 78342 August 20. 2002 ... Jul-02-02 Page 2 Make corrections to petition. 1.30 195.00 CLK Totals 4.30 $655.00 Retainers Carried Forward 275.00 Total Fees, Disbursements $380.00 Previous Balance Previous PaYlnents Balance Now Due , Recent Fees and Disbursements may not be entered on your account and, if not, will be subsequently billed. Statement reflects previous month's information. Payments received after the last day of the month will be reflected on the next statement. Please include your file # on your payment. Thank You. . , , ~ "-I ,.. 'P_ '''"i, iti.-i>"fi-, ... James, Smith, Durkin and Connelly, LLP P. O. Box 650 Hershey, PA 17033 TAX ID# 25-1584038 Phone: (717) 533-3280 Fax: (717) 533-2795 September 23, 2002 Invoice# 91779 Ourfile# 030378 025173 Rebecca 1. Chandler 1116 Apple Drive Mechanicsburg, PA 17055 Balance forward as of invoice dated August 20,2002 Payments received since last invoice $380,00 0.00 Accounts receivable balance carried forward $380.00 PROFESSIONAL SERVICES RENDERED: 08/05/2002 Return call to Tom 08/12/2002 Update client on telephone call from Tom, 08/23/2002 Telephone conference with client re: bill, HOURS 0,10 0,10 0,10 0.30 Billing Summary Total professional services $45.00 Total of new charges for this invoice Plus net balance forward $45.00 $380.00 Total balance now due ** Trust account remaining balance is $425.00 Please include your file # on your payment. Thank You. AMOUNT 15,00 15,00 15,00 $45.00 LAWYER CLK CLK CLK ~". " .iIlri.lt;s;.:" "'~ REBECCA 1. CHANDLER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-616 THOMAS M. CHANDLER, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 30, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service ofthe Complaint 3. I consent to the entry of a fmal decree of divorce after service of the notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifrcation to authorities. Date: q- :A./- 19/ ;;;;L ---111 ~.-1 Thomas M. Chandler, DEFENDANT . !--:" fit nrT ,~ ~'I ";1,,, - J i~, -,_I t'f I ,~). C' I t_.. .,} : CUlv; ~~~i,,~;-; '~'S ~~'::<~!.')_~J ij"'~1 J~ f1Y l ' I,J\'''-'','' \.. ..J."I\I _ i ,V l L~</\NIA I i ~ ~ ~ ~~ l "f -$, 1 1: ~ ~ :!1 ~ ~ \fJ ~ ~ I ~ ! ijg ~ ,~ ,-L ~ - " ~ ~ ~ - ~W:Eb'" . . " ' REBECCA 1. CHANDLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-616 THOMAS M. CHANDLER, Defendant CIVIL ACTION - 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: I. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and marmer of service of the complaint: February 9, 2001 by USPS certified mail, restricted delivery. Affidavit of Service filed September 28, 2001. 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 September 21, 200 I; by Defendant September 21, 200 I. (b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b )(2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None ":,,,",,'I!l:ll "'"" ~ co 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: September 28,2001. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 28, 20 . PO Box 6656 Harrisburg, PA 17112 (717) 652-9485 ID # 36817 G! or.-r I , "l, 1 I o. . I: ?: 23 _Wl I , i I CiJ\,!;~tn~~<:> \~,~; (::0: Ie, IT i r ll',"'4",,\,'r\H 'J Ji\il) . ! ,..) LI"Fd\1,I/\ " ill j . ij ~~ , '! ~ j ,~ . :? ~ I I . ~i I ~ " " .,~ ~ i --. ,'" ,,,' .'" f ~ MARITAL SETTLEMEN'l' AGREENBNT AGREEMENT, made this S+i\daY of ~, 2000, by and between llEBECCA L. CHANDLER, hereinafter referred to as "Wife", and THOMAS M. CHANDLER, hereinafter referred to as "Husband" . WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on June 29, 1996. There is one child born of this marriage, said child being Christopher, born December 16, 1996. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or main~enance of Wife by Husband or of Husband by Wife; the settling of all matters relating to the children of the parties including custody, visitation and support; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. "";'"-"<!!IJ( I,',v t' . -":- ". " .., , , ':..:f .'~ ',~ I i ,."',','" C"", A I . ,. ., " .' . 1\ *' " if ~-..,F ,. 'I.';, '. i .,. ,-- ~, " NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable considerations, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1.' A,GlREJl:MENT NOT A BAR TO DIVORCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed a condonation on the part of either party hereto of any act or acts on the part of the other party which have occurred prior to or which may occur subsequent to the date hereof. 2. EFFECT OF DIVORCE DECREE. The parties agree that, unless otherwise specifically provided herein, this Agreement shall continue in full force and effec~ after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the pa~t~es hereto that this Agreement shall create contractual rig~ts and obligations entirely independent of any Court Order and that this Agreement may be enforced by contract remedies in addition to any other 2 Ill" """",,~ '"'M'" ,I, i ~~ -;. I .,",' , , '--",) ,I'- ,~ . 'I',','..,'",' ' ~ '~ . " " / '. '.."',.,.",',', ,. ., .! .. :'. -,"" ,,,I. ,.Iii ,,- .1,'".,",'.,.,. . , , S ':, I i. I ',,,,.__: i '~" l ; " .. 'Ii" :-, '" ."" - ",'.,' '. ,~, :~~!,' ""ill,. II? j, ,'", .' Wt ','."J 'I' -, ,: ,-' "fi~::' ill ,.l'" ,~ I "1" ; ,~,' . , ~ fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable; that it is being entered into freely and voluntarily, after having received such advice and with such knowledge; that execution of this Agreement is not the result of any duress or undue influence; and that it is not the result of any collusion or impropeJC or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full and complete disclosure of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. Each party agrees that he and she shall not, at any future time, raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. 6. PERSONAL RIGHTS. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respeccs as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. 4 ~-L&>>,,gl-ii __,,'- ,.. j . i it , , . . '. t Ii- ., . - I 'I it . ".,', ~; . " t - " ~ ~~ .,,--, ,-"'" ,- '< ^ lliiil. "jillr ~ Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell, by any means or in any manner whatsoever, with him or her. 7. S~S~QUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent co-habitation or resumption of marital relations, unless the parties otherwise specifically agree in writing. 8. ~~ RELEASES. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature or wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nat~re of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate ~aws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testame~tary, or all other rights of a 5 """"" ,," '" .., ~ ,I;;" ., '", '. .i , . ~ . ". ,< , .'".,,3.,. -'-"'" ,',,-: .a, ce. .>';', . .::. .", ' , . Co", :"..,., ".".,'" " i .i I . . ""',',.., '. 'c' rt 11 it t I'"."".,'., ' . , ' .. .. .. , . ,.... ~ ~ -, ~ surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relation or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of ,whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 6 '~iWi:&.@' b<< >14.: .'. -::"",...':, ,'\ ;-" . ".. ',', ., -'," ,. t " ., i. t ~ " I' - i.: ,I".,iij~ , ' I,,', I. ~, ~~ . . i,-i " It . "',', ' i ",. it '. '>".' J _~ ~ 9. BANK ACCOUNTS AND RETIREMENT ACCOUNTS. Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that these accounts and plans shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title or interest they may have in the other parties' account. 10.' PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have divided their tangible personal property, including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the proper~y of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. (See Exhibit A for partial allocation). The parties do hereby specifically waive, release, renounce and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties further agree that the following items shall be shared by the parties: lawnmower, blower, hedge trimmer, "sawzall", weed trimmer and edger. The parties further agree to share equally in any repair expenses for the shared items. 7 -~-'^ ~- ~ ;A!'-' I ".",e",. '-;, ~ .. .. 'I.,..",", -.,:, . .,t.. .,..'.",...i.,',.,,"', j ..", ','," . . , '. .",.',',..',.,.., .. .' .t .',.".,' , , .~, ~'-- '. ~:__'d' ,t."" " t'," . . ,m"., :.- ",.1' \.,"" ~ t ~, 1 -, ~ , -. ~ " T -,_ .