Loading...
HomeMy WebLinkAbout01-2585 FX "' , . . , . , , , , . , , , , , . , , , . , , , ,)! ., , '-~""r,"",,",';"'" '''''",O";'O;~('.,'''__ " , Of.;F.;F. Of. ;F. Of. ;F. Of. :Ii Of. Of. Of. , '" ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Cathy L Watson Plaintiff No. VERSUS Randall K Watson Defendant , , , , , DECREE IN DIVORCE , , AND NOW, i!pVI , 10, . . . , , , , , , , DECRE:ED THAT Cathy L Watson AND Randall K Watson , , , , , , . . , , , ARE DIVORCED FROM THE BONDS OF MATRIMONV, PENNA. 01-2585 , ?1J}f, IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT VET BEEN ENTERED; \Jo1A..JL. , , , , , , . . , . It is further O~DERED that the terms of the attached April 3, 2003 Marital Settlement Agreement are hereby i porated, but not merged, into th~s final dec~~ . . , , , , , , , , , , , . , . . , , , , .~ BvT ATTEST: . _/ PROTHONOTARV Of. :liOf.:Ii :Ii Of. Of. Of. Of. Of. Of. Of.~~~ <," I"": ,-. 'I" "'f; "T , .. '" , , . , . , , . . . , , . , , , . . , , , . . . , , . . , . , . . , , , , , , . . . . , , , , , . , , , , , . . , . , , , , J. , , , . , . , ' 'l~~ . ---~~'~~ ~";"I;""~ltti!~,.;ili.!l.~iliId~,~IIItiiI!l~; L~ ~~ 5. I -C/.] c5 (03 ,LfJm.l.~,"_,., , ~-.=,"= ~ ,~ ~ =~~".~ , """"illIiiiIIIlIIilIl"_l..-. l,',,-- -. C"!!'"". ~. ' ~ '~, . ~ . ,.:;,{, .-~. -. &.d:~ ~~ 4 /~ 7'~ ~ zC; cp '",' - ,I .........<1 II '" \ .'"L "T,,~' " " '" Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01 - ..)sl<S Go ll~€tUYt Randall K. Watson, 55#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in Court, If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3: (~ James A iller, Esquire Attor for Plaintiff " " ~I " """, , I'" '" o . .. . Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. OJ- ':Uy~ (l",;;J ~ Randall K. Watson, 5S#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Cathy L. Watson, who currently resides 200 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, 2. Defendant is Randall K. Watson, currently residing at 771 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025, 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 25, 1977, in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties, 6, The Plaintiff is a citizen of the United States of America, 7, The Defendant is not a member of the Armed Services of the United States of America, 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling, ~, ", " . <, ",,'~,~"f ' _~__, 'I'" ! - -r 'c, ,,':' - , "I '. r" I ~'" 'j] '- . \ COUNT 1 REQUEST FOR A NO.FAUL T DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9, The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken, WHEREFORE, Plaintiff requests this Honorable Court to enter a decree dissolving the marriage between Plaintiff and Defendant. Respectfully submitted, {~~ . . " ",~ ---''''' , ~" - I, !'--'. - "'" ,I' - I' " ~, YERIEI.C.AIION I verifY that the statements made in the attached 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: Y-Z7-0J ,1 () L~f~r-- "... _, ,,,.,,,_,,, "- .- '-In,:", - '''',-' -I" vI'" I, ,,' =~~ !.Ii t.-S t ~:, ~"""" ,,' ~^ ," " ,~ ",r.',,', ">"1^>J..,>,Tf''k', ~,~, - . rr~ i () ~ "6<a. r; '" ~ 0 c:::' 0 ~ ~ ~ C n GJ " .~ -~ ......... :-::,~ ~E. ...... ~ 8 '" -0(",0 :;"'f:Y 0. mn-, -< --J z::r; "__,joT'; Q, 2-:C~ --.-=:- ,-'~, ..0 '~.~ t I O}d?; ,~(~) ~ 1:) !;;c-; c' - .!o::~--; ft- tJ ):-;:,....., ~~ ~:~;; zl."--< 5>0 r:-? \,j i-- c =;! '<~ Z N =< ~ I ~~~'.lf_~,l...l~~~~._~~,l1~i"t1":h1'!'''--fI!!'l:iHw..,~!''':'~,VW'ii'''~''i'~~~J!I!li!_~~~~~~\' ~ Cathy L. Watson, SS#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-2585 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE Randall K. Watson, SS#208-38-4610 Defendant NOTICE You have been sued in Court, If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 I James . Miller, Esquire ey for Plaintiff -::" ,--', "', ',-~.- ,,'" "1_.~'i<,1o, " " ., '-' ,~ r,'f ,] '''''''', ~, ,0' ' ",1'" :l','C'",," - '"1 - j Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-2585 CIVIL TERM Randall K. Watson, 55#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE AMENDED COMPLAINT IN DIVORCE PURSUANT TO Pa.R.C.P. No. 1920.13 NOW COMES, Plaintiff Cathy L. Watson, by and through her counsel, James A. Miller, Esquire and the Law Offrices of James A. Miller, and respectfully submits this Amended Complaint in Divorce, pursuant to Pa.R.C.P. No, 1920.13, providing in pertinent part that the Plaintiff may as of course amend the complaint to include such other claims and accordingly, states as follows: 1. Plaintiff is Cathy L. Watson, who currently resides 200 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Randall K. Watson, currently residing at 771 S. Humer Street, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 25, 1977, in Dauphin County, Pennsylvania. 5, There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America, 'c-,n""r '<, ,~, "--"',~,"" '''I' ,", ,1""'" '" ~, "I "", _ ,'''''1 " _ '," ~ _ I r,_, "- ~,' 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken, COUNT II EQUITABLE DISTRIBUTION OF PROPERTY 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The parties have acquired certain property and assets which constitute marital property. 13, In the event the parties are unable to resolve distribution of marital property by way of an agreement, then this Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. COUNT III ALIMONY 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto, 15, Plaintiff is unable to sustain herself during the course of litigation and to :,C;~"",~ ," , .' ".' ,~, ~,,~_. , , ' . 1 I' ~ ,! ) '"'1 i~ ' I' "':".""'1 _~ ,"n/ defend the divorce action. 16. Plaintiff lacks sufficient income and property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree: 1. dissolving the marriage between Plaintiff and Defendant; 2. equitably distributing all marital property pursuant to section 3502 of the Divorce Code. 3. awarding Plaintiff alimony in her favor pursuant to section 3701 of the Divorce Code. Respectfully submitted, Law Offices of James A. Miller BY: Ch~,~uire 2010 Market Street Camp Hill, PA 17011 (717) 737-6400 ,"~~ .~ ~, ,r.,"", ' ,'_' __~,,_ T1 - ", ~~~ , ~ VERIFICATION I verify that the statements made in this Amended Complaint are true and correct. 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: 6-1"-/-Od-.. ~~f~~ Plaintiff "~ WlPf "~; 'j ,C , '"" , ,:,<'", ~', !-" , "I '. 'I"": ',I' -: '" ,~ " - ~, Of-'l 0~ lll~ ~=~~~J _~ ,_ <", , ,M . ~ ., -, -"I'" ,"" ,,-^ "", .'" "~, - "" ~ ~ "" \J,l 00 "'" '''",,'''''~','\''~'''''''i.-..-'.,"' .," --".>'~--" ,,~.,..""'-_ 1'::1 ~ ~ ~ lj\J .~ ~, !:!'I ::;:" ~ ~, ~ j~~ J!.: '2. f 1" ~ } , y: ~ < () c .,;; -TJ1~ '"1'1"'::-; -;;;~ Lt, ~~;' ~~i~ :s -< i.llillll~l.lmrr' CJ ,\,) f= ..:;; ~- o -" ,::Ii g~ ,~rl1 ~ 5i -< () (). ,~ '" " " ...J..... -.J "n ~ '- .. t_w ,"~J"1__"'~~~~~'il'll1''''0''li''W!!'0;gf..,'':n''''r'>\J1<'~''';);'':,j'''''-?J~$'>%'>1If~W~~1I'~~~~"'"=" "'r'~ \ ,; -. ,I' ~' I . Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-2585 Civil Term Randall K. Watson, 55#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF SERVICE OF DIVORCE COMPLAINT I, James A. JMiller, Esquire, hereby certifY that I served the Defendant, Randall K Watson, with a certified copy of the divorce complaint as evidenced by the attached United States First Class Mail return receipt card number P 016 244 745, DATE: Wednesday, May 30, 2001 ~y(~ James A, j iller, Esquire 20 10M et Street C 'I,PAI7011 17) 737-6400 -,---,--,-"" ................ __,_ ,_., "........"..0. ...........".". :::-'i"S:ENDER:~::" "",.,',,' ...... f l al&'p' 'Wish t6 teceive "the :: ""in" ;0 Ccimplete::',l'tei'ns"t::'6iiW/0f:7. for additional servIces. foiio~j'ng services (for an extra. ~,' _,__ 1ft .. C'om'plete l~elTls 3, and 4a & b. .. . . .t.~. . I:n .. Print your:name and address on the reverse of thIS Term so that we- can fee); "a.: ..:Qj return this card to you, . '1. 0 Addressee's Address .~. .il.. ..' 'Attach rtlTs. form to the front of the maiJplBce, or on the back If $.pace rn ~ does 110t permit. ... a .~ .. Write "Re,.t"ur, n Receipt Flequested" on themailPieCf;lbelo~th............~...rticlenUffibeL!2.0RestrictedDeliVerY.1ii ~ .. The Rettifrl'Recelpt will show to whom the article was dellV~~p and the date Consult postmaster for fee. g'.".. e del1vered. . ...,'. ~ 0;' . .~. 3~ticTe: Addressed to: , 4a. Article NU~bel' ,'_ ~ ;J.tc h?Mt.<2... t It)C;,!SUi ! I (:;((,1."",L.jl../ 7L/~ ~ l '1; ", I-kund S+. ]' 3.R;~~:;~~eJype 0 Insured ~ .Q ..! t ../ . 5?eertlfied [] COD ~': ffi\ t:. \---d.a. /)/+ j I o).~ 1 0 Express Mail '0 ~e:~~a~c;~Pt for ~'.:': ..~I 7. Date of Dr~Y -:,. ,.,,~I - ?L -l{> ~,. ',~ -8. A dresseS's Address (Only if requested ;:.1."., : :,a: 5. and fe'e is paid) S ,.~ . '~,~16'" / f ~ .- Slgna::t'ure (Agent) Yi? U S ''-'- :g.:PS ~,OT~'3811~ :December 1:991 *u.S.GPO,1se3-352.714 2! .. ',~ DOMESTIC RETURN RECEIPT ~ r' ~ ~ -~, , ^. "' ,""~" - o ~ aJ~r ~(~.' " ~7E ~=: )>~~ v '.."..' ~ L'''; '.,t) :< :",) 01 -' T- ~c1~ :''''r''?~~c~.'-, ,,;,li.<;?V',f:-"o,~,~t j"t--<-:<,~,,!... c' '":::~'=T->~W;,~,-::'::1;9f"'::~"'"'~~:X"~;t":"~': 't;-, ' 'C,"); ~~':_ ~~~~'~,< ~, .Jtlfpr__, ' - ilijJ[ j" , .,'-- . . ',,'~" _', "J!!IW , . " Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-2585 CIVIL TERM Randall K. Watson, 55#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, 0 ,', , , hereby certif that I have served the Defendant, Randall K. Watson, ... e-t! ~ . t ~ With~. true and correct copy of the above captioned Amended Divorce Complaint on e.I~' - . /0 ../ . ~ ,2002, at 7'! Y7, (":'M" at '7 '7 I' s. /I W 1M e r-.s::1c , 6'/4 Ct /,., '" , Pennsylvania. / ~ 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,SA 94904, relating to unsworn falsification to authorities. Commonwealth of Pennsylvania: ss: County of Cumberland , hereby certify that on the -LL day of ~,a) ,200J:.. before me, the undersigned Notary Public, personally appeared C ~ Ff::",J iY. Rol wr.h~,er- known to me or satisfactorily proven to be said person; who acknowledged th jhe executed the foregoing document for the purposes therein contained. (j In Witness Whereof, I have hereunto affixed my hand and Notorial Seal. <;; Notary Public .~, "-\01 f\B.\I\L SEp"L pu'O\iC \. \" 1'1.0\8-1'1 \'1\ tJ,\LLE.f\. d counW. JP>.M,ES p... \-\i\\, GuO'berlan ri\ 30, 2005 0' cam'P E~?ife5 f\p 60ro misSIOfl """,...... WW Co," __'~ :,i " ,..~ . '_'"4,, ,1,__"" ""0'" "1- -, !' ". . ~ ,- - ".= .N_ ., JllljIf "<,~, ~ "'~ ~ I "'~~~"~"_'" -'~h'^"'''~- '" ~, ',<V, ,". '~',",""JL""""""'''.'_ (') c :<' ~0~1?, !lll' . -7--- "'....-"'". {~~ ~,~, ~~(J .,- ;,,""j'""" :::~(~'~! ;;'::. ~;:; ."':, o N (/) ,." c." .........:. t i ~-i o -n .-\ ;;~~fD i~ ~ ,..;" ~ .;~"' :;;: i',,' '" .- ~~:"",,fl.~~~m~~lWfi~''IjlJ:-,,<!;,\IDrW'W''h''~n''i''~WW~~l'(fi~.'ii,*m!\!l'~*HI<:~\'!i!I!)-I:l~jl'l~ I .~I.jlili~ t' ..... .,. .. Cathy L Watson, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2585 Randall K Watson, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on May 1, 2001 and service was obtained upon the defendant by certified mail number .p 0"1"6244J45 on May 15, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. /?/j. C [to~ruJroLOn-~ Cathy Latson Date: /01'/ y hfy l {f . -, _ .~~<<. '" c_ _~, _ ... ...... - ...., (') 0' c C~ (..,,:;;- " s: ~ "'D IT) -U f1l ;;:::J 2-} ~ ::2 L- V) (j '" -< -- (-;, r2 "-,. I,,; :;.j > ,~"' --;,,, :z: C~~ r>;1 ". ;~~ :> <;~ -, ""~ ~'''J. ~ -:J -', c:> -< ,~ ,-,_~II""",~".<.. '" .~, '" ,!I\IlL__~'~!~tl!il!li~~'_ml3"" ,.,"","'!!W""~,"'" ."'~,~ .- .". , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2585 Cathy L Watson, Plaintiff Randall K Watson, Defendant .. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsificatio"n of authoritn 0."1/1 .'I ]d'! ~~~"'- Cathy Latson "\-_,'0, '-j, ' --~ , "'C- . '<I, ,I ",',-~ ",.. ,I ., "'I' ,^.'--.. ,c . "~ ~ . .... ,~ '" ~ ~ ","",?"""I~~:,,",~_"!III!I~- . ~~~> ~o __~,. ~.~_~_ --< " ,."" ,,,." ~""..- . ''''tl'~~"' -Of'.. 0 s: ,""" '__l- e (.. n s: ;::'!" ,-" -u 0::1 "'" m I'; 7-J .- z::c' t;:?