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Home My WebLink About99-04843I `- STEPHANIE A. KEEBAUGH Plaintiff Vs. SHANE A.KEEBAUGH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4843 NO. CIVIL 19 IN DIVORCE Defendant STATUS SHEET DATE: (r-) ACTIVITIES: YYY ?'? ? 71 / I ?^ 1 ??// GwM2// Lu-,n/?v_.c C21C,1!-G?u C, CF?•, E.tU,•.c, G, - 7/? /?A•t?/ ?-L q. A(tt.,- j •-t... ?y-?4.ce. Ch??u /LQI.c• vt/ ?"' ?y.?'•tu.«..?L.n;°?.;.,.;? k.(,v.• ;J+-?.??c?ccl a ?,?.CC,.,,,yG,.Y ? ,tu.riw tn. /Wn t4A STEPHANIE A. KEEBAUGH, Plaintiff VS. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 9893 CIVIL IN DIVORCE TO: Joanna Harrison Clough Douglas R. Roeder Attorney for Plaintiff Attorney for Defendant DATE: Monday, December 9, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 4843 CIVIL SHANE A. KEEBAUGH, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Joanne H. Clough Stephanie A. Keebaugh , Counsel for Plaintiff , Plaintiff Douglas R. Roeder Shane A. Keebaugh Counsel for Defendant Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 20th day of April, 2001, at 1:30 p.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II April 6, 2001 Divorce Master STEPHANIE A. KEEBAUGH, Plaintiff VS. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 9893 CIVIL IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Joanne H. Clough , Attorney for Plaintiff Douglas R. Roeder , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 5th of April, 2001, at 1:30 p.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 2/28/01 E. Robert Elicker, II Divorce Master REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL, PENNSYLVANIA 17011.4642 717-763.1363 TELEFAX 717.730.7366 WEBSITE: ReagerAdlerPC.com THEODORE A. ADLER + DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENICLE DEBRA DENISON CANTOR THOMAS O. WILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH Writer's E-Mail Address: jclough®epix.nel June 27, 2001 Special Master E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Stephanie A. Keebaugh v. Shane A. Keebaugh No. 99-4843 Dear Master Elicker: +Certified Trial Specialist I am enclosing the original Transcript setting forth the settlement in the above referenced case which has been signed by both Mr. Keebaugh and Mrs. Keebaugh. It is my understanding that I was to return the original signed Transcript to your office for filing in this action. I am sending a check for the cost of the transcription under separate cover. I thank you for your assistance in resolving this action. Sincerely, Harrison JHC/ak cc: Douglas Roeder, Esquire Stephanie Keebaugh 4?h OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Coiyer Office Manager/Reporter West Shore 697.0371 Ext. 6535 April 23, 2001 Joanne H. Clough Attorney at Law REAGER & ADLER, P. C. 2331 Market Street Camp Hill, PA 17011 Douglas R. Roeder, Esquire D.L. REICHARD, II & ASSOCIATES 70 West King Street, Suite B Chambersburg, PA 17201 RE: Stephanie A. Keebaugh vs. Shane A. Keebaugh No. 99 - 4843 Civil In Divorce Dear Ms. Clough and Mr. Roeder: Enclosed is a draft of the agreement which you put on the record on April 20, 2001. Please review the draft for any corrections r,ith the understanding that no substantive changes can be made. When you have reviewed the draft give us a call and let us know if you want us to send the original to the Plaintiff's attorney for signature who then can transmit the original to the Defendant's attorney for signature. When I receive a signed copy of the document, I will then obtain a Court order vacating my appointment. Thank you for your continuing cooperation in bringing this matter to settlement. Very truly yours, E. Robert Elicker, II Divorce Master IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY e, STATE OF ll PENNA. STEPHANIE A. KEEBAUGH, Plaintiff VERSUS SHANE A. KEEBAUGH, Defendant N O. 99-4843 CIVIL CIVIL ACTION - LAW IN DIVORCE DECREE IN DIVORCE AND NOW, DECREED THAT STEPHANIE A. KEEBAUGH (, 40 s& IT IS ORDERED AND AND SHANE A. KEEBAUGH ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. It is further ordered that the Plaintiff shall pay the cost o hese proceedings. By T O, r: OTHONOTARY ??- G •/o7.Gb CGr? ??j? /ti? .?G D.L. REICHARD, II & ASSOCIATES BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant STEPHANIE A. KEEBAUGH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-4843 CIVIL SHANE A. KEEBAUGH, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Grounds for divorce: Separation for over two years under Section 3301(d) of the Divorce Code. Plaintiff and Defendant were separated since March of 1998. 2. Date and manner of service ofthe com faint: The Complaint was filed on August 11, 1999; service was made on the Defendant, on or about August 17, 1999 at 66 Rustic Drive, Shippensburg, PA 17257 via certified mail. 3. . u.p LAY VI VG Code: The date of execution ofthe affidavit required by Section 3301(d) of the Divorce Code: by Defendant was April 26, 2000. The Plaintiff received that affidavit on or about April 29, 2000. The plaintiff filed a Counter-Affidavit of Consent under Section 3301(d) of the Divorce Code on May 17, 2000. 4. Related claims pending: Equitable Distribution. &J? 0, P-t?tL By: Douglas R. Roeder, Esquire Attorney for Shane Keebaugh W-C - '4 JQ C1'+ ]r 1 Lli" 1 JZ U L fJ][y v o U S:\W P,DOCS\DOMESTIC\COMPLAINikeebaugh.cmp.wpct August 9, 1999 REAGER & ADLER PC BY: DEBRA DE NON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff STEPHANIE A. KEEBAUGH, Plaintiff IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Y 4 _ Lr<el?3 SHANE A. KEEBAUGH, CIVIL ACTION - LAW Defendant. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment maybe entered against you by the Court. y udgment may also be entered against you for any other claim or relief requested in these papers by the ?lamtiff. 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, Room 101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM LAWYERS FEES OR EXPENSES BEFORE A D DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. SHOULD TAKE THIS PAPER TO R LAWYER AT ONCE. IF YO DO NOT HAVE AOLAW ER OR CANNOT AFFORD OE UGO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YaU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Court Administrator South Hanover Street Carlisle, PA 17043 (717) 240-6200 S:\W PpOCS\DOMESTIC\COMPLAIN\keebaugh.cmp.wpd August 9, 1999 STEPHANIE A. K:EEBAUGH, V. SHANE A. KEEBAUGH, Plaintiff Defendant. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las qquejas expuestas en las pdginas siguientes, debar tomar acci6n con pprontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decisi6n puede tambi6n ser emitida en su contra por caulquier otra queja o compensactlon reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de conseeros matrimoniales est5 disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTbS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO LISTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE'ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDO PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Court Administrator South Hanover Street Carlisle, PA 17043 (717) 240-6200 S:\W PDOCS\DOME$TIC\COMPLAI N\keebaugh.cmp.wpd August 9, 1999 REAGER & ADLER PC BY: DEBRA DENYSON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff STEPHANIE A. KEEBAUGH, V. SHANE A. KEEBAUGH, Plaintiff Defendant. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 1. Plaintiff is Stephanie A. Keebaugh, an adult individual, who currently resides at 332 East King Street, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is Shane A. Keebaugh, an adult individual, who currently resides at 66 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, 17257. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 29, 1992, at Shippensburg, Pennsylvania, 17257. 5. There have been no prior actions of divorce or for annulment between the parties. S:\W PDOCS\DOME$TIC\COMPLAI N\keebaugh.cmp.wpd August 9, 1999 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and I its amendments. 7. Plaintiff avers that there are two (2) children of this marriage under the age of eighteen years, namely Kayla Keebaugh, date of birth, February 24, 1992, and Gabrielle Keebaugh, date of birth, June 21, 1995. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. Y?. S:\WPDOCS\DOMESTIC\COMPLAIN\keebaugh.cmp.wpd August 9, 1999 COUNTI EQUITABLE DISTRIBUTION 12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 14. Plaintiff and Defendant have acquired marital debt during the course of the murriage, 15. The parties are unable to amicably resolve the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. Respectfully Submitted, REAGER & ADLER, PC Date: August 9, 1999 By: \ f dN N VE SON TSQU[RE it'ogmi?6kyq.D.To. 66378 2331 Market Strect Camp Hill, PA 17011-4642 Telephone No. [7171763-1383 Attorneys for Plaintiff 3 S:\W PDOCS\DOMESTIC\COMPLAIN\keebaugh.cmp.wpd May 14, 1999 VERIFICATION I, Stephanie A. Keebaugh, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. q Q ephanie A. Keebaug Dale: 11Bl`( al ESEL•EU WO ZKK LOLL Vd 'IIIH dWV3 133HIS IMMY LEM MV11V SA3NHO11V 'O'd VICIV R W39V3H ? b IT °' rn LIB ._ ? ?(?^ CJ V (`\J-J eeel-Eft ILILI ZVW-LLOLL WITH dMO 133UIS 13HtlVW LCCZ MV'I 1V SA3NNO.UV •3 •d'N3'lOV V k130V3e a iCL rJ 6 C? S:\N: PDOCS\DOMESTIC\FORMSW FFIDAVI.SVE REAGER x ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff STEPHANIE KEEBAUGII, V. SHANE A. KEEBAUGH, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor, Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the following: 1, Debra Denison Cantor, Esquire, being duly sworn according to law, depose and state that service of the Complaint in Divorce in the above-captioned matter was served by Certified Mail, Return Receipt Requested, on Defendant, Shane A. Keebaugh, 66 Rustic Drive, Shippensburg, PA 17257 on August 18, 1999. The Certified Receipt is attached hereto as "Exhibit A." 13y: Subscribed and sworn to before me this ?.` day of a, 1999. ts/ti ? lJ Notary Public Notarial Seel Deborah L Brenneman, Notary Public }j Camp HIII SOM, Cumb8darlO COUnty My CormNnelon ElIm June 18, 2002 Member, PennNanle AaaoCUlbn of NOIanN? ry ' S:\W PDOCS\DOMESTIC\FORMS\AFFIDAVI.SVE Exhibit A SEN Dow Can a CPro an cards O AIIaI a Wdu C OTN p dativ 3. Antic " I thamA anaor 2 for additional services. Ilemfr; 4a, and 4b. I also wish to receive the follow. ing services (for an extra fee): nemeimd address on the reverse of this form so that we can return this brtn to the Iron) of Ihemeilpiace, of on IN bock 11 space does not O Addressee's Address R the mail i ee below the iodide number. 2. ? Restricted Delivery I A t Will 1 WhO RecOO eipt will show show m whom pre article i de was delivered and the date Shane A.Keebaugh g 66 Rustic Drive Shippensburg, PA 17257 S. Received By''rPdnt Name) 8. Sill a a (Add Gr gent) 4a. Anicle Number Return Receipt Requested IC E 4b. Service Type 3 O Registered )M Certified o? ? Express Mail ? Insureds g ? Return He ccelpt for Merchandise ? COD 7. f /10'IN i i d. Kadressee's Address (Only rerequestedand fee is paid) December 1994 fa2ses-ss-eo223 D: L. REICHARD, II & ASSOCIATES 134 W. Main Street The Fort Chambers Bldg. P.O. Box 8 70 W. King Street Waynesboro, PA 17268 SuiteB - 717-762.1131 Chambersburg, PA 17201^- , 717.267.3006 717.267.2288 FAX: 717.762.8800 FAX: 717-267-1151 BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant STEPHANIE A. KEEBAUGH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. SHANE A. KEEBAUGH, Defendant NO. 99-4843 CIVIL CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE The parties to this action separated in March of 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: Shane A. Keebaugh, Defendant D.L. REICHARD, H & ASSOCIATES BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-4843 CIVIL SHANE A. KEEBAUGH, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Douglas R. Roeder, Esquire, of D.L. Reichard, II & Associates, hereby certify that a copy of the Defendant's Affidavit Under Section 3301(D) of the Divorce Code in the above captioned matter was served by depositing the same at the Post Office in Chambersburg, Pennsylvania, first class mail, postage prepaid, addressed as follows: Debra Denison Cantor, Esquire Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 By: ? ? 44L Douglas R. oeder, Esquire D.L. Reichard II, & Associates Dated: '7 ,-I?-GU 70 W. King Street, Suite B Chambersburg, PA 17201 (717) 267-2288 ?i .. ; ('1 Ebel-Ek QW Z090-L LOLL W'IIIH dWVO 133N1S 13AUVW LEEZ MVl 1V SA3NHO11V 'Jd 'ILL3NOO7 19 831OV '83OV3W U C. LJ ?' 1 ' U-s LL. - q r EAGER ADLER & COGNETTI, PC BY. DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 JULIE A. MCCONAHY, ESQUIRE Attorn ey I.D. No. 77061 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff STEPHANIE A. KEEBAUGH, Plaintiff, V. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL CIVIL ACTION -LAW IN DIVORCE COUNTER-AFFIDAVIT OF CONSENT UNDER § 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: (I) The parties to this action have not lived separate and apart for a period of at least[wo(2) years. o (ii) The marriage is not irretrievably broken. 2. 0 (a) I do not wish to make any claims for economic relief. 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. K (b) I wish to claim economic reliefwhich may include alimony, division ofproperty, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, l must also file all of my economic claims with the Prothonotary in writing and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request a Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. *Stepanic A. Keebaugh, Plaintiff Dated: 511%J NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ESEl-E91 UL) Z1194-LL041 Vd'IIIH dWV9 133HIS 13HHVW LEEZ MVl 1V SA3NH011V '0-d 'H310V R H3+JV3H .l _ U STEPHANIE A. KEEBAUGH, Plaintiff V. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE NO. 99-4843 CIVIL PLAINTIFF'S PRE-TRIAL STATEMENT Stephanie Keebaugh, the Plaintiff, by and through her Reager & Adler, PC, files the following Pre-Trial Statement: TABLE OF CONTENTS 1. Background Information II. Listing of Marital Assets and Debts III. Listing of Personal Property IV. Listing of Non-Marital Assets V. Pensions VI. Income and Expenses VII. Counsel Fees and Costs VIII. Expert Witnesses IX. Non-Expert Witnesses X. Listing of Proposed Exhibits XI. Proposed Resolution Respectfully Submitted, Dated: February 21, 2001 By: Joan H. Clough, E: ID #36461 2331 Market Street Camp Hill, PA 17011 717-763-1383 I. BACKGROUND INFORMATION A. PARTIES HUSBAND NAME Shane A. Keebaugh ADDRESS 66 Rustic Drive, Shippensburg, PA 17257 AGE 32 DATE OF BIRTH 6-22-1968 PLACE OF BIRTH Cumberland County, PA SOCIAL SECURITY NUMBER 199-56-1194 HEALTH good EMPLOYER Excel Logistics OCCUPATION Forklift operator LENGTH OF RESIDENCY IN PA life EDUCATIONAL BACKGROUND 10"' grade WIFE NAME Stephanie A. Keebaugh ADDRESS 44 Montgomery Ave. Shippensburg, PA AGE 27 DATE OF BIRTH 4-12-73 PLACE OF BIRTH Franklin County, PA SOCIAL SECURITY NUMBER 208-54-3033 HEALTH Good EMPLOYER Franklin Clothing OCCUPATION Payroll clerk post separation LENGTH OF RESIDENCY IN PA life EDUCATIONAL BACKGROUND G.E.D. obtained post separation B. CHILDREN NAME AGE DATE OF CUSTODIAN BIRTH Gabrielle May 5 6-21-95 mother Keebaugh Kayla Ann Keebaugh 9 2-24-92 mother C. MARRIAGE INFORMATION DATE OF MARRIAGE 6-29-1991 PLACE OF MARRIAGE Cumberland County, Pennsylvania DATE OF SEPARATION March, 1998 CIRCUMSTANCES OF SEPARATION abusive husband, irreconcilable differences, indignities D. PRIOR MARRIAGE WIFE none HUSBAND none E. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES WIFE none HUSBAND none F. PROCEEDINGS INFORMATION DATE ACTION COMMENCED 8-11-99 DATE OF SERVICE OF 8-17-99 COMPLAINT MANNER OF SERVICE OF certified mail COMPLAINT ISSUES RAISED IN DIVORCE Equitable distribution COMPLAINT DATE AMENDED COMPLAINT N/A FILED ISSUES RAISED IN AMENDED COMPLAINT DATE OF FILING OF ANSWER AND/OR COUNTERCLAIM ISSUES RAISED IN COUNTERCLAIM BIFURCATION Divorce entered on 6-10-2000 PREVIOUSLY RESOLVED ISSUES IL MARITAL ASSETS AND DEBTS The following is a listing of the marital assets and debts of the parties: ITEM DESCR. TOTAL HUSBAND'S W I F E' S COMMENTS NO. VALUE POSSESSION POSSESSION 1. Real Estate LA 1997 Double $ 54,000.00 Husband Balance owed wide mobile purchase resides here approx. home price $ 49,000.00 2. Vehicles 2.A 1993 Toyota $ 2,500 Husband has jointly titled Corolla trade in, vehicle $5,000 retail 3. Bank Accounts 3.A Allfirst unknown Husband took Wife shall checking all funds and receive 1/2 of account closed monies account at husband took time of when he closed separation this account 4. Pensions 4.A Excel Logistics $ 9,300.00 Husband 401(K) approx. Net marital value ITEM DESCR. TOTAL HUSBAND'S W I F E' S COMMENTS NO. VALUE POSSESSION POSSESSION 6. Household Goods 6.A, contents of $ 2,000.00 Husband nick nacks, marital Wife's retained children's residence estimate of clothes and minimum T.V. nominal value value 7. Debts 7.A 1997 taxes $ 608.00 paid by Husband post separation III. LISTING OF PERSONAL PROPERTY ITEMS RETAINED BY WIFE DESCRIPTION VALUE nick nacks, TV, childrens' clothes $ 200.00 ITEMS RETAINED BY HUSBAND DESCRIPTION VALUE household contents and all furnishings $ 2,000.00 IV. LISTING OF NON-MARITAL PROPERTY The following is a listing of the non-marital assets of the parties: No. Description Basis of Exclusion Owner I. 2000 Saturn SL2 Leased by Stephanie Keebaugh and Mr. Armstrong post separation V. PENSIONS The following is a listing of the pensions of the parties: I PARTY I DESCRIPTION I Husband 1401(K) Excel Logistics value as of 3.31-98 $ 11,485.81 I Wife I none I VI. INCOME AND EXPENSES The following is a listing of the income and expenses of the parties: PARTY DESCRIPTION AMOUNT Husband Gross Monthly Income $ 2,248.97 Net Monthly Income $ 1,767.86 Monthly Expenses Wife Gross Monthly Income $ 1,129.96 Net Monthly Income $ 910.46 Monthly Expenses $ 2,079.07 VII. COUNSEL FEES The following is a listing of the counsel fees and expenses incurred, or to be incurred by the parties: PARTY DESCRIPTION DATES AMOUNT Husband Counsel Fees Costs Anticipated Fees and Costs Wife Counsel Fees actual fees incurred through 1.31- 2001 $ 1,596.00 Costs $ 232.91 Anticipated Fees and Costs future cost for pretrial and trial estimate: $ 750.00 additional fees, $300 additional costs if transcripts needed VIII. EXPERT WITNESSES The following is a listing of the anticipated experts who will be called to testify in this case: NAME SUBJECT TO TESTIMONY A Real Estate Appraiser none A Pension Appraiser none Personal Property Appraiser none Additional experts who may be called to testify are not known at this time. If such additional experts are retained, the Plaintiff reserves the right to call them as witnesses upon proper notification to the Defendant. IX. NON-EXPERT WITNESSES NAME SUBJECT TO TESTIMONY Stephanie A. Keebaugh History of the marriage; identification and valuation of marital assets and debts; other relevant testimony relating to the factors set forth in the Divorce Code. Shane A. Keebaugh, as of cross History of the marriage; identification and valuation of marital assets and debts; other relevant testimony relating to the factors set forth in the Divorce Code. Additional witnesses who may be called to testify are not known at this time. If such additional witnesses are identified, the Plaintiff reserves the right to call them as witnesses upon proper notification to the Defendant. X. LISTING OF PROPOSED EXHIBITS The following is a listing of Exhibits which are anticipated to be submitted at the hearing in this case: NO. DESCRIPTION I Plaintiffs Income and Expense Statement 2 Plaintiffs Counsel Fees Statements 3 Plaintiffs W-2 Statements/tax returns 4 Defendant's 401(K) statement 5 Defendant's W-2 Statements/tax returns NO. DESCRIPTION 6 Defendant's brother's note re: alleged loan 7 other exhibits may be introduced at time of trial If additional exhibits are identified, Plaintiff reserves the right to submit additional Exhibits upon proper notification to Defendant. XI. PROPOSED RESOLUTION A. EQUITABLE DISTRIBUTION: Plaintiff was a homemaker and stay at home mother during the parties marriage. She did not work full time or obtain her G.E.D. until after separation from Defendant. She is the custodial parent of the parties two minor children. Her monthly full time income is approximately half the monthly income of the Defendant. Plaintiff should receive 65% of the parties marital estate. Defendant has continued to reside in the marital residence post separation and should be 100% responsible for all post separation mortgage, taxes and home expenses with no contribution or credit due him from Plaintiff. Defendant should refinance the debt on said marital property to remove Plaintiff as an obligor thereon and Defendant shall retain the marital residence and assume the liability thereon. There is no equity in said marital residence. Plaintiff should receive 65% of the marital portion of Defendant's 401(K) with Excel Logistics via a Qualified Domestic Relations Order. Defendant should retain the 1993 Toyota Corolla and assume the balance of the obligation due thereon. There is little equity value in said vehicle. Each party shall retain personalty in his or her possession. Defendant may retain the monies he took from the parties joint checking account. B. ALIMONY: None C. COUNSEL FEES AND COSTS: Defendant to pay one half of Plaintiffs counsel fees and costs for trial of case. OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 West Shore Divorce Master 697-0371 Ext. 6535 Traci Jo Colyer Office Manager/Reporter January 29, 2001 Joanne H. Clough Douglas R. Roeder, Esquire Attorney at Law D.L. REICHARD, II & ASSOCIATES REAGER & ADLER, P.C. 70 West King Street, Suite 8 2331 Market Street Chambersburg, PA 17201 Camp Hill, PA 17011 RE: Stephanie A. Keebaugh vs. Shane A. Keebaugh No. 99 - 4843 Civil In Divorce Dear Ms. Clough and Mr. Roeder: According to correspondence from counsel, discovery was contemplated to have been completed by the end of January 2001. Consequently, I am going to proceed with the outstanding economic claim of equitable distribution, which was raised in the complaint. The parties were divorced on June 10, 2000. The decree apparently continued the spousal support payments "if any economic claims remained pending". The economic claim, I assume, that is pending is equitable distribution. No claims have been raised for alimony or counsel fees. Ms. Clough and Mr. Roeder, Attorneys at law 29 January 2001 Page 2 In accordance with P.R.C.P 1920.33(b) I am directing each counsel to file a pretrial statement on or before Monday, February 26, 2001. Upon receipt of the pretrial statements, I will immediately schedule a pre- hearing with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set Forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. l ti 2025 E. Main Street Post Office Box 8 Waynesb;rm PA 17268 717.762.1131 717.267.3006 FAX 717.762.8800 REICHARD LAW OFFICES, LLC. The Fort Chambers Bldg. 70 W. King Street Suite B Chamb`rsburg,,PA 17201 717-267-288 FAX 717.267.1151 STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS Yjf Q/a Plaintiff OF CUMBERLAND COUNTY, PO ' ?r PENNSYLVANIA (ISM vs. NO. 99-4843 CIVIL SHANE A. KEEBAUGH, Defendant IN DIVORCE PRE-TRIAL STATEMENT (1) ASSETS OF PARTIES• MARITAL PROPERTY Defendant lists all marital property in which either or both spouse have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Value of PropertX All Owners 1. Excel Logistics 401(K) Shane A. Keebaugh As of 3-31-98 $11,473.57 total value. Approximately $3,476.84 is a non-marital portion as it was contributed by Shane Keebaugh prior to the marriage 2. 1993 Toyota Corolla Shane A. Keebaugh As of 3-31-98 Stephanie A. Keebaugh value of $5,000.00. As of 3-31-98 lien on Lien for $5,139.86 to Unitas National Bank As of 2-21-01 value of $2,500.00; lien to Unitas National Bank paid off. 3. 1996 Doublewide Mobile Home NON-MARITAL PROPERTY Shane A. Keebaugh Stephanie A. Keebaugh As of 3-31-98 value $45,000.00 Mortgage to Conseco Finance for approx. $52,000.00. As of 2-21-01 Value $42,000.00. Mortgage to Conseco Finance for $48,306.81 Defendant lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property. Item Description Names of Value Number of Property All Owners 1. 2000 Saturn SL2 Leased by As of 2-21-21 value Stephanie Keebaugh $12,000.00. and Mr. Armstrong Lease terns and/or lien amounts are unknown to Shane Keebaugh. 2. Excel Logistics Shane A. Keebaugh As of 3-31-98 401(K) $11,473.57 total value. Approximately $3,476.84 is a non-marital portion as it was contributed by Shane prior to the marriage. (2) EXPERT WITNESSES: At this time Shane Keebaugh does not intend to call any expert witnesses. Shane Keebaugh reserves the right to call expert witnesses upon reasonable notice to the Plaintiff and the Court. (3) WITNESSES: A) Shane Keebaugh: 66 Rustic Drive, Shippensburg, PA 17257 Shane Keebaugh will testify about assets of the parties, the marital debts, his current income and expenses, the conditions under which Stephanie left, and other matters relevant to equitable distribution. B) Linda Mixell: 144 Fairview Road, Shippensburg, PA 17257 Linda Mixell is expected to testify about the nature of the assets of the parties, marital debts that were paid by Shane Keebaugh, and the conditions under which Stephanie Keebaugh left the marital residence. Shane Keebaugh reserves the right to call other witnesses upon reasonable notice to the Plaintiff and the Court. (4) DEFENDANT'S EXHIBITS: A) Excel Logistics Retirement and Savings Account Statement dated March 31, 1998. (Attached hereto as exhibit "A") B) Cumberland County Tax Claim Bureau Receipt for 1997 Real Estate Taxes. (Attached hereto as exhibit "B") C) Real Estate Tax Notice for 1998-1999 tax year. (Attached hereto as exhibit "C") D) Real Estate Tax Notice for 1999-2000 tax year. (Attached hereto as exhibit "D") E) Pay receipt for Shane Keebaugh for the pay period ending 2-18-01. (Attached hereto as exhibit "E") F) Shane Keebaugh's Pennsylvania State Tax Return for 2000. (Attached hereto as exhibit "F") G) Shane Keebaugh's Federal Income Tax Return for 2000 (Attached hereto as exhibit "G") H) Income and Expense Statement for Shane Keebaugh (Attached hereto as Exhibit "W') 1) Mortgage billing and interest statement dated 1-16-01. (Attached hereto as exhibit "I") J) 1998 Blue Book with Used Car Values - Describes value of various automobiles giving consideration to options, condition, and mileage. K) 2001 Blue Book with used Car Values - Describes value of various automobiles giving consideration to options, condition, and mileage. L) Shane Keebaugh's bank statement - details checks cashed from March of 1998 through the present. M) Shane Keebaugh's transaction register from checkbook - details checks written from March of 1998 through the present. N) Payment book for the 1993 Toyota - details payments that Shane Keebaugh made on the 1993 Toyota. (5) DEFENDANT'S GROSS INCOME FROM ALL SOURCES: Gross income per week - $540.00 Taxes Weekly Federal Tax - $41.85 Weekly Social Security - $31.91 Weekly Medicare - $7.46 Weekly PA tax - $14.41 Weekly Silver Springs tax - $5.40 Pretax Deductions Weekly Standard Medical - $21.86 Pretax Dental Plan - $3.54 After-Tax Deductions Weekly Supplemental Life - $1.10 Weekly Child Support - $123.93 Net Pay - $288.54 A 2000 Pennsylvania State tax return for Shane Keebaugh is attached hereto as exhibit "F." A 2000 Federal Tax return for Shane Keebaugh is attached hereto as exhibit "G." Shane Keebaugh's current pay receipt is attached hereto as exhibit " H" (6) (7) (8) (9) (10) INCOME AND EXPENSE STATEMENT Attached hereto as exhibit "H" PENSION/RETIREMENT ACCOUNTS: Excel Logistics 401(K) of Shane Keebaugh As of 3-31-98 $11,473.57 total value. approximately $3,476.84 is a non-marital portion as it was contributed by Shane prior to the marriage. CLAIM FOR COUNSEL FEES: None VALUATON METHODS: No disputes exist as to valuation at this time. MARITAL DEBTS: A) Mortgage on mobile home to Conseco Finance in the amount of $48,306.81 as of 2-21-01. As of 3-31-01, the approximate date of separation, the Mortgage balance was approximately $52,000.00. The mobile home was purchased in the late spring of 1996 and the mortgage was taken out at that time. Monthly payments of $363.89 have been made since the inception of the mortgage. The mortgage is currently paid to date. Shane Keebaugh has made all those monthly payments himself, since and including the March of 1998 payment. A mortgage billing and interest statement (exhibit "I") and Shane Keebaugh's bank statements evidence the mortgage payments. B) Lot Rent for the Mobile Home of $215.00 per month to Country Side Village. The monthly lot rent has remained the same since the time of separation. The debt was incurred in the late spring of 1996. The lot rent payments are currently up to date. Shane Keebaugh has made all of the lot rent payments by himself, since and including the March of 1998 payment. Shane Keebaugh has bank statements and a transaction register to evidence these payments. C) Real estate taxes for 1997 paid by Shane Keebaugh after the separation with penalty in the amount of $608.28. On 3-31-01, the date of separation, approximately 564.36 was owed on the 1997 real estate taxes. The real estate tax debt was incurred in July of 1997. A real estate tax receipt (exhibit "B") is evidence of payment of this debt by Shane Keebaugh. D) Real estate taxes for 1998, which became due July 1, 1998 in the amount of $478.46, which was paid by Shane Keebaugh with penalty in the amount of $600.96 in 2000. Although those taxes did not become due until July of 1998 they were due at the end of July 1998 and were at least in part for the time period, which Stephanie Keebaugh resided in the mobile home. A tax bill and payment receipt (exhibit "C") evidence Shane Keebaugh's payment of the debt. E) Real Estate taxes for 1999 now owing and overdue in the amount of $531.14. This debt was incurred in July of 1999 and is unpaid. This debt is evidenced by the tax bill (exhibit "D"). F) 1993 Toyota loan payments of $5,139.86 as of 3-31-98. Shane Keebaugh made all these payments since the date of separation and the vehicle is now paid off' The debt was incurred in February of 1995. Shane Keebaugh's bank statements, his transaction register and his payment book evidence payment of the car loan. G) Other Martial Bills for utilities, credit cards and other household expenses incurred during marriage and prior to March 31, 1998. The amount of which as of the date of separation has not yet been determined. (11) PROPOSED RESOLUTION OF ECONOMIC ISSUES: Defendant, Shane Keebaugh, proposes that he refinances the mobile home in his name alone and removes Stephanie Keebaugh from the Mortgage. Once Stephanie's name is removed from the mortgage she would deed her interest in the mobile home over to Shane. Shane will be assuming substantial negative equity in the mobile home. Shane will assume responsibility for all the other martial debt. Stephanie will transfer her interest in the 1993 Toyota to Shane. (Stephanie should not be considered to have any interest in the equity in the Toyota, since when Stephanie and Shane separated the Toyota had no positive equity. The car now only has positive equity because of the payments that were made solely by Shane since the time of separation.) Shane would be assuming substantial negative equity in the Mobile home and will coverall of the marital bills; therefore, Shane proposes that Stephanie would not receive any portion of Shane's Exel Logistics 401(k) retirement plan. Respectfully submitted, Douglas R. Roeder, squire Reichard Law Offices, LLC Attorney for Defendant, Shane Keebaugh 70 West King Street, Suite B Chambersburg, PA 17201 (717) 267-2288 VERIFICATION 1 verify that the statements made in foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. 3 Date: ? ?-3 -b 1 rG? l lX . Shane A. Keebaugh N# E SHANE A KEEBAUGH Shippensburg BEGINNING BALANCE WITHDRAWALS LOAN ORIGINATION 2ND QTR - 1999 CONTRIBUTIONS ASSOCIATE 401(K) EMPLOYER MATCH 2ND QTR - 1999 EARNINGS 2ND QTR - 1999 LOAN REPAYMENTS INVESTMENT TRANSFERS ENDING BALANCE INVESTMENT ELECTIONS: 2ND QTR 1999 TOTAL ACCOUNT BALANCE: ASSOCIATE 401(x) EMPLOYER MATCH PROFIT SHARING EXEL LOGISTICS RETIREMENT AND SAVINGS PLAN STATEMENT OF ACCOUNT AS OF 03/31/98 PA 17257 PIN M: 3669 COMPANY NUMBER: 7882 EMPLOYEE NUMBER: 92605 0% 0% SHORT TERM GOVERNMENT BOND BALANCED STOCK MONEY MKT FUND A FUND B FUND C FUND D FUND M TOTAL $11,025.69 $0.00 $0.00 $0.00 $0.00 $11,025.69 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $12.24 $0.00 $0.00 $0.00 $0.00 $0.00 $11,473.57 0.00 0.00 0.00 0.00 0.00 0 00 0.00 0.00 0.00 0.00 0.00 . 0.00 139.41 0.00 0.00 0.00 0.00 139.41 320.71 0.00 0.00 0.00 0.00 320.71 0.00 0.00 0.00 0.00 0.00 0.00 $11,485.81 $0.00 $0.00 $0.00 $0.00 $11,485.81 100% 0% 03 $12.24 $0. 00 $0. 00 $0.00 $0. 00 $0. 00 $11,473.57 $0. 00 $0. 00 Year-to-Date Associate 401(x) Contributions: Year-r.-Date Employer Match Contributions: $0.00 $0.00 For quarter-to-date and year-to-date investment returns, please call the Benefits Service Center. lid CUMBERLAND COUNTY TAX CLAIM BUREAU ONE COURTHOUSE SQUARE CARLISE PA 17013 PHONE 717 240-6366 FAX 717 240-6534 Printed: 6/15/99 13:11:34 ------------------------- TAX CLAIM RECEIPT Control Number: 39-002092 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 Map No: 39-13-0102-OOBA TR03542 COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 28X48 Situs Information: 0066 RUSTIC DRIVE Receipt No.: 11489 Receipt Date: 6/15/1999 Page: 1 Property Description: SOUTHAMPTON TOWNSHIP Tax Year Description Penalty & Face Interest ---------------------- Costs ------------- Total -------- ------------------------------- 1997 SCH-SHIPPENSBURG --- 488.22 100.06 20 00 588 .28 1997 BUREAU COSTS . Received For Yea r Of 1997;,.•--, $608.28 ---- -------- ----- -------- Tendered > ------------------- CASH ------------------------.- Total" - Recei.ved $608.28 Received By > MM ,t '•` Paid By > KEEBAUGH, SHANE ? `.??,`?X. •, Remarks > 1997 SCHOOL R.E. PAID IN FULL Balance ? Due As-Of 6 /15/1999 Claim Year: 1998 564.36-' - Claim Balance: 564.36 -' ?H?BR Receipt Number: 11489 Total Received: $608.2 TAX renn 1998-99 REAL ESTATE TAX NOTICE *. onTE ASSESSMENT BILL NO. Cl ?,FANSBURG AREA SCHOOL DISTRICTHOOL ** JULY 1 ]998 *umnrtcen e l 3, 7 0 0 928 VIVIAN F COY JUL AUG MAR APR MON 4-6PM TUES 9,30- 110 RAILROAD LN HOME PH 532-8620 1OA WED _ SHIPPENSBURG PA 17257 1 416PMMTUES 930-1130AM ALL OTHER OFFICE IN SOUTHAMPTON TOWNSHIP BLDG MONTHS MON 4-6PM CLOSED WK OF 6-28 1.0 LP 131 .9M_ %P -M +.P q p -YP 478 -_M OUpINO ^7= 488.2t2 .46 488.22 SE COUN I UL-A 537_0-4 -_ -M EPTC ENAL1'Y F7E- __ACCT NO 39-13-0102-OOBA TR03542 66 RUSTIC DRIVE KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 IF ES SCRO , FOR ARD THIS BILL TO YOUR MORTGAGE COMPANY COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 2BX48 IF UNPAID BY 4/01/99 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED TAX YEAn 1998-99 REAL ESTATE TAX SHIPPENSBURG AREA S NOTICE * * HOOL CHOO DATE ** JULY 1 1998 ASSESSMENT BILL NO. CZ uue cPeRe rn,Ml uo; L DISTRICT VIVIAN F COY 3,700 928 110 RAILROAD LN HOME SHIPPENSBURG PH 532-8620 JUL AUG MAR 13-30AM WED APR 4-6PM MON 4-6PM TUES 930- S PA 17257 OFFICE IN SOUTHAMPTON TOWNSHIP BLDG 4--6PM TUES 930-1 EPT OCT MON 130AM ALL OTHER MONTHS MON 4-6PM CLOSED WK OF 6-28 478. 