--' ~ 11. AFTER-ACQUIRED PERSONAL PROPERTY. Each of the parties " shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 12. REAL ESTATE. Husband and Wife are the owners of a house located at 1116 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania. Wife shall assume full responsibility for the payment of the mortgage, taxes, utilities and maintenance. Husband agrees to execute a deed to transfer his interest in said property to Wife on or within 3 months after February 1, 2003. If both parties agree, husband may transfer his interest prior to February 1, 2003. If the property is sold prior the the execution of a deed of transfer, husband shall not be liable for any settlement costs, nor shall he share in the proceeds of sale. Further, Husband agrees not to e~ter the home, nor to remove items from the home, or otherwise attempt to exert any control of the use or renovation of the home. 13 . AUTOMOBILES. The parties are the owners of various automobiles. Wife shall be the sole and separate owner of any vehicle titled in her name and/or in her possession at the execution of this agreement. Husband shall be the sole and 8 "",,-i i")> , ..,. '" ,. I '. I,'".,'..',', ' " I', ,,'I'.,,::.; '. I "'&,d. '. j . ,I,."',.'. -'," ',.,.., .'. ,-.;~ II .' ;1_' ",:' 'I",j(" " ' iF'; .,..,','\,....' , "'''' . "M :,...,:', ~ i "'-~ . . I "' '.' " separate owner of a van titled in both his and her names and in his possession at the execution of this agreement. Each party agrees to execute all documents necessary to implement this paragraph. Husband shall be solely responsible for the payment of the loan on the vehicle in his possession and shall indemnify and hold wife harmless for the repayment of said loan. 14. C~T LIABILITIES. Wife shall be solely responsible for payment of the mortgage, utilities, taxes and insurance on the house at 1116 Apple Drive. Further, Wife shall be responsible for all individual bills which she has incurred since the date of separation. Husband shall be responsible for all individual bills which he has incurred since the date of separation. ). 5 . ~ OF ALIMONY PENDENTE LITE AND PAYMENT OF LEGAL FEES. Each party hereby waives any right to alimony pendente lite and the payment of legal fees. ). 6 . RELEASE, OF SUPPORT - ACKNO~GEMENT ,OF ADEQUACY. The parties herein acknowledge that, by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support or 9 ,-~, JlllJ~9;j'~1 f~'", '. . I,',.,.",'.,'"",, , :'",,, ,,' , . ,""*',' . ,i ..",',",',', , ~ ,-: '."'" ' , o "i~: "."" " - . r4. ~~ . t ,. I',"" ,"'. ;, ; -:',.,'; . "I: , ~* _, J -, ,,~-_,'" , ~ maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 17 . CUSTODY AND VISITATl:ON. Husband and Wife shall have shared legal custody of the parties' child. Wife shall have primary physical custody. Husband shall have liberal periods of partial physical custody, not less than every other weekend from 5:30 pm on Friday un~il 6:00 pm on Sunday. Wife shall be responsible for transporting the child no farther than 25 miles from child's current residence. Husband shall be responsible fro remaining transportation. 18 . CHILD SUPPORT. Husband agrees to pay $80.00 per week directly to Wife. If not paid, Wife will file a formal complaint for child support wi~h the applicable Court. The parties agree that this amount shall be reviewed every February and July. This review will consist of providing pay stubs for the previous six month period to determine the current applicable rate of support. Husband agrees that no expenses shall be deducted from the weekly sum for out-of-pocket expenditures. Husband further agrees to pay one-half of any uninsured medical and dental expenses, as well as one-half of any child care costs. Any further support shall be as agreed by the parties or, if applicable, the Court. 10 JLAL,! !,J'W'--' '.,i' eo,,^' 1(' 'I ' ,,~ , '::'f""':-- ~ '. i. .,," , ' './,!,"". . . .,1"".",/."., ;.>, 'i' , ,>Ioli" ; f!.' I, i ;JI"" !.' ''.> /Ii . II i ',.,',",' ;;~: t '\'1) .) , ~, , I '-. " 19. MDTOAL CONSENT DIVORCE. The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counselling, and that they both consent to the entry of a decree in divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (herein referred to as the Code). Accordingly, both parties.agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of The Code. Upon request, to the extent permitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce. 20. WAlUUWTY AS TO EXISTING OBLIGATIONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligations for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for 11 ""1$1'" 'ii&!t" . .. "''-'',, f .e/' .. i,ll' ,:.:' .'i&,'i',', " ,0";"/ t ,",', } .- ,..,',', , '.", ' , ,,' '~',\< 'I' ~ " , /I .,,1",... . ;, , ,. ." '" '6,,',',',' ".. \I Ii " .;Ii; -J. '.".,r" ~~ ",",- ~, . necessities, except for the obligations arising out of this ~greement. 21. ~y AS TO JrUTul(2 OBLIGATIONS. Wife and Husband each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate.of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 22. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 23. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the ether party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 12 .~, k;~L " .. i . . . . . , i " - " . ft. .... .,; 11 '"' " r "I 'i' .'{.~ ,~ - . , ~-~ ~ 24. LAWS OF PENNSYLVANIA APPLJ"Mk1lToE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 25. AGREEMENT BINDING HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 26. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 27. NO NAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 13 - - ~ '" '~~~.rmil- H0'i t "., .:,~. t',',','", \ ,t.".,",.'.,",,' . '.,..,'""",.,',',, j, , , . '." f ,,'i,',"',' . I'"~ , ' ",:' . ,,& '~ l;r~.... '.:",y, i Ii ,'",,' I',. ~ ", ~'- ez: ". -' ; -,<-,,' ,&,',',' "',',, '.' :1 '. ;',< :I ,. '1',",' , , i ",~,' .' >~ '~" ' ~ 28 . ENFORCEMENT OF AGREEMENT. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her. 29. SEVERABILITY. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall, in no way, void or alter the remaining obligations of the parties. 30. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement, nor shall they affect its meaning, construction or effect. 14 -......""""ill i;"_~ ;- ;~. . '. '. i. <", ....,.,,','. t ~ " .' ;" ' . " .,"'", . " , ~","" .' ,.',,""; " " . ~ !,.. . i' '."; " .' ;:7~ " , ,-,", :". e"". . 'I&: .; 'I:;'" " ~- " ;, " " ',v.;, It I] ... :;!lI!; . ., ~ ~ ~' ,.- , ~ IN WITNESS WHEREOF, the parties hereto have set their hands and seal the day and year first above written. ~w~~, ~/ {~~/?f/~/L/1 .~ci-- jl-/ L..//r.c:V"'1L& ~_ REBECCA L. CHANDLER ~~-~, . ---;-~/l/ u.~ 'THOMAS M. CHANDLER 15 "'~,;:,,'i I L\; " ,'i,',',,"',',,", .~, ',I" : .,. .)~(; "~ " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :ss. [.;,f_ day of On this, the ~2 /-%5!1~ , 2000, before me a Notary Public of the Cornrnonwealthof Pennsylvania personally appeared REBECCA L. CHANDLER, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. '-ro~ NOTARIAL SEAL I MICHAEL R. CARANCI, Notary Public , Camp Hill Bora. Cumberland County : My Commission Expires June 15, 200? 16 . -~i:tl~~-' I@, .',',,',y,i', ' , . '.' I !',;~- "'-~ ., .liAk,-2U"UJ(TUii} U~:S~ TEL: 71 i73i6658 . COMMONWEALTH OF P~NNSYLVANIA :ss. COUNTY OF CUMBERLAND .~ ~~; On this, the .i:t:: day of ;:;;~Be , 2000, before me, a Notary ?ublic for the Commonwealth of Pennsylvania, personally appeared THOMAS M. CHANDLER, known to me to be che person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WlBRSOF, I have hereunto set my hand and official seal. ~~~. NOTARIAL SEAL MICHA8. R. CARANCI, NIl\BIY Public , c..,p Hili Baro. CUrnbelIeIl1f Coun~ MyCommlssllln..~lresJuIl1l1~. ",n 17 .-';''''''-'-''.-<" POOl .'-~llH --,~; Ii" I :/ ~ I. ~AR,-j4'O!IWED) 13:40 - ',1 f. ',' REBECCA Snowblower SllIIlIlISsolllllent of hand tools 3 small air conditione.. Present cODlenulfurnilUre Crock pot Elecrric knife. hand lIliAer Microwave 2 TV, and VCR CO, and videotapes Small stereo Car -,,' ,-. ~; ,- .- TEL:)lJ7376658 P 003 " .~ mOMAS All powerlOols Hand tools. " Room air conditioner l> of dishes. utensils, pots, P.... Sel'Ying dishes T owe!$, washrag. Blender Toaster oven 2 TV, oDd VCR Ceiling ran Co. and videotape, Stereo Futon, dre$ser, chair Tillie, TV ,land Kitchen table 2 cluWs All .... products/tool; Cwsrers Va LoveSe()..+ Also sho.nV19 Vld~o' CQWle nt , EXHIBIT IlAt! ~"'!IL ~1'-' :~ ;- - ~ I" 1 .' ~ i ~'T..~~"i~Y ""'-',", ,~" ': 1 ('-),-j 2: 2'0 CUi\.'!: '_ (>_~jUf'JTY f:'c>~i'~:)Y L\'//J<i/\ '; I ~ I ~ ~ ~ m !ji ~ ~ I I I ,_ _ _ ___M'- _ ~ ,__~ "~~~& .... , ~' -- ..,-,--_-O.......e' ~., -" ",- ,..- """';'~,^~ -.