~ c -< :~,. ~ '. ."1:' '"'" I:'; ,~ Z () ;:;;3 5> ,..-"- .0::..-, "":> -:;1 \:) -, - .,- TIl ~:"""",".~"~IW1I!f;~r'''''''"!,f<'!'!'c0f~.-flI ~""'~"''!'J~lld~I.!:~''l')!I!', ., ""r_~ ( " - , Cathy L Watson, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2585 Randall K Watson, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on May 1, 2001 and service was obtained upon the defendant by certified mail number P :Q162440745 on May 15, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: tJf~ 3, ,;toD3 ;&~ 1<.. tJ~ Randall K Watson L - I,~ ~ . !I~,"" r' _1.",~..,~ =._,,~~ """'." ~. ,". ^ ''''''''''''.'~''=~ () c If ~:2:,:- H'_'~ .~ __'" ". ::;i -<. -.. r', c.""2 ~) " ):~ -''1'''' ::I:J "," C" ::C1 ~"/ '" c' ~~~ ~lJMil::il?J:!l'\!l~~~~~P~Ij!!~IlIWl!~ ..' "- v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01.2585 Cathy L Watson, Plaintiff Randall K Watson, Defendant CIVIL ACTION. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: 0f^J~. to 0 3 ((~k. tJ~ Randall K Watson ::~'r,~ " ",'", ' - -. r,' ,~: I',,'~',I''',,' _ " ,.'r ~, - r, _"_ ~,,~ ~ " ~ ~ -='''' " _.JJ!I!IIQ1.""_,~,, r" _ ,< ~. __" " J',^ -c.'l:-:f m,T'\ Z~~. :2: c.: U)",' -< ...~ ~~:: ~,- )> ~~; "'::- ~-"~ ~< - ",- ~ -. C;, (.....:1 o " (') r- _.. -~:-- ;:::r.-, ~::::J ::::::J (, -u ~.~~: ~;! ::'0- -< ~3 ',') C:) ,"U~",l., ,<,~ ~""" "','~'''''T''''''- ""'~;J;~!M~~~1 ",;n(~~~$.,;, ,:,,, ':", ,,-,"'-"_ Cathy L. Watson, 55#168-48-4610 Plaintiff IN THE COURT OF COMMON PLEA5 CUMBERLAND COUNTY, PENN5YLVANIA V. NO. 01-2585 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE e.el t\ s-t-", ~-t^" e (\ -\' PRAECIPE TO REISSUE COMPLAINT TO THE PROTHONOTARY: Randall K. Watson, 55#208-38-4610 Defendant Kindly reissue the enclosed amended complaint. It will be served personally upon the Defendant by private process server. Respectfully submitted, Law Offices of James A. Miller BY: ~.~1;: Attorney for Plaintiff Supreme Court ID# 86889 2157 Market Street Camp Hill, PA 17011 (717) 737-6400 ,~l~.". __ " < ""'1',"'" ' 1'1"'- 1'-, ," ~~ ~ " .~~ .", ~,." ".- ~'- ,'~, v" ,,<. ',,-_~ ,~ _,JiJf(l. ,l"":"~,,- ,,~ -"t. ",,,-~,- 'T" ,. ~;,'" '_~'~"C,"''''' _",",' """,.,. - ""~= ' .. -_..-. . ~- itLiu-"-"'T1i~ 0 0 ,.., C ""') ,~ " ;;: ,,') 1:11"'" rq l"nrr; "-0 "[1 ;~:J Z"'C ~- -'- ---:;;r-,.. ,".,.~ [rj~', ID ~C~~; -.::;(~) P;;r, '. ;];j ;~ ~(< '..j :r.-.......C ;--. (P '-' Z "0 :11 )> ::;I '_0 :.:a , -< ''''~',I",~~~''''"~'"'";y.~j!IfI,~'!\~'''''~'''1'Hl>:'ll''?'i'''\.'?-'\:t;~-ili'lf"'!"'w~~~ffi.*if'l'1'!l~~i!\ii~!1I!l~ CATHY L. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND. COUNTY, PENNSYLVANIA v. NO. 01-2585 RANDALL K. WATSON, Defendant CIVIL ACTION - DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned as counsel for Defendant in the above- captioned action, Date 101n-~/ , ~~;VJJct ID 0, 46801 132-134 Walnut Street Harrisburg, PA 17101 (717) 238-1484 Attorney for Defendant , ~Imllllll_ ~~. ",=" '~I ,>~" "'J~ """"', ~,'~O" <" -""0"''-< 'h~Y', '~8 . :=r'; "'>','j(CTfi'j(' ~j' 11IRflj,tr' :."'~=' 'rnrt~'[lr,"'"' w;n~j'l~~<'; 0 0 Q c " ;;: 0 '""Om i:J r:;:!rr~ ~-I ,----- L.o,....L 65;;;;: ".,"','1 ...... -I: ,,=' r::;,"" '.cj;;;' ~~ ::;:: ,--' .,~ ,< ~G ::-c: ~,E5 --0 )>c 0-' 6i'l ~ V) ~ ,(n -< ~ ~~~_~n!M"a1~ _, _. _~",~'"$I.'!W'l"'~;"~i'l';<fJ""''''''''''!iS'''''''''!'~i!;'f.'l'WIll!t!Jl1'''ill!m'J~!!;1!i~f''''1tf'l''1''_>i"-~'ll'~~~, .. . STATE OF Pennsylvania CASE # 01-2585 COUNTY OF Cumberland IN THE Common Pleas COURT OF Cumberland COUNTY. Pennsylvania IN RE THE MARRIAGE OF: Cathy L. Watson Petitioner and Randall K. Watson Respondent Qualified Domestic Relations Order This order creates and recognizes the existence of an alternate payee's right to receive a portion of the partidpant's benefits payable under an employer-sponsored defined contribution plan, which is quali- fied under Section 401 of the Internal Revenue Code (the "Code"), This order is intended to constitute a Qualified Domestic Relations Order ("QDRO") under Section 414(p) of the Code and Section 206(d) of the Employee Retirement Income Security Act of 1974 ("ERISA:') and shall be interpreted and adminis- tered in conformity with such laws, This order is entered pursuant to the authority granted under the applicable domestic relations laws of the state of Pennsylvania 1. PLAN This order applies to the (select applicable plan[ s]): o Verizon Savings Plan for Management Employees (the "Plan") o Verizon Savings and Security Plan for New York/New England Assodates (the "Plan") o Verizon Savings and Security Plan for Mid-Adantic Assodates (the "Plan") o Verizon Savings and Security Plan for West Region Hourly Employees (the "Plan") ilQ Consolidated Employee Stock Ownership Plan of GTE (the "Plan") [only applicable if the valuation date is on or before February 28, 1997J Any successor to this Plan shall also be subject to the terms of the order, 2. PARTICIPANT The name, address, Sodal Security Number, and date of birth of the partidpant are as follows: Name: Randall K. Watson Address: 771 S. Humer Street Enola. FA 17025 208-38-5322 Social Security Number: Date of Birth: November 2. 1950 ';:~[ ,~ "~r,,,,~ ,',), , " 1,)"<,, ' .' ~, ,. 3. ALTERNATE PAYEE The person named as alternate payee meets the requirements of the definition of alternate payee as set forth in Section 4- below, The alternate payee's name, address, Social Security Number, date of birth, and relationship to the participant are as follows: Name: Address: Cathy L. Watson 124 W. Portland Street, Apartment 44 Mechanicsburg, PA 17055 168-48-4610 AUl?;ust 25, 1957 Ex- Wife Social Security Number: Date of Birth: Relationship to Participant: THE ALTERNATE PAYEE SHALL BE RESPONSIBLE FOR NOTIFYING THE PLAN ADMINISTRATOR. IN WRITING OF ANY CHANGES IN HIS OR HER MAILING ADDRESS SUBSEQUENT TO THE ENTRY OF THIS ORDER. 4. DEFINITIONS Alternate Payee The alternate payee is any spouse, former spouse, child, or other dependent of a participant who is recognized by a domestic relations order as having a right to receive all or a portion of the benefits payable under the Plan with respect to the participant, Liquidation Date The liquidation date is the date a portion of the participant's account is liquidated to allow the payment to the alternate payee's account under this order. An assignment as of the liquidation date assigns a portion of the participant's current account. Plan Administrator Verizon Communications !nc, (Verizon) is the Plan Administrator for Verizon's employee benefit plans, Verizon has contracted with Hewitt Associates LLC to establish procedures and administer QDROs, Valuation Date The valuation date is the date on which the participant's vested account balance will be valued ill order to determine the alternate payee's designated portion ill accordance with the terms of this order. Accounts are valued on a daiJy basis, If, however, the QDRO re'[uires a his- torical division of the participant's account and a daily valuatiqm is not available for such date, the participant's account will be divided as of the valuation date immediately preceding the date specified in the order, Vested Account Balance The participant's vested account balance is the participant's betiefit as if he/she termillated employment and received a distribution On the valuation date, 2 '~, ~ 'I , ~,r ~, -I" ~, ~ , '- , , 5 (i) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-DEFINED CONTRIBUTION PLAN(S) (Choose either Option A or Option B) o Option A -Straight Percentage The order assigns to the alternate payee an amount equal to account balance under the Plan (identified in Section I) as of 100 % of the participant's vested l\.pril :3, 2003 (insert date) From the muation date to the liquidation date, the amount assigned to the alternate payee (select one): I1i Will include earnings and losses, o Will not include earnings and losses, The participant's vested account balance (select one): o Will be reduced by the value of outstanding loans before the alternate payee's portion of the benefit is determined. ell Will not be reduced by the mue of outstanding loans before the alternate payee's portion of the benefit is determined, If the assigned amount is greater on the liquidation date than the net vested account balance after any outstanding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount, OR o Option B- Dollar Amount The order assigns to dle alternate payee an amount equal to $ of the participant's vested account balance under the Plan (identified in Section I) as of the liquidation date. If the assigned amount is greater on the liquidation date than the net vested account balance after any outstanding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount. 3 r"\""'!'.."'j1W-....""""'..,,~~ ~,~ '-, 1'- , " O~" . 5 (ii) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-GTE EMPLOYEE STOCK OWNERSHIP PLAN (applies to former GTE population only) (Choose either Option A or Option B) (ll Option A-Straight Percentage The order assigns to the alternate payee an amount equal to account balance under the Plan (identified in Section i) as of must be a date on or before February 28,1997), 100 % of the pilIticipant's vested F'ilbrl.lilry 28 (insert date - 1997 From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): IU Will include dividends, o Will not include dividends, OR o Option B-Share Amount The order assigns to the alternate payee under the Plan (identified in Section 1) as of on or before February 28, 1997), shilIes of the participant's vested account balance (insert date - must be a date From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): o Will include dividends, o Will not include dividends. + ,)~:~, ,.,U"IJ_ c ~~"I ,r , , , '" ;'1' 6. FORM OF PAYMENT The alternate payee shall receive the portion of the Plan benefits assigned to the alternate payee in a single lump-sum payment, Such amount shall be adjusted for earnings and losses from the liquidation date to the date of distribution to the alternate payee, 7. COMMENCEMENT The alternate payee shall be eligible to receive payment as soon as administratively reasonable following the determination that this order is a Qualified Domestic Relations Order, In no event can the alternate payee commence his/her benefit later than April I following the year in which the participant attains age 70 Y, , 8. DEATH PROCEDURES If the participant predeceases the alternate payee prior to payment of the alternate payee's assigned benefits under the Plan, the alternate payee's benefits will not be affected, In the event of the participant's death. the account balance, which remains the property of the participant. will be payable to the participant's desig- nated beneficiary or in accordance with Plan provisions, This order does not require the participant to name the alternate payee as the beneficiary for the benefits not assigned to the alternate payee. In case of the death of the alternate payee prior to distribution of the alternate payee's benefits from the Plan, the assigned benefits will be paid to the alternate payee's designated beneficiary or, if none, in accor- dance with Plan provisions, 9. RETENTION OF JURISDICTION This matter arises from an action for divorce or legal separation in this court under the case number set forth at the beginning of this order, Accordingly; this court has jurisdiction to issue this order, In the event the Plan Administrator determines that this order is not a Qualified Domestic Relations Order. both parties shall cooperate with the Plan Administrator in making any changes needed for it to become qualified, This includes signing all necessary documents, For dlis purpose, this court expressly reserves jurisdiction over the dissolution proceeding involving the participant. the alternate payee, and the partici- pant's interest in the Plan, 5 '"'~~"'" 0',,", 1-:" ' -,,,, , 10. LIMITATIONS Pursuant to Section 414(p)(3) of the Code and except as provided by Section 414(p) (4), this order: (i) Does not require the Plan to provide any type or form of benefit, or any option, not otherwise provided under the Plan; (ii) Does not require the Plan to provide increased benefits; and (ill) Does not require the payment of benefits to an alternate payee which are required to be paid to another alternate payee under another order previously deternlined to be a Qualified Domestic Relations Order, 11. TAXATION For purposes of Sections 402 and 72 of the Code, any alternate payee who is the spouse or former spouse of the participant shall be treated as the distributee of any distribution or payments made to the alternate payee under the terms of the order and, as such, will be required to pay the appropriate federal. state, and local income taxes on such distributions, 12. CONSTRUCTIVE RECEIPT If the Plan inadvertently pays to the participant any benefit that is assigned to the alternate payee pursuant to the terms of this order, the participant will immediately reimburse the Plan to the extent that the participant has received such benefit payments and shall forthwith pay such amounts so received to the Plan within ten (10) days ofreceipt. If the Plan inadvertently pays to the alternate payee any benefit that is actually payable to the participant, the alternate payee must make immediate reimbursement. The alternate payee must reimburse to the extent that he/she has received such benefit payments and shall forthwith pay such amount so received to the Plan within ten (10) days of receipt, 6 !