488. ACCT NO 39-13-0102-008A TR03542 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 ISCOUNT UL-AUGUST 478.46 ACE EPT-OCT 488.22 FTER-OCT_- -537.04 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 2BX48 IFTAxES ARE IN ESCROW, FORWARD THIS BILL TO YOUR MORTGAGE COMPANY IF UNPAID BY 4/01/99 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED EXHIBIT Receipt for Payment of Delinquent Real Estate Taxes CUMBERLAND COUNTY TAX CLAIM BUREAU -I'r V CARLISLE, PA 17013 When this account includes checks theteceipt will not be valid until said checks are paid. ?? Date LOCATIO 0 PROPERTY d/Ca - 66FA -7;4?26Va- CAS14 TAXES PAID YEAR TAX AMOUNT - INTEREST L County Library Municipal School /1 g Cost F 1 ] T &'X /.,w q6. d. By CUMBERLAND CCMM TAX CLAIM BUREAU TAXPAYER'S COPY 1999-Q00 REAL ESTATE TAX MAR[ C1l14,4,Ai1gL?g.NS B U RG AREA S VIVIAN F COY 110 RAILROAD LANE SHIPPENSBURG PA 17257 OFFICE IN TWP BLDG CHOOL1 _R/-E- - - "-30...5M-----`?--- M .. 473.19 482.85 _-53.1...14 _ NOTICE •• SCHOOL •* JULY 1 1999 L.J. CHOOL DIS'TRICT 3,700 944 MAR-APR-JUL-AUG MON&WED 4-6PM TUE 9:30-11:30AM MAY-JUNE-SEPT-OCT MON 4-6PM TUE 9:30-11:30AM OTHER MONTHS MON 4-6PM PH 717-532-8620 11 Oun1ND TIn9 PERIOD PAY 711...... U(If I SCOUNT 7/01-08/31 473.19 ACE 9/01-10/31 482.85 1/01-_04/0.1 __._--..531.14. ACCT NO 39-13-0102-OOSA TR03542 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 IF TAXES ARE IN ESCROW, FORWARD THIS BILL TO YOUR MORTGAGE COMPANY 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 2BX48 IF UNPAID BY 4/01/00 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED TAX YEAR DATE ASSESSMENT BILL NO. C2 1999-00 REAL ESTATE TAX NOTICE *= SCHOOL ** JULY 1 1999 wMCCCxeL LfF,NSBURG AREA SCHOOL DISTRICT 3,700 944 VIVIAN F COY MAR-APR-JUL-AUG MON&WED 4-6PM TUE 110 RAILROAD LANE 9:30-11:30AM MAY-JUNE-SEPT-OCT MON SHIPPENSBURG PA 17257 4-6PM TUE 9:30-11:30AM OTHER OFFICE IN TWP BLDG MONTHS MON 4-6PM PH 717-532-8620 OOL-R/ ____ - --- _ • • • • 3.0_. M %P M M %r %P M OURINIi T/((5 PERI00 AY THIS A1(JU(II 73.19 82.85 r]3J-?lA ISCOUNT ACE 7/01-08/31 473.19 9/01-10/31 482.85 1/01-04/01 531 _76 ACCT NO 39-13-0102-OOSA TR03542 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 IF TAXES ARE IN ESCROW, FORWARD THIS BILL TO YOUR MORTGAGE COMPANY 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 28X48 IF UNPAID BY 4/01/00 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED EXHIBIT E Xel LIZ 02/16/2001 301 West: sdamk Rd. 'WtA=vMc, 0H 47011 . D061707 ADVICE OF DEPOSIT = NON-NEGOTIABLE Irst Union Ba k of Delaware ilmingtorl, DE 19803 In 07oA-1-18130 SHANE A KEEBAUGH •? 66 RUSTIC DR SHIPPENSBURG,PA 17257 + NON-NEGOTIABLE F.mninvice Id Social Security Status Exemptions/Allowance; Number SHANE A KEESAUGH 092605 199.56-1194 Married US-2/0 PA-0/0 D081707 CAXlg _ Payxroue Division Department Hire Date Period Start Period End Pay Date EXEL1 GO 1400 1131 12/13189 02/12!01 02/18/07 02/18101 Famines Rate Units Current Year To Date Overtime 1.5x - - - 1fi6.05 Holiday Pay - - 270.00 Hour H Pay 13 5000 40.00 540,00 3483.00 Total Grose 540.00 3919.05 Taxes Federal Income Tex _ 41.85 313.81 Social Security (FICA) 31.91 231.96 Federal Medicare 7.46 54.25 Pennsylvania Income Tax 14.41 104.76 SINer Sprina Two Res (Cumber 5.40 39.19 Total 101.03 743.97 PreTax DeductIon3 Standard Mod 21.86 153.02 Pretax Demal Plan 3.54 24.78 Total 25.40 177.80 AKerTax Deductions Suppiementtt Life 1 1.10 7.70 Child Support 123.93 927.51 Total 125.03 935.21 Net Pay 288.54 Direct DeeooK Accounts Amount Checking - 82899801 288.31 Current Ycar To Date W2 Gross Weae3 514.60 3741.25 Messages Hourly associates pay period ts trom 02105 - 02111/01. EXHIBR: Excl Inc. - 501 West Schrock Rd. Waterville, 011 43081 -Pr+oBw1ness _ J PA-40EZ •'1000 0000310045 PA-40EZ(09-00) G PA DEPARTMENT OF REVENUE, PA ONLY Your Social Security Number Spouse's Social Security Number ,I 9 Identification Label Change. O / Fill In this oval it the label you received with this booklet is not completely correct, or it - - - - you did not file a 1999 PA tax return. Do not _r Your First Name MI make corrections on the label - DISCARD IT. _ l - Important. If you moved Into or out of _ 1 - - - Pennsylvania during 2000, you must fife a Spouse's First Name MI ) PA-40. Amended Return. Fill in this oval if you are O 3 c? = amending your 2000 PA retum. ;S ouse's Last N l O t p ame - n y i different from Last Name above '? - T _ w ^ M e ype Filer. Fill in only one oval. Single S O First line of address • P.O. Box; Apartment Number; Suite: RR No. - it applicable Married, Filing Jointly J O Second line of address • Street Address Married, Filing Separately M 4ab Important. If a final return or filing for a deceased City or Post Office State ZIP Code person, you must use a PA-40. See Forms Ordering. County where you lived on 12/31/00. Lr? School Code Daytime Telephone Number ??E,I ? / ? C3 a g d U / a (Cl/% r-i Name of school district where you lived on 12131100. rn Municipality where you lived on 12131/00, C3 C3 i? MI5 ? G 1a. Gross Compensation from PA Schedule W-2S, or your Form(s) W-2, or other statements. ....... 1a. / (9 a D 6 0 .r7 u .. T lb. Unreimbursed Employee Business Expenses, from PA Schedule UE ....................... lb. 1c. Net Compensation. Subtract Line ib from Line 1a ...................................... 1c. O? '1 6 5 O p yf ( 7 2. Interest Income. Complete and enclose a PA Schedule A, if over $2,500 ..................... 2. 3. Dividend Income. Complete and enclose a PA Schedule B. if over $2,500 .................... 3. 4. Total PA Taxable Income. Add Lines 1c, 2, and 3. ..................................... 4. C?11 / 2 6 ? (;Zee C79, 5. PA Tax Liability. Multiply Line 4 by 2.8% (0.028) . ................ ..................... S. / 3,r 9-, 6. Total PA Tax Withheld, from PA Schedule W-2S, or your Form(s) W-2, or other statements. ...... 6. 735- 8-/ Tax Forgiveness Credit. Read the instructions. O Unmarried or Separated O Married 7a. Filing Status from your PA Schedule SP 7b. Total Eligibility Income. . ...... ....... 71b. From your PA TeleFile Schedule SP, Line 10. 8. Tax Forgiveness Credit. From your PA TeleFile Schedule SP ................. .......... 8. 9. Total Payments and Credits. Add Lines 6 and 8 . ...................................... 9. f / 10. TAX DUE. If Line 5 is more than Line 9, enter the difference here ........... ............ 10. Side 1 EXHIBIT . EC ?-. c. A, uca ^.rn ? L 0000310045 1 , 0000310 045 ?? PA-40EZ - 5000 0000420042 PA•40EZ (09-001 PA DEPARTMENT OF REVENUE FIG_l Pennsylvania Income Tax Return Commonwealth of Pennsvlvan lasEONr /J / 6/ IL Y Social Security Number our Name. 11 OV i?? sd 9y . ERPAYMENT. If Line 91s more than Line 5, color the difference here ..................... 11. ' Enter how you want your overpayment applied. It you only want a refund check, enter the amount from Line You may not request direct deposit on a paper return If ou want t d t 11 on Line 12. . y o ona e to one or more of the funds listed The total of Lines 12 through 17 roust equal Line 11. below, enter the amount on those lines. 2. Refund - Amount of Line 11 you want as a check mailed to you. Refund 12. ' 13. Donation - Amount of Line 11 you want to donate to the Wild Resource Conservation Fund..... 13 f i . . i n 14. Donation - Amount of Line 11 you want to donate to the U.S. Olympic Committee PA Division 14 i , , . 1 15. Donation - Amount of Line 11 you want to donate to the Organ Donor Awareness Trust Fund.. 15 j Yi .. ' ) 16. Donation - Amount of Line 11 you want to donate to the KoreaMetnam Memorial, Inc........ . I 16 17. Donation - Amount of Line 11 you want to donate to the Breast and Cervical Cancer Research Fund. 17. f i tax return, Number of Form(s) W-2 If you need more soace. you may nnnmonnv mm --.Hale .,....,.__._ .._... (a) Include the total on Line to Include the total on Line 6 (b) (D) (d) Employer Identification Number from box B Federal wages from PA taxable compensation PA tax withheld box 1 from box 17 from box 18 1. S S S 2. $ $ 6 3. S S $ 4. S S 9i 5. $ S S 6. $ $ S 7 $ S S Total. S S Side 2 L 0000420042 chedule in this format. •Donot Yhdxlebral incorne tax withheld in wham (d). -Do not Include tax wMdield to another state or (" in colon Caution. The Department reserves the right to require your actual Form(s) W-2. 0000420042 1 You must submit other statements for amounts you are reoortinD as cmmnensanr. E o?® Department of the Treuaury-Internal Rovonuu Sarvlee ®o LL U.S. Individual Income Tax Return 20 ns Use Only-Do not write or feel. In rule epeca. For the year Jan. 1-Dec. 31, 2000. or other tax year beginning , 2000, ending .20 OMB No. 1545.0074 Label Your first name and mina) Last name Your eoclei security number (sea L instructions A on page 19.) E If a feint return. spous is e' fist r and initial La nyne Spouse's social eeeurlrynJmbar Use the IRS L •?- i i label. H Home atltlress (nu¢b sir et). II you have a P.O. bo , so ego 19. Apt. no. Otherwise, E 0 Importantl please print R You must enter Qty' town or post office, slate. and 21P code. If You have a foreign atltlress, see page 19. or type. E your SSN(s) above. Presidential Election Campaign Note. Checking "Yes" will not change your tax or reduce your refund. You Spouse (See page 19.) Oo you or your spouse if filing a joint return want $3 to go to this fund? ? ?Yes ?NO ?Yee ?NO Filing Status z single Married filing joint return (even if only one had Income) 3 Married filing separate return. Enter spouse's social security no. above and full name here. ? Check only 4 ?? Head or household (with qualifying person). (See page 19.) If the qualifying person is a child but not your dependent, one box. enter this child's name here. ? 5 Ouali in widow(er) with dependent child (year spouse died ? ). (See page 19.) 6a ?Z Yourself. If your parent (or someone else) can claim you as a dependent on his or her tax l No. of boxes Exemptions return, do not check box 6a y chocked on It more than six dependents, see page 20, b ? Spouse c Dependents: (1) First name Last name (2) Dependent's social security number (3) Dependent's relationship to u (4) it qualng chit far child ax credit see a 20 0 u a / ? .. , a,a, I un,ucr vi exemptions elalmeo , Income 7 Wages, salaries, tips, etc. Attach Form(s) W2 Be Taxable interest. Attach Schedule B if required . . , , , • Attach b Tax-exempt Interest. Do not include on line SO . 18b Fortes W-2 and 9 . , Ordinary dividends. Attach Schedule B if required here. Also attach Also 10 Taxable refunds, credits, or offsets of state and local income taxes (see 22 , page ) Form(s) 1099•R 11 Alimony received . • , , , , , , , , If tax was 12 Business income or (loss). Attach Schedule C or C-EZ withheld. 13 . Capital gain or (loss). Attach Schedule D if required. If not required, check here ? ? 14 Other gains or (losses), Attach Form 4797 . If you did not get a W-2, 15a Total IRA distributions , 15a b Taxable amount (see page 23) see page 21. 16a Total pensions and annuities 16a b Taxable amount (sea page 23) 17 Rental real estate, royalties, partnerships, S corporations trusts etc Attach Schedule E Enclose, but do 18 , , . Farm income or (loss). Attach Schedule F , not attach, any payment. Also, 19 Unemployment compensation please use 20a Social security benefits , i 20a I J b Taxable amount (see page 25) Form 1040-V. 21 Other income. List type and amount (see page 25) .................................... 22 Add the amounts in the far right column for lines 7 throuch 21. This is vour total income ? Adjusted 23 IRA deduction (see page 27) . , , , , , , , , 23 Gross 24 Student loan interest deduction (see page 27) , 24 Income 25 Medical savings account deduction. Attach Form 8853 , 25 26 Moving expenses. Attach Form 3903 . . . . . . 26 27 One-half of self-employment tax. Attach Schedule SE 27 28 29 Self-employed health insurance deduction (see page 29) Self-employed SEP, SIMPLE and qualified plans 28 29 , E3 30 Penalty on early withdrawal of savings , , 30 31a Alimony paid b Recipient's SSN ? 31a 32 Add lines 23 through 31a . 33 . . . . . . Subtract line 32 from line 22. This is your adjusted gross Income ? For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 56. Cal. No. 113208 be sod ON No. of your children on So / he, • lived with you a did not Ilea with you due to divorce or separation pee page 20) Dependents on Be not entered above Add number entered lines above ? Form 1040 (2000) Form 1040 (2000) Tax'ahd 34 Amount from line 33 (adjusted gross income) , , , , . , Credits 368 Check it: ? You were 65 or older, ? Blind; ? Spouse was 65 or older, ? Blind. 2 Add the number of boxes checked above and enter the total here . . . , ? 35a b If you are married filing separately and your spouse itemizes deductions or Standard , you were a dual-status alien, see page 31 and check here . . . ? 35b ? Deduction 36 Enter your itemized deductions from Schedule A, line 28, or standard deduction shown for Most on the left. But see page 31 to find your standard deduction it you checked any box on People line 35a or 35b or If someone can claim you as a dependent . . . . 36 7.2 Single: 37 Subtract Ilne 36 from Ilne 34 37 He d of II line 34 is $96,700 or less, multiply $2,800 by the total number of exemptions claimed on household: line 6d. II Ilne 34 is over $96,700, we the worksheet on page 32 for the amount to enter 38 Q Q $6,450 39 , Taxable Income. Subtract line 38 from line 37. If line 38 is more than line 37 enter -0- 39 Marred filing 40 , Tax (see page 32). Check 8 any tax is from a ? Form(s) 8814 Is ? Form 4972 . . , 40 Qualifying 41 Alternative minimum tax. Attach Form 6251 41 wi ow( r). 42 Add lines 40 and 41 . . . . . . . . . . . . . . . . . . . . . ? 42 Married 43 Foreign tax credit. Attach Form 1116 If required filing 44 Credit for child and dependent care expenses. Attach Form 2441 44 $3.675 te1y: 45 Credit for the elderly or the disabled. Attach Schedule R r , 45 46 Education credits. Attach Form 8863 - 46 47 Child tax credit lase page 36) 47 O O al!) 48 Adoption credit. Attach Form 8839 . . . . . 48 49 . Other. Check if from a ? Form 3800 Is 50 Form 8396 c ? Form 8801 d ? Form (specify) 49 `- S 50 Add lines 43 through 49. These are your total credits 5o 51 Subtract line 50 from line 42. If line 50 is more than line 42, enter -0- , , ? 51 Q A fl/ Other 52 Self-employment tax. Attach Schedule SE . . . . . . . . . . . . . . 52 Taxes 53 Social security and Medicare tax on tip income not reported to employer- Attach Form 4137 63 64 Tax on IRAs, other retirement plans, and MSAS. Attach Form 5329 if required . . , 54 55 Advance earned Income credit payments from Form(s) W-2 . , , , 55 56 Household employment taxes. Attach Schedule H . . . , 58 57 Add lines 51 through 56. This is your total tax . ? 57 U!! Payments 58 Federal Income tax withheld from Forms W-2 and 1099 . , 58 7 59 2000 estimated tax payments and amount applied from 1999 return 59 E q u ] boa Earned Income credit (EIC) NU , . , . 60a c h ild, b Nonta xable earned income: amount EIC. and type ? .......................................... 61 Excess social security and RRTA tax withheld (see page 50) at 62 Additional child tax credit. Attach Form 8812 , . , , , 62 63 Amount paid with request for extension to file (see page 50) 53 64 Other payments. Check if from a ? Form 2439 b ? Form 4136 114 65 Add lines 58, 59, 60a, and 61 through 64. These are your total payments . ? 1 as .? / ,3v / 76 Refund 66 If line 65 is more than line 57, subtract line 57 from line 65. This Is the amount you overpaid Have it 67a Amount of line 66 you want refunded to you . . . . . . . . . . . . . ? ? b Routing number ? d Account number c Amount 69 If line 57 is more than line 65, subtract line 65 from line 57. This is the amount you owe. You Owe For details on how to pay, we page 51 . , , , . ? 70 Estimated tax penalty. Also include on line 69 . . I m I Sign uniser penailles or perjury. I declare that I have examined this return and accompanying schedules and statements, and to the bast of my knowledge anc belief. they are true, co t. a d complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge Here Joint retum7 Your sign e Oats Your occupation Daytime phone number I o See Page 19. `J- 9 42 Keep a copy Spouse's signs re. Lea joint return, both must sign. Date for Keep your Spouse's occupation May the IRS d15Cpee Ih1s return with the preparer records. Fir I shown below (see page 52)7 ? yes ? No Paid Preparer's Data Preparer's SSN or PTIN signature Check it Preparer's sell-employed ? Firm's name (or Use Only yours if self„employedl,, EIN ,l,lr- _ 9101.x. Forth 1090 (2000) SCHEDULES ASB Schedule 0 - ? emlzed Deductions OMB No. 15450074 A (Form 1040) ) ?oYo .mal Re (Schedule B Is on back Wv of the ar Treasury Name(s) Revenus amice mo (1) 11- Attach to Form 1040. ? Sea Instructions for Schedules A and B (Form Attachment 1040 1040). Sequence No. 07 ho NamMs) swWn . Form A ` Your social security number Medical Caution. Do not include expenses reimbursed or paid b others ?F? and 1 y . Medical and dental expenses (see page A-2) . 1 Dental 2 Enter amount from Form 1040, line 34. 2 Expenses 3 Multiply line 2 above by 7.5% (.075). 3 4 Subtract line 3 from line 1. If line 3 is more than line 1, enter -0- Taxes You 5 State and local income taxes 6 Paid 6 Real estate taxes (see page A-2) 8 ' (See 7 Personal property tares . . . . 7 page A-2.) 8 Other taxes. List type and amount ? ........... 9 ....dd..lines......5.......throw...h..6................ ....... ................. 