-';-" ,,-"7, ,'" ".""C>""'~.,"'"N''"''''"'. ,_, "_,, '_'-[.;j , , REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-616 THOMAS M. CHANDLER, Respondent CIVIL ACTION - LAW : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this 'lJltdaYOf ~ , 2002, upon consideration of the foregoing Petition to Enforce Property Settlement Agreement, a Rule is hereby entered against the Respondent, Thomas M. Chandler, to show cause why he should not be held in contempt. Rule returnable in writing dO days from the date of service. J. [la-pJQD~~ f- g-7'OJ<. lRXS 1:.0: oJty C.ha.~d\ep. j~le~J ~tnii-hJ tJU.R~iJ". Co/JeJlr " l, - .., "-, -,", ,I"" ". ,-," ~'I;' ",,---~,' ,~-..,'" "', .~ >- ," ~",. ,-. - - ~. !"': FILED-OfFICE OF T:-1~ '-:'-ryr; !CNOTARY 02AUG-? Atill:[,4 CU'ip.r:,:c "'\'" (-r'UN, iTV I\:H...I.....l.t...r\,.;\,j ~..., i Ii l PENNSYLVANIA --, ',"""k""",~<_~ ^..,,,<,.,,,,-,.-'1"C ""-"'-~':~' ,-~-, -'~'" ',-""-" ' " " ~- ~ 'C-' ,,- ;-'-'-01'."-,-" '-^,' <'~"',,-...." ,.,.. ;, " ~ , .,--:c ~, -:oJ. -~;;J ,~"' "', _n_-'",..-_:,',,;_, ,../~ '.if'. .J_"';;~~_'.,; ,,<~",;"_'h-;-_; '=.'. '" '-,,' ,,,,,-,'~ ;J I I REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-616 THOMAS M. CHANDLER, Respondent CIVIL ACTION - LAW IN DIVORCE PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT AND NOW, this 31 ST day of July, 2002 comes the above-named petitioner, by and through her attorney, Courtney L. Kishel, Esq., and the law firm of James, Smith, Durkin & Connelly, LLP, and files this Petition to Enforce The Property Settlement Agreement, and in support thereof avers the following: I. Petitioner is Rebecca L. Chandler, who resides at 1116 Apple Drive, Mechanicsburg, Pennsylvania 17055. 2. Respondent is Thomas M. Chandler, who resides at 412 S. High St., 1st Floor Mechanicsburg, Pennsylvania 17055. 3. The parties were married on June 29, 1996. 4. On October 19, 2001, a decree in divorce was entered at the above-captioned docket. 5. As part ofthe divorce action, the parties entered into a Marital Settlement Agreement on September 5, 2000. The agreement is attached herein as Exhibit A. , , ~ t~,,~ c '. "" ,,' , ,; , _,'.e , '-'."-;,' 'r""-_',--'J;:~',, , "-"'--",;~ ..-_IN.'.' _,___, ,~ .. c"'"". ~",;, , .~i--0-,'C' ., . ,~- . "-'- , 6. The parties owned several vehicles, which were subject to distribution. Respondent received possession ofthe parties' van, which was encumbered by a loan in both Respondent's and Petitioner's name. 7. According to paragraph thirteen (13) of the Agreement, the parties agreed that the "Husband shall be solely responsible for the payment of the loan on the vehicle in his possession and shall indemnifY and hold wife harmless of the repayment of said loan." 8. Petitioner has learned that Respondent has failed to make timely monthly payments to the vehicle in his possession. As a result, Respondent is in violation of the Marital Settlement Agreement. 9. Petitioner avers that her credit rating has been negatively impacted as a direct result of Respondent's failure to make timely monthly payments on the vehicle. 10. Petitioner believes and therefore avers that if Respondent fails to make timely payments on the vehicle in Respondent's possession, Petitioner will be necessarily be forced to assume the liability. II. Petitioner believes and therefore avers the only way to remedy this situation is to have Respondent obtain alternative financing and have her removed from the loan. WHEREFORE, Petitioner prays This Honorable Court grant her relief and order Respondent to immediately obtain alternative financing for the vehicle in his possession, to be solely in his name, and removes her from any further liability. "'- -,--,-- ~,', - -,,;'" ,,-.~;._J; ,---:; , ,,_ "_~.' ,..,'__,,; _>,:" ~~_ 0 ';"-'~U;;;;-",""o' -"\'- COUNT II. REOlJEST FOR ATTORNEY'S FEES 12. Paragraphs one (I) through eleven (II) are incorporated herein by reference. 13. Paragraph twenty-eight (28) of the Marital Settlement Agreement provides in part, "The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her." 14. Respondent is in breach of his obligations under the Agreement in that he has failed to timely maintain payments on the vehicle that he possesses. 15. Petitioner has incurred legal expenses, including but not limited to attorney's fees, as a result of Respondent's breach of the Martial Settlement Agreement. WHEREFORE, Petitioner respectfully requests This Honorable Court order that Respondent pay for any and all necessary legal expenses incurred in initiating this action, directly resulting from his breach of the terms of the Marital Settlement Agreement. Respectfully Submitted, James, Smith, Durkin & Connelly, LLP P.O. Box 650 Hershey, PA 17033 (717)533-3280 -, - nr r"-..jt:J~.:::.t:JlUc. .1...)..l~ l'IUKNt;HU :SUl:It;CO P.03 717 737 5558 " Mll.1UTAI. SETTLENEN'r AGREDa:NT AGaZZMSw.r, made this 5+h.~y of ~, 2000, by ar.u;l bG tween REBECCA L. cEANtlLE1\, hereinafter :;:efe:r:rec:l to as "Wife", OUlQ 'rBOKAS K. CIlANDLER, hereinaf1:er referred to as "Husband" . WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on June 29, 1996. There is One child born of this marriage, said child being Christopher, born December 16, 1996, WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution or such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; the settling of all matters relating to the children of the parties including custody, visitation and support; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. . 1l<W: _.'" , . '. . . f.,: , " , .,0," '. . f :. \1It " :ifti. ,.,"..,' ~,~ ..".,i, '~,;:,~ "--., ':~ ,> ft ~::",,"~ ".'t' _\'t' ./" ", '. L ~ 1-, ,_ ~-'--- ,""'L - '" RPR-30-2802 13:12 MORNERU SOBECO 717 737 6658 P.04 : ' NOW, TBERZiORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable considerations, receipt of which is hereby acknowledged by each of the parties heteto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1.. AGREma:NT NOT ~ BAR TO D,IVOl1CE PROCEEDINGS. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and sh,all not be deemed a condcnation on the part of either party hereto of any act or acts on the part of the other party which have occurred prior to or which may occur subsequent to the date hereof. 2. EFFECT OF DIVORCE DECREE. The parties agree that, unless otherwise specifically provided herein, this Agreement shall continue in full force and effec~ after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the pa:t~es hereto that this Agreement shall create contractual rigits and obligations entirely independent of any Court Orde: and that this Agreement may be enforced by contract remedies in addition to any other 2 ~LM,I i':J~; . ('Y,_" , ',':', , i :.. ~~~ " ;~If 'f, :"11 i III r . II Ii! j:, I;' , l:iiililo:l' ~l ~ ,-. . -- '~ APR~30-2002 13:12 MORNEAU 50BECO 717 737 6658 P.05 fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable; that it is being entered into freely and voluntarily, after having received such advice and with such knowledge; that execution of this Agreement is not the result of any duress or undue inflUence; and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full and complete disclosure of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. Each party agrees that he and she shall not, at any future time, raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraUdulently withheld. 6. PERSONAL RIGHTS. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respec~s as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. 4 "!,ii~, " I a Y,~ I .,"," .. ."~",' , " I"", , . ',:\',' :1 , , ~','" :a.,' '~'~ .J I'," " ~, ~~' i ,..l ~ ..,', , ~' " .," v. .' ~,,',' '~ " . - - ~ RPR-30-2002 13:12 MORNERU SOBECO 717 737 6658 P.06 Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell, by any means or in any manner whatsoever, with him or her. 7. SUBSEQUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent co-habitation or resumption of marital relations, unless the parties otherwise specifically agree in writing. 8. MUTO~ RELEASES. Husband and Wite each do hereby mutually remise, release,. quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property here~fter accruing) of the other or against the estate of such other, of whatever nature or wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out cf any former acts, contracts, engagements or liabilit.:.es of such other or by way of dower or curtesy, or claims in the nat~re of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate ~aws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testame~tary, or all other rights of a 5 iIi,jj, Ifi;i.