~,,< , ,~,~q " 1'1 -1- " I, - - ~ 13. EFFECT OF PLAN TERMINATION If the Plan is terminated, the alternate payee shall be entitled to receive Iris/her portion of the partidpant's benefits as stipulated herein in accordance with the Plan's termination provisions for partidpants and beneficiaries. 14. CERTIFICATION OF NECESSARY INFORMATION All payments made pursuant to this order shall be conditioned on the certification by the alternate payee and the partidpant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein. Dated this ~ day of ,~3 By the court:/, //" ~ , ~~ l-\\ \~to.J ,~(f) O~~\ 7 ',j '. '''','",""" 1'( ,~ 1',1 ~ 1 '" 'I Ol' ~(X ,- . -- =~- . .~.~"U~ .,' ~,,_ a_. _"a _'.,,,,, I"" ~ , <,",' '",,,..,, -";' ;~'>-',i, - -,,~- \7!~\!"tJ?(; \0;'.!t I:J I / r~, {I-' ,..,,'~ -'-;':; \ -_1(, L'~' "'"' "'.,"" ';:-:i~~~:v~nc) t'l : II 1'J\"' ""0 C:.J\) t.t j;.G\/i(~:;:_,! ' !__;~'"' '::k.JI..:::~:U" u:~ .:10 '.,"~'".. <">"~,,,,,--'<,, -""""''''''~'"-'->I''- ""'" 0' co' 1,J, ..-" ~"~~= h@fj~~!t.q~~~,i?,jrw-""'.a"''''f'''PP'f''\')'W'fi<T'<-' '""'J!1;:f',,,,ry,,~'fl!~~M*l!!ii\'!o"li,!'''A~t'<<!i!#'''I>'"l~~~~' ... 1 r",' "--"'-"'1 ... \ '" Cathy L. Watson, 55#168-48-4610 PEN N5YLVAN IA Plaintiff IN THE COURT OF COMMON PLEA5 CUMBERLAND COUNTY, V. NO. 01-2585 CIVIL TERM Randall K. Watson, 55#208-38-4610 Defendant CIVIL ACTION - LAW IN DIVORCE MOTION TO ENTER OUALIFIED DOMESTIC RELATIONS ORDER NOW COME, Plaintiff and Defendant and respectfully request your Honorable Court to enter the Qualified Domestic Relations Orders (QDRO's) in this matter and for reasons therefore state: 1. Plaintiff, Cathy L Watson, and Defendant, Randall K Watson, were divorced from the bonds of matrimony on April 30, 2003, to the above term and docket, the final Decree in Divorce incorporating the terms of their April 3, 2003, Marital Settlement Agreement. 2, In accordance with the terms and conditions set forth in said agreement, the QDRO is to be entered subsequent to the entry of the final Decree in Divorce, 3, Plaintiff and Defendant desire the entry of said QDRO's by your Honorable Court, WHEREFORE, Plaintiff and Defendant respectfully request that your Honorable Court enter the QDRO's attached hereto, Respectfully submitted: MILLER LIPSITT LLC z:~ James A Miller 2157 Marke treet Camp . PA 17011 737 6400 " r-',' _','-, I"::"'~'h"'~',~ ~, ,'F ,,,",,'.\ <',-dF--cj -, '1->,"'I'!'" ~" - -' ., ','~ III ~ fe, , "'l~'" ~~<< ,'1,""',', " ~,.7'~<:" ,.,,,~"!'l"'~' ;!!'.~, ,', r! ,1I"1'!lll ""1- .."..,.. -..,<> '" "'":""1 I " ","}"" 1(11' J~ .iI (') c..) 0 C e,,1 --c] s: ;"j') '-;-j "Jt'";0 n1 Sf~ ~~~~ "a :::-~ [-0" f ;-,=! (/) ',0 T -< ~ '- -0 " ):.; *',.,~ ~~5 F:1 z: ~',~" -.,". :;;. :..J ,.-,) n'l ~~ :,>...> S! -j ::'u -, \,0 -< ~,~ ."~:,...."~~~,,-.l"1~I~,,,~~~,jf1jt~~.I!l!~\I~!~lffli!!I!~ > , , /:.."".,- -.. l Cathy L Watson, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2585 Randall K Watson, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner service of the Complaint: complaint flied on May 1~ 2001 and service was obtained upon the defendant by certified mail number R":QI6"Z44745 on May 15, 2001. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: "1"/1 ( f!. 2- &0:3 by Defendant: /tf/; I 3 2.--&03 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: ,/f'r/J 15" ~.,po.5 by Defendant: /4r" J I r z dO:> 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Miller Lipsitl ;L~ -fI// . BY:';;:??) ~ ~ am A Miller, Esquire ~Qrney for Plaintiff ~2157 Market Street ~ Camp Hill, PA 17011 . (717) 737-6400 J1r1 ~ ~,1 ' , " ", , . , -'~,'- -- """ ., I "e. ~",'''', ""I' '~'Wr lJn'l I' 11 T'T~mlrTI': Lltmllli"Y "'" " o c .;;; ,,"!,;~::'>: fl:::Jr;-:: -? . Z (j) -~.::-,. ~'-- ~: p "~ 'l ","f'''''^T ~ ~ ,~!l'!11l~!:~__,", 0; ... ~ :'::1" ~'0 C..:' '" 1,_"-.-' ,,"'~~. '-" i'M,"; '.'~'-------<';",--- . Cathy L. Watson, Plaintiff v. Randall K. Watson, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01.2585 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MARITAL SETTLEMENT AGREEMENT ,It! 3 2003 '~. ,d.'_ o>'"".~.,,_ ~< .,'" ," ',1,'""<".,,, '=" _."~~' '0 ," r.." 1 ,,'- ~ , ,-- I ," j'" ~:~ ~;, i" , ,e, I':' I f) r" L;: ",i ;:;:: i',; ,~1,,,~,,," ',1,' " Watson MSA TABLE OF CONTENTS PAGE SECTION 1, SEPARATION AND NON INTERFERENCE:..,..,..,.."....,......,.."..,.....,.."..,..,......,..,..".....,..,..,.."..,....,..,3 2, RECONCILIATION: ,., ,.., ,.,., ,., ,., ,., ",., ,., '., ,.,."., ,., ,., ,., ,., ,., ,., ,..,.., ,., ,., ,., ,..,.., ,., ,., ,." ,,' ,." ,., ,., ,., ,."..,.., ,., ,., ,., ,.4 3, ENFORCEMENT: .,..,.., ,., ,.,."., ,., ,., ",., ,., ", ,.,..,..,..,., ,., ,."., ,..,..,..,.., ,., ,., ,.".., ,., ,., ,.., ,., ,..,..,.., ,., ,., '."..,.., ,., ,.,.4 4. SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE (APl), COSTS AND EXPENSES:..5 A. WIFE'S lEGAL FEES: ,....,..,..,.., ..,......., ,...,..,.., ...,... ,.......,.., ............,.., ,.., ,., ,...., ......,..,..,.., ,....,.."..,..6 5, EQUITABLE DISTRIBUTION: ,....' '.,.., ....,..,..,..,..,..,........,..,.., ,.. ,...., ,..,.., ,., ,.. ,........,..,......' ..,..,..,.., c....,.." ,6 A. PREFACE: ,., ,., ,., ,., ,., ,,' ,.,..,., ,., ,.""" ,., ,,' ,."" ,., ,.' '" ,."" ,., ,., ,., ,., ,." '" '" ,., ,."", '" ,,' ,., ,., ,.., """ ",." ,., ,."" ,6 B, DISTRIBUTION OF ASSETS: ..,....,..,..,..,..,.......,.........,..,..,..,.."..,..,..,.."..,.."....,.....,..,....."..,..,..,..,6 1, WIFE'S ASSETS: ,.........,..,..,..' ..,.. ,.. .........." ........,..,..,..,..,.." ,.,..'..' ,..,..,..,..,..,..,.., ,.. ,...." ..,..,.., ,.. ,.6 2, HUSBAND'S ASSETS:, ,....,.., ....,..,..' ..,.. ,....,.., ,........' ,.. ,...., ......,..,.., ......,..,..,..,..,..,.., ,..,..,..,.., ,.,..,,7 3, ASSET DIVISION: ..,..,..,.., ,., .......,..,.., ....,.., ,.. ............,..,..,..,.."..,..,..,.."..,..,..,..'..,.., ......, ..,....,..' ,..,7 A, REAL ESTATE: 771 South Humer Street, Enola, Cumberland County, Pennsylvania ,..,..,..,7 B, DISTRIBUTION AND WAIVER OF PERSONAl..........,..,......,.............,..........,..,..,.................8 1) MARITAL, TANGIBLE AND INTANGIBLE, ASSETS AND,.....,.....,..,......,...........,..,..,..,..,..,....8 2) NON-MARITAL, TANGIBLE AND INTANGIBLE, ASSETS: .,...............,......,..,..,..,..,..,...........,8 3, Automobiles ..' ,....,.., ..,.......,..,..' ,.... ,.. ,...., ,....,..,..,.., ..'.., ,....' ,........,.., ,..,..,..,.., ,.. ,..,....., ,....,..,..,..,.., ,." ,9 4, Life Insurance Policies: .........,..,..,..,..,.....,......,......,..,..,..,..,..,..,.....",.,..,..,.."..,..,..,..".",....,.."....,..,.....10 5, FUrnishings and Personal Property at 771 Humer Street ,...........,..,..,......,..,..,..,..........,.......,.......10 6, Bank Accounts ....,....,.., ,....' ..,....' ,...., ..,....,.., ..'.., ,., ,..,........,..,..,......,..,..,.... ,.. ,...., ,.,..,.."..,..,..,..,.., ..,1 0 7, Fidelity Magellan Investment Account (#2BE230472):......................,..,......,..,.....................,..,..,..11 8, Retirement Accounts and 401(k): ....,..,..'.........,.,..,..,..,......'..'......................,..,..,..,............,......,...11 C, INTENT: ,..,.., ..,..,..,..' ,......, ,., ....,..,..,..,.., ..,..,.., ,.,..,.., ,., ......,.., ,........,.., ,....' ,..,... ,.. ,...., '..,.., ..,..,..,12 ADDITIONAL DOCUMENTS ..,...., .....,.., ...., ,.. ,...., ..,........,..,.., ..,..,..' ,..'..' ,...."..,..,..,.., ,........ ,..'..'..' ,.. ,.. ,.. ,.. 12 TAXES '..' ,., ,., ,., '" ,..,."., ,..,..,., ,., ,., ,., ,., ",..,."., ,.,..,."" ,..,.., ",.', """,., ,., ,.".., ,., ,., ,." ,., ,., ,., ,., '.',.., ,., '" ,., ,., ,., ,., ,.12 6, AFTER ACQUIRED PROPERTY: ....,....,..,....,..,........,..,..,.."..,..,..,..'....,..,........".,..,..,..,..,..,.."..,..,..,..,,12 7. DEBTS:, ,., ,....,..,..,.., ,.,..' ,...., ,.. ,...., ,...,..,.., ..,....,..,..,..,..' ,.. ,.. ............,.., ,..,..,..,..,.., ...,... ..,.....,... ,.,..,..,..,..,,13 A. Wife's Debts: ...., ....., ,...., ..,..,.., ....,..' ..,.. ,.. ,...., ,.,..,..,..,..,..,..,.., ,..,..,.., ,..,.., ,.. ,.. ,....,..,.., ......,..,..,..,..,..,13 B, Husband's Debts: ......' ,.. ,.. ,....,..,..,....,..,..,..,..,.. ,.., ....., ,.. ,....,..,.."..,..,.., ,.., ,.,..,.., ,.. ,.. ,.. ,.. ,....,..,..,..,..,13 C, Joint Debts: ......., ,...., ..,..,..,.., ..,..,....' ,., ..,....,..,..,..,..,.., ,..,..,..,.., ,., ......, ", '.,..,.."..,..,..,..,..,..,..,..,..,.., ,.13 1, PNC Bank Home Equity Line of Credit #4003048012108328.............,..,..,..,..,..,..,..,..,..,....,..,......13 2, Alan M, Watson - Messiah College Tuition ..,..,..,..,..,..,............,..,..,...,..........................,..,..,........,..14 D, Indemnification: "" ",..".,..,..,.....,.,..,.".' ,., ,., ,., '" ,., ,., ",." ,., ,,' ,., "".., ,., ,..,..,.., ,., ,., ,.' ,., ,.,..,., '." ,,'.' ,., ,., ,.14 E, Bankruptcy - Obligations Not DiSChargeable .,..,..,..,.........,..,..,..,..,......,..,..'......,.................................15 8. FUll DISCLOSURE: ..,.."............"..,....,..,....,..,..,.."....,..,..,..,..,......,..,..,.."..,..,..,..,..,..,..,..,....,..,..,..,..,,15 9, RELEASES:.... ,..... ...., ,....,..,..,.., ..........,..,..' ,.,..'.. ,.. ,.. ,.. ,..,..,..'..' ,.. ,.. ...,... ,....,..,.... ,., ,., ,...., ,...,.....,..,..,..,..,16 1 0, B~EACH: .,...., ,.,..,..,..,..,.., ..,....,.., ..,..,....,..,..,..,..,..,..,.., ,...., ......,..,..'..'......, ,...., ,....' .....,..,..,..,..'..'..' ,.,..17 11, REPRESENTATION: "..,..,..,..,....,....,........,....,.........,....."....".....".".,..,..",.,.....,.."..,.,..,....".............17 12, VOLUNTARY EXECUTION:....,.., ....,..,..,..,..,..,..,..,..,.., ,...." ..,..,..,..,.."..,..,.., ..,..,.." ..,..,..,....,..,..,..,..,,17 13. ENTIRE AGREEMENT:, ..,.., ..,....,..,.., ..,....,..,.., ..,......,..,..,..,..,.."..,..,..,..,.."..,.., ,..,..,..,..,..,..,..,..,.., ...., 18 14. PRIOR AGREEMENT:..,..,..,..,..,..,....,.., ,.,..,..,..'..'..,..'.."..,..,..,..,.., ,.....,..,..,......,..,..,..,..,..,..,..,..,..,.., ..18 15, MODIFICATION AND WAIVER:,....,..,..,..,....,.."..,..,..,..,..,...,.....,........,.."..,..,..".,,..,.........."."....,..".18 16, GOVERNING LAW: ..,....,..,..,.., ..,....,.., ,.,.., ........,............ ,.. ......,.., ,.. ,.. ,..,.., ,.. ......,..,..'..,..,.., ...." ..........18 17, INDEPENDENT SEPARATE COVENANTS: ,..,..,.."..,..,..,..,..,..,......,..,..,..,........................,..,..,..,..,,18 18, VOID CLAUSES: .......,....,.."....,..,....,..,..,....".......,...,..,..,..,..,.."