8 A Interest 10 Home mortgage Interest and points reported to you on Form 1098 10 1 You Paid 11 Home mortgage interest not reported to you on Form 1098. If paid (See to the person from whom you bought the home, see page A-3 page A-3.) and show that person's name, identifying no., and address ? ................................................................ Note. ...................................... .......................... ......................................... 11 Personal rest Is 12 ....................... Points not reported to you on Form 1098. See page A-3 Y not . , , , , , , . 12 for special es. . deductible. 13 Investment interest. Attach Form 4952 if required. (See page A-3.) . . . . . . . . . . 13 14 Add lines 10 through 13 . Gifts to 15 Gifts by cash or check. If you made any gift of $250 or Charity more, see page A-4 . . . . . , . , , , , 15 1 If you made a 16 Other than by cash or check. if any gift of $250 or more, WOR gift and got a benefit for it see page A-4. You must attach Form 8283 if over $500 16 , am page A-4. 17 Carryover from prior year . 17 18 Add lines 15 through 17 Casualty and Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See page A-5.) Job Expenses 20 Unreimbursed employee expenses-job travel, union and Most dues, job education, etc. You must attach Form 2106 ! Other or 2106-EZ if required. (See page A-5.) ? ............... Miscellaneous ............................ Deductions .................................... 20 ...'.'. ............................. ................ ............ 21 Tax preparation fees . . . . . . 2Y (See 22 Other expenses-investment, safe deposit box, etc. List page A-5 for type and amount ? ........... . expenses to deduct here.) . ............................ ................................................................ 22 j 23 Add lines 20 through 22 . 23 24 Enter amount from Farm 1040, line 34. 24 25 Multiply line 24 above by 2% (.02) 25 j 26 Subtract line 25 from line 23. If line 25 is more than line 23 enter -0- Other 27 Other-from list on page A-6. List type and amount ? . Miscellaneous ............................. Deductions ............................................................................................... Total 28 Is Form 1040, line 34, over $128,950 (over $64,475 if married filing separately)? Itemized Deductions ? No. Your deduction is not limited. Add the amounts in the far right column for lines 4 through 27. Also, enter this amount on Form 1040, line 36. ? ? Yes. Your deduction may be limited. See page A•6 for the amount to enter. For Paperwork Reduction Act Notice, see Form 1040 Instructions. Cat. No. 1133ox Schedule A (Form 1040) 2000 PAGE 1 199-56-1194 SHANE A KEEBRUGH TAX IO NUMBER ?- 66 RUSTIC DR SHIPPENSBURG, PA 17257-9461 ALLFIRST BANK 52-0312840 FORMERLY KNOWN AS FIRST NRTL BANK OF MO EIN NUMBER 25 SOUTH CHARLES STREET BALTIMORE, MD 21201-3330 IMPORTANT TAX RETURN DOCUMEINT I-800-533-9630 71752 FORM 1099-DR 2000 INTEREST Dc%E COPY 8 (OMB NO.1545-0112) FOR RECIPXENI RETAIL-CHECKING -------------------------- 00826-9980-1------------------------------ --------------------------- SHRNE RKEEBRUGH DRS REPORT3M NAPE DRS ROWTIM TIN SHANE R KEEBRUGH 199.56-1194 1 - INTEREST INCOME NOT INCLUDED IN ITEM 3 $5 22 2 - EARLY WITHDRAWAL PENALTY . $0 00 3 - INTEREST ON U.S. SAVINGS BONDS B TREAS. OBLIGATIONS . $0.00 4 - FEDERAL D100lE TAX Wrn ELD $0 00 5 - INVESTMENT EXPENSES . $0.00 6 - FOREIGN TAX PAID $0 00 7 - FOREIGN COUNTRY OR U.S. POSSESSION . This Is Important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this Income Is taxable and the IRS deter. mines that it has not been reported. Instructions for Recipient Item 1: Shows Interest paid to you during the calendar year by the payer. This does not include interest shown in item 3. If you receive a Form 1099-INT for interest paid on a tax-exempt obligation, see the instructions for your income tax return. Item 2: Shows Interest or principal forfeited because of early withdrawal of time savings. You may deduct this on the 'Penalty on early withdrawal of savings" line of Form 1040. Item 3: Shows interest on U.S. Savings Bonds, Treasury bills, Treasury bonds, and Treasury notes. This may or may not be all taxable. See Pub. 550, Investment Income and Expenses. This interest is exempt from state and local income taxes. This Interest Is not Included in Item 1. Item 4: Shows backup withholding. For example, persons not furnishing their taxpayer identification number to the payer be. come subject to backup withholding at a 31 % rate. See Form W-9, Request for Taxpayer Identification Number and Certification, for information on backup withholding. Include this amount on your Income tax return as tax withheld. Item S: Any amount shown is your share of investment expenses of a single-class REMIC. If you file Form 1040, you may deduct these expenses on the 'Other expenses' line of Schedule A (Form 1040) subject to the 2% limit. This amount is included in Item 1. Item 6.. Shows foreign tax paid. You may be able to claim this tax as a deduction or a credit on your Form 1040. See your Form 1040 instructions. Nominees: If this form includes amounts belonging to another person, you are considered a nominee recipient. You must file Form 1099-INT for each of the other owners showing the income allocable to each. You must also furnish a Form 1099-INT to each of the other owners. File Form(s) 1099-INT with Form 1096, Annual Summary and Transmittal of U.S. Information Returns, with the Internal Revenue Service Center for your area. On each Form 1099-INT, list yourself as the "payer' and the other owner as the 'recipient.' On Form 1096, list yourself as the 'filer.' A husband or wife is not required to file a nominee return to show amounts owned by the other. INCOME AND EXPENSE STATEMENT OF SHANE A. KEEBAUGH Employer: Exel Logistics Address: 6 Daughton Road, New Kingston, PA Type of Work: Forklift Operator Payroll #: D081707 Pay Period: Weekly (Weekly, Bi-weekly, etc.) GROSS PAY PER PAY PERIOD: 540.00 Itemized Payroll Deductions: Federal Withholding: 41.85 Social Security: 31.91 Medicare: 7.46 Local Wage Tax: 5.40 State Income Tax: 14.41 Unemployment Tax: $ Retirement: $ Savings Bonds: $ Credit Union: $ Life Insurance: $ Health Insurance: 25.40 Other: (specify) Child Support: 123.93 NET PAY PER PAY PERIOD: 288.54 OTHER INCOME: Week Month Year Interest: $ _ $ $ Dividends: $- $ $ Pension: $ $ $ Annuity: $ $- $ Social Security: $ $ $ Rents: $ $ $ Royalties: $ $ $ Expense Account: $ $ $ Unemployment Comp.: $ $ g Workmen's Comp.: $ $ $ TOTAL OTHER INCOME TOTAL MONTHLY NET INCOME $1,250.34 EXPENSES HOME: Weekly Monthly Yearly Mortgage/rent $ 574.00 $ Maintenance $- 30.00 $ Repairs $ $ $ UTILITIES: Electric $- 60.00 $ Gas $- 100.00 $ Oil $ $ $ Telephone $- 65.00 $ Water $ 25.00 $ _ Sewer EMPLOYMENT: Public Transportation Lunch TAXES: Real Estate 50.00 Personal Property $ $ $ Income $ $ $ INSURANCE: Homeowners$ 35.00 $ Automobile 48.83 $- Life $ Payroll deduction $ Accident $ $ $ Health $ Pavroll deduction $ Other $ $ $ AUTOMOBILE: Payments $ $ $ Fuel 80.00 $ Repairs 30.00 $ Maintenance 10.00 $ Licenses 3.00 $ Registration 3.00 $ Auto Club $ $ $ MEDICAL: Weekly Monthly Ye9rly Doctor $ 30.00 $ Dentist 100.00 $ Orthodontist $ $ Hospital $__ $_20;00 $- Medicine $ $ $- Special needs (Glasses, braces, orthopedic devices, etc.) $ $ $ EDUCATION: Private School $ $ $- Parochial School $ $ $ College $ $ $ Religious $ $ $ School Lunches $ $ $ Books/Misc. $ $ $ PERSONAL: Clothing $ $ 80.00 $ Food $ 140.00 $ Barber/ Hairdresser 20.00 $- Personal care $ $ $ Laundry/dry cleaning $ $ $ Hobbies $ $ $ Memberships $ $ $ CREDIT PAYMENTS: Credit card $ 35.00 $ Charge account $ $ $ LOANS OR DEBTS: Credit Union $ $ $ Bank $ $ $ MISCELLANEOUS Household help $ $ $ Child care $ $ $ Camp $ $ $ Pet expense $_ 20.00 $ Papers/books/magazines $ $ $ Entertainment $ $ $ Pay TV $ 38.00 $ MISCELLANEOUS (Cont.) Vacation Gifts Legal fees Charitable Contributions Religious Memberships Children's allowances Other Child Support Alimony payments Lessons for children OTHER: TOTAL EXPENSES: Weekly Monthly Yearly $_ 35.00 $ $_ 60.00 $ $- 43.33 $ $ Payroll Deduction $ Weekly Monthly Yearly $- 1735.16 ?_ CONSECO FINANCE 500 LANDMARK TOWERS, 345 ST. PETER STREET Sr. PAUL, MINNESOTA 55107.1641 Where To Send Your Payment: CONSECO FINANCE PO Boa 17235 Brltimare, Ale 21297.1235 I?xir Shane A. Keebaugh 66 Rustic Or Shippensburg PA 17257-9461 Itlllll 1 1 all 1 1 1 111 all If I III I Is I i l l i l l l l 11611111119111114111111 Customer Service: Phone 1.800.543.0202 C0NSF.C0, MONTHLY BILLING STATEMENT Account Information: Statement Date: 1-16-01 Account Number: 733220859 Year To Date Interest Paid: 363.89 Next Payment Due Dale: 2-10.01.. Current Payment ' 3153,89r PastDUe PaymenE 00 Billed' Late. Charges: 00;; Insurance: AQ' Misc. Charges: AD, Total. Amount Due: $363.83 Correspondence Address: Please see the hack of this form for address. 73 Important Messages Person (Including a financial institution. a iovernmenlal uni(. and a comparative housing calculation) "a a engaged in a trade or cosiness and, in the course of such trade or business. Alcoved from you at least $000 of mortgage interest on any one mortgage in me calenmer year must furnish this statement to you. If -/a reamed this nuemem n Me dater of record pis a mortgage on will Mere are other L114.1s emitted to a deduction for this interest. Crease furnish each of the other borrow, 1 with inlormapon about the proper distribution of the amounts shown on this farm. Eaee barrowel is entitled to deduct only the amount he or ilia paid that represents MiS or eer she. Of the 2MOUnl allowamte as a mortgage interest deduction. If your mortgage payments were subrinced by a government agency, you may not oe axle to deduct Ina amount of the subsidy. OEFINmON OF'. This calendar ymc fh NNN pro talent secured by real property. This amount does no subsdy payments. or sailer payments on a 'buy-down' n deductible by you only in certain CdcdmStanaas. Cauppn: s calendar mar that accrued in full by January 1s. nest year. included in Sox 1. however. oven though the prayaid imam you cannot deduct Me prepaid amount in Mu calendar Year. F 545, Interest Expenses. II you can claim the mongage ICI Mortgage Interest credit. If the interest eas nand on a mo resonance. n may be subject to a deduction umdadon. Sea (Form 10eat. Boa 2.iMS box is far use oV the interest tact to lumleh real estate taxes or insurance paid from escrow. s is the Year printed on the face of this form. Form 1098 Department of the Treasury - Internal Revenue Service Box t: Shows the mortgage not...at received by the Internal racioient during the year. Instructions for PayadDorrower amount includes interest an any auilgatmn (including a home sourly, line at credit. or in 2025 E. Main Street Post Office Box 8 Waynesboro, PA 17268 717.762.1131 717.267.3006 FAX 717.7628800 REICHARD LAW OFFICES, LLC. The Fort Chambers Bldg, 70 W. King Street Suite B Chambersburg-, PA 17201 717-267.2288 FAX 717.267-1151 STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. SHANE A. KEEBAUGH, Defendant NO. 99-4843 CIVIL IN DIVORCE INVENTORY OF DEFENDANT Defendant files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ?A. Keebaugh, efendant ASSETS OF PAR'T'IES Defendant marks on the list below those items applicable to the case at bar and item izes th e assets on the following pages. O I. Real property (X) 2. Motor vehicles () 3. Stocks, bonds, securities and options () 4. Certificates of deposit () 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes O 8. Trust () 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () I 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home i O 15. Business (list all owners, including percentage of ownership, and officer/director I positions held by a party with company) O 16. Employment termination benefits - severance pay, worker's compensation claim/award j () 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments 21. 22. 23. 24. 25. Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemizes list if distribution of such assets is in dispute) (]Q 26. Other: 1996 Double Wide Mobile Home MARITAL PROPERTY Defendant lists all marital property in which either or both spouse have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Number of Property All Owners Excel Logistics 401(K) Shane A. Keebaugh 2. 1993 Toyota Corolla Shane A. Keebaugh Stephanie A. Keebaugh 1996 Doublewide Mobile Home Shane A. Keebaugh Stephanie A. Keebaugh NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property. Item Description Number of Property Names of All Owners 2000 Saturn SL2 Leased by Stephanie Keebaugh and Mr. Armstrong PROPERTY TRANSFERRED Item Description Date of Consid- Person to Who Number of Property eration Transferred I • None LIABILITIES Item Description Names of Names of Number of Property All Creditors All Debtors I • Mortgage on Conseco Finance Shane A. Keebaugh Mobile Home Stephanie A. Keebaugh 2. Marital Bills Various Stephanie A. Keebaugh 3. Marital Bills Various Shane A. Keebaugh 4. Lot Rent Country Side Shane A. Keebaugh for Mobile Home Village Stephanie A. Keebaugh 5. Real Estate Taxes Cumberland Co. Shane A. Keebaugh Tax Claim Bureau Stephanie A. Keebaugh 6. 1993 Toyota Unitias National Shane A. Keebaugh loan payments Bank Stephanie A. Keebaugh 2025 E. Main Street Post Office Box 8 Waynesboro, ?A 17268 717.762-1131 717.267-3006 FAX 717.762.8800 REICHARD LAW OFFICES, LLC. The Fort Chambers Bldg. 70 W. King Street . Suite B Chambersburg, PA 17201 717.267.2288 FAX 717.267.1151 r ? ?^: c?: 'f _. ?..i ".1 ?._ i ? J STEPHANIE A. KEEBAUGH, Plaintiff vs. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL IN DIVORCE INVENTORY OF DEFENDANT Defendant files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Shane A. Keebaugh, Defendant ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. () 1. Real property (X) 2. Motor vehicles () 3. Stocks, bonds, securities and options () 4. Certificates of deposit () 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trust () 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits - severance pay, worker's compensation claim/award () 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments 21. 22. 23. 24. 25. (7Q 26 Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemizes list if distribution of such assets is in dispute) Other: 1996 Double Wide Mobile Home MARITAL PROPERTY Defendant lists all marital property in which either or both spouse have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Number of Propert y Excel Logistics 401(K) 2. 1993 Toyota Corolla 1996 Doublewide Mobile Home Names of All Owners Shane A. Keebaugh Shane A. Keebaugh Stephanie A. Keebaugh Shane A. Keebaugh Stephanie A. Keebaugh NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property. Item Description Number of Propert y Names of All Owners 2000 Saturn SL2 Leased by Stephanie Keebaugh and Mr. Armstrong PROPERTY TRANSFERRED Item Description Date of Consid- Person to Whom Number of Property eration Transferred 1. None Item Description Number of Property 1. Mortgage on Mobile Home 2. Marital Bills 3. Marital Bills 4. Lot Rent for Mobile Home 5. Real Estate Taxes 6. 1993 Toyota loan payments LIABILITIES Names of Names of All Creditors All Debtors Conseco Finance Shane A. Keebaugh Stephanie A. Keebaugh Various Stephanie A. Keebaugh Various Shane A. Keebaugh Country Side Shane A. Keebaugh Village Stephanie A. Keebaugh Cumberland Co. Shane A. Keebaugh Tax Claim Bureau Stephanie A. Keebaugh Unitias National Shane A. Keebaugh Bank Stephanie A. Keebaugh REICHARD LAW OFFICES, LLC. Attorneys and Counselors at Law htip://www.reichud-pemmu.com D.L. Reichard 11, Esquire Douglas R. Roeder. Esquire Eric J. Weisbrod. Esquire 2025 East Main Street P. 0. Box 8 Waynesboro, PA 17268 717-762.1131 717.267.3006 Fax: 717.762.8800 Shelva J. Barton. Office Manager Terri L. 1larbaugh, Paralegal Kathy Barnhart, Legal Assistant The Fort Chambers Building 70 W. King SL, Suite B Chamber strg, PA 17201 717.267.2288 FAX: 717.267.1151 February 23, 2001 Robert Elicker, Esquire Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Keebaugh v. Keebaugh No. 99-4843 Civil Dear Mr. Elicker: Please find enclosed a pre-trial statement and inventory for the above matter. Thank you for your attention to this matter. Should you have any questions or concerns, please contact me at the telephone number below. Very truly yours, DRR Enclosures Douglas R. Roeder, Esquire D.L. Reichard, II & Associates 70 West King Street, Suite B Chambersburg, PA 17201 (717) 263-8940 cc: Shane Keebaugh Joanne Harrison Clough, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STEPHANIE A. KEEBAUGH Plaintiff VERSUS SHANE A. KEEBAUGH Defendant No. 99-4843 CIVIL CIVIL ACTION - LAW IN DIVORCE DECREE IN DIVORCE AND NOW, DECREED THAT AND STEPHANIE A. KEEBAUGH SHANE A. KEEBAUGH ARE DIVORCED FROM THE BONDS OF MATRIMONY. 