- ,; ., ., ., " .'.: ;1; 'I' I ,.Ji.' ',. ,. t t A... ":r': ,J!& '. .iii, 'II' ",' ., i- .' ... It &.... ",. ~It '~r!' ,,~I.I:"- ,,'" 41"" :., ,~( , .,i1.'.1 ,~. -r ~. . ( !,". -~- ~l:: ',. -i.... '.. RPR-30-2002 13:13 MORNERU SOBECO 717 737 6558 ,.I , .. surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (el any other country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relation or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to eaCh other the execution of this Agreement a full, complete and general release with respect to any ana all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 6 P.07 1li\!W;,~e ,t I I " 'I.".:,.. '.~, " ,.' " Z.': '", " f- t " Ji.' -;~ * ,. .. ;,It .4~ ~~ r :,~, .~' 4l~ ' ~ j, ~-- " ~ RPR-30-2002 13:13 '" MORNERU SOBECO 717 737 6658 9. BANK ACCOUNTS AND RlTIRBMEHT ACCOUNTS. Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that these accounts and plans shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title or interest they may have in the ether parties' account. 10. P~RSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have divided their tangible personal property, including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the proper~y of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. (See Exhibit A for partial allocation). The parties do hereby specifically waive, release, renounce and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties further agree that the following items shall be shared by the parties; lawnmower, blower, hedge trimmer, "sawzall", weed trimmer and edger. The parties further agree to share equally in any repair expenses for the shared items. 7 , "'., '1,\" P.08 '!~4~:'ir t .'" r , .t.. ., ,.. ,~ r'T :f .,( " \ ' '"Ili' r+ ","""""-~ ..oIi ~ ~~ RPR-30-2002 13:13 ! I. MORNERU SOBECO 717 737 6658 P.09 11. AFTER-ACQUIRED PERSONAL PROiERTI. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, ~n all respects and for all purposes, as though he or she were unmarried. 12. REAL ESTATE. Husband and Wife are the owners of a house located at 1116 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania. Wife shall assume full responsibility for the payment of the mortgage, taxes, utilities and maintenance. - Husband agrees to execute a deed to transfer his interest in said property to Wife on or within 3 months after February 1, 2003. If -" - both parties agree, husband may :ransfer his interest prior to February 1, 2003. If the property is sold prior the the execution of a deed of transfer, husband shall not be liable for any settlement costs, nor shall he sha~e in the proceeds of sale. Fu~ther, Husband agrees not to enter the home, nor to remove items from the home, or otherwise attempt to exert any control of the use or renovation of the home. 13 . AU'J.'OMOBILES. The pa~ties are the owners of varlOUS automobiles. Wife shall be the sole and separate owner of any vehicle titled in her name and/or in her possession at the execution of this agreement. Husband shall be the sole and a ,j~; - i' 'I ... .' i . " ,t t Ilk <~' . " i' ., ~ 0.1 ~ _ , ~ " ~ .', ,-,' c.,._ ~PR~30-2002 13:13 MORNERU SOBECO 717 737 6658 P.10 ~ separate owner of a van titled in both his and her names and in his possession at the execution of this agreement. Each party agrees to execute all documents necessary to implement this paragraph. Husband shall be solely responsible for the payment ~ of the loan on the vehicle in his possession and shall indemnify and hold wife harmless for the repayment of said loan. 14. C~ LIABILI~I!S. Wife shall be solely responsible for payment of the mortgage, utilities, taxes and insurance on the house at 1116 Apple Drive. Further, Wife shall be r responsible for all individual bills which she has incurred since the date of separation. Husband shall be responsible for all individual bills which he has incurred since the date of separation. 15. WAIVER OF ALIMONY PENDEN'1'E LITE AND PAnGlN'l' OF LEGAL FEES. Each party hereby waives any right to alimony pendente lite and the payment of legal fees. 16, RELEASE 01' SUPPORT - ACKNOWLEDGEMENT OF APEQTJACY. The parties herein aCKnowledge that, by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficienL financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, support or 9 ~,' ....:~ j~ I . '''" I. }'," , . . . ...1 . t ,~ ,., ,-~>--,.. J-'^ > PPR~30-2002 13:13 MORNERU SOBECO 717 737 6658 P.ll maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 17 . CUSTODY ~ VISITATION. Husband and Wife shall have shared legal custody of the pa~ties' child. Wife shall have primary physical custody. Husband shall have liberal periods of partial physical custody, not less than every other weekend from 5:30 pm on Friday until 6:00 pm on Sunday. Wife shall be responsible for transporting the child no farther than 25 miles from child's current residence. Husband shall be responsible fro remaining transportation: 18. CHILD SUPPORT. Husband agrees to pay $80.00 per week directly to Wife. If not paid, Wife will file a formal complaint for child support wich the applicable Court. The parties agree that this amount shall be reviewed every February and Julv. This ~ review will consist of providing pay stubs for the previous six month period to determine the current applicable rate of support. Husband ag~ees that no expenses shall be deducted from the weekly sum for out-af-pocket expenditures. Husband further agrees to pay one-half of any uninsured medical and dental expenses. as " well as one-half of any child care costs. Any further support shall be as agreed by the parties or, if applicable, the Court. ~ 10 ~, I J ,. &, \p- -. .,,: ., f '. ~. " . .,. 1.1\ll', I~",it-: -<' P~R~30-2002 13:13 MORNEAU SOBECO 717 737 5658 ~ 19. MUTUAL CONSENT nrvoacz. The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counselling, and that they both consent to the entry of a decree in divorce pursuant to Section 3301(c) of the Pennsylvania Divorce COde, Act 26 of 1980, as may be amended (herein referred to as the Code). Accordingly, both parties.agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of The Code. Upon request, to the extent permitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such diVorce. 20. WAlUU\N'r1' AS TO EXISTING OBLlGAUONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligations for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those tor 11 . P.12 """'l>\;; ,~,*i!' I,'" " , . ..rl ~ t " t "... ," '. ," ... \ ., , . , . .., , . '. " ~- RPR~30-2002 13:13 MORNERU SOBECO P.13 717 737 6558 . necessities, except for the obligations ariSing out of this Agreement. 21. WAilMNTY AS 'rO ~U:l.'u~ OBLIGATIONS. Wife and Husband each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate.of the other may be liable. Each party shall indemnify . and hold harmless the other party for and against any and all . debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 22. w.I\l:VER OR MOOIFICAUON TO aE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 23. MUTQAL COOPERATION. Each party shall, at any time and tram time to time hereafter, take any and all steps and execute, aCknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 12 )i;lit.ft!,i ilIit\~ I ~~, \ '. . :. .. '. '.' :. .. :ff' ~l:;l :) :'l _:11 "A ~J !1~-~m_'J {~:[1 ' ,':,,1 1I;.;!1,: ,"C'_ !t , '~:. . - , " , ~ L - ,~"', RPR~30-2002 13:14 MORNERU SOBECO 717 737 6658 P.14 , 24. ~S OF PENNSYLVAIUA APllL:r~!JT,1ol. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 25. ~ BINDING HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 26. O~BER DO~A~XON. Wife and Husband covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 27. NO ~ OF DlrAOLT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 13 'deI',,:\JIIfi'i..<', t~t,' . , .'.' . '1':'.',. . . ", . ., t';:" , .,' '. ,...."., .: ,. i". . , S",,: .. , ,j.'. .. '. " ,,.:. . ' I" .. ( . : ' :1' -< "~~ ' " J ~PR~30-2002 13:14 MORNERU SOBECO 717 737 6558 ~ 2 8 . ENi'ORCEMImT OF AG1\UMI!:NT. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her. 29. SEVE~ILITY. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall, ~n no way, void or alter the remaining obligations of the parties. 30. B~tN~S NOT PART OF AGRE.EMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement, nor shall they affect its meaning, construction or effect. 14 P.1S .~ - _~ I;;,;,;,-_,~t .... .T 'f .t ,'" t t'.. ' . '. . J '.. ,~, -' ~* "-W' if' t .~ if.. . . .al, .