..,..,..,......,..,..,..,..,.....,........,..,.....,..,,18 19. DI$iRIBUTION DATE: ......,..,..,.., ....,..,..,.., ,.,..,..,.., ,., ,.....,..,... ,....,..' ........., ,....,......, ..,..,..,....,..,..,.., ,.,,19 20, D~TE OF EXECUTION: ,....,..,..,..,....,....'.....,..,..,.."..,..,..,..,..,..,..,..,...,..,......"..,..,..,..,....,..,..,....,..,..,,19 EXHIBIT "AU ., '" "'" ,., ,.,'.' ,.' ,., ,.' ,., ,.' ,.,., ,., ,., ,., ,.,..,."., ,..,." ,.,.., ,., '" ,., ,."." '" ,., ,." ,., ,., ,., ,., ,., ,., ,., ,., ,.,., ,., ,., ,,' ,., ,21 I have read this page and understand the contents herein, RKW 1tKvJ: CLW (! uJ page 2 .,-,',,,."~.'1-,"~,,' r ,"""" f^, .,' '~I:.'" r , . _, .' ~,' ,.." ,,, " '" . -"~="'-~'c'~" , ~.'-~, Watson MSA ;: ,~ MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this _ day of between Randall K. Watson, hereinafter called "Husband", and hereinafter called "Wife". WHEREAS, Husband and Wife were lawfully married on June 25, 1977 in Dauphin County, Pennsylvania; WHEREAS, the parties are the natural parents of one child, namely Alan Michael Watson, born February 24,1982; WHEREAS, differences have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto desire to settle 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 and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, 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: , 2003, by and Cathy L. Watson, ii, l:: t' [' f: i" ,'..1 1/ ~ , 1. SEPARATION AND NON INTERFERENCE: It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. Each party shall be free from interference, authority and control by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry I have read this page and understand the contents herein, RKW t€ kttl.. CL W C 10 page 3 -T:'_~ ~,_ ' '.' ~_ " 0 _^'o/~."!,'" _'^""'.'<~'" .'\, _ ~I ,n -:r . ,.. f'c__ 1-- - 1', " ~~ ,r,~' , -.....".. .""'".'" Watson MSA out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. 2. RECONCILIATION: This Agreement shall not be deemed to have been waived, extinguished, discharged, terminated, invalidated or otherwise affected by a reconciliation between the parties hereto, cohabitation between the parties, a living-together or resumption of marital relations between them. They shall not be deemed to have reconciled with the intention of vitiating or terminating this Agreement unless they make such actions through a written instrument, executed and acknowledged in the same manner as this Agreement. 3. ENFORCEMENT: The parties acknowledge that Wife has filed with the Cumberland County Court of Common Pleas, Pennsylvania (Civil Term, Docket No: 01-2585), a no-fault divorce action pursuant to Title 23, section 3301 (c) of the Pennsylvania Divorce Code and amendments thereto prior to the execution of this agreement, and Husband has been served with a Certified Copy of said complaint. It is specifically understood and agreed by the parties that the provisions of this agreement relating to equitable distribution of property and all other matters contained herein including but not limited to support, alimony, alimony pendente lite, counsel fees, costs and/or expenses are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code and shall be submitted to the court at the time of filing the praecipe to transmit the record to conclude the divorce. The parties agree to execute their respective Affidavit of Consent and Waiver of Notice and proceed with entering same to the court docket for the purpose of finalizing the divorce action as soon as is practicable within the time frame permitted pursuant to the Rules of Civil Procedure. Each party shall further execute any and all documents that may require his or her signature for the purpose of effectuating all of the terms and conditions of this I have read this page ancl understand the contents herein, RKwl!k.W ; CLW CW page 4 ")1""""",' -,",,' ,_ ,_" ',,' "' ". '~,,<"'1 ''''1'''11'' , _"".",_,,0 _. " ^~=~"--,,"' '""'- , Watson MSA Agreement so as to give full force and effect to this Agreement. Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement. . It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE (APL), COSTS AND EXPENSES: Husband and Wife hereby acknowledge that they have been advised or have the right to obtain advice in regard to the fact that each may have the right to assert a claim for spousal support, alimony, alimony pendente lite, costs and/or expenses. Further, Husband and Wife acknowledge that they understand that said rights are available in their divorce action. Husband and Wife further acknowledge that they are aware of the income, education, income potential, and assets and holdings of the other or have had full and ample opportunity to become familiar with such items. Husband and Wife hereby accept the mutual covenants and terms of this Agreement and the benefits and properties passed to them hereunder in lieu of any and all further rights to support or alimony for themselves, counsel fees, and alimony pendente lite at this time and during any and all further or future actions of divorce brought by either of the parties hereto, except as specifically provided herein. The parties do hereby remise, release, quit claim, and relinquish forever any and all right to support, alimony, alimony pendente lite, counsel fees and expenses beyond those provided for herein, during the pendency of or as a result of any such actions, as I have read this page and understand the contents herein, RKW R. W .. CLW r fu..J page 5 Pl", ,.',,-' .', p '''', ..-<- -' ,- , ,. '.' I '~I -, -~ 'r, '1'-' 1'< -~ , .-"'" ,"~"~~""',"'-'" _e_, "~'..~,.. Watson MSA provided by the Divorce Code of Pennsylvania or any other applicable statute, at this time and at any time in the future. A. WIFE'S LEGAL FEES: Husband and Wife acknowledge and agree that Husband has elected to continue the finalization of this legal matter without counsel. Husband hereby acknowledges and agrees that a form agreement was inadvisable for the parties to use in this matter. Husband acknowledges and agrees to pay any and all fees incurred by Wife for the preparation of this Agreement up to $800.00. On the date of execution hereof Husband shall pay by check to Wife the sum of $800 for Wife's fees and costs incurred in drafting this Agreement, as indicated on the invoice(s) supplied by Wife to Husband. Moreover, in light of the necessity to transfer the real estate from Husband and Wife to Husband (section 5B3A hereunder), Husband acknowledges and agrees to pay the fees for the preparation of instruments transferring title, including but not limited to quitclaim deeds and recording fees up to $165. Husband shall pay to Wife on the date of execution hereof, a check in the amount of $165 representing Wife's fees and costs incurred in drafting, reviewing and finalizing instruments transferring title under this Agreement. 5. EQUITABLE DISTRIBUTION: A. PREFACE: The parties have valued to the best of their ability their entire marital and non- marital estates. The parties have made use of either the information provided between themselves and/or statement values associated with such assets and/or have attributed fair market values and/or other agreed upon values to such assets and for purposes of negotiation and settlement, and hereby stipulate to such valuations. The parties desire to effectuate the division of all assets in undertaking these terms of settlement. B. DISTRIBUTION OF ASSETS: 1. WIFE'S ASSETS: Husband does hereby grant, convey, transfer, assign, and deliver and set-over unto Wife the assets so identified within this agreement; said assets shall be and I have read this page and understand the contents herein, RKW ((ktJ .. CLW (! ;jtJ page 6 '~...~ _.C__""'^""I.' ,,'~, ",," -~" "" ,~" '. .,,1 ,,' ,,' , ,..,_...."'1 """,_, _~ ,,'. ' , _~ < ., ,'" -~ "~~" ~ Watson MSA remain the sole and separate property of Wife hereafter, free of any claim by or interest of Husband, regardless of whether such assets were deemed by either of the parties to be marital property or non-marital property. And further, Husband does hereby waive, release, relinquish, and surrender forever any and all claim to or interest in said assets, which shall be and remain the sole and separate property of Wife hereafter. 2. HUSBAND'S ASSETS: Wife does hereby grant, convey, transfer, assign, and deliver and set-over unto Husband the assets so identified within this agreement; said assets shall be and remain the sole and separate property of Husband hereafter, free of any claim by or interest of Wife, regardless of whether such assets were deemed by either of the parties to be marital property or non-marital property. And further, Wife does hereby waive, release, relinquish, and surrender forever any and all claim to or interest in said assets, which shall be and remain the sole and separate property of Husband hereafter. 3. ASSET DIVISION: The parties hereby agree that the following assets shall be divided in accordance with the terms as provided herein. Husband and Wife agree to execute any and all documents required to effectuate the intent herein: A. REAL ESTATE: 771 South Humer Street, Enola, Cumberland County, Pennsylvania The parties are the record title owners of the real property known as 771 South Humer Street, Cumberland County, Pennsylvania (referred to herein as the "premise"), The parties hereby agree that Husband shall be entitled to all right, title and interest to said premise and Wife shall waive any and all right, title and/or interest, claim she may have therein and shall further execute upon request a quitclaim deed transferring any interest she may have therein. Upon request, Wife shall execute a transfer deed transferring any and all right, title and interest she may have therein unto Husband. Husband shall indemnify and hold Wife harmless for all past, present and future indebtedness on the premise including, but not limited to, any and all mortgage obligations 1, real estate taxes, utilities and municipal assessments, and repairs, costs and maintenance. Husband shall be entitled to claim all interest, real estate taxes and I PNC Home Equity Line of Credit is believed to be the only debt associated with the marital residence, J have read this page and understand the contents herein, RKW (( k:tAf ; CLW ~.;/tJ page 7 ,~ ''''-'",,-/-- -I,'i"_'" , ,'-j ",- -..........,~- , Watson MSA any other permissible expense paid for purposes of tax filings. Husband agrees that he shall refinance the premise in his name alone and have Wife released from the existing mortgage obligations identified herein, within one (1) year from the date of execution of this Marital Settlement Agreement. Husband further agrees that he shall modify his last Will and Testament, within sixty (60) days of execution of this Agreement, to provide for the inheritance of the marital residence by the parties' son, Alan M. Watson. Husband shall within fifteen (15) days of completion of such act provide a true and correct copy of such Will to Wife. Husband further agrees that so long as Husband retains the use, enjoyment and possession of the marital residence, he shall not dissipate, transfer ownership interests and/or destroy his ownership interest in the marital residence such that the parties' son's beneficial interest as provided hereunder would be less than the equity in the marital residence at the time of execution hereof. This provision of Husband's last Will and Testament may be made contingent upon the parties' son surviving the Husband and may be removed from Husband's last Will and Testament upon the parties' son attaining the age of twenty-six (26) years. Husband further agrees that if Husband should sell the marital residence, prior to the parties' son attaining the age of twenty-six (26) years, the parties' son, Alan M. Watson, shall be entitled to a sum equal to one-half of the equity in the marital residence, but in no instance less than one-half the equity existing at the time of execution of this Agreement. Husband acknowledges and agrees that upon any sale of the marital residence by Husband, Husband shall pay, at the time of settlement, unto the parties' child, Alan M. Watson, a sum equal to one-half the proceeds from the sale of the marital residence, but in no instance less than one-half of the existing equity in the marital residence at the time of execution of this Agreement. Upon the parties' son attaining the age of twenty-six (26) years, Husband shall be free to dispose of the marital residence as he deems fit and proper. B. DISTRIBUTION AND WAIVER OF PERSONAL 1) MARITAL, TANGIBLE AND INTANGIBLE, ASSETS AND 2) NON-MARITAL, TANGIBLE AND INTANGIBLE, ASSETS: 1. Husband and Wife do hereby acknowledge that they have divided to their mutual satisfaction all non-marital and marital assC:~:I)ing, but without I have read this page and understand the contents herein, RKW I<W ; CLW page 8 '-~, ''''''',~ "'-"", ,'" "" -,~", "' , ':"1",,' '", +!, ~ ,"~" - , r' ,~ '.