4ND PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Any existing spousal support order shall hereafter be deemed an order for alimony pen dente ite Zany economic claims remain pending. It is further ordered that Plaintiff shall pay the cos' of these proceedings. BY THE COURT: ATTEST: J. PROTHONOTARY REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL, PENNSYLVANIA 17011.4642 717.763.1383 TELEFAX 717.730-7366 WESSITE: ReagerAdlerPC.com THEODORE A. ADLER a DAVID W. REAGER LINUS E. FENICLE DEBRA DENISON CANTOR JOANNE H. CLOUGH (of counsel) Writers E-Mail Address: ddenison®epiz.net January 17, 2001 Special Master Robert Ellicker Dauphin County Courthouse 1 Courthouse Square Carlisle, PA 17013 Re: Keebaugh v. Keebaugh No. 99-4843 Civil Dear Special Master Ellicker: THOMAS O. WILLIAMS SUSAN H. CONFAIR PETER L. LEONE . Certified Civil Tdal Specialist I am enclosing a copy of our Certification Report indicating that discovery is not completed to date in the above-referenced divorce action. However, I spoke to defense counsel recently and I am confident we should be able to exchange any of the outstanding discovery information within 30 days of today's letter. I am sorry for the delay in forwarding this Certification Report back to your office. Sincerely, JHC/ak Enclosure cc: Douglas R. Roeder, Esquire Stephanie Keebaugh EOEL-Esc ILILI ZV9V-L LOLL Vd 'llIH d VYV3 133H1S 139HVLN LEEZ MVl 1V SA3NHO11V 'O'd "H310V 9 k13OV3H T C? Fr 1 ,J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. SHANE A. KEEBAUGH, : IN DIVORCE Defendant : NO. 99-4843 CIVIL MOTION FOR APPOINTMENT OF MASTER 9 ?1 .irP AND NOW, this 'U day of 2000, comes the undersigned attorney for the plaintiff and certifies to the Court that the above action in Divorce is at issue; that no issue has been directed by the Court to be tried byjury, and therefore respectfully moves the Court for appointment of a Master. The following matters are at issue between the plaintiff and the defendant: ( ) Grounds for divorce; ( ) Alimony Pendente lite, ( ) Support; Counsel fees; ( ) Alimony; ( ) Paternity; (X) Equitable distribution of ( ) Custody; property; ( ) Other Service of the complaint was made on the above named defendant on August 18, 2000 by Certified Mail, Return Receipt Requested. An appearance on behalf of the defendant has been entered by Douglas R. Roeder, Esquire. The following attorneys have been interested in other matters arising between the plaintiff and defendant: Contest indicated. \ Reager & Adler, P C By: Joanne Harrison Clough Attorney for Plaintiff AND NOW, /C 4Zl (iYN a?- , 2000, , Esq., is hereby appointed Master in this proceeding to hear the testimony and return the record and a transcript to the Court together with report and recommendation. BY THE COURT: lvfte-? J. L ? I RXS REAGER & ADLER, PC DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 170114642 Telephone No. [7171763-1383 ttornevs_for Plaintiff STEPHANIE A. KEEBAUGH, Plaintiff, V. SHANE A. KEEBAUGH. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL IN DIVORCE INVENTORY OF STEPHANIE A. KEEBAUGH Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. STEPHANIE A. KEEBAUG ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemize the assets on the following pages. ( )I. Real property (X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( )9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryNA benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held ( ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) (X) 26. Other: Mobile Home MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other persona as of the date this action was commenced: Item Description Number of Property 1. Excel Logistics 401(K) 2. 1993 Toyota Corolla 3. 1997 Mobile Home Names of All Owners Shane A. Keebaugh Shane A. Keebaugh Stephanie A. Keebaugh Shane A. Keebaugh Stephanie A. Keebaugh NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to excluded from marital property: Item Description Number of Property 1. 2000 Saturn SL2 Reason for Exclusion Leased by Stephanie Keebaugh and Mr. Armstrong PROPERTY TRANSFERRED Person Item Description Date of to Whom Number of Property Transfer Transferred Consideration 1. None 3 Item Description Number of Property Loan for Mobile Home 2. Marital Bills 3. Marital Bills LIABILITIES Names of All Creditors Greentree Financial Names of All Debtors Shane A. Keebaugh Stephanie A. Keebaugh . Stephanie A. Keebaugh Shane A. Keebaugh 4 INCOME AND EXPENSE STATEMENT OF STEPHANIE KEEBAUGH Employer: Stephanie Keebaugh Address: zub 14. urgan Avenue, ippens urg Type of Work: vayroii Clerk Payroll Number: 2.12 Pay Period (weekly, twee y, etc.) i- ee y GROSS PAY PER PAY PERIOD: $548.00 Itemized Payroll Deductions: Federal Withholding: $ 33.91 Social Security: 33.98 Medicare 7.95 Local Wage Tax: 5.48 State Income Tax: 15.34 Unemployment Tax Retirement: Savings Bonds: Credit Union: Life Insurance: Health Insurance: 2.31 Other: (specify) NET PAY PER PAY PERIOD: $449.03 OTHER INCOME: Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account OTHER INCOME: Unemployment Comp. Workmen's Comp. Week -Z- ee TOTAL OTHER INCOME: Month Year o wear TOTAL MONTHLY NET INCOME: $ 973.03 HOME: Mortgage/rent Maintenance Repairs UTILITIES: Electric Gas Oil Telephone Water . Sewer. EMPLOYMENT: Public Transportation Lunch TAXES: Real Estate Personal Property Income INSURANCE: Homeowners Automobile Life Accident Health Other AUTOMOBILE: Payments Fuel Repairs Maintenance Licenses Registration Auto Club MEDICAL : Doctor Dentist Orthodontist Hospital Medicine Special needs (glasses, braces, orthopedic devices) EXPENSES Weekly Monthly $ 300.00 79.00 213.17 25.00 -2- Yearly .G,V;; EDUCATION: Private school Parochial school College Religious School lunches Books/misc. PERSONAL: Clothing Food . Barber/hairdresser Personal care - Laundry/dry cleaning Hobbies Memberships CREDIT PAYMENTS: Credit card Charge account LOANS OR DEBTS: Credit Union MISCELLANEOUS: Household help Child care Camp Pet expense Papers/books/ magazines Entertainment Pay TV Vacation Gifts Legal fees Charitable Contributions Religious . Memberships Children's Allowances Other Child Support Alimony payments Lessons for Children EXPENSES ?v Weekly Monthly 62.50 6?0,& .!) u - -- T . 67- 300.00 -3- Yearly O EXPENSES OTHER : Weekly Monthly Yearly TOTAL I=RN838 $ $ 2,079.07 S -4- 1 STEPHANIE A. KEEBAUGH, Plaintiff VS. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4843 CIVIL IN DIVORCE TO: Joanna Harrison Clough , Attorney for Plaintiff Douglas R. Roeder Attorney for Defendant DATE: Monday, December 4, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. The defendant has requested information from plaintiff regarding any retirement or like accounts, and any marital bills plaintiff claims to have paid, or which are still out- standing. There are no outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. I would expect discovery to be completed by the end of January, 2001. The defendant's attorney has requested the above indicated information from her client and the parties are cooperating to complete discovery without any further formal discovery requests. b?Ldo 92,? C. 4,?, DATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT (X) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. D. L. REICHARD II & Associates Attorneys and Counselors at Law http://w .reichud-p? w.com 2025 E. Main Street P. O. Box 8 D.L Reichard, 11, Esquire Waynesboro, PA 17268 Douglas R. Roeder, Esquire 717-762-1131 Eric J. Weisbrod, Esquire 717-267.3006 Paz: 717.762-8800 Shelve 1. Barton, Office Manager -ILe Port Chambers Building Terri L. Ilarbaugh, Paralegal 70 W. King SL, Suite B Chambersbur PA 17201 Kathy Barnhart, Legal Assistant 717-267-2298 PAX: 717-267-1151 December 27, 2000 Mr. Elicker, Esquire Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: . Keebaugh v. Keebaugh No. 99-4843 Civil Dear Mr. Elicker: Please find enclosed the certification that discovery is not complete in this matter. I have contacted the Plaintiff's attorney and we have agreed to complete discovery in an informal manner, so I do not expect to file any further interrogatories or discovery motions. I would expect discovery in this matter to be completed by about the end of January 2001. Also, I think that there is still a reasonably good chance that this matter may settle prior to a Master's hearing. Thank you for your attention to this matter. Should you have any questions or concerns, please contact me at the telephone number below. Very truly yours, Douglas R. Roeder, Esquire D.L. Reichard, 11 & Associates 70 West King Street, Suite B Chambersburg, PA 17201 (717)263-8940 DRR cc: Shane Keebaugh Enclosure STEPHANIE A. KEEBAUGH, Plaintiff VS. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4843 CIVIL IN DIVORCE TO: Joanna Harrison Clough , Attorney for Plaintiff Douglas R. Roeder Attorney for Defendant DATE: Monday, December 4, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. Discovery has not been completed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. k.? (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Plaintiff has forwarded a Request for Production of Documents and Interrogatories to Defendant regarding assets and outstanding debt. Counsel for Plaintiff has been in touch with counsel for Defendant and anticipates discovery responses should be received within the next 30 says from the date of this report. Likewise, counsel for Plaintiff has forwarded discovery requests to Plaintiff for her to answer to submit to defense counsel as per Defendant's request. DATE COUNSEL FOR P I T FF ( X ) COUNSEL FOR DEFEgD T ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ht1p:/1w .reichard-pennmar.corn D.1.. Reichard II, Esquire Douglas R. Roeder, Esquire Eric I Weisbrod, Esquire Shelve I Barton, office manager Terri L. Harbaugh, Paralegal Kathy BamhaM Legal Assistant December 18, 2000 Mr. Elicker, Esquire Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: KEEBAUGH v. KEEBAUGH NO. 99-4843 CIVIL Dear Mr. Elicker: 2025 E. Main Street P. O. Box 8 Waynesboro, PA 17268 717.762.1131 717.267.3006 Fax: 717-762-8800 The Fort Chambers Building 70 W. King SL, Suite B Chambersburg, PA 17201 717.267.2288 FAX: 717-267-1151 I received the paper work from your office to certify whether or not discovery is complete in the above referenced matter. For over a week, I have been attempting to contact opposing counsel and my own client to discuss this matter, but I have not been able to reach either opposing counsel or my client despite numerous attempts. Therefore, I am not yet in a position to certify whether discovery is or is not complete. I do not expect to make any further discovery requests at this point. However, I would like to at least confirm two matters with opposing counsel, before I can say for sure that further discovery will not be necessary. I am requesting that you give me a brief extension to confer with opposing counsel and my client before certifying whether or not discovery is complete. I believe I should be able to have a response in the mail to you by December 27, 2000. I thank you for your attention to this matter. If you have any questions or concerns, please contact me at the telephone number below. Very truly yours, DRR cc: Shane Keebaugh Joanna Clough 2ip to ?, Douglas R. Roeder, Esquire D.L. Reichard, II & Associates 70 West King Street, Suite B Chambersburg, PA 17201 (717) 267-2288 D. L. REICHARD, II & ASSOCIATES 134 W. Main Street P.O. Box 8 Waynesboro, PA 17268 717.762.1131 717.267-3006 FAX: 717.762-8800 The Fort Chambers Bldg. 70 W. King Street Suite B c - Chambersburg, PA 17201 717-267.2288 FAX: 717-267-1151 D.L. REICHARD, II & ASSOCIATES BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant STEPHANIE A. KEEBAUGH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. SHANE A. KEEBAUGH, Defendant NO. 99-4843 CIVIL CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I consent to the entry of a final divorce decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce decree 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 that decree will be sent to me immediately after it is entered with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unswom falsification to authorities. Date: /'17-00 C- ane A. Keebaugh, Defendant o v AI D. L. REICHARD, II & ASSOCIATES 134 W. Mein Street P.O. Box 8 Waynesboro, PA 17268 717-762-1131 717-267-3006 - FAX: 717.762.8800 D.L. REICHARD, II & ASSOCIATES BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant STEPHANIE A. KEEBAUGH, Plaintiff VS. SHANE A. KEEBAUGH The Fort Chambers Bldg. 70 W. King Street Suite B Chambersburg, PA 17201 717-267.2288 FAX: 717-267.1131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) was filed on August 11, 1999. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of divorce decree under 3301(c) of the Divorce Code. 1 verity that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unswom falsification to authorities. Date: 1--0-00 G lr' S ane A. Keebaugh, Defe ant - !i - fLJ 2025 E M ' Street REICHARD LAW OFFICES, LLC. ne Fort Chamber Bldg. . an Post Office Box 8 70 W. King Street Waynesboro, PA 17268 . Suitri8 ',117.762-1131 Chambersburg, PA 17201 717.2673006 717.267.2288 FAX 717.762.8800 FAX 717.267.1151 STEPHANIE A. KEEBAUGH, Plaintiff vs. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4843 CIVIL IN DIVORCE PRE-TRIAL STATEMENT (1) ASSETS OF PARTIES: MARITAL PROPERTY Defendant lists all marital property in which either or both spouse have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Value of Property All Owners 1. Excel Logistics 401(K) Shane A. Keebaugh As of 3-31-98 $11,473.57 total value. Approximately $3,476.84 is a non-marital portion as it was contributed by Shane Keebaugh prior to the marriage 2. 1993 Toyota Corolla Shane A. Keebaugh As of 3-31-98 Stephanie A. Keebaugh value of $5,000.00. As of 3-31-98 lien on Lien for $5,139.86 to Unitas National Bank As of 2-21-01 value of $2,500.00; lien to Unitas National Bank paid off. 1996 Doublewide Shane A. Keebaugh Mobile Home Stephanie A. Keebaugh As of 3-31-98 value $45,000.00 Mortgage to Conseco Finance for approx. $52,000.00. As of 2-21-01 Value $42,000.00. Mortgage to Conseco Finance for $48,306.81 NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property. Item Description Names of Value Number of Property All Owners 1. 2000 Saturn SL2 Leased by As of 2-21-21 value Stephanie Keebaugh $12,000.00. and Mr. Armstrong Lease terms and/or lien amounts are unknown to Shane Keebaugh. 2. Excel Logistics Shane A. Keebaugh As of 3-31-98 401(K) $11,473.57 total value. Approximately $3,476.84 is a non-marital portion as it was contributed by Shane prior to the marriage. (2) EXPERT WITNESSES: At this time Shane Keebaugh does not intend to call any expert witnesses. Shane Keebaugh reserves the right to call expert witnesses upon reasonable notice to the Plaintiff and the Court. (3) WITNESSES: A) Shane Keebaugh: 66 Rustic Drive, Shippensburg, PA 17257 Shane Keebaugh will testify about assets of the parties, the marital debts, his current income and expenses, the conditions under which Stephanie left, and other matters relevant to equitable distribution. B) Linda Mixell: 144 Fairview Road, Shippensburg, PA 17257 Linda Mixell is expected to testify about the nature of the assets of the parties, marital debts that were paid by Shane Keebaugh, and the conditions under which Stephanie Keebaugh left the marital residence. Shane Keebaugh reserves the right to call other witnesses upon reasonable notice to the Plaintiff and the Court. (4) DEFENDANT'S EXHIBITS: A) Excel Logistics Retirement and Savings Account Statement dated March 31, 1998. (Attached hereto as exhibit "A") B) Cumberland County Tax Claim Bureau Receipt for 1997 Real Estate Taxes. (Attached hereto as exhibit "B") C) Real Estate Tax Notice for 1998-1999 tax year. (Attached hereto as exhibit "C") D) Real Estate Tax Notice for 1999-2000 tax year. (Attached hereto as exhibit "D") E) Pay receipt for Shane Keebaugh for the pay period ending 2-18-01. (Attached hereto as exhibit "E") F) Shane Keebaugh's Pennsylvania State Tax Return for 2000. (Attached hereto as exhibit "F") G) Shane Keebaugh's Federal Income Tax Return for 2000 (Attached hereto as exhibit "G") H) Income and Expense Statement for Shane Keebaugh (Attached hereto as Exhibit "If') I) Mortgage billing and interest statement dated 1-16-01. (Attached hereto as exhibit "P") J) 1998 Blue Book with Used Car Values - Describes value of various automobiles giving consideration to options, condition, and mileage. K) 2001 Blue Book with used Car Values - Describes value of various automobiles giving consideration to options, condition, and mileage. L) Shane Keebaugh's bank statement - details checks cashed from March of 1998 through the present. M) Shane Keebaugh's transaction register from checkbook - details checks written from March of 1998 through the present. N) Payment book for the 1993 Toyota - details payments that Shane Keebaugh made on the 1993 Toyota. (5) DEFENDANT'S GROSS INCOME FROM ALL SOURCES: Gross income per week - $540.00 Taxes Weekly Federal Tax - $41.85 Weekly Social Security - $31.91 Weekly Medicare - $7.46 Weekly PA tax - $14.41 Weekly Silver Springs tax - $5.40 Pretax Deductions Weekly Standard Medical - $21.86 Pretax Dental Plan - $3.54 After-Tax Deductions Weekly Supplemental Life - $1.10 Weekly Child Support - $123.93 Net Pav - $288.54 A 2000 Pennsylvania State tax return for Shane Keebaugh is attached hereto as exhibit "F." A 2000 Federal Tax return for Shane Keebaugh is attached hereto as exhibit "G." Shane Keebaugh's current pay receipt is attached hereto as exhibit "IT' (6) INCOME AND EXPENSE STATEMENT Attached hereto as exhibit "H" (7) PENSION/RETIREMENT ACCOUNTS: Excel Logistics 401(K) As of 3-31-98 of Shane Keebaugh $11,473.57 total value. approximately $3,476.84 is a non-marital portion as it was contributed by Shane prior to the marriage. (8) CLAIM FOR COUNSEL FEES: None (9) VALUATON METHODS: No disputes exist as to valuation at this time. (10) MARITAL DEBTS: A) Mortgage on mobile home to Conseco Finance in the amount of $48,306.81 as of 2-21-01. As of 3-31-01, the approximate date of separation, the Mortgage balance was approximately $52,000.00. The mobile home was purchased in the late spring of 1996 and the mortgage was taken out at that time. Monthly payments of $363.89 have been made since the inception of the mortgage. The mortgage is currently paid to date. Shane Keebaugh has made all those monthly payments himself, since and including the March of 1998 payment. A mortgage billing and interest statement (exhibit "I") and Shane Keebaugh's bank statements evidence the mortgage payments. B) Lot Rent for the Mobile Home of $215.00 per month to Country Side Village. The monthly lot rent has remained the same since the time of separation. The debt was incurred in the late spring of 1996. The lot rent payments are currently up to date. Shane Keebaugh has made all of the lot rent payments by himself, since and including the March of 1998 payment. Shane Keebaugh has bank statements and a transaction register to evidence these payments. C) Real estate taxes for 1997 paid by Shane Keebaugh after the separation with penalty in the amount of $608.28. On 3-31-01, the date of separation, approximately 564.36 was owed on the 1997 real estate taxes. The real estate tax debt was incurred in July of 1997. A real estate tax receipt (exhibit "B") is evidence of payment of this debt by Shane Keebaugh. D) Real estate taxes for 1998, which became due July 1, 1998 in the amount of $478.46, which was paid by Shane Keebaugh with penalty in the amount of $600.96 in 2000. Although those taxes did not become due until July of 1998 they were due at the end of July 1998 and were at least in part for the time period, which Stephanie Keebaugh resided in the mobile home. A tax bill and payment receipt (exhibit "C") evidence Shane Keebaugh's payment of the debt. E) Real Estate taxes for 1999 now owing and overdue in the amount of $531.14. This debt was incurred in July of 1999 and is unpaid. This debt is evidenced by the tax bill (exhibit "D"). F) 1993 Toyota loan payments of $5,139.86 as of 3-31-98. Shane Keebaugh made all these payments since the date of separation and the vehicle is now paid off. The debt was incurred in February of 1995. Shane Keebaugh's bank statements, his transaction register and his payment book evidence payment of the car loan. G) Other Martial Bills for utilities, credit cards and other household expenses incurred during marriage and prior to March 31, 1998. The amount of which as of the date of separation has not yet been determined. (I1) PROPOSED RESOLUTION OF ECONOMIC ISSUES: Defendant, Shane Keebaugh, proposes that he refinances the mobile home in his name alone and removes Stephanie Keebaugh from the Mortgage. Once Stephanie's name is removed from the mortgage she would deed her interest in the mobile home over to Shane. Shane will be assuming substantial negative equity in the mobile home. Shane will assume responsibility for all the other martial debt. Stephanie will transfer her interest in the 1993 Toyota to Shane. (Stephanie should not be considered to have any interest in the equity in the Toyota, since when Stephanie and Shane separated the Toyota had no positive equity. The car now only has positive equity because of the payments that were made solely by Shane since the time of separation.) Shane would be assuming substantial negative equity in the Mobile home and will cover all of the marital bills; therefore, Shane proposes that Stephanie would not receive any portion of Shane's Exel Logistics 401(k) retirement plan. Respectfully submitted, Dougla R. Roeder, Esquire Reichard Law Offices, LLC Attorney for Defendant, Shane Keebaugh 70 West King Street, Suite B Chambersburg, PA 17201 (717) 267-2288 VERIFICATION I verify that the statements made in foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unswom falsifications to authorities. Date: .2. p ,3 Shane A. Keebaugh EXF.L LOGISTICS - _./ C/ C L RETIREMENT AND SAVINGS PLAN ll o•a 1 8 T I c s S'T'ATEMENT OF ACCOUNT AS OF 03/31 /98 SHANE A KEEBAUGH PIN 4: 3669 COMPAN Y NUMBER. : 7882 EMPLOY EE NUMBER: 92605 Shippensburg PA 17257 SHORT TERM GOVERNMENT BOND BALANCED STOCK MONEY MKT FUND A FUND B FUND C FUND D FOND M TOTAL BEGINNING BALANCE $11,025.69 S0.00 $0.00 $0.00 $0 .00 $11,025 .69 WITHDRAWALS 0.00 0.00 0.00 0.00 0 .00 0 .00 LOAN ORIGINATION 0.00 0.00 0.00 0.00 0 .00 0 .00 2ND QTR - 1999 CONTRIBUTIONS ASSOCIATE 401(K) 0.00 0.00 0.00 0.00 0 .00 0 .00 EMPLOYER MATCH 0.00 0.00 0.00 0.00 0 .00 0 .00 2ND QTR - 1999 EARNINGS 139.41 0.00 0.00 0.00 0 .00 139 .41 2ND QTR - 1999 LOAN REPAYMENTS 320.71 0.00 0.00 0.00 0 .00 320 .71 INVESTMENT TRANSFERS 0.00 0.00 0.00 0.00 0 .00 0 .00 ENDING BALANCE $11,485.61 $0.00 $0.00 $0.00 $0 .00 $11,485 .81 INVESTMENT ELECTIONS: END QTR 1999 100: 0% Ot 04 04 TOTAL ACCOUNT BALANCE : ASSOCIATE_ 401(x) $12.24 s0. 00 50.00 $0.00 $0 .00 $12 .24 EMPLOYER MATCH $0.00 $0.00 $0.00 $0.00 $0 .00 $0 .00 PROFIT SHARING $1!,473.57 $0.00 $0.00 $0.00 $0 .00 $11,473 .57 Year-to-Date Associate 401(K) Contributions: $0.00 Year-r.-Date Employer match contributions; $0.00 For quarter-to-date and year-to-dace investment returns, please cal l the Benef its Service Center. EXHIBIT CU14SERLAND COUNTY TAX CLAIM BUREAU ONE COURTHOUSE SQUARE CARLISE PA 17013 ------------------------------------------------ Printed: 6/15/99 TAX CLAIM RECEIPT 13:11:34 Control Number: 39-002092 PHONE 717 240-6366 FAX 717 240-6534 --------------------------- Receipt No.: 11489 Receipt Date: 611511999 Page: 1 Property Description: KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 Map No: 39-13-0102-OOBA Tax Year Description --------------------------- 1997 SCH- SHIPPENSBURG 1997 BUREAU COSTS TR03542 COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 2BX48 Situs Information: 0066 RUSTIC DRIVE SOUTHAMPTON TOWNSHIP ------------------------------------------- Penalty & Face Interest Costs Total 468.22 100.06 588.28 20.00 20.00 Received For Year Of 1997 $608.28 G 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - Tendered > CASH Total- Received $608.28 Received By > MM ? ? l" Paid By > KEEBAUGH, SHANE • (_, - Remarks > 1997 SCHOOL R.E. PAID IN FULL Balance Due AS-Of 6/15/1999 Claim Year: 1998 564.36 Claim Balance: 564.36 EXHIBIT 11 -0 1 Receipt Number: 11489 Total Received: $608.2E TAX renn 1998-99 REAL ESTATE TAX NOTICE n>r SCHOOL AA nn1E ASSESSMENT ea1.NO•C1 SFA;I;?Fi?NS.BURG AREA SCHOOL DISTRICT JULY 1 1998 uuamans n 3,700 928 VIVIAN F COY JUL AUG MAR APR MON 4-6PM TUES 9.30- 110 RAILROAD LN HOME PH 532-8620 1130AM WED 4-6PM SEPT OCT MON SHIPPENSBURG PA 17257 4-6PM TUF.S 930-1130AM ALL OTHER OFFICE IN SOUTHAMPTON TOWNSHIP BLDG MONTHS MON 4-6PM CLOSED WK OF 6-28 SCIIO.O.L_R/E - --- -- - 1GRC_.131._?A?___ °•P _ -M-;:P .. _.q ._._ _ ..- YP?.. __-N O?N6 TNIS PEf1100_' r?L+fi?s. __.__ IA _ PAY 11115 AMDUNI _ 478.46 ISCOUNT UL-AUGUST 488.22 478.46 __._537_04 ACE EPT-OCT 488.22 ACCT NO 39-13-0102-008A TR03542 66 RUSTIC DRIVE KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 28X48 IF UNPAID BY 4/01/99 TAXES WILL BE IF A ES AR IN ESCROW FORWARD TURNED OVER TO CUMBERLAND CO. , THIS BILL TO YOUR MORTGAGE COMPANY TAX CLAIM BURE '$1 00 FEE F AU. ' . OR ADD L RECEIPTS REQUESTED rnx renn 1998-99 REAL ESTATE TAX NOTICE >. H DATE OOL ** JULY ASSESSMENT eul. NO. C2 SHIPPENSBURG AREA SCHOOL DISTRICT u.ut cPt 11 MIUL III: 1 1998 3,700 928 VIVIAN F COY 110 RAILROAD LN HOME SHIPPENSBURG PA PH 532-8620 JUL AUG MAR 11-30AM WED APR MON 4-6PM TUES 930- 4-6PM SEPT OCT 17257 OFFICE IN SOUTHAMPTON TOWNSHIP BLDG 4-•6PM TUES MONTHS M MON 930-1130AM ALL OTHER ON 4-6PM CLOSED WK OF 6-28 478. 488. ACCT NO 39-13-0102-008A TR03542 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 IF TAX S RE IN ESCROW, FORWARD4 THIS BILL TO YOUR MORTGAGE COMPANY DISCOUNT UL-AUGUST 478.46 ACE EPT-OCT 488.22 ENALTY_ .FTER OCT._ 04- 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 2BX48 IF UNPAID BY 4/01/99 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED EXHIBIT Receipt for Payment of Delinquent Real Estate Taxes CUMBERLAND COUNTY TAX CLAIM BUREAU ^I .. v CARLISLE, PA 17013 When this account includes checks the eceipt wfif not be valid until said checks are pald. Date LOCATIO O PROPERTY d/ca - 64-FA ?Xss3S ?l>z TAXES PAID I? YEAR TAX AMOUNT INTEREST w Ia County Library Municipal School I I /; I C Cost ? OTALAMCUNT-> /?QO Cj6 v G d. By • • -? O :1 pl :ICf. 3 • il• H211 CUMBERLAND C e TAX CLAIM BUREAU TAXPAYER'S COPY 1999-00 REAL ESTATE TAX NOTICE nA SCHOOL •+ JULY 1 1999 L1 unu enesll Pin?g.NSBURG AREA SCHOOL DISTRICT 3,700 944 VIVIAN F'COY MAR-APR-JUL-AUG MON&WED 4-6PM TUE 110 RAILROAD LANE IMI 9:30-11:30AM MAY-JUNE-SEPT-OCT MON SHIPPENSBURG PA 17257 4-6PM TUE 9:30-11:30AM OTHER OFFI•.CE IN TWP BLDG MONTHS MON 4-6PM Pit 717-532-8620 - - CHOOL R/-E "....... •f,i4!H?... N."d 'S?I?x?'. ,.'r:µ.•'? 0 '" ±:r -n.r - JA numnn niln renlao rnY nus nMOUrR 473.19 COU7/01-08/31 473.19 482.85 - E 9/01-10/31 482.85 53.1 _1_-NALT.Y_.---.--. 1/01-D4/O1 .531.14 ACCT NO 39-13-0102-OOBA TR03542 KF.EBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 28X48 IF TAXES ARE IN ESCROW, FORWARD THIS BILL TO YOUR MORTGAGE COMPANY IF UNPAID BY 4/01/00 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED TAI( YEAR DATE ASSESSMENT BILL NO. C2 1999-00 REAL ESTATE TAX NOTICE An SCHOOL •* JULY 1 1999 „n,ja,ee7{A&?g.NSBURG AREA SCHOOL DISTRICT 3,700 944 VIVIAN F COY MAR-APR-JUL-AUG MON&WED 4-6PM TUE 110 RAILROAD LANE 9:30-11:30A!4 MAY-JUNE-SEPT-OCT MON SHIPPENSBURG PA 17257 4-6PM TUE 9:30-11:30AM OTHER OFFICE IN TWP BLDG MONTHS MON 4-6PM PH 717-532-8620 C .P M DUMNIi THIS Pe"166 PAY THIS A!"011111 ISCOUNT 7/01-08/31 473.19 ACE 9/01-10/31 482.85 1/01-o4/nI r1l IA ACCT NO 39-13-0102-008A TRO3542 KEEBAUGH, SHANE 66 RUSTIC DRIVE SHIPPENSBURG PA 17257 66 RUSTIC DRIVE COUNTRYSIDE ESTATES LOT 23 1996 PINE GROVE 28X48 .. 1i .. •Ab, IF TAXES ARE IN ESCROW, FORWARD' THIS BILL TO YOUR MORTGAGE COMPANY IF UNPAID BY 4/01/00 TAXES WILL BE TURNED OVER TO CUMBERLAND CO. TAX CLAIM BUREAU. $1.00 FEE FOR ADD'L RECEIPTS REQUESTED EXHIBIT 'Exel 301 Wet SrLrccl, Rd.' •Wa1arIIIC' OH 43081 02%16/2001 D081707 ADVICE OFDEPOSIT-'NON-NEGOTIABLE to uroamtec0 SHANEAKEEBAUGH -- 66 RUSTIC DR SHIPPENSBURG,PA 17257 NON-NEGOTIABLE _Employee Id Social Securirv $faNS Fxemotions/Alinwanca Numher SHANE A KEE3AUGH 092605 199-56.1194 Married US-2/0 PA-0/0 D081707 (•.xic IXELt Pay up Division Department Him Date_ _ Period Start Period End Date GO 1400 1131 12113/89 02112/01 02/18/01 M 02/16/01 Earnings Rate Un'ts Cunent Year To Dare CNaNma 1.5x Holiday Pay - - - - 168.05 Hourlv Par - - 13.5000 40.00 540.00 270.00 3483 00 Total Gross 540.00 . 3919.05 Totes Federal Income Tax 41.85 313.81 Social Security (FICA) 31.91 231.96 Federal Medicare 7.46 54.25 Pennsylvania Income Tax 14.41 104.76 Silver Soring Two Res (Cumber 5.40 39.19 Total 101.03 743.97 PreTax Deductions Standard Mod 21.86 153.02 Pretax Dental Plan 3.54 24.78 Total 25.40 177.80 AKerTax Deductions Supplemental Life 1 1.10 7.70 Child Support 123.93 927.51 Total 125.03 935.21 Net Pay 288 54 Direct Deposit Accounts Amount Checking - 82699801 288.54 Current Year To Date W2 Gross Wages 514.60 3741.25 Messages Hourly associates pay period Is from 02/05 - 02/11/01. EXHIBIT 11 - E? _j First Union Bank of Delaware Wilmington, DE 19803 Exci Inc. - 501 West Schrock Rd. Waterville, Oil 43081 •?roBusiness _ J -PA-40EZ - 2000 0000310045 PA-40EZ (09 -00) / PA DEPARTMENT OF REVENUE, D Nnrixbure, PA 17129.0003 Pennsylvania Income Tax Return Commnnu Your Social Security Number Spouse's Social Security Number Identification Label Change. O J (pi / l? sl Name Fill in this oval it the label you received with this booklet is not completely correct, or it - you did not file a 1999 PA tax return. 00 not ., Your First Name MI 3 make corrections on the label - DISCARD IT. - _ Important. It you moved Into or out of f _ Pennsylvania during 2000, you must file a ..'Spouse's First Name MI j _ - PA-40. = Amended Return. Fill in this oval if you are O 1 ; - amending your 2000 PA return. - ' - : Spouse s Last Name - Only if different from Last Name above r - Type Filer. Fill in only one oval. Single S O First line of address - P.O. Box; Apartment Number; Suite; RR No. - if applicable Married, Filing Jointly J O Second line of address - Street Address Married, Filing Separately M 4im Important. It a final return or filing for a deceased City or Post Office State ZIP Code person, you must use a PA-40. See Fortes Ordering, County where you lived on 12/31/00. Ln School Code Daytime Telephone Number i/ `ne/% oa/?0U t ltl?? rl Name of school distract where you lived on 1931,00. m Municipality where you lived on 12/31100. cm o e? C3 0 1a. Gross Compensation from PA Schedule W-2S, or your Form(s) W-2. or other statements........ 1a. tp 7 7 lb. Unreimbursed Employee Business Expenses. from PA Schedule LIE . ...................... l 1b. 1c. Net Compensation. Subtract Line tb from Line 1a ...................................... 1c. J6 0290 q /l 7 7 2. Interest Income. Complete and enclose a PA Schedule A. if over $2.500. .................... 2. 3. Dividend Income. Complete and enclose a PA Schedule 8, if over S2,500 .................... 3. 4. Total PA Taxable Income. Add Lines 1c, 2, and 3 . ..................................... 4. a v Q 9 5. PA Tax Liability. Multiply Line 4 by 2.8% (0.028) . ...................................... 5. 7 3 f D 6. Total PA Tax Withheld, from PA Schedule W-2S, or your Form(s) W-2, or other statements. ...... 6. / 3 S 8' Tax Forgiveness Credit. Read the instructions. O Unmarried or Separated O Married 7a. Fling Status from your PA Schedule SP 7b. Total Eligibility Income . ............... 71b. From your PA TefeFife Schedule SP, Line 10. 8. Tax Forgiveness Credit. From your PA TeIeF.Je Schedule SP ............................. 8. 9. Total Payments and Credits. Add Lines 6 and 8. ...................................... 9. n / 10. TAX DUE. 11 Line 5 is more than Line 9, enter the difference here........... 10. slde 1 EXHIBIT EC c,.1? dca 0000310045 0000310045 J . PA-40EX - 2000 0000420042 PA-40EZ (09-00) PA OEPARTAIENT OF REVENUE OFFICIAL USE OHLI Pennsylvania Income Tax Return Commonwealth of Pennsylvania) / Social Security Number Your Name: _?(? (? (f P?f G/G?____ 1191, 11. OVERPAYMENT. It Line 9 is more than Line 5, enter the difference here .................... 11.7 y Enter how you want your overpayment applied. If you only want a refund check, enter the amount from Line 11 on Line 12. You may not request direct deposit on a paper return. II you want to donate to one or more of the funds listed below, enter the amount on those lines. The total of Lines 12 through 17 must equal Line 11. 12. Refund - Amount of Line 11 you want as a check mailed to you. Refund 12. r. 13, Donation - Amount of Line 11 you want to donate to the Wild Resource Conservation Fund...... 13. f _ r 14. Donation - Amount of Line 11 you want to donate to the U.S. Olympic Committee, PA Division. 14. 15. Donation -Amount of Line 11 you want to donate to the Organ Donor Awareness Trust Fund.. 15. ti 16. Donation - Amount of Line 11 you want to donate to the Korea/Vietnam Memorial, Inc........ 16. .1 17. Donation - Amount of Line 11 you want to donate to the Breast and Cervical Cancer Research Fund. 17. i rU C3 C3 C3 _ N PA S PA G Na C3 C3 as shown on your PA Statement •^ ?__? u. suwmumg your rormtsi Wz, or pnotocopies, you may write the necessaryinformatton below. Keep your original one(s) W2. Important. Your PA compensation may be different from your federal wages. Caution. If you believe that the PA amount on a Form W-2 is incorrect. you must submit your actual Form W-2 with a written explanation from your employer. You must submit other statements for amounts you. are reporting as compensation on your PA tax return. Number of Form(s) W-2 (a) Employer Identification Number from box B Federal, box 1 compensation from box 17 PA tax withheld from box 16 1. S S S 2. S S S 3. g S S 4. S S S 5. g $ S 8. g S S 7. I S S S Total. S S Side 2 If you need more space, you may photocopy this schedule or prepare your own schedule in this format. Include the total on Line to Include the total on Line 6 •Do not include local (hl (cl (d) hoxme tax witineld ages from pq taxable rl column (CO. •Do nct vrhrtle tax Wittleld to another state or=nay in cakrrrl (d). Luton. The Department reserves the right to require your actual Form(s) W2. L. 0000420042 0000420042 1 PLEASE DO NOT CALL A90UT YOUR REFUND UNTIL 9 WEEKS AFTER YOU FILE. Label (See L instructions A on page 19.) E Use the IRS L label. H Otherwise, E please print R or type. E Presidential Election Campaig (See page 19.) Filing Status Check only one box. Exemptions If more than six dependents, see page 20. number A Important! A You must enter your SSN(s) above. You Spouse ?Yes?No ?Yes?No - Single Married filing joint return (even if only one had Income) Married filing separate return. Enter spouse's social security no. above and lull name here. ? Head of household (with qualifying person). (See page 19.) If the qualifying person is a child but not your dependent, enter this child's name here. ? Ouali in widow(er) with dependent child (year spouse died ? ). (See page 19.) Yourself. If your parent (or someone else) can claim you as a dependent on his or her tax No. of hoses return, do not check box 8a . . . . . . . . . . . . . . . 1 checked on . . . . . . . . Dependents: n) First name Last name . . . . . . . . (2) Dependent's social security number b . . . . (3) Dependent's relationship to ou . . . . . R) d gualdnlp child far child tax avoid nee m e 201 D u 211 72 543 , c ? a i otui numoer or exemptions created Income 7 Wages, salaries, tips, etc. Attach Form(s) W-2 8a Taxable interest. Attach Schedule B if required . . , Attach b Tax-exempt interest. Do not include on line as . . , 18b ( Forms II and 9 Ordinary dividends. Attach Schedule B if required here. Also attach Also 10 Taxable refunds, credits, or offsets of state and local income taxes (see page 22 ) Form(s) 1899.R 11 Alimony received . . . . . . . . . . . . . . . . . . . . . if tax was 12 Business income or (loss). Attach Schedule C or C-EZ , withheld. 