- '~i ,~t ,,""'-"'-'~' ~ I _ ~ ~PR~30-2002 13:14 MORNERU 50 BE CO 717 737 6658 .. IN WITNESS ~OF. the parties hereto have set their hands and seal the day and year first above written. ~~~, ;f.d~/ {~~'1l ~.I' l..,V", REBECCA HANDLER ~, W ESS ~, /1' // ,0 :~~ " 11'.1 (~,Ccc;.-'L THOMAS M. CHANDLER 15 P.16 -~, i""" ,-- ~ -" RP~~30-2002 13:14 MORNERU SOBECO 71 7 737 6658 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :55. ..,,-.;/ day of On this, the -2 .,~&"t( ~ , 2000, before me a Notary Public of the COmmonwealth of Pennsylvania personally appeared REBECCA L. CHANDLER, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained, IN ~TNESS ~OF, I have hereunto set my hand and official seal. ~"'~ NOTARIAL SEAL I MICHAEL R. CARANCI, Notary Public . Camp Hill Boro. Cumberland Counly i My Commlasion Expires Juno 15, ~e~ 16 P.17 "L_~",",' ~v " ! , , , "~I .''i .,"( RPR-30-2002 13:14 MORNERU SOBECO 717 737 5658 COMMONWEALTH OF P~NNSYLVANrA :n. COUNTY or CUMB~RtAND .~ 6;;-; On this, the ~day of ;:;;~€k , 2000, before me, a Notar~ Public for the Commonwealth of pennsylvania, personally appeared T~OMAS M. CHANDLER, known to me to be the per~on whose name 1s subscribed to the within ~g~eement and acknowledged that he executed the same for the purposes therein contained. IN W1~SS W8&1&OF, I have hereunto set my hand and cfficial seal. =~-~, NOTARIAL SEAl.. Mile MICHAS. R. CARAt<<l1. NlUri . c.nJ HI ~ Bllro. CUnUriIn'I ~~ M1Cammbll~,~I~JUIlll1fi ~. 1 '1. P.18 ~i:t-',;' 8PR-30-2002 13:14 MORNERU SOBECO I '" ~ , , R.F.BECC~ SIlowblower STIliU 1Ii1lOlllIlW Ofbll\4 tl)all J amall air condldoom Present eonDm~filI1Iirurt Crock pOl gloom. k/life, Iwtd Olixtr Microwa,,~ 2 TV, ilia VCR COI an4 vidlOlap.. Smlll stereo Cat ~ .~ THOMAS 717 737 5658 All po..... 1001, HUlhools , , Rilolll air conditioner "atdWlCll, .IoI14UI, pOLl, PIN, SeMo( dlshes Toweis, wiil\rl.gs B I..der TOU1I'ovon 2 TV. ..d VCR Ceilill( r.n Co. ",d vllleo14pts ~lm. fllloll, drAs$cr, chait TiIlllc,rv,l&lld KilClIcnc:al>lc 2.llain AI) CI( prlldum'too l> C;nJmrs VIll LOVe5e~+- It/S/) sho.n.nfJ Vfct~o ca.rne r'l , E.XHI8lT itA" P.19 ",:i_,~__': --'--t.,'.. _ '~ _ 'N oC' o _,. ..,_ "-----,,, "* ",i."~,< ,-;:;,~ '''-' ""6,~- ~- ; ,. - - '''';'-M".,'--i<f'',_" '- .'" ;. '''":~fj ; , I , . " , VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. (- Date: 7 )!J/ Jo~ ,~~ Rebecca L. Chandler, Petitioner "-',' --,1'0 __.___" ',--,..-," _"_,,-'o.,_k, , 'fH i ~ ' . . I '. . ~ 'I ~ REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-616 THOMAS M. CHANDLER, Respondent CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Courtney L. Kishel, Esquire, of James, Smith, Durkin & Connelly, attorney for the Petitioner, Rebecca L. Chandler, hereby certify that I have served a copy of the Petition to Enforce Property Settlement Agreement on the following on the date and in the manner indicated below: U.S. MAIL, FIRST CLASS. PRE-PAID Mr. Thomas M. Chandler 412 S. High St., 1st Floor Mechanicsburg, PA 17055 JAMES, SMITH, DURKIN & CONNELLY DATE: '6\\\OL \ \, By: Courtney L. Kishe Esquire Attorney for Petitio er Post Office Box 650 Hershey,PA 17033 (717) 533-3280 Pa. Supreme Court ID #81509 FIl.EU--OfFICE ('- -co ",- "''''Y'') ,~, ""T"R'V Ji" ! \- ,':: i<'(;,): 'j'.)l'-.!U .M. -? 02 MJG -2 Pl1 2: 59 CUlv\8~HL?J~D COUNTY PENNSYLVA:\JIA il , '-,,, - ,_ e' " -, '~.- ~.. - "".. -- -~ .'.-._, - -'-.' '", - "-~-:',-~" -'iJ",_' -- -~ ~'_N ,,",i'U,-, __~,_" r.-,;:, ''"'~ .",:;.,~0.';, "><"";_,,,,'L,_ "~~: . REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 THOMAS M. CHANDLER, Respondent : CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this G.~day of ~ 2002, upon consideration of the attached Motion, it is hereby ORDERED that the Rule which was issued on the Respondent, Thomas M. Chandler, in the above-captioned matter, on or about August 9, 2002, to show cause why the Petitioner's Petition for Enforce Property Settlement Agreement should not be granted, is made Absolute due to the Respondent's failure to answer said Rule. Respondent is ORDERED to . immediately obtain temative f~anci~r th~~l~~e:.s~i~nS~ ."'C r.w~) (_t.-L:., FtKa,~utl61~, R~o~~i~clv lU pay f~:ir ~l ~~d ro A result ~P~6C:~~~ .....S~In~~;l3,.,lClII;). of :,,;r;,,lll'~ thi" aetiB ' i h rp<nltpn from hi< hr~ec of the qe~s r ~' il1~ ::p1~:!Sf''''' to:... ~ F ~ 3'Ofo~~ / ~ fe...... (10/3 I ~ L~ lu1uL 'H. 0:1. -ft Air 1:0: ) Ib-t:to.1) ishe } /tJe.F t . J. .~ ~""" . '" " - .,..'''L-,''- ...""..... UI);. ' ;:}!. F[)-{)~FiCE OF ;-;""'=::i'i'.<\\:OTARY D2 SfP - 6 IH'i 9: I! CUIVib[}/Lii,D COUNTY PENNSYLVANil\ A, _]!!ll~.1Wf~.~ 0.,_' ~". ""'~':",-c:. 0" - "~ ~'--,-' ,- .-'-"~', , . ,'-,',' . <. ,,,-- --- -- ~ -, -~""k~_C^_"_ --' ~,], -, -, ''''.. . ~'.,,-, "i-.." _~~>"k"""""," -,,:,~ ;_~- ." '':: ;".>__ '),i . REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 THOMAS M. CHANDLER, Respondent CIVIL ACTION - LAW IN DIVORCE MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE AND NOW, this _ day of August, 2002, comes the above-named Petitioner, Rebecca L. Chandler, by and through her attorneys, Courtney 1. Kishel, Esquire, and James, Smith, Durkin & Connelly LLP, and respectfully requests this Honorable Court to make Absolute the Rule to Show Cause which was issued in the above-captioned matter on August 7, 2002, and in support thereof, states the following: 1. On or about August 2, 2002, Petitioner filed a Petition to Enforce Property Settlement Agreement in the above-captioned matter. 2. On August 7, 2002, Your Honor signed an Order requiring Mr. Chandler to show cause why he should not be held in contempt. The Rule was returnable in twenty (20) days from the date of service. Service was made on or about August 9, 2002, a true and correct copy of the letter is attached hereto and marked Exhibit "A". 3. At least twenty (20) days have passed since the filing of Your Honor's Order and Mr. Chandler has failed to respond. WHEREFORE, Petitioner, Rebecca 1. Chandler, respectfully requests this Honorable Court to make Rrue Absolute in the above-captioned case and Order Respondent to immediately obtain alternative fmancing for the vehicle in his possession. Furthermore, Petitioner respectfully requests ". _c" ,~ -" "~', - < . -~,-.- .1 . < --,' ,~;,; ',- ~;'"'~" "'- - . , ,_,,~~ '~,:.60-;:"' , . this Honorable Court to Order Respondent to pay for any and all legal fees incurred as a result of initiating this action which resulted from his breech of the terms of the Property Settlement Agreement. Respectfully Submitted, ~~A~~ ourtney L. Kishel tI Pa. Supreme Court ID #81509 James, Smith, Durkin & Connelly, LLP P.O. Box 650 Hershey, PA 17033 (717)533-3280 ~, . JAMES 8Mrrn DuRi<IN & CONNELLY UP . Courtney L. Kisbel clk:@jsdlegal.com August 9,2002 . Mr. Thomas M. Chandler 412 S. High St., lstPloor Mechanicsburg, P A 17055 Re: Chandler v. Chandler Dear Mr. Chandler: Enclosed please find a certified copy of the Rule to Show Cause and Petition to Enforce Property Settlement Agreement in the above-referenced matter. Please govem your actions accordingly. Q:I:,~:^~ \UJl Courtney ~ CLK:has Enclosure cc: Rebecca L. Chandler .-", !lIIL ~-.~"" 134 BIPE AVENUE HUMMELSTOWN, PA "17036 JI"lAILlNG ADDRESS: I-' .0. SOX 650 Hf:RSHEY, PA 17033 TEL 7i7.53.3,3;:'S() FAX 711_533.2786 :t.JrO@JSDLEGALCOM V'/WW.JSDC.C\JM GARY L. JAMES MAX J. SMITH, JR. KAREN DURKIN JOHN J. CONNELLY, JR. SCOTT A. DIETTERICK JAMES F. SPADE GREGORY K. RICHAflOS RICHARD L DAHLEN SUSAN M. KADEL JARAD W. HANDELMAN DONNA M. MUL.L1N EDwARD P. SEEBER NEIL W. YAHN BERNARD A. RYAN, JR. COURTNEY L. KISHEL. OF COUNSEL: ANDRri!N W. BARBIN HERSHEY, PA MANLEY & DEAS, LLC COLUMBUS, OH ~- ",,. " ",j c _~ ." 0 ' " ,~ -~'H -- _.., -, "-_c-_ REBECCA L. CHANDLER, Petitioller THOMAS M. CHANDLER, Respondent ----~ , - "-10,,;.;, ,,-'__. :'-<- '/, _~,"_ _',~ "".-,~._, ~,_<. "~:''';~'''__-_''~-_'~''''__' -__" '-""'~I : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-616 : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, Courtney L. Kishel, Esquire, of James, Smith, Durkin & Connelly, attorney for the Petitioner, Rebecca L. Chandler, hereby certify that I have served a copy of the Motion to Make Rule to Show Cause Absolute on the following on the date and in the manner indicated below: U.S. MAIL. FIRST CLASS. PRE-PAID DAm /;IT';>. ".''- Mr. Thomas M. Chandler 412 S. High St., 1st Floor Mechanicsburg, PA 17055 JAMES, SMITH, DURKIN & CONNELLY BY:~~L Courtney L. Kishel, Esquire t/ Attorney for Petitioner Post Office Box 650 Hershey,PA 17033 (717) 533-3280 Pa. Supreme Court ID #81509 ~ _ ~-=!t,EI)'-OfF;CE OF ! HE ?