~ <,',',..< ~.= -.. : "-~~~ "" ~ Watson MSA limitation, business interests, corporate interests, partnership(s), joint ventures, inheritance(s), jewelry, clothing, retirement accounts, 401 k's, pensions, brokerage accounts, stocks, bonds, life insurance policies or other securities, Individual Retirement Accounts, checking and savings accounts, mutual funds, and other assets whether real, personal or mixed, tangible or intangible. 2. Husband and Wife further acknowledge and agree that the assets in the possession of the other spouse unless otherwise so divided by way of this agreement shall remain that spouse's sole and separate property, each party hereto specifically waiving, releasing, renouncing and forever abandoning whatever claim, if any, he or she may have with respect to any of the foregoing items which are the sole and separate property of the other. 3. Automobiles: Husband and Wife agree that the vehicles in their respective physical possession shall remain the possession of the party and each shall cooperate if necessary in executing any and all documents to reflect such ownership, including but not limited to titles, insurance documentation and registration forms. Specifically, Husband shall retain the 1995 Acura Integra, currently jointly titled and the 1994 Mazda 84000, currently jointly titled. Wife shall retain the 1998 Toyota Camry titled in Wife's name alone. Husband and Wife further acknowledge and agree that the parties own a 1992 Nissan 240SX currently titled in Husband's name alone. Husband agrees to and shall transfer ownership of the 1992 Nissan 240SX,to the parties' son, Alan M. Watson, within sixty (60) days of son's graduation from college with a bachelor's degree. Husband and Wife do hereby waive, release, and relinquish any and all claim to or interest in the motor vehicle in the possession of the other. If the title to any vehicle is encumbered by any debt or obligation, Husband and Wife agree that they shall each be solely responsible for and shall pay and satisfy said obligation, in accordance with its terms and provisions, and shall indemnify and save the other harmless from any loss, cost, or expense I have read this page and understand the contents herein, RKW It.IcJ CLW..MJ page 9 ^,,',' .' ",",' .,",11', ".'-" ,,'--'~-'I"'l'T 1, ,0/, '""" '-1"- ~ , 1"" ~ ," f "'?""1_ Watson MSA caused to either by their failure to make payment of such debt. 4. Life Insurance Policies: During the course of the marriage, the parties acquired insurance policies, in their individual names, that have cash value. Husband hereby acknowledges that he is the owner of Equitable Variable Life Insurance Policy #42307753. Husband hereby further acknowledges that he is the owner of WRL Freedom Equity Protector Insurance Policy #15B0961973. Husband and Wife acknowledge that these policies have a cash value of approximately Fourteen Thousand ($14,000) Dollars each. Within sixty (60) days of the execution of this Agreement, Husband shall surrender these policies for cash value and the entire proceeds therefrom shall become the sole and separate property of Wife, The tax consequences of surrendering these policies shall become the sole responsibility of Wife. 5. Furnishings and Personal Property at 771 Humer Street: Husband and Wife hereby acknowledge and agree that the household furnishings and personal property located at 771 Humer Street, shall remain the sole and separate property of the Husband except as provided for in Exhibit A of this Agreement. Items listed in Exhibit A of this Agreement shall become the sole and separate property of Wife but are currently located at the marital residence. Husband and Wife shall agree with specificity regarding the items listed in Exhibit A and Wife shall remove these items from the marital residence within ninety (90) days after the execution of this Agreement. 6. Bank Accounts: Husband and Wife acknowledge and agree that they are joint owners of bank accounts with PNC Bank. Specifically, the parties jointly own PNC Checking Account #5000980427 with an approximate balance of $590.00 and PNC Money Market Account #5130211183 with an approximate balance of $994.46. The proceeds from these accounts shall be the sole and separate property of Wife and the accounts shall either be closed or transferred to Wife's name alone. Husband does hereby waive, release, and I have read this page and understand the contents herein, RKW ~((v/; CLW C~J pagefO . 'h . 'l~"e r,,,',~ c,,__ -','~ I"''!" ~,,-- '1"'" "~'''.I ."~r - ~-".",--~ Watson MSA relinquish any and all claim to or interest in these accounts and the proceeds therein to Wife. Husband shall execute any and all documents necessary to transfer ownership of these accounts to Wife's name alone. 7. Fidelity Magellan Investment Account (#2BE230472): Husband and Wife acknowledge and agree that during the course of the marriage, they jointly acquired a Fidelity Magellan Investment Account (#2BE230472), Husband does hereby waive, release, and relinquish any and all claim to or interest in this account and its proceeds to Wife. This account shall be the sole and separate property of Wife. Husband shall execute any and all documents necessary to transfer ownership of this account to Wife's name alone within sixty (60) days of the date of execution of this Agreement. 8. Retirement Accounts and 401 (k): Husband's Highmark Investment Plan shall remain Husband's sole and separate property, Wife hereby waiving, relinquishing and transferring any and all past, present and/or future right, title and/or interest she may have therein. Husband's Verizon Savings Plan shall be transferred to Wife's name alone within sixty (60) days of the date of execution of this Agreement and become Wife's sole and separate property, Husband hereby waiving, relinquishing and transferring any and all past, present and/or future right, title and/or interest he may have therein. Wife's Caretti, Inc. 401 (k) shall remain Wife's sole and separate property, Husband hereby waiving, relinquishing and transferring any and all past, present and/or future right, title and/or interest he may have therein. Husband and Wife acknowledge and agree that the parties' son, Alan M. Watson, is the sole beneficiary on Wife's 401 (k) plan and shall remain the sole beneficiary of Wife's Caretti, Inc. 401 (k) plan until the parties' son attains the age of twenty-six years. After the parties' son has attained the age of twenty-six years, Wife may change the beneficiary designation on her Caretti, Inc. 401 (k) plan if she so chooses. I have read this page and understand the contents herein, RKW f(ktJ .. CLW (l;f(J page 11 "--',- "0 '_',,'_ '<' ~-' --,,'1 - '<__. r"~""~'lr,r f"- p , '. , I'~'Y,"""'~',' 1 , I ~ ".-,-," ,,' ~-<>~~.<, Watson MSA C. INTENT: This Agreement is intended to distribute all property of the parties, whether real or personal, and whether determined to be separate or marital property. In the event that any property may be omitted from this Agreement, it is understood and agreed that the person having possession and/or title to such property following the execution of this Agreement shall be deemed the owner thereof and each of the parties will execute any and all legal documents without any charge therefore to evidence title to such property in the other party. ADDITIONAL DOCUMENTS: Each of the parties shall on demand execute and deliver to the other any deeds, documents, records or closing statements relating to the sale of real estate under this Agreement, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. TAXES: Husband hereby agrees to pay all income taxes assessed against him, if any, as a result of the division of the property of the parties hereunder. Wife hereby . agrees to pay all income taxes assessed against her, if any, as a result of the division of the property of the parties hereunder. 6. AFTER ACQUIRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are 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. The parties hereby agree that, as to all assets not specifically mentioned herein which are presently titled in the sole name of one of the parties hereto or, if untitled, are presently in the sole possession of one of the parties hereto, the party not having title thereto or possession thereof hereby waives, releases, relinquishes and forever abandons any and all claims therein, and acknowledges that the party having title or possession of such items shall be the sole and exclusive owner thereof. I have read this page and understand the contents herein, RKW (( kt-l; CLW GUt.{) pagel2 ,^"O'C"""""" -'" '~"""'"-:-"':''I''~T'',,'' ~""- -'-I'~ t"'''- 'I,~r'.'- "r ,~'~~ ~, " Watson MSA 7. DEBTS: A. Wife's Debts: Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. B. Husband's Debts: Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debtor liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him, C. Joint Debts: 1. PNC Bank Home Eauity Line of Credit #40 03 048012108328 The parties acknowledge that Husband shall be individually responsible for and solely liable for this debt which is jointly titled and shall further indemnify and hold Wife harmless to every and all extent including but not limited to all past, present, and future fees, costs and/or expenses associated with the collection of such debts, judgments, interest, taxes and suits, including reasonable attorneys fees incurred to enforce this indemnification. Husband shall take any and all steps necessary and sufficient to remove Wife's name from this obligation within ninety (90) days of execution of this Agreement. Husband does hereby agree that he shall be responsible for the entire amount due regardless of any amount stated herein. Further, Husband covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold Wife liable for said debt, obligation, liability, act or omission of such Husband, such Husband shall at his sole expense, defend Wife against any such claim or demand, whether or not well-founded, and that he will indemnify and hold harmless Wife in respect of all damages as resulting therefrom including reasonable attorneys fees incurred to enforce this indemnification. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including I have read this page and understand the contents herein, RKW ,1/<-tJ .. CLW~ page 13 -';"1"!1' - ""~Y"W~__':':"..,<";!A'l"~ 1",,"" '"1'~""II",..-- - -"1''-,,... - ""',I.'~ ,"'~1"- "" ~ -~~,.~ Watson MSA without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Wife from any inaccurate representation made by Husband to Wife in this Agreement, any breach of any of the warranties made by Husband in this Agreement, or breach or default in performance by Husband of any of the obligations to be performed by such party hereunder, Wife agrees to give Husband prompt written notice of any litigation threatened or instituted against him, which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 2. Alan M. Watson - Messiah Colleae Tuition Husband and Wife agree and acknowledge that there remains approximately nineteen months until the parties' son, Alan M. Watson's, expected graduation from Messiah College. Husband hereby acknowledges and agrees that he shall timely pay Thirteen Hundred ($1300) Dollars per month towards Alan M. Watson's, including but not limited to, tuition, fees, meals, housing, supplies, and other necessary school fees, expenses and/or costs and until Alan M. Watson's graduation from Messiah College. D. Indemnification: All further debts incurred by the parties shall be their individual responsibility. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the, other party in respect of all damages as resulting therefrom including reasonable attorneys fees incurred to enforce this indemnification. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this I have read this page and understand the contents herein, RKW I<.. k. J ,. CLW f~ page 14 ~ . ~. ""1- /" "1" :.'; . -- . . --" ,T,. -'7" :",'!"p..,I-: '," , f'- " " ~', 1'-" ,~," 1- ",-~~ _'"M Watson MSA Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party, which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. E. Bankruptcy - Obligations Not Dischargeable The parties represent that to the best of their knowledge there are no bankruptcy proceedings pending involving either of the parties. The debt payments provided for in this Agreement are not, and are not intended to be, a debt which is affected by a discharge in bankruptcy. Therefore, these debts shall not be discharged in any bankruptcy proceeding initiated by either party. In the event that at any time prior to either Husband's or Wife's fulfillment of all of the financial obligations set forth in this Agreement, he or she declares personal bankruptcy as a result of which the other spouse becomes liable for any such debt herein identified, at either spouse's sole option and within sixty (60) days of actual receipt of notice of such bankruptcy, this Agreement shall be null and void and the parties returned to as close to the respective financial positions as they were in prior to the effective date of this Agreement as practicable. Alternatively, either spouse so affected by the other's bankruptcy filing may elect to enforce the terms of this agreement in a bankruptcy proceeding wherein the bankrupt spouse acknowledges that the debt(s) hereinabove set forth are non-dischargeable in as much as it/they is/are or may be considered necessary as a means of support and maintenance of the affected spouse given the equitable division of property as devised within this agreement. 8. FULL DISCLOSURE: The parties acknowledge that each of them have had a full and ample opportunity to consult with counsel of their choice regarding their claims arising out of the marriage and divorce and that they have specifically reviewed their rights to the equitable distribution of marital property, including rights of discovery, the right to I have read this page and understand the contents herein, RKW R kJ; CLW (!,JJJ pagel5 ,&~ , ~ ---- '" " -""'" '... ,- - . '~.' ",' " , '":'"'1.'1"" " I, "c .,-,~ Watson MSA compel a filing of an Inventory and Appraisement, and the right to have the court review the assets and claims of the parties and decide them as part of the divorce action. Being aware of those rights, and being aware of the marital property owned by each of the parties, the parties hereto, in consideration of the other terms and provisions of this agreement, do hereby waive, release and quitclaim any further right to have this court or any other tribunal equitably distribute or divide their marital property. The parties acknowledge that they have been fully advised and informed of the wealth, real and/or personal property, estate and assets, earnings and income of the other and are familiar with and cognizant of such and the value thereof, or has knowingly waived such advice and/or information. The parties hereto have been fully advised and informed of all rights and interests which, except for the execution and delivery hereof, have been conferred upon or vested in each of them by law with respect to the property or estate of the other by reason of their marital status, or has knowingly refused or waived such advice or information. 9. RELEASES: Except as otherwise herein provided, each party releases and discharges completely and forever the other from any and all right, title, interest or claim or past, present or future support, division of property including income or gain from property hereafter accruing, right of dower and courtesy, right to act as administrator or executor in the estate of the other, right to distributive share in the other's estate, right of exemption in the estate of the other, or any other property rights, benefits or privileges accruing to either party by virtue of said marriage relationship, or otherwise, and whether the same are conferred by the statutory law or by the common law of the Commonwealth of Pennsylvania, or any other state, or of the common law of the United States of America. It is further specifically understood and agreed by and between the parties hereto, that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said parties' rights against the other for any past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital I have read this page and understand the contents herein, RKW f( kJ; CLW.!!:IJJ page 16 'f., ,,~ "',"~~'~,7';",~","" ,_ _,:." ,,,'_, "," _'1:.'1 . ,._"1"". 'f"'- -. 1" ' Watson MSA property and any other claims of each party, including all claims raised by them in the divorce action pending between the parties. 10. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 11. REPRESENTATION: It is recognized by the parties hereto that each party has the right to be represented by counsel by his or her own free and voluntary choosing. It is fully understood and agreed that he or she has the right to have advice of counsel prior to the signing of this Agreement. By the signing of this Agreement, Husband and Wife recognize that he and she fully understand the legal impact of this Agreement and waives his or her right to have the Agreement reviewed by an attorney of his or her choosing, and further intends to be legally bound by the terms of this Agreement. Each of the parties acknowledges that he or she has read and understands the nature and importance of this Agreement, that each considers the provisions of this Agreement to be fair, just and reasonable, that each enters into it freely and voluntarily, and that each does not desire to have or become possessed of any property of the other party or any interest therein which the other party now owns or hereafter may own, except as expressly provided for in this Agreement. Husband does hereby acknowledge that he has been advised to seek independent, separate counsel and has voluntarily waived such right to do so without any coercion, force or representation asserted by Wife. 12. VOLUNTARY EXECUTION: The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and that it is not the result of any duress or undue influence. Further, I have read this page and understand the contents herein, RKW /({<.J., CLW MJ page 17 --..,.- . -. ,'" _','. ,c,~,'-' --. "'~1 ~,o-''''''I'~r ,,' ~~"","" -,' I (,,-' . '1 " - - ",', "'~ ,~ Watson MSA each party acknowledges that he or she has the mental capacity to understand the terms provided herein and has not been placed under duress, coercion or any physical or mental stress. 13. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein, 14. PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements executed between the parties, and/or mayor have been executed prior to the date and time of this Agreement, are null and void and of no effect. 15. MODIFICATION AND WAIVER: Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 16. GOVERNING LAW: This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 17. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 18. VOID CLAUSES: If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then et;Jt term, condition, I have read this page and understand the contents herein, RKW f( (c J.. CL W page 18 "t(Ilif ;";"'''',,- -,' ,'^"" , ,,' "'I"r , '1 -"" --" ,. -I'" ~~ 'I, ~.- ~~ w " ~>' . Watson MSA 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. 19. DISTRIBUTION DATE: The parties hereto acknowledge and agree that for purposes of distribution of property as provided for in this agreement, the date of execution of this agreement shall be known as the Distribution Date. 20. DATE OF EXECUTION: The parties hereto acknowledge and agree that the date of execution referred to herein shall be known as the last date upon which either party executes this agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written, WITNESS: ~V~ R,"~ W~ ~ L. on I have read this page and understand the contents herein, RKW ~ kw.. CLW (!...~) page 19 , -,,"""'C- J" . ~,',., ,"", ~",' '"'1,-"", ~, ',' " .' I . , I "" ''''',...~>~~'~ Watson MSA EXHIBIT "A" PERSONAL PROPERTY OF WIFE A) 1- woman's bicycle B) Assorted personal books, papers and novels not previously obtained by Wife C) Assorted personal childhood toys (dolls, table set, etc.) not previously obtained by Wife D) Assorted personal school records and mementos (yearbooks, etc.) not previously obtained by Wife E) Assorted family photographs and mementos not previously obtained by Wife F) Assorted collectibles, clothing and jewelry not previously obtained by Wife I have read this page and understand the contents herein, RKW ;CLWW page 2] ~, ~,-, ,~ ','I_,>"":<y.",'c,',"'N ."~" ","",_., ''''''I'''r''I!~'~,,;, ~ -,'1, ,~ - Watson MSA Commonwealth of Pennsylvania ss, COUNTY OF Cumberland On this, the 2 day of r1t,.! ' 2003, before me, a Notary Public, personally appeared Randall K. Watson, known to me or satisfactorily proven to be the person whose name is subscribed to the within Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL JAMES A, MILLER, Notary Public BolO of Camp HIli, Cumberland County PA My Commission Expires April 30, 20~5 Commonwealth of Pennsylvania --- NOTARIAL SEAL JAMES A. MILLER, Notary PUbllo Bora of Camp Hili, Cumberland County, PA My Commission Expires April 30, 2005 I have read this page and understand the contents herein, RKW i ;CLWW page 20 , ~ "",." "1'",',"., r"~r"',,.,,<,,,,,,,- ," ,-- -"" ,"',' -' "~ I 'I - - .,", 'I ' " I I: Ii ii' 1 /: fi ~ I ~ " . . ~~,,--~ - ~ '~"~'~"'o__""~~"' <, ". ,-r ~"' - "'''''l~ .",--'"7""'ll , I" l'",~'(, '~ "G',,"'_" """.'~~J"'", '"'''' <",'~~'"H ~"'""'" '''~_ "hl1%lfl~j~'l'l~l1-~~~. >~~ ^. M~~_' Co "'1 "" :,i ,-' (.," C' t?~ " ~;~ =iJ -< ()i ~R ,~"lJim,lj~l~lU!ij!I]!I'~~ '0,. _",,?' tJ /.,.1S7:f JAN 1 2 2005u Name and Address Verification Form Alternate Payee's Name: Cathy L. Miller Formerly Known As: Cathy L. Watson Social Security number: 168-48-4610 Date of Birth: Au<!ust 25. 1957 Address: 1830 Anna Street New Cumberland, PA 17070 Previous Address: 124 W. Portland Street. Apartment 44 Mechanicsburg, PA 17055 Participant's Name and Social Security Number: Randall K. Watson - 208-38-5322 ~~~ Alternate Payee's Signature Please return to: No Public P<lMMONWEAI; OF PENNSYLVANIA NOTARIAL SEAl. KIMBeRLY A. MEYERS, NoI8ry PuhIIc Camp HI" Boro, CUmberlBl1d County My Commlsslon Elcplres AprI/ 26, 2008 Verizon Benefits Center Qualified Order Team Post Office Box 1433 Lincolnshire, 1L 60069-1433 Fax: (847) 883-9313 !~ -"."