13 Capital gain or (loss), Attach Schedule D if required. If not required, check here ? ? 14 Other gains or (losses). Attach Form 4797 , , , , , , If you did not 15a Total IRA distributions . 15a to Taxable amount (see page 23) get a W-2, see page 21. 18a Total pensions and annuities t6a b Taxable amount (see page 23) 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E Enclose, but do 1S Farm income or (loss). Attach Schedule F . . . . . . . . . . . . . . not attach, any 19 Unemployment compensation payment. Also. please use 20a ' Social security benefits 120a b Taxable amount (see page 251 Form 10404. 21 Other income. List type and amount (see page 25) .................................... 22 Add the amounts in the far right column for lines 7 through 21. This is your total income ? 23 IRA deduction (see page 27) 29 Adjusted 24 Student loan interest deduction (see page 27). . . . 24 Gross 25 Medical savings account deduction. Attach Form 8853 . 25 Income 28 Moving expenses. Attach Form 3903 . . . . . . 28 27 One-half of self-employment tax. Anach Schedule SE 27 EXHIBIT 28 Self-employed health insurance deduction (see page 29) 28 G 29 Self-employed SEP, SIMPLE, and qualified plans , : 29 30 Penalty on early withdrawal of savings 30 31a Alimony paid b Recipient's SSN ? 31a 32 Add 'Ines 23 through 31a . . 33 Subtract line 32 from line 22. This is your adlusted gross Income ? For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 58. Cat. No. 113208 Department of the Treasury-Internal nevenue Service U.S. Individual Income Tax Return For the year Jan. 1-Dec. 31, 2000, or other tax Year benin first name and initial name Dee Only-Do not write or 9 ,20 If n joint return, spouse's vsl 5e and Ia?l Homo atldrass (numb. sb.q have a PA bol/seia 19. Apt. no. I City, town or post office, state, and ZIP code. If you have a foreign address, see page 19 Note. Checking "Yes" will not change your tax or reduce your refund. Do you, or your spouse if filing a joint return, want $3 to go to this fund? ? 1 2 3 4 5 8a to ? Spouse c as and Be No. of your children on Be who: / • lived with you • did not live with you due to divorce or separation (sea page 20) _ Dependents on Be not entered above _ Add numbers entered on If... asses ? Form 1040 t2ooo) Form 1040 (2000) - ' Page rl Tax' and 34 Amount from line 33 (adjusted gross Income) , , , , 34 . Credits 35a Check if: ? You were 65 or older, ? Blind; ? Spouse was 65 or older, ? Blind. Add the number of boxes checked above and enter the total here . . . , ? 35a b if you are married filing separately and your spouse itemizes deductions or Standard , you were a dual-status alien, see page 31 and check here . . . . . . ? 35b ? Deduction 36 Enter your Itemized deductions from Schedule A, line 28, or standard deduction shown for Most on the loft. But see page 31 to find your standard deduction if you checked any box on 7? 9 People line 35a or 35b or if someone can claim you as a dependent . • , . . . . , , 38 5 Single; 37 Subtract line 36 from line 34 . . . . . . . . . . . . . . . . . . . 37 r?a_? $4,400 38 If line 34 Is $96,700 or less, multiply $2,800 by the total number of exemptions claimed on Head of household: Head of line 6d. If line 34 is over $96,700, see the worksheet on page 32 for the amount to enter 38 Q tic) $6,450 39 Taxable Income. Subtract line 38 from line 37. If line 38 Is more than line 37, enter -0- 39 Married filing 40 Tax (see page 32). Check if any tax is from a ? Form(s) 8814 b ? Form 4972 40 jointly or Ouallfying 41 Alternative minimum tax. Attach Farm 6251 . . . . . . . . . . . . . . 41 widow(er): $7 350 42 Add lines 40 and 41 . . . . , ? 42 , Married 43 Foreign tax credit. Attach Form 1116 if required . . . . 43 filing 44 Credit for child end dependent care expenses. Attach Ron 2441 44 $3,875 separately; 45 Credit for the elderly or the disabled. Attach Schedule R , 45 46 Education credits. Attach Foml 8863 , , , , , , , , 46 47 Child tax credit (see page 36) . . . . . . . . . . 47 U U U d 48 Adoption credit. Attach Form 8839 . . . . . . 48 49 Other, Check if from a El Form 3800 b ?] Form 8396 e ? Form 8801 d [3 Form (specify) 49 s 50 Add lines 43 through 49. These are your total credits . . . . . . . 50 51 Subtract line 50 from line 42. If line 50 is more than line 42, enter -0- , , ? 51 d 0 Oth 52 Self-employment tax. Attach Schedule BE . . . . . . . . . . . . . . . 52 er T 53 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 53 axes 54 Tax on IRAs, other retirement plans, and MSAS. Attach Form 5329 if required , . , , 54 65 Advance earned income credit payments from Form(s) W-2 , . . . . . . . , , 55 55 Household employment taxes. Attach Schedule H . . . . . . . . . 56 57 Add lines. 51 through 56. This is your total tax . P. 57 I q, d U fa Payments 58 Federal income tax withheld from Forms W-2 and 1099 . , 5a 1 ;21 2000 estimated tax payments and amount applied from 1999 return 59 Edanach you 60, Earned income credit (EIC) 61/U 80a b Nontaxable earned income: amount . ? I I I C. and type ? .................................................. 61 Excess social security and RRTA tax withheld (see page 50) 61 62 Additional child tax credit. Attach Form 8812 . . . . . 82 63 Amount paid with request for extension to file (see page 50) 83 64 Other payments. Check if from a ? Form 2439 b ? Form 4136 64 65 Add lines 58, 59, 60a, and 61 through 64. These are your total payments . ? 65 V 37, Refund 66 If line 65 is more than line 57, subtract line 57 from line 65, This is the amount you overpaid Have it 67a Amount of line 66 you want refunded to you . . . . . . . . . . . . . ? ? b Routing number ? of Account number ?c Savings Amount 69 If line 57 Is more than line 65, subtract line 65 from line 57. This is the amount you owe. You Owe For details on how to pay, see page 51 . . . . . . . . ? Sign Under penalties of perjury. I declare that I have examined this return and accompanying scnedules and statements, and to the best of my knowledge and belief, they are true, correct, and ^complete. De :Iaratlon of preparer (other than taxpaye4 is based on all information of which preparer has any knowledge. Here Your signs a \, ? 4eDate Your occupation Daytime phone number Joint "turn? / r See Page age 1 19. (f is d- q ?, ha Y^ 1 1 Keep a copy Spouse's signs re. a joint return, both must sign. Date Spouse's occupation May the IRS aiscuss the retum ash the prepare for your records. frown Oelow tsee page 5211 ? Yaa ? No Preparei a Date Preparer's SSN or PTIN Paid c -emp I signature sellff-employed ? Preparer s Pmn s name for EIN Use Only pours if self.emoioyear, Mrase. and PIP undo Phnne nn. 1 1 Form 1 U4U (2000) SCHEDULES A&B l U Schedule temized Deductions OMB No. 1545-0074 (Form 1040) ) ?ooo (Schedule B Is on back 0epnnment Inc Treasury Inlnrnnl aeveh us Sankt, 111 1- Attach to Form 1040. 1,- Sea Instructions for Schedules A and B (Form 1040). Attachment Sequonce No. 07 Name(s) oho n en Farm 7t0•t0 Your social security number S?o[YSte (. Pt ?QC<G _}? /CXi ri : I/nil Medical Caution. Do notincluJeexpenses reimbursed orpaidb ethers and 1 y . Medical and dental expenses (see page A-2) . 1 Dental 2 Enter amount from Form 1040, line 34. 12 Expenses 3 Multiply line 2 above by 7.5% (.075) . 3 4 Subtract line 3 from line 1. If line 3 is more than line 1, en ter -0 - 4 Taxes You 6 State and local income taxes 5 Paid 6 Real estate taxes (see page A-2) . . . . . . . , 6 a (See 7 Personal property taxes . . . . . . . . . 7 page A-2.) 8 . Other taxes. List type and amount ?......-- ............ 9 .............................................................. Add lines 5* throw h 8. 8 . 9 93 Interest 10 Home mortgage interest and points reported to you on Form 1098 10 You Paid 11 Home mortgage interest not reported to you on Form 1098. If paid (See to the person from whom you bought the home, see page A-3 page A-3.) and show that person's name, identifying no., and address ? ................................................................ Note. P ............................................ .................... .............,................................................... 11 ersonal interest is 12 Points not reported to you on Form 1098. See page A-3 not for special rules . . . . . . . . . . . . . . 12 deductible. 13 Investment interest. Attach Form 4952 if required. (See page A-3.) . . . . . . . . . 13 14 Add lines 10 through 13 . . 14 7;2 9 1/9" O Gifts to 15 Gifts by cash or check. If you made any gift of $250 or Charity more, see page A-4 . . . . . . . . . 15 If you made a 16 Other than by cash or check. If any gift of $250 or more gift and got a benefit for it , see page A-4. You must attach Form 8283 if over $500 16 . see page A-4. 17 Carryover from prior year . , . . , , , , . I 18 Add lines 15 throw h 17 . 18 Casualty and Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See page A-5.) . 119 Job Expenses 20 Unreimbursed employee expenses-job travel, union and Most dues, job education, etc. You must attach Form 2106 Other or 2106-EZ if required. (See page A-5.) be ............... Miscellaneous ............ Deductions .................................................... ................ 20 21 . Tax preparation fees . . . . . . . . . . . . 21 (See 22 Other expenses-investment, safe deposit box, etc. List page A-5 for type and amount ? ..... expenses to deduct here.) .................................... ................................................................ 22 23 Add lines 20 through 22 , , , 23 24 Enter amount from Farm 1040, line 34. 24 25 Multiply line 24 above by 2% (.02) . . . . . . . 25 ..ua„i ,,,,- co turn nne 4J. it ime eo is more than fine z:3, enter -0- Other 27 Other-from list on page A-6. List type and amount ? ..................... Miscellaneous .............. ............................. .................................................... Total 28 Is Form 1040, line 34, over $128,950 (over $64,475 if married filing separately)? Itemized ? No. Your deduction is not limited. Add the amounts in the far right column Deductions for lines 4 through 27. Also, enter this amount on Form 1040, line 36. . ? 28 ? Yes. Your deduction may be limited. See page A-6 for the amount to enter. For Paperwork Reduction Act Notice, see Form 1040 instructions. Cat. No. 11330X Schedule A (Form 1040) 2000 IItill Itill rtill llll1lr11llll111IIIIIII1111 SHANE A KEEBAUGH ?- 66 RUSTIC OR SHIPPENSBURG, PR 17257-9461 I6ullui1611 PAGE ALLFIRST BANK FORMERLY KNOWN AS FIRST NRTL 25 SOUTH CHARLES STREET BALTIMORE, MO 21201-3330 52-0312840 BANK OF MO EIN NUMBER IMPORTANT TAX RETURN DOCIIMENT 1-B00-533-4630 71752 FORM 1099-INT (OMB N0.1545-0112) 2000 INTEREST I N=% RETAIL-CHECKING -------------------------- 00826-9980-1-------------------------- SHANE R KEEBAUGH IN REI AITINGBNAME AUGH - INTEREST INCOME NOT INCLUDED IN ITEM 3 - EARLY WITHDRAWAL PENALTY - INTEREST ON U.S. SAVINGS BONDS B TREAS. OBLIGATIONS - FEDERAL INCOME TAX WIT IEL11 - INVESTMENT EXPENSES - FOREIGN TAX PAID - FOREIGN COUNTRY OR U.S. POSSESSION COPY B FOR RECIPIENT ------------------ IRS REPORTING TIN 199.56-1194 $5.22 $0.00 $0.00 $0.00 $0.00 $0.00 This Is Important tax Information and Is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be Imposed on you if this Income is taxable and the IRS deter. mines that it has not been reported. Instructions for Recipient Item 1: Shows interest paid to you during the calendar year by the payer. This does not include interest shown in item 3. If you receive a Farm 1099-INT for interest paid on a tax-exempt obligation, see the instructions for your income tax return. Item 2: Shows interest or principal forfeited because of early withdrawal of time savings. You may deduct this on the 'Penalty on early withdrawal of savings' line of Form 1040. Item 3: Shows interest on U.S. Savings Bonds. Treasury bills, Treasury bonds, and Treasury notes. This may or may not be all taxable. See Pub. 550, Investment Income and Expenses. This interest is exempt from state and local income taxes. This Interest Is not Included in Item 1. Item 4: Shows backup withholding. For example, persons not furnishing their taxpayer identification number to the payer be- come subject to backup withholding at a 31 % rate. See Form W.S. Request for Taxpayer Identification Number and Certification, for Information on backup withholding. Include this amount on your Income tax return as tax withheld. Item 5: Any amount shown is your share of investment expenses of a single-class REMIC. If you file Form 1040, you may deduct these expenses on the 'Other expenses' line of Schedule A (Form 1040) subject to the 2% limit. This amount is included in Item I. Item 6: Shows foreign tax paid. You may be able to claim this tax as a deduction or a credit on your Form 1040. See your Form 1040 instructions. Nominees: If this form includes amounts belonging to another person, you are considered a nominee recipient. You must file Form 1099-INT for each of the other owners showing the income allocable to each. You must also furnish a Form 1099-INT to each of the other owners. File Formis) 1099-INT with Form 1096, Annual Summary and Transmittal of U.S. Information Returns, with the Internal Revenue Service Center for your area. On each Form 1099-INT, list yourself as the 'payer' and the other owner as the 'recipient.' On Form 1096, list yourself as the *filer.' A husband or wife is not required to file a nominee return to show amounts owned by the other. INCOME AND EXPENSE STATEMENT OF SHANE. A. KEEBAUGH Employer: Exel Logistics Address: 6 Daughton Road, New Kingston, PA Type of Work: Forklift Operator Payroll #: D081707 Pay Period: Weekly (Weekly, Bi-weekly, etc.) GROSS PAY PER PAY PERIOD: 540.00 Itemized Payroll Deductions: Federal Withholding: 41.85 Social Security: 31.91 Medicare: $ 7.46 Local Wage Tax: 5.40 State Income Tax: 14.41 Unemployment Tax: $ Retirement: 5 Savings Bonds: S Credit Union: 5 Life Insurance: 5 Health Insurance: S 25.40 Other: (specify) Child Support: 5 123.93 NET PAY PER PAY PERIOD: S 288.54 OTHER INCOME: Week Month Year Interest. S S Dividends: 5 S 5 Pension: $ S Annuity: 5 S S Social Security: $ $ $ Rents: $ 5 $ Royalties: $ $ $ Expense Account: $ $ Unemployment Comp.: 5 $ $ Workmen's Comp.: 5 5 TOTAL OTHER INCOME: $ , TOTAL MONTHLY NET INCOME $1,250.34 $ EXHIBIT EXPENSES HOME: Week 1v Monthly Yearly Mortgage/rent $ $574.00 $ Maintenance $ 30.00 $ Repairs $ $ $ UTILITIES: Electric $ 60.00 $ Gas $_ 100.00 $ Oil $ $ $ Telephone _ 65.00 $ Water $ 25.00 $ Sewer $ 5 Q EMPLOYMENT: Public Transportation Lunch TAXES: Real Estate $ 50.00 Personal Property $ Income $ $ S INSURANCE: HomeownersS 35.00 $ Automobile $ 48.83 $ Life $ Pavroll deduction $ Accident $ $ $ Health $ Pavroll deduction S Other $ 5 _ $ AUTOMOBILE: Payments $ $ $ Fuel $ 80.00 $ Repairs $ 30.00 $ Maintenance $ 10.00 $ Licenses $ 3.00 $ Registration $ 3.00 $ Auto Club $ S MEDICAL: Weekly Monthly Yearly Doctor $ 30.00 $ Dentist 100.00 $ Orthodontist $ $ $ Hospital $_ 20.00 $ Medicine $ $ $ Special needs (Glasses, braces, orthopedic devices, etc.) $ $ $ EDUCATION: Private School $ $ $ Parochial School $ $ $ College $ $ $ Religious $ $ $ School Lunches $ $ $ Books/Misc. - $ 5 PERSONAL: Clothing 5- 80.00 $ Food $- 140.00 $ Barber/ Hairdresser $_ 20.00 $ Personal care 3 $ $ Laundry dry cleaning Hobbies S Memberships S 5 CREDIT PAYMENTS: Credit card B 35.00 $ Charge account S S $ LOANS OR DEBTS Credit Union Bank MISCELLANEOUS Household help $ $ Child care $ $ $ Camp $ $ $ Petexpense 20.00 $ Papers/books/magazines 3 $ $ Entertainment $ $ $ Pay TV $ ' 38.00 $ MISCELLANEOUS (Cont.) Vacation Gifts Legal fees Charitable Contributions Religious Memberships Children's allowances Other Child Support Alimony payments Lessons for children OTHER: TOTAL EXPENSES: Weekly Monthly Yearly $- 35.00 $ S 60.00 $ $- 43.33 $- $ Payroll Deduction $ WeeTkly Monthly Yearly $- $1,735.16 $ CONSECO FINANCE 500 LANDMARK TOWERS, 345 ST. PErER STREET ST.,PADL, &11f1AIESOTA 55102-1641 LYhere To Send Your Payment: CONSECO FINANCE PO Boa 17235 BSllimore. Me 212971235 VµV^ MII?; Shane A. Keebaugh 66 Rustic Dr Shippensburg PA 17257-9461 u" ea C0NSF.C0, MONTHLY BILLING STATEMENT 73 Account Information: Statement Date: 1-16.01 Account Number: 733220859 Year To Date Interest Paid: 363.89 next Payment Due:Datee 2-10.01 Current Payment: 363,89 Past Due Payment 011' Billed Late Charges: 100: Insurance: pp Misc,'Charges: 00; Total. Amount Due: $363:89 Itt$[III if 111111111 111, n 111 its l I l l I I I I l l l t l I I l 1111111,1111111 Customer Service: Phone 1.800.643.0202 Correspondence Address Please see the hack of this form for address. Important Messages Account Information Since Last Statement I Account reflects transactions posted ar of 1.76-0Y INSURANCE Date Read Prau$al Interest Late Charges PhrkalDamage Lifer10sa6R4 Other ffmDarges AddrlPrm R 116.01 .00 36139 .00 DO co ..00 .00 12•119•00 .00 36139 .DC .DC .DO .00 ,0D PAYER'S (inst. mlaale. 'asq • The .moan, mown may not be • ,¢ r haneA. ,. S Keebau h 9 73 F Irv deductible by You an your fio Rustle or Lt. r7a , to Me et. on t be cost and n .. - cue ar t secured Indoorry may Shippensburg PA 17257-9461 .00411.3 1".. .yoU may only deduct n amaun, al mort a t• g ge mlenll ,0 Ib aMml it Wy in.urrq by You, ac:U It Pam by Yau, and Y. FEC:F'E.\irs Feoeral (denunciation no. PAYEa'J weal security numcer tea, reimbours M oy another aersan. 1 Vanaage interest received tram oavenslloa m rw GLENOAR YE 41-1796066 199-6"-11?4 erysr IS 53 779 04 AR REOIPIENTS name, street. actress, city, state, and P ccce 2 . . 