~cOTHONOTARY * 02 SEP -3 Al110: 26 CUMElb:,LFC\;U ('ni 1N1'( P(_~'I\ '" V...,;",J t:j'~! ~v YlVANfA / '""'<:'~" '" ',. '.-~ ,~ = ~ ,-. REPECA L. CHANDLER, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS M. CHANDLER, Respondent 01-0616 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of September, 2002, after hearing, our order of September 6th, 2002, IS VACATED. The respondent, Thomas M. Chandler, is directed to timely pay all future payments due on the loan to Allfirst in connection with the 1996 van. The request for legal fees IS DENIED. Edward E. Guido, J. Courtney L. Kishel, Esquire For the petitioner .~ ~ JD_O~.O.:u 1t ~ Thomas M. Chandler, Pro se , fILED-OfFiCE ",... ~,,_ ",,','T' ,_,,,,>,'/.OV l.Jr \ ;';;..: ~ :;' ';',,:' ! 'i ~\.,',-,+.,l tt'll.' CU"I'-'" ... .' -i \'.10....' ,Vlctrl,w-\"-.0 0Uul\j\ l PENNSYL'IAN\/'\ I I ~. ~. ~ B ~ I 02 Gel - \ ?l'\ 3; 39 r:r ,] -~, OP' V_' ..", ~~,._~'~ '~=.I~'-' ~,__c_ ._,..",",__~ 0".1'.-' '," ~".--e-' ,. - ,,,'~-,-,,~ .-,~ ;-:'j . . t .... REBECCA L. CHANDLER, Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 THOMASM.CHANDLE~ Respondent : CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this/;'~ayof OlAf ,2004, upon consideration of the within Petition to Enforce Property Settlement Agreement, a hearing is hereby scheduled for the 10 tl?dayof UUAl" , 2004, at I: <J () o'clock I.m. in Court Room - No..!J ,of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 05 - J3-0Lj iit . -'1-'" ,-~- F\lEo-OfFICl Of ThE PP.01HOHOil\HY 2O\l\d1~ y \ 3 ~M \ \: 3 I CI:J'I'.i.iC.~ ,. ...., ", :"."" I".\~" ".-,;.,..;;_1 ,,,,, ~,,-,,-,,'l\ 'I PE~,iNS'!lVN\l'A ..... : - '''''',,,,,,'-J" ',,,". ~~1~~_~' ., ,,"-. '''''''''-- .=,^"~.~ .,-- ",~-",'~ "~' " eo J~~ ,,-, ''''-I~:'' :~, ,'!"<":,'''''- --~ t , . . , . REBECCA L. CHANDLER, Petitioner THOMAS M. CHANDLER, Respondent AND NOW, this l5 MAY 0 6 2004 \r : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 : CIVIL ACTION-LAW : IN DIVORCE RULE TO SHOW CAUSE day of ,2004, upon consideration of the foregoing Petition to Enforce Property Settlement Agreement, a Rule is hereby entered against the Respondent, Thomas M. Chandler, to show cause why he should not be held in contempt. Rule returnable in writing days from the date of service. BY THE COURT: EDWARD E. GUIDO, JUDGE , , 'I ~',~, "O',_~ __ '" p_ '--', - t-. _,~_ . -'_0_ - ,_" . '0" '.' __ '" '-,",,'''~ ,..- ,'" '""S"."O,<",:&,','.",,.,,, " OJ: ) REBECCA L. CHANDLER, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-616 THOMAS M. CHANDLER, DefendantJRespondent : CIVIL ACTION - LAW : IN DIVORCE PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT COMES NOW, Petitioner, Rebecca 1. Chandler, by and through her attorneys, James, Smith, Dietterick & Connelly, by John J. Connelly, Jr., Esquire, and files the following Petition to Enforce Property Settlement Agreement and in support thereof respectfully represents as follows: 1. Petitioner is Rebecca 1. Chandler who currently resides at 1116 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Respondent is Thomas M. Chandler currently resides at 412 South High Street, 1" Floor, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties were married on June 29, 1996. 4. On October 19,2001, a Decree in Divorce was entered. 5. As part of the divorce action, the parties entered into a Property Settlement Agreement on September 5, 2000. The Agreement is attached hereto and marked Exhibit "A". 6. The parties owned several vehicles, which were the subject of equitable distribution. Respondent received possession of the parties' 1996 Ford Windstar van which was encumbered by a loan in both Respondent's and Petitioner's names to Allfirst Bank, now M&T Bank. J 7. On August 2, 2002, your Petitioner filed a Petition to Enforce the Property Settlement Agreement in this matter. 8. After hearing on September 23, 2002, the Court entered the attached Order marked Exhibit "B" directing the Respondent to "timely pay all future payments due on the loan to Allfirst in connection with the 1996 van." 9. Since the date of the Order, the Respondent has failed to make timely payments on the vehicle (1996 Ford Windstar Van). The Petitioner contacted M&T Bank on March 2, 2004, and was advised that they were repossessing the vehicle as of March 11, 2004. The Petitioner subsequently detennined that the Respondent made the November 2003 payment on January 23, 2004 and the December 2003 payment on March 8, 2004, thereby delaying the repossession scheduled for March 11, 2004. 10. Consistent with Paragraph 13 of the Property Settlement Agreement, the parties agreed that "Husband shall be solely responsible for the payment of the loan on the vehicle in his possession and shall indemnify and hold Wife harmless of the repayment of said loan." 11. Paragraph 28 of the Property Settlement Agreement provides in part, "The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her." 12. The Respondent is in breach of the tenus of the Court's Order of September 23, 2002 as well as the tenus of the Property Settlement Agreement by failing to make timely payments on the vehicle, thereby causing significant financial harm to the Petitioner. 13. The Petitioner has incurred legal fees as a result of the breach of the Property ~ .- -. ~~ - - """"'''-''~'! , Settlement Agreement. In addition to legal fees, the Petitioner is exposed to a potential for additional liability on the loan for the default by the Respondent and has had her credit substantially impaired by the Respondent's behavior. WHEREFORE, your Petitioner, Rebecca 1. Chandler, respectfully requests that the Court hold the Respondent, Thomas M. Chandler, in contempt for failing to comply with this Court's Order of September 23, 2002. It is further requested that the Court order the Respondent to pay reasonable counsel fees incurred by the Petitioner and to order the Respondent to immediately sell the vehicle, pay it off, or remove Petitioner's name from the loan, as well as any other remedies that the Court deems appropriate.. Respectfully submitted, JAMES, SMTIH, DIETTERICK & CONNELLY Date: 5/j/()Jf I I By: , -, ,'''e' ~. ,~" H._ "', _~~ . " 'C - ,- \ ~ ~ '<" _ "-,"-'-"=""-_~'-"-,,__~_~~_~,,, ~.._,_., - ~^-__"_'.< .,:c, ,,~._,-~----'~,'~-"...,_,",,< ";""!: VERI FICA TION I verifY that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: Dlfl6lot.J ~;f:~ Rebecca L. Chandler, Petitioner -~7t !i\~_ ~ o ., ~ o . .0 lGRI'l'AI. SETTLEMI!:NT AGJI '" oaoI1l'JqT AGREEMEN'.r, IllAde thill 5+l-\ciot.y of ~, 2000, by and l:lGt_en REBECCA L. CBAliltlt.!:P., b.~einafter ;:efer;:-ecl to as "Wife", and 'l'JlOMAS H. CIlANDLER, hereinafter refer~&d to as "Husband". WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on June 29, 1996. There is one child born of this marriage, said child being Christopher, born December 16, 1996. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property, the equitable distribution of such property; the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; the settling of all matters relating to the children of the parties including custody, visitation and support; and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. ~- "~~~~ " rl)n1Iil~k,' 10 ; o. *....., ~ , ,& . :i(j, 'W . I.i'. . , ~'>;~ , ,,-~ ~ .~' ., NOW, TBERIiORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable considerations, receipt of which is hereby acknowledged by each of the parties ~ereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1 .' AGREEMEN1r NOT;' BAR TO DIVOaCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed a condcnation on the part of either party hereto of any act or acts on the part of the other party which have occurred prior to or which may occur subsequent to the date hereof. 2. EFFECT OF DIVOaCE DECREE. The parties agree that, unless otherwise specifically provided herein, this Agreement shall continue in full force and effec~ after such time as a final decree in divorce may be enterec with respect to the parties. It is the intent of the part~as hereto that this Agreement shall create contractual rig~ts and obligations entirely independent of any Court Order and that this Agreement may be enforced by contract remedies in addition to any other 2 "" ~lIDfJn"~,":~,,,' :I&..}" . .I", ;.... ., I , .. t..' , . t,~,.' . *...'\..... w 'I.'.'. . , 'I', -~ "- " 1-, ;.., "" '-'''-' ...."-'''-'.... ....-'--/0.... "'-"""\-n,-, ,-,Wo.,Jl...,-,U (J. ( (..)