~~ ,;.. ".,~ '~~'~'='"'. \7 STATE OF PennHylvania CASE # 01-2585 COUNTY OF Cumberland IN THE Common Pleas' COURT OF Cumberland COUNTY, Pennsylvania IN RE THE MAl\1\lAGE OF: Cathy L. Miller Petitioner and Randall K. Watson Respondent Qualified Domestic Relations Order ... This order creates and recognizes the existence of an alternate payee's right to receive a portion of the participant's benefits payable under an employer-sponsored defined contribution plan, which is quali- fied under Section 40 I of the Internal Revenue Code (the "Code"), This order is intended to constitute a Qualified Domestic Relations Order ("QDRO") under Section 414(P) of the Code and Section 206(d) of the Employee Retirement Income Security Act of 1974 ("ERISK) and shall be interpreted and adminis- tered in conformity with such laws. This order is entered pursuant to the authority granted under the applicable domestic relations laws of the state of pp..nnRyl vaTli.a 1. PLAN This order applies to the (select applicable p1an[s]): o Verizon Savings Plan for Management Employees (the "Plan") o Verizon Savings and Security Plan for New York/New England Associates (the "Plan") o Verizon Savings and Security Plan for Mid-Atlantic Associates (the "Plan") o Verizon Savings and Security Plan for West Region Hourly Employees (the "Plan") ~ Consolidated Employee Stock Ownership Plan of GTE (the "Plan") [only applicable if the valuation date is on or before February 28, 1997J Any successor to this Plan shall also be subject to the terms of the order, 2. PARTICIPANT The name, address. Social Security Number, and date of birth of the participant are as follows: Name: Randall K. Watson Address: 771 S. Humer Street Enola, PA 17025 208-38-5322 Social Security Number: Date of Birth: November 2, 1950 -Z~^e " ...., r"" , , -~ 3. ALTERNATE PAYEE The person named as alternate payee meets the requirements of the definition of alternate payee as set forth in Section 4 below, The alternate payee's name. address, Social Security Number, date of birth, and relationship to the participant are as follows: Name: Address: Cathy L. Watson 1830 Anna Street New Cumberland, PA 17070 168-48-4610 August 25, 1957 X-Wife Social Security Number: Date of Birth: Relationship to Participant: THE ALTERNATE PAYEE SHALL BE RESPONSIBLE FOR NOTIFYING THE PLAN ADMINISTRATOR IN WRITING OF ANY CHANGES IN HIS OR HER MAILING ADDRESS SUBSEQUENT TO THE ENTRY OF THIS ORDER. 4. DEFINITIONS Alternate Payee The alternate payee is any spouse, former spouse, child. or other dependent of a participant who is recognized by a domestic relations order as having a right to receive all or a portion of the benefits payable under the Plan with respect to the participant. Liquidation Date The liquidation date is the date a portion of the participant's account is liquidated to allow the payment to the alternate payee's account under this order, An assignment as of the liquidation date assigns a portion of the participant's current account. Plan Administrator Verizon Communications Inc, (Verizon) is the Plan Administrator for Verizon's employee benefit plans, Verizon has contracted with Hewitt Associates liC to establish procedures and administer QDROs, Valuation Date The valuation date is the date on which the participant's vested account balance will be valued in order to determine the alternate payee's designated portion in accordance with the terms of this order, Accounts are valued on a daily basis, If, however, the QDRO requires a his- torical division of the participant's account and a daily valuation is not available for such date, the participant's account will be divided as of the valuation date immediately preceding the date specified in the order, Vested Account Balance The participant's vested account balance is the participant's benefit as if he/she terminated employment and received a distribution on the valuation date, 2 0-b" ~ , '"'"' ., " .r. . , " " 5 (i) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-DEFINED CONTRIBUTION PLAN(S) (Choose either Option A or Option B) o Option A-Straight Percentage The order assigns to the alternate payee an amount equal to account balance under the Plan (identified in Section I) as of % of the participant's vested (insert date) From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): o Will include earnings and losses, o Will not include earnings and losses, The participant's vested account balance (select one): o Will be reduced by the value of outstanding loans before the alternate payee's portion of the benefit is determined, o Will not be reduced by the value of outstanding loans before the alternate payee's portion of the benefit is determined. If the assigned amount is greater on the liquidation date than the net vested account balance after any outstanding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount. OR o Option B- Dollar Amount The order assigns to the alternate payee an amount equal to $ of the participant's vested account balance under the Plan (identified in Section I) as of the liquidation date. If the assigned amount is greater on the liquidation date than the net vested account balance after any outstanding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount. 3 ;',0,_ ~ "'C, "?,~, ", f-', ,~- ~ ",", 'I't -<', " '~"<'~" - ~-~" ' S(ii) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-GTE EMPLOYEE STOCK OWNERSHIP PLAN (applies to former GTE population only) (Choose either Option A or Option B) 1]1 Option A-Straight Percentage The order assigns to the alternate payee an amount equal to 100 % of the participant's vested account balance under the Plan (identified in Section 1) as ofFebruarv 27. 1997 (insert date- must be a date on or before February 28,1997). From the valuation date to the liquidation date. the amount assigned to the alternate payee (select one): .Will include dividends, o Will not include dividends. OR o Option B-Share Amount The order assigns to the alternate payee under the Plan (identified in Section 1) as of on or before February 28,1997). shares of the participant's vested account balance (insert date - must be a date From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): o Will include dividends. o Will not include dividends, 4 (~ ~, . , I",T'-I p" "1-; ?)l~~,~". 6. FORM OF PAYMENT The alternate payee shall receive the portion of the Plan benefits assigned to the alternate payee in a single lump-sum payment, Such amount shall be adjusted for earnings and losses from the liquidation date to the date of distribution to the alternate payee, 7. COMMENCEMENT The alternate payee shall be eligible to receive payment as soon as administratively reasonable following the determination that this order is a Qualified Domestic Relations Order, In no event can the alternate payee commence his/her benefit later than April 1 following the year in which the participant attains age 70~, 8. DEATH PROCEDURES If the participant predeceases the alternate payee prior to payment of the alternate payee's assigned benefits under the Plan, the alternate payee's benefits will not be affected, In the event of the participant's death, the account balance, which remains the property of the participant, will be payable to the participant's desig- nated beneficiary or in accordance with Plan provisions, This order does not require the participant to name the alternate payee as the beneficiary for the benefits not assigned to the alternate payee, In case of the death of the alternate payee prior to distribution of the alternate payee's benefits from the Plan, the assigned benefits will be paid to the alternate payee's designated beneficiary or, if none. in accor- dance with Plan provisions, 9. RETENTION OF JURISDICTION This matter arises from an action for divorce or legal separation in this court under the case number set forth at the beginning of this order, Accordingly. this court has jurisdiction to issue this order, In the event the Plan Administrator determines that this order is not a Qualified Domestic Relations Order, both parties shall cooperate with the Plan Administrator in making any changes needed for it to become qualified, This includes signing all necessary documents. For this purpose, this court expressly reserves jurisdiction over the dissolution proceeding involving the participant. the alternate payee. and the partici- pant's interest in the Plan. 5 _,e __ ~" M' ~,. ~. " " ~ ,. '''I" . ,> 'f' -' .", , .. = ,> 10. LIMITATIONS Pursuant to Section 414(P)(3) of the Code and except as provided by Section 414(P)(4), this order: (i) Does not require the Plan to provide any type or form of benefit, or any option, not otherwise provided under the Plan; (Ii) Does not require the Plan to provide increased benefits; and (ill) Does not require the payment of benefits to an alternate payee which are required to be paid to another alternate payee under another order previously determined to be a Qualified Domestic Relations Order, 11. TAXATION For purposes of Sections 402 and 72 of the Code. any alternate payee who is the spouse or former spouse of the participant shall be treated as the distributee of any distribution or payments made to the alternate payee under the termS of the order and. as such, will be required to pay the appropriate federal. state, and local income taxes on such distributions, 12. CONSTRUCTIVE RECEIPT If the Plan inadvertently pays to the participant any benefit that is assigned to the alternate payee pursuant to the terms of this order, the participant will immediately reimburse the Plan to the extent that the participant has received such benefit payments and shall forthwIth pay such amounts so received to the Planwithin ten (10) days of receipt. If the Plan inadvertently pays to the alternate payee any benefit that is actually payable to the participant, the alternate payee must make immediate reimbursement, The alternate payee must reimburse to the extent that helshe has received such benefit payments and shall forthwith pay such amount so received to the Plan within ten (10) days ofreceipt. 6 '"". --,"" ""<'.-'<k':f".."-' 'I 'Ir ~. , ~ . 1 " " 13. EFFBCT OF PLAN TERMINATION If the Plan is terminated, the alternate payee shall be entided to receive his/her portion of the participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries, 14. CERTIFICATION OF NECESSARY INFORMATION All payments made pursuant to this order shall be conditioned on the certification by the alternate payee and the participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein, ~~ , ~f '- 7 ,0 i~_,~, , ","'" -"-->,',' -c- " ^ I ~ , , , " . Copyright@ 2001 Hewitt Associates LLC 08730DCL12/01 16Y 16109 1"-"',,,,,',' " , p ,", ~ " , ~,' _,r" '- ,~.." ,^' ~'"__ I -, q , " " ,'-- 1~ '''i ,~'"', ''''''M''-''-r ,-,"". ci. ~. >, O'l ~ CC <<;,.f- I'"" 6" U_l~ ..* <( 1',--4-_ .~,-- ::,~) /:: c:~i c::t ,--L.....A__. -~ r)i~~ .~~ C"':l Luw- T ~UJ .". """~ .. ""::::: :~ -r= -, !,~} lL. <h -~ cc"> :-..:J 0 = u '" \.,ti '?\ :;'-1 ...... I ('~ ...:... \ "\) ~"Q l~ j S I ,~6 VtfV "J"" _. '.. ."..."....''"' .' '''.. ""....'.lii".. 1m' fil'l ILT' '. " . l~ '~~l'!!'ft' '9111"4~ _~ !!~~~~'!~'"'~'ij~W,i\w:W,~''''''WJiI''''1!~~I7-~,,-In';'_.,''''H,C\''':q$m~~!l!~!/!ffll'l\lwr~iI'~~ml~~~1'I' ,~ .:0- . ,1 , i '1 'i RECEIVED MAY 042005 (}.../ ~ STATE Ol~G0r0 ~'-t Lvf'>.{\.j\P, CASE # 0\. ;A :) ~ ~ COUNTY OF C ./'l.\,In~ G ~\...A-'())> IN THEU,"'....~n Plm>r!:> COURT O(y.fT\~~(l.lA':'"!> COUNTY,"'9G00t,\.j1-'IIl'>.I\.),/\ IN RE THE MARRIAGE OF: r '" p" -(\-'1: '-l L. f'{\\LLG~ Petitioner and 'R~r-)"DPt-LL \"l, Wp..\~D(,\ Respondent Qualified Domestic Relations Order This order creates and recognizes the existence of an alternate payee's right to receive a portion of the participant's benefits payable under an employer-sponsored defmed contribution plan, which is quali- fied under Section 401 of the Internal Revenue Code (the "Code"), This order is intended to constitute a Qualified Domestic Relations Order CQDRO") under Section 414(p) of the Code and Section 206(d) of the Employee Retirement Income Security Act of 1974 CERISA") and shall be interpreted and adminis- tered in conformity with such laws, This order is entered pursuant to the authority granted under the applicable domestic relations laws of the state of tV 8 t00 ~ '\,j L Y 1-\/0 \ P. . 