( bb:)t:l ~,l::::J::> fully understand the facts and have been fully informed as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in the circumstance, fair and equitable; that it is being entered into freely and vol~ntarily, after having received such advice and with such knowledge; that execution of this Agreement is not the result of any duress or undue influence: and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full and complete disclosure of their respective assets, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purposes of this Agreement. Each party agrees that he and she shall not, at any future time, raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraUdulently withheld. 6. PERSONAL RIGHTS. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. 4 '~"~~;il. I~*-, t '1,,:< ,. t " .' . . , . t.". t I..". . . :1 ' " ,t'"'' 't'... '~ ' . . I ,'.;;. , ,. t . ....". . f..;'...... . , I.' _ '.' I ,. . I. -,-,. - Wife aD.d Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell, by any means or in any manner whatsoever, with him or her. 7. suaSEQOBNT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent co-habitation or resumption of marital relations, unless the parties otherwise specifically agree in writing. 8. ~~ RELEASES. Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property here~fter accruing) of the other or against the estate of such other r of whatever nature or wheresoever situate, which he or she now has or at any time hereafter may have against the other I the estate of such other or any part thereof, whether arising cut cf any former acts, contracts, engagements or Uabili t:.es or such other or by way of dower or curtesy, or claims in the nat~re of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate ~aws, or the right to take against the spouse's willi or the right to treat a lifetime conveyance by the other as testame~tarYI or all other rights of a 5 ~ '~<Jik;~~;';\-: ;*. '. ......., " , .. I,'.. . . # ..' " ,< ,~, .' . ~. " llii ,I I t it'.'. ,. .. surviving spouse to participate in a deceased spouSe's estate, whether arising under the laws of lal Pennsylvania, (bl any State, COll"Ul\Onwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter shall have for past, present Or future support Or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relation or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereo..I, It is the intention of Husband and Wlfe to give to each other the execution of this Agreement a full, complete and general release with respect to any ana all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature aris~ng or which may arise under this Agreement or for the breach or any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 6 -"_'.i,"~':' .1.".... ' ' t :w .' , :\ ,I '. j ''*.'. '9' 1'< :. " ~~~ ~ " <'-.' . ."~----"- - ~ riL"oG~~-'~ :{ '. 9. ~ ACCOUNTS AND RBTIRBNENT ACCOUNTS. Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that these accounts and plans shall be the sole and separate property of the person in whose name they are titled and each party waives any right, title or interest they may have in the other parties' account. 10. P.RSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have divided their tangible personal property, including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the proper~y of Husband or in his possession shall be the sole and separ~te property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife, (See Exhibit A for partial allocat~on). The parties do hereby 5pecifically waive, release, renounce and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. The parties further agree that the following items shall be shared by the parties: lawnmower, blower, hedge trimmer, "sawzall", weed trimmer and edger. The parties further agree to 5hare equally in any repair expenses for the shared items. 7 "., ': A '. '1.'<. ., ., Jl',: ,& . ."; t . ...'..' '" f' if -f.' ....,; " '. ,'; ..^ .'''' , , . ~-j' , ;I .) ~ - .~........ ,. '.-- , .U...I 11. AF'!'Ea-ACQUIRED PlASONAL PRO~TY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, ~n all respects and for all purposes, as though he or she were unmarried. 12. REAL ~STATE. Husband and Wife are the owners of a house located at 1116 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania. Wife shall assume full responsibility for the payment of the mortgage, taxes, utilities and ma~ntenance. Husband agrees to execute a deed to transfer his interest in said property to Wife on or within 3 months after February 1, 2003. If ~ botn parties agree, husband may transfer his interest prior to February 1, 2003. If the property is sold prior the the execution of a deed of transfer, husband shall not be liable for any settlement costs, nor shall he sha~e in the proceeds of sale~ Further, Husband agrees not to enter the home, nor to remove items from the home, or otherwise attempt to exert any control of the use or renovation of the home. 13 . AU'l'OMOBILES . The pa~ties are the owners of varlOUS automobiles. Wife shall be the sole and separate owner of any vehicle titled in her name and/or in her possession at the execution of this agreement. Husband shall be the sole and a -~''''.,illi''.~''J .' 'J:;'<( . i 'it.: ."" t i ,. " t i l ~ I::. ~""".. . ~. ,'........,,, ''-',........ ..............................u fJ.. r r..J r 00"">0 ~ separate owner of a van titled in both his and her names and in his possession at the execution of this agreement. Each party agrees to execute all documents necessary to implement this paragraph. Husband shall be solely responsible for the payment ~ of the loan on the vehicle in his possession and shall indemnify and hold wife harmless for the repayment of said loan. 14. CURRENT LIABILI~tES. Wife shall be solely responsible for payment of the mortgage, utilities, taxes and insurance on r the house at 1116 Apple Drive. Further, Wife shall be responsible for all individual bills which she has incurred since the date of separation. Husband shall be responsible for all individual bills which he has incurred since the date of separation. 15 . WAIVER OF AI.IMONY PENDENTE LITE AND PA1HIllNT OF LEGAL FEES. Each party hereby waives any right to alimony pendente lite and the payment of legal fees. 16. RELEASE 01' SUPPORT - ACKN~GEHEN'I' OF ADEQUACY. The parties he!ein acknowledge that, by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficienL financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectlvely have against the other for alimony, support or 9 r h":,,,,~~t r..l~ ." , . ') ." ,. '. . t " f ~-"'-; ,'''']'\\''1" '-r., ",'-''''' '-'-''-'..... , ,Ur" ~l-r lU UUL,Jl-.....U (1 ( (.) ( bb~tj maintenance. It shall be, from the execution of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 17 . CUSTODY ~ VISITAi'ION. Husband and Wife shall have shared legal custody of the parties' child. Wife shall have primary physical custody. Husband shall have liberal periods of partial physical custody, not less than every other weekend from 5:30 pm on Friday until 6:00 pm on Sunday. Wife shall be responsible for transporting the child no farther than 25 miles from child's current residence. Husband shall be responsible fro rema.ining transportation. 18 . CHILD SUPPORT. Husband agrees to pay $80.00 per week directly to Wife. If not paid, Wife will file a formal complaint for child support with the applicable Court. The parties agree that this amount shall be reviewed every February and JulV. This " review will consist of providing pay stubs for the previous six month period to determine the current applicable rate of support. Husband agrees that no expenses shall be deducted from the weekly sum for out-of-pocket expenditures. Husband further agrees to pay one-half of any uninsured medical and dental expenses. as well as one-half of any child care costs. Any further support shall be as agreed by the parties or, if applicable, the Court. .--- 10 >" "h!l..~f.li1lii:e;i' r'.11 '11'.';..' , . i . . .1".'. .. , . " !t .t ,j. '1!J . t'. '. " t. ~. .~~-~ ~ L,= ~ ~ J , ~ 19. MUTUAL CONSENT DIVORCE. The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counselling, and that they both consent to the entry of a decree in divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (herein referred to as the Code). Accordingly, both parties. agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file such consents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of The Code. Upon request, to the extent permitted by the law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such diVorce. 20, ~YAS TO EXISTING OBLIGATIONS. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligations for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for 11 - ~ .. rm~'!JL"~l':o!M~'I:..J,:': r ....<::.. ,. I ",'1' -.l ,. ".. ,. I :1.... ., . .. ~ ~. ~.' ,.:f t. . . ., :j ; ,t 'i.!lll/iil.~," "' ,l.,':", . ''-'' '-''-'.....'-' I ..........J . necessities, except for the obligations arising out of this Agreement. 21. ~ AS TO J!u'.ru4 OBLIGATImtS. Wife and Husband each covenant, warrant, represent and agree that, with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify .. and hold harmless the other party for and against any and all , debts, Charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise ~ specifically provided for by the terms of this Agreement. 22. muvER OR. MODIFICA'.1'IONTO aJ!: IN WRITING, No modification Or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 23. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the ether party may reasonably requlre for the purpose of giving full fOrce and effect to the provisions of this Agreement. 12 '~~~"',.II:~~o" :'r '. t ,. ., '1'1.. , '" ' ".'. .. I ';.;.,;" 01l-"'~ ~ - ,~ "'. --<- ^"',- , 24. LAWS OF PENNSYLv..NZA APPL!~~T?. This Agreement shall be construed in accordance with the laws of the Commonwealth of pennsylvania which are in effect as of the date of execution of this Agreement. 25. AGRBZHmNT BINDING HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 26. OTHER DQCOKENTATION. Wife and Husband covenant and agree that they will forthwith (and within at least ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 27. NO ~ OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 13 , . ~~~W:!i:t,.;bi~"1', ."', . I'fi '", .' , ..,.. . . t V\ ,t . . ~; ~ :1 .- , .&".'. <. ,. """....-..l " 1-. , . , "'",1" .,~~~,,"' 1ll"'!':t3;~*ii- . - " '. ~ 28 . EN1'ORC'EMENT OF AGRa:MEN'.r. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her selection, to sue for damages for such breach or to require specific performance. The party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other party in enforcing their rights under this Agreement or for seeking such other remedies of relief as may be available to him or her. 29. SZVERABILITY. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall, in no way, void or alter the remaining obligations of the parties. 30. B~INGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragra9hs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement, nor shall they affect its meaning, construction or effect. 14 " '~9- ,t .'1"'." ., , , ,Ii ," . , + "' ;," " ~'-' ~~'-'~ '..., 1-..11 WW-'W .. ~ WITNESS NBEREOF, the parties hereto have set their hands and seal the day and year first above written. ~-~:~- 'd!~~/ {~~~i;~L , 1 ~- /.' / 1.1/~"".fz{; .~ REBECCA . HANDLER r~~ ~ .. /p UfC&:L THOMAS M. CHANDLER 15 I....U -~l~ ~"~J}' ,''-~' .- '''" '. I " - . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : S5. .[.;/ day of On this, the 2. '~6t1 ~ , 2000, before me a Notary Public of the Commonwealth of Pennsylvania personally appeared REBECCA L. CHANDLER, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN ~TNESS WHEREOF, I have hereunto set my hand and official seal. ~~~. NOTARIAL SEAL I MICHAEl. R. CARANCI, Notary Public . Camp Hill Boro. CiJrnbertand Counly ; My Commission Expires June 15. 2802 16 ""'^--"'~~I'J",,-'~~ 'L , .. ,~. ,- . > COMMONWEALTH OF PENNSYLVANIA :u. COUNTY O~ CUMB~RLAND .~ ~:-; On this, the k day of ~h&.nB~ , 2000, before me, a Notary Public for the Commonwealth of Pennsylvania, personally appeared T~OMAS M. CHANDLER, known to me to be the ger~on whose name 1s subscribed to the within Ag~eement and acknowledged that he executed the same for the purposes therein contained. IN W1~ss W8Ea&or, 1 have here~nto set my hBnd and official seal. ?~4 NOTARIAL SEAl.. MICHAEl. R.l:AIWl1l, NlUri Mile . CwnJl HIU iIllro. CUnarlenQ C<aln~ M, CDmmla~~I~ Ju"" 1fi "" 17' ,'~. -o\iIiml.",','~'Ill!,tih.: ,..~~b> . ',.' . RF.Bt::CC~ SIlowblower STDlIU IillOl1IlW\l ofbl/ld !neu J &lI111l ~ll coBdlrioc'n Prescnt conD:ll~filr4jl\ltt Crock. pOl ElcCllic kl>ife. hand Ol~er MicrOW8'n 2 TVs&Ild VCR CD.I/ld vidlOlapos Small stereo Car ili' , '"'-~ll!iIsl"':'i,~M::" . .~ THOMAS An pa>m' 10011 Hudlools , , Roolll air condltioMr l> otdlsllCll, 'lllnsils. pot!, PIllS, SctIIioC ill511.. 1owels. "'.w.gs BIOIldtr TOINr OVtrl 2 TV. ond VCR Cellin, fun Co, i/ld 'llko14flt. S rarco f\llll;, ds1l$$cr. chair Table, TV stolid KilCiI<n lIOle t cllalls ...IJ \W produmlto. Ls Canl5tcrs VIlJ Love5e",,+' /}lsc sho.nn9 Vi'ctc:O CQ.vl'hm\ , ~lT"AtI =' - I,~. ' .~~ ' . -- ~", ) '. ~ . . ~ " . REPECA L. CHANDLER, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. THOMAS M. CHANDLER, Respondent 01-0616 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of September, 2002, after hearing, our order of September 6th, 2002, IS VACATED. The respondent, Thomas M. Chandler, is directed to timely pay all future payments due on the loan to A11first in connection with the 1996 van. The request for legal fees IS DENIED. Edward E. Guido, J. Courtney L. Kishel, Esquire For the Petitioner Thomas M. Chandler, Pro se 1"t fRUECOPY FROM RECORD In T ll8tlmony woe.oof. I oorlllilltll set my RallO 3,d the seal 01 S;lld Court at Carlisle. fa. rillS It) M.~a~ ~~'" ,~0()2- 'i prothoRutar~ ,,,- -'~ >'~ " ~ .. . REBECCA L. CHANDLER, PlaintiffJPetitioner v. THOMAS M. CHANDLER, DefendantJRespondent oq <__". -_"A"",,'''~ "" __,_I"'~""'_" ~_,,=,,___,,~ '_"0' ,,_._,_ ~,_- _,_n',,,",,,,,.,:',,,,'''_ ,-~- ~i:, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-616 : CIVIL ACTION - LAW : IN DIVORCE CERTunCATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, attorney for the Petitioner, Rebecca 1. Chandler, hereby certifY that I have served a copy of the foregoing Petition to Enforce Property Settlement Agreement on the following on the date and in the manner indicated below: DATE: 5/3/ ()Lf I I V.S MAIL. FIRST CLASS. PRE-PAID Thomas M. Chandler 412 South High Street, 1" Floor Mechanicsburg, P A 17055 JAMES, SMITH, DIETIERICK & CONNELLY '-"'-.'; ,I.' ~Ji ,~ -Ji" - ^ -<- ~J., " '" '~"i''''' '<"~-,.':r.-~-~_' ~~.'''-o__'j_ "-~ " _ _~ . < I'J" hll ~ -.~ ~", _k '" ..L" L".' .. ';," .. ~ ,..., = ~ = Je". -r:., :;-,;: .-/ ,. :r:>". :r::;n -< n1"'- ~ , ::u rn .:::- :JJ6 Q( ,,; -0 :t-r; ~ r):rJ 5-=. f~;~ ~. ~-;). L" '" r)lt'l .c. :::.., -., $ ~. , ~- -< ~ 'r.. , " REBECCA L. CHANDLER V. THOMAS M. CHANDLER ',' ~ - '", .,,'''-1 <' __"'" ,'_" ., _~. '''''" ~j":;;", ',.".. ,.co, ". " . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-0616 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 1ST day of JUNE, 2004, the hearing in the above captioned matter, scheduled for Thursday, June 10, 2004, at 1:00 p.m. is rescheduled for THURSDAY. JUNE 17. 2004. at 3:00 D.m. in Courtroom # 5. /John J. Connelly, Jr., Esquire P.O. Box 650 Hershey, Pa. 17033 .Jl'homas Chandler 412 South High Street 1st Floor Mechanicsburg, Pa. 17055 :sld Edward E. Guido, J. / 01.0 - 02-0~ ". ,~ '. ';;-"a.rmt~\:jj~:i;iQj.~~t.i~iiM' :i''-<-~ - ',~ il'-'liH~~Ili:liltl!Mj'.~"" .~"-, Ilt,n~Ci f\..L '<;~ 1',-_, __ t~ :6 ~nI z- N!lf ~UOl AtNlOi~OHJ.Olid 3H1 :10 . 381:J:.l0.a311:! ."--.. .,,'- '^ - ,~'" ,f'_ d ~,I-,_".,,,-,-- 'f.1,,,c ..z.h-..,..... ~I ~. ,- ~ ""'ia.-..;---- """"'-j ~~ ~1 i" ,~ -,t',,,, O'~, < =,','~ '0"- ,",).'1,,_- ""-"; , . ,,,~- , r: REBECCA L. CHANDLER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-0616 CIVIL TERM THOMAS M. CHANDLER, Defendant CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 22nd day of July, 2004, the Defendant having appeared for sentence in connection with our prior adjudication of contempt, this matter is continued until September 27, 2004, at 8:30 a.m. If the Defendant has paid Plaintiff a total of $825.00 to be used to reimburse her for legal fees incurred in this matter, and provided information to Plaintiff's satisfaction that she is no longer responsible for the payments due to M&T, the finding of contempt shall be vacated. John J. Connelly, Jr., Esquire For the Plaintiff Thomas Chandler Defendant, Pro se ~~ 1.,;n -0'1 q-, srs iw '" "'-~~---'-. -> . . ".~... ,,,,I -- ~-~~'T'"~" FlLED-OFi:'!CE 0-1- TI W. C'Dr)'rUi"'v'ltfj"t1f-V ill: t IL ir1!jl\,"_, ilJ'., ! 'I' "21 'Jil 3: 27 2001 Jll .:: CUil./I::,':_~' . ~.~ ;~,,<JUNTY 1-)E.r\ji\~)\'!_VA,>'J1A -C; ~~i ~1J~,I~!ii~_m~l~ '__ "__'___'_,_ .'!"",'" ~. " ~~ _ _, .mfi'_~q\l 9.,:,___,,,,,,, .