1. PLAN This order applies to the (select applicable plan[ s]): ~erizon Savings Plan for Management Employees (the "Plan") o Verizon Savings and Security Plan for New York/New England Associates (the "Plan") o Verizon Savings and Security Plan for Mid-Adantic Associates (the "Plan") o Verizon Savings and Security Plan for West Region Hourly Employees (the "Plan") o Consolidated Employee Stock Ownership Plan of GTE (the "Plan") [only applicable if the valuation date is on or before February 28. 1997] Any successor to this Plan shall also be subject to the terms of the order, 2. PARTICIPANT The name, address, Social Security Nwnber, and date of birth of the participant are as follows: Name: '\2..f-\t...Ybf.:lrU. h, WA, ~'60 Address: 1"\,\,\ !S. \\um82-.. 's"t"i1-..GI3'\ F..ru I'>L,(=1; PP\ I'\D ~ S ~'i? ?1''i?' ~ ~~: \J G N\(bG \ q ~D Social Security Nwnber: Date of Birth: '~"~~~~t~, ," -, "" ~"'~d,'!"""~",/,,,,,,,~-v'_~,.', .. """"'::t'I~<'""Tr<":,,"~, '""'"~'1-,__ ~,' ,,!,"":"-r,,""t;'~~',",:,~.,,~,,"n '," ,~ - "<-h"',,,~"~,,"''',,, ,.'r' ",. .~ ~ ~"'"' r 3. ALTERNATE PAYEE The person named as alternate payee meets the requirements of the definition of alternate payee as set forth in Section 4 below. The alternate payee's name, address, Social Security Number, date of birth. and relationship to the participant are as follows: Social Security Number: Date of Birth: Relationship to Participant: t PtT\-\ I..\. L. m\LL.G~ \ ~'OD G\.l\Jr0r-\ ~\R8B\ (\j\2, \ 1" W'O\'OG il.-U\ r0 "b J Qr:\. \ '\ () '\, D \ lll'B- \.\'3- \.4\...o\D "\-\uGlu S-r ~~ J \ C\ S'1 'I.- u.)\ 'YG Name: Address: THE ALTERNATE PAYEE SHALL BE RESPONSIBLE FOR NOTImNG THE PLAN ADMINISTRATOR IN WRITING OF ANY CHANGES IN HIS OR HER MAILING ADDRESS SUBSEQUENT TO THE ENTRY OF THIS ORDER. 4. DEFINITIONS Alternate Payee The alternate payee is any spouse, former spouse, child, or other dependent of a participant who is recognized by a domestic relations order as having a right to receive all or a portion of the benefits payable under the Plan with respect to the participant. Liquidation Date The liquidation date is the date a portion of the participant's account is liquidated to allow the payment to the alternate payee's account under this order, An assignment as of the liquidation date assigns a portion of the participant's current account. Plan Administrator Verizon Communications !nc, (Verizon) is the Plan Administrator for Verizon's employee benefit plans. Verizon has contracted with Hewitt Associates liC to establish procedures and administer QDROs, Valnation Date The valuation date is the date on which the participant's vested account balance will be valued in order to determine the alternate payee's designated portion in accordance with the terms of this order, Accounts are valued on a daily basis. If, however. the QDRO requires a his- torical division of the participant's account and a daily valuation is not available for such date, the participant's account will be divided as of the valuation date immediately preceding the date specified in the order. Vested Account Balance The participant's vested account balance is the participant's benefit as if he/she terminated employment and received a distribution on the valuation date, 2 :;h!"f:"", " - , ' - ,..,,~ ,'~'''.':<~'~,N-'' ",:'!~"'''''''''' . , ""L-,'>'"~,,:, c,,~, "..7',"~"'""I"_ , "-1""" \"',"1'" . ",- '7>-' ",=.., ."," ,"~ _ _" ~'" ,~._ 1_ j I 5 (i) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-DEFINED CONTRIBUTION PLAN(S) (Choose either Option A or Option B) o Option A-Straight Percentage The order assigns to the alternate payee an amount equal ro account balance under the Plan (identified in Section I) as of % of the participant's vested (insert date) From the valuation date to the liquidarion date, the amount assigned to the alternate payee (select one): o will include earnings and losses. o will not include earnings and losses, The participant's vested account balance (select one): o will be reduced by the value of outstanding loans before the alternate payee's portion of the benefit is determined, o will not be reduced by the value of outstanding loans before the alternate payee's portion of the benefit is determined. If the assigned amount is greater on the liquidation date than the net vested account balance after any outstmding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount, OR o Option B- Dollar Amount The order assigns to the alternate payee an amount equal to $ of the participant's vested account balance under the Plan (identified in Section I) as of the liquidation date. If the assigned amount is greater on the liquidation date than the net vested accormt balance after any outstanding loan balances and/or withdrawals have been deducted, the net vested account balance will be the assigned amount. 3 ':;~-'l':,.: . ~" . ,,?,-.~:,,,,~~~,ry"!',. _0,0_,<,,_, ~~~'1,",_ '~d~,:" .c. "'.~,''I',~-"^."~;,,,,_?,,, ~l~'~',~".r,,,.. ,_ .. < < .~ ,,' " , ' ~-'. - " - 5(ii) BENEFIT PAYABLE TO THE ALTERNATE PAYEE-GTE EMPLOYEE STOCK OWNERSHIP PLAN (applies to former GTE population only) (Choose either Option A or Option B) ut' Option A-Straight Percentage The order assigns to the alternate payee an amount equal to \. 00 % of the participant's vested account balance under the Plan (identified in Section 1) as of "".p(l..\L '\ I 'd-DD5 (insert date - must be a date on or before February 28,1997), From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): ~ill include dividends, o Will not include dividends, OR o Option B-Share Amount The order assigns to the alternate payee under the Plan (identified in Section 1) as of on or before February 28, 1997), shares of the participant's vested account balance (insert date - must be a date From the valuation date to the liquidation date, the amount assigned to the alternate payee (select one): o Will include dividends. o will not include dividends. 4 ).~\flIP'l"~ ,~,'" "_"';'31"'f'o/'.~",,r' '-"'V"-?:I"~ "", ,r,''', _"._~,~""b',~",_~ ,0 ,",,-,," - '"j' ,.~ ,_c~,' , ~ ~~ .~, d f 6. F.oRM .oF PAYMENT The alternate payee shall receive the portion of the Plan benefits assigned to the alternate payee in a single lump-sum payment, Such amount shall be adjusted for earnings and losses from the liquidation date to the date of distribution to the alternate payee. 7. C.oMMENCEMENT The alternate payee shall be eligible to receive payment as soon as administratively reasonable following the determination that this order is a Qualified Domestic Relations Order. In no event can the alternate payee commence his/her benefit later than April I following the year in which the participant attains age 7 OX, 8. DEATH PROCEDURES If the participant predeceases the alternate payee prior to payment of the alternate payee's assigned benefits under the Plan. the alternate payee's benefits will not be affected, In the event of the participant's death, the account balance, which remains the property of the participant, will be payable to the participant's desig- nated beneficiary or in accordance with Plan provisions. Ibis order does not require the participant to name the alternate payee as the beneficiary for the benefits not assigned to the alternate payee. In case of the death of the alternate payee prior to distribution of the alternate payee's benefits from the Plan, the assigned benefits will be paid to the alternate payee's designated beneficiary or, if none, in accor- dance with Plan provisions, 9. RETENTION .oF JURISDICTI.oN This matter arises from an action for divorce or legal separation in this court under the case number set forth at the beginning of this order, Accordingly. this court has jurisdiction to issue this order. In the event the Plan Administrator determines that this order is not a Qualified Domestic Relations Order, both parties shall cooperate with the Plan Administrator in making any changes needed for it to become qualified, Ibis includes signing all necessary documents. For this purpose, this court expressly reserves jurisdiction over the dissolution proceeding involving the participant, the alternate payee, and the partici~ pant's interest in the Plan. 5 '~ """''''' ,P:.-.;','. ,="--",,, ~", '.' ,-~,~,~,,,, 0;" __ I.." __ ._-'.~ __',~"c"""~,~~' _ .c, __ .~", ~, _,__",,,~,_ ~"., .'. ,~" 10. LIMITATIONS Pursuant to Section 414 (p)( 3) of the Code and except as provided by Section 414 (p) (4), this order: (i) Does not require the Plan to provide any type or form of benefit, or any option, not otherwise provided under the Plan: (ii) Does not require the Plan to provide increased benefits; and (ill) Does not require the payment of benefits to an alternate payee which are required to be paid to another alternate payee under another order previously determined to be a Qualified Domestic Relations Order. 11. TAXATION For purposes of Sections 402 and 72 of the Code, any alternate payee who is the spouse or former spouse of the participant shall be treated as the distributee of any distribution or payments made to the alternate payee under the terms of the order and, as such, will be required to pay the appropriate federal, state. and local income taxes on such distributions, 12. CONSTRUCTIVE RECEIPT If the Plan inadvertendy pays to the participant any benefit that is assigned to the alternate payee pursuant to the terms of this order. the participant will immediately reimburse the Plan to the extent that the participant has received such benefit payments and shall forthwith pay such amounts so received to the Plan within ten (1 0) days ofreceipt. If the Plan inadvertendy pays to the alternate payee any benefit that is actually payable to the participant, the alternate payee must make immediate reimbursement, The alternate payee must reimburse to the extent that he/she has received such benefit payments and shall forthwith pay such amount so received to the Plan within ten (1 0) days ofreceipt. 6 iv"'"'' .. """"<",","'--'~.,_o,""-,,,,,'~",~,.,,,, - '-~'''~''i,0~~,'~'~' ,t,' C" "i-I"'".". ~ .., """"'l~" c".""" ~,' "'~'''H''r,,' ,^"'",~,,, , ,. '_'_".,_ 0 _.~ c 13. EFFECT OF PLAN TERMINATION If the Plan is terminated, the alternate payee shall be entitled to receive his/her portion of the participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries, 14. CERTIFICATION OF NECESSARY INFORMATION All payments made pursuant to this order shall be conditioned on the certification by the alternate payee and the participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein. Dated thi~day Of_~ ?ao.r By the cour;:Y Judge's " / Copyright Ci 2001 Hewitt Associates lie 7 08730DCll12/01 07N 16113 ~.m,,~" , '~', """7 ,__""._,;,.;~,,:n, ,- -' ,<,'~'-', "-(--; ___~ '>""~I 'f' '-' """:~,, ~"'-__'~.""I,_,,.,,'F ,Ie'. .:..,:,p --'9--1 ", 'i_ "', ,_ __C"." .~ I i ,I I" i I I II i II I" iil JI II ill " , I J, i1 il I :1 0>- cr; ;:::: lu(~ ('>:2" !'fa !J_.::r 9s C)CJ: lLJCL. iJ!LW FE 13 j .1 , j! ij Ij II :li Ii" :i:] 1.' ii r: f; ':, l~i ~.'i ]~~ i'\ , Iii ;:'~ j "- \.() '" N 0>- ~.- ;:... ,;j~ :l!;: CL ~, ,::.::;: <'-' ~t" (~};j -:_- ..;"~ /~~,!f 6:.1 ~,~LJ ;;,~ .... t5 -'" I >- ~'" :lI:: ...." "'" "" '" - 1~- " , QII!~~~:::r,~_,.",lf1~If1!J~,~ '. RECEIVED MAY 042005 p" Name and Address Verification Form Alternate Payee's Name: Cathy L. Miller Fonnerly Known As: Cathy L. Watson Social Security number: 168-48-4610 Date of Birth: Au"uRt 25. 1957 Address: 1830 Anna Street New Cumberland, PA 17070 Previous Address: 124 W. Portland Street. Apartment 44 Mechanicsburg, PA 17055 Participant's Name and Social Security Number: Randall K. Watson - 208-38-5322 ~~~ ~ Alternate Payee's Signature Please return to: Nota Public , COMMONWEAL H OF PENNSYLVANIA NOTARIAL, SEAL KIMBERLY A. MEYERS,Notary Public Camp Hi! 80m, CUrnberllII1d County My Commission expires April 26, 2008 Verizon Benefits Center Qualified Order Team Post Office Box 1433 Lincolnshire, 1L 60069-1433 Fax: (847) 883-9313 .';:~, ~""" ' """',- .. " ' - I ,~ .., ., w "" "~v~'o' ,','_'. '" '",,' ."> -<I' ;,_":<".c'" '"'",~wn'~''' ""',"'~' ~"',."". " .,""""~P '1 "lIliIIIlIJflCt '(""'III!l:f' .' ~ tf tlJ :~~ ,~~ ~'" ~~m-~'~~~""~,'=r..~"<!~-ID,~f'I.,~",1,1'~',,"~W'!~.'tl\1.,""1"~~,"'f;l-"lI'~~,,",'I'"?!~"'~~~