2000 CpNSeCO FINANCE Points $.00 The Intarmnwn in ees t b do Content tea imarmlwn SCO LanZmark Towers and n burp wmuhad to lho nl.rnu A.y.na. s.rvk,, to SL Paul, Minnesota 65102 u an ,enured to file a 'Yo etum, a npligence penalty or inner landUan wnl W PHONE NO. 1-2C0-643-0202 IIn= on you it the IRs aae.mmn ,IT an SIT . Myment of Ica le.ulls Ac::unt numcer 733220669 cause you fall" to b e omy mew tole am0unl an your plum. Instructions for Payer16orrower Pnnen Including a 11nmc331 ;ns,itudan, a Imernmenral unit, and a <edoermrva nausmg caroanuonl who n lnlflu ea in a trace or auamess and h the tours! al "cacti hate v business, "coned train you at 'east S600 of monq.ga muresl on anY one mangage ? m! CCllna0, 7e81 mast Morino, :his slaremenl to YOU. OIMar So I Me mlte" rlo .na"aCt1O, to, in.. T IrlSl.nt Wise IOrmen an 101 Ins *,he, borrOwen Wh mlormtion about I" or...I dlslnbuln n 01 the a ni unu snow" an Inns arm, 6"n oalwwer n lmNw to d"uct anm the amount he ar sole oaro that rehrnlm, nle sr 1., share it 'no amOonl 3110waote as . monc.ge rnllle9r deduction. It your mnrrgage assonant, wua xuosaved oy a aayernmer, uph-cy, you they at ae True to ueduct no amount 01 the tuonay. NNN eEFINITICN OF. This ealenaar year, In ueoartment at the Treasury • Internal Revenue Service S. tahowa the mrutgege interest recalled by In• Interest ,etl0len, during the "Sr. This amount includes interest an any obligation (including a home pony, IIM It Credit, 01 Credit Card loam secured by real "oawtI. This amount doe. Col include con.u. gOVOmrIMI suCfwy Payhol ar style, o•ymmol an a •buyEo hn• mongede. sued amounts 0 deductible by you only in cemmn crmumnancos. caution: or Au .redald 7nlnOr M fill, Connor J•u Ina, .could in run by lanuarv IQ turn )car, and Conscious, ins ff m0 ea "Chun" rte 3" 1. Howevon. on in0ugn 'tie Oresund amount may os inClYded in eery 1, rou cannot awucr me 01•vud amount m old c.An air n.,. Far mOn inlolmatbn, M, Pu0. 54. Interest ExiI It You can harm Ina mangaga Im 11. sons I" pen, Manq.q. Interest colon. It the m,., H1 n. O.w 0n a mgr (rIdeal, n may be fuolect to a deduction IimTell on. S. pysJI8sr? (Far. GGAArf1I ,1 eta 2.Thq 0aa is tar 11e 0V the m,nrn.I recmunt (a lurmen rear vaNU Ides, ar lnmrancs dam som escrow. 3 a the ".r Panted on in, to,. or inn ,Mm. REAGER & ADL.ER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL. PENNSYLVANIA 17011-4642 717.763-1383 TELEFAX 717.730.7366 WEBSITE: ReagerAdlerPC.com THEODORE A. ADLER + DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENICLE DEBRA DENISON CANTOR WrIer's E-Mall Address; 1clough0epix.net THOMAS O. WILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH PETER L. LEONE +Cenilled Tdal Specialist May 18, 2001 Special Master E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Stephanie A. Keebaugh v. Shane A. Keebaugh No. 99-4843 Dear Master Elicker: Please be advised that I have reviewed your correspondence of April 23, 2001 and the transcript of April 20, 2001, which specifically sets forth the terms of the settlement agreement reached in the above-reference divorce action. Please forward the original to my office for Stephanie Keebaugh's and my signature and I will forward the same to defense counsel, Doug Roeder for signature by him and the defendant, Shane Keebaugh. I thank you for your attention and assistance in reP Iving this matter. Sincerely, 'U JHC/ak cc: Douglas Roeder, Esquire Stephanie Keebaugh REICHARD-LAW OFFICES, LLC &torneys and Colmsclors at Law http://www.r,lichord•pcn=ar.com 2025 East Main Street P. O. Box 8 D. L. Reichard, II Esquire Waynesboro, PA 17268 Douglas R. Roeder, Esquirc 717. Eric J. Wcubrod, Esquirc 0 -7d2.8862.8800 Fax: 717 Carrie M. Bowmmtcr, Esquirc Shelva J. Barton, ORice Manager Terri L. Harbaugh, Paralegal The Fort Chambers Building Kathy A. Barnhart, Legal Assistant 70 West King St., Suite Chambersburg, PA 17201 717.267.2288 FAX.717.267.1151 June 7, 2001 E. Robert Elicker,.ll Divorce Master Cumberland County Court House Center Square Carlisle, PA 17013 RE: Keebaugh v. Keebaugh No. 99-4843 Dear Mr, Elicker: We received a call from Tracey whom, I assume, is a court reporter, this date inquiring as to the status of the above-captioned action. On May 15, 2001, we forwarded a letter and stipulation to Mrs. Keebaugh's counsel, Joanne H. Clough, and have not had a response. On another matter, the bill for the transcription in the above case for 512.50 evidently has been misplaced. Could you please send another bill, and we will take care of it. Thank you. Very ruly yours, Kathy A. Brnhart, Legal Asst. Reichard Law Offices, LLC STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - 4843 CIVIL SHANE A. KEEBAUGH, Defendant IN DIVORCE ORDER OF COURT AND NOW, this •'9)y' day of , 2001, the parties having previously been di rced by decree entered June 10, 2000, and the parties and counsel having entered into an agreement and stipulation resolving the economic issues on April 20, 2001, the date set for a four-party conference, the agreement and stipulation having been transcribed and subsequently signed by the parties and counsel, the appointment of the Master is vacated. cc: Joanne H. Clough Attorney for Plaintiff Douglas R. Roeder Attorney for Defendant BY THE COURT, AN A Geo g o P V C Lz9 STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - 4843 CIVIL SHANE A. KEEBAUGH, Defendant IN DIVORCE THE MASTER: Today is Friday, April 20, 2001. This is the date set for a conference with counsel and the parties to discuss the outstanding economic claim of equitable distribution raised in the complaint. Present in the hearing room are the Plaintiff, Stephanie A. Keebaugh, and her counsel Joanne H. Clough, and the Defendant, Shane A. Keebaugh, and his counsel Douglas R. Roeder. The parties were divorced by decree entered by President Judge George E. Hoffer on June 10, 2001. The matter before the Master involves the distribution of the marital estate and any allocation of debt that the parties incurred during the marriage. The Master has been advised that the parties, after negotiations, have reached an agreement with respect to the claim of equitable distribution. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of `i^ typographical errors which may be during the transcription. The agreement is going to be transcribed and sent to counsel to review for typographical errors. The corrections will be made, if any, and then the parties and counsel will be asked to sign the agreement affirming the terms of settlement as stated on the record at this time. When the parties leave this hearing room today they will be bound by the terms of the agreement, even though there has been no signing of the agreement affirming the terms of settlement. After the Master has been provided a completed agreement, he will prepare an order vacating his appointment and the matters pending before the Court in the divorce proceedings will be considered concluded. Ms. Clough. MS. CLOUGH: The parties have reached an agreement to equitably divide the marital property in this case as follows: 1. The 1997 double-wide mobile home purchased during the marriage shall be awarded to husband. Husband shall be responsible to indemnify wife and hold her harmless on any debt or lien obligation thereon. Husband further is obligated to apply to refinance the debt on the mobile home to remove wife as an obligor thereon once a year until such time as he is able to sucessfully obtain refinancing. Husband further agrees to make the payments on the debt on a timely fashion such that there is no delinquency. In the event of a deficiency in payment by husband on the obligation on the debt on the mobile home which results in a foreclose or sale with a deficiency still due on the balance on said debt obligation, then said debt deficiency shall be the sole and exclusive responsibility of husband as will any foreclosure or other debt collection costs on said obligation. 2. Husband shall be awarded the 1993 Toyota Corolla automobile. Wife agrees to execute a title document transferring any and all interest she has in said vehicle solely to husband. Husband shall provide title documents to wife via counsel for the purpose of transferring wife's interest in said vehicle to husband. 3. The parties acknowledge that husband has a pension with Exel Logistics in the form of a 401(k) plan that had a separation balance of $11,473.57. The parties further acknowledge that a significant portion of this pension was acquired during the marriage and prior to separation. Husband and wife agree that in consideration of husband transferring $4,200.00 from said 401(k) to wife, wife agrees to waive any further right, title, or claim she may have whatsoever to the pension with Exel Logistics. The parties further agree that this transfer shall be pursuant to a QDRO and in accordance with any further requirements of Exel Logistics to effect said transfer. Wife's counsel will be responsible for preparing any Domestic Relations orders necessary to transfer the funds from husband's pension account to an account for wife. There will be no tax consequences to either party as a result of this transfer since the roll over to wife will be into a qualified account. 4. The parties do further acknowledge that any property currently in the possession of wife shall remain the sole and exclusive property of wife and any property currently in the possession of husband shall remain the sole and exclusive property of husband except as otherwise provided in this agreement. 5. Husband and ,aife both acknowledge there was no spousal support being paid to the Plaintiff and there was no alimony pendente lite being paid during the pendency of the Court retaining jurisdiction on these economic issues and that no alimony pendente lite will be paid in this case. It is further agreed that there are no additional costs that are to be paid by either party to the Court with reference to these proceedings. 6. Husband and wife both agree to cooperate fully in executing any documents that may be necessary to give effect to the terms and provisions of this agreement. THE MASTER: Ms. Keebaugh, have you been present during the statement of the agreement on the record? MS. KEEBAUGH: Yes. THE MASTER: Do you understand the agreement as stated on the record? MS. KEEBAUGH: Yes. THE MASTER: And do you understand that this will conclude all ou-standing economic claims in your case and that you are bound by the terms of this agreement even though it is not subsequently signed? MS. KEEBAUGH: Yes. THE MASTER: Mr. Keebaugh, were you present during the statement of the agreement? MR. KEEBAUGH: Yes, sir. THE MASTER: Do you understand it? MR. KEEBAUGH: Yes. THE MASTER: Do you lave any questions about it? RIR. KEEBA??CH: No, sir. THE MASTER: Do you understand that you are bound by the terms of the agreement even though it is not subsequently signed by either you or your wife? MR. KEEBAUGH: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. W ITM;SS : DATE: --ul 6 /0 1 ?I?Mu AAAJ Jo nne H. Cloug Ste hanie A. Keebau g Attorney for P 'ntiff ?. ?fiti S' /S- 6 Dougl's R. Roeder ?--S ane A. Keebau h Attorney for Defendant EBEL-E9L ULLI EV917-LLOLL Vd'IIIH dWVO 133H1S 13HHVW LEEZ MVl 1V SA3NH011V '04 '831OV 19 H3E)V3H -D :J --I Z .:J1 u. O (V CD U STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. SHANE A. KEEBAUGH, : IN DIVORCE Defendant : NO. 99-4843 CIVIL RULE TO SHOW CAUSE r? AND NOW, this O?.tfAl1 ?? day of 2002, upon review of the attached Petition to Enforce Settlement Agreement and Petition For Contempt, a Rule is issued against Respondent Husband Shane A. Keebaugh to show cause, if any, why the Petition to Enforce Settlement Agreement and Petition For Contempt should not be granted. Rule returnable within I Zg?days of date of service. 1?,V4 V .1 4 STEPHANIE A. KEEBAUGH, Plaintiff V. SHANE A. KEEBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE NO. 99-4843 CIVIL PETITION TO ENFORCE SETTLEMENT AGREEMENT AND PETITION FOR CONTEMPT 1. Stephanie A. Keebaugh Petitioner Wife and Respondent Husband Shane A. Keebaugh were divorced in a bifurcated divorce on June 10, 2001. On April 20, 2001 the parties entered into a Comprehensive Property Settlement Agreement specifically providing for the equitable distribution of the parties martial assets. Said Settlement Agreement was transcribed on record before Special Master Robert Elicker. Paragraph 3 of said Agreement specifically provided that $4,200.00 of Respondent Husband's 401(k) plan with Exel was to be distributed to wife pursuant to a Qualified Domestic Relations Order provided and further provided wife's counsel was responsible to prepare the Domestic Relations Order to transfer said funds. 3. Paragraph 6 of said Settlement specifically provided that husband agreed to cooperate fully in the executing of any documents that may be necessary to give effect to the terms and provisions of the Agreement. 4. Since April 20, 2001 counsel for Petitioner Wife, through counsel, has repeatedly requested Respondent to provide the contact information for his 401(k) pension plan to her so that she could contact the plan administrator and obtain sample QDRO forms or other necessary documents to correctly draft the QDRO Order to effect the transfer of $4,200.00 from Respondent's 401(k) account to Petitioner Wife. 5. Despite Petitioner's repeated requests for the information, Respondent has failed to provide any information to date. 6. Respondent has breached the terms of the parties' Settlement Agreement by failing to cooperate in the distribution of the pension funds from his 401(k) plan to wife in direct violation of the terms of the equitable distribution settlement agreement. 7. As a result of Respondent's failure to abide by the terms of the Settlement Agreement, Petitioner has incurred counsel fees, costs and expenses in pursuing the enforcement of the Settlement Agreement and claim is made therefore. WHEREFORE, Petitioner Stephanie Keebaugh respectfully requests the Honorable Court to find that Respondent Husband is in violation of the Settlement Agreement entered into by the parties for the equitable distribution of the marital portion of the Respondent Husband's 401(k) and direct him to immediately provide the necessary information and execute any documents necessary to effect the transfer of said 401(k) monies to wife and further direct Respondent to pay all of Petitioner's reasonable counsel fees, costs and expenses incurred in her pursuit of her rights to receive these monies under the terms of the parties Settlement Agreement and grant ever other relief this court deems appropriate. Respectfully submitted, REAGER & ADLER, Date: o t By: ID #36461 2331 Market Street Camp Hill, PA 1701 717-763-1383 Attorney for Petitior Esquire 2 CERTIFICATE OF SERVICE 1 hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individual via United States First Class Mail, postage prepaid as follows: Shane A. Keebaugh c/o Douglas R. Roeder, Esquire D.L. REICHARD, II & ASSOCIATES 70 West King Street, Suite B Chambersburg, PA 17201 Dated: I Z i i I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHANIE A. KEEBAUGH, PLAINTIFF CIVIL ACTION-LAW -vs- NO. 99-4843-CIVIL SHANE A. KEEBAUGH, DEFENDANT IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ' l day of 1?hr'WAI f 2002, I, Douglas R. Roeder, Esquire, do hereby certify that I have served the Defendant's/Respondent's Answer to Rule to Show Cause on Petition to Enforce Settlement Agreement and Petition for Contempt in the above-captioned matter on the following person: Joanne Harrison Clough, Esquire REAGER & ADLER, PC 2331 Market Street Camp Hill, PA 17011-4642 DouRoed, Esquire Attorney for Defendant l- ? ?,r_ 1 ^' u REICHARD LAW OFFICES, LLc. 2025 E. Main Rtreet F • The Forts hamlkta Bldg i ._. Poet Office Box 8 " 70 W. King Street, Suite B Waynesboro, PA 17268 Chambersburg, PA 17201 717.762.1131 717.267.2288 FAX 717.762. WW FAX 717.267.1151 D.L. REICHARD, 11 & ASSOCIATES BY: DOUGLAS R. ROEDER, ESQUIRE Attorney I.D. No. 80016 70 West King Street, Suite B Chambersburg, PA 17201 Phone: (717) 267-2288 Attorneys for Defendant a STEPHANIE A. KEEBAUGH, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-4843 CIVIL SHANE A. KEEBAUGH, Defendant CIVIL ACTION - LAW IN DIVORCE AND PETITION FOR CONTEMPT NOW COMES, Shane A. Keebaugh, by and through his attorneys, Reichard Law Offices, LLC and answers the Plaintiff's Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. Petitioner, has not "repeatedly requested" Respondent to provide contact information. Moreover, Petitioner's Counsel has now received such requested contact information. By way of explanation, In July of 2001, the Petitioner contacted Respondent through Counsel regarding obtaining information necessary to complete a Qualified Domestic Relations Order (QDRO). The Respondent was uncertain of how to obtain such information and did not respond. Through his undersigned counsel, Respondent received a letter from Petitioner's Counsel dated December 28, 2001 requesting information necessary to complete a QDRO, which Respondent inquired about to his undersigned counsel and by way of letter dated January 9, 2002 Respondent provided all information that he could gather in order to facilitate the preparation of a QDRO. Respondent's Counsel has also requested that Petitioner's Counsel contact him should any additional information be required. No request for additional information has been forth coming as of this date. 5. Denied. As state above, by way of correspondence sent January 9, 2002 Respondent sent all available information pertaining to preparing a QDRO to the Petitioner. 6. Denied. The Respondent has provided all of the requested information that he could obtain and thus has not breached the terms of the parties' settlement agreement. 7. Denied. As set forth above, the Respondent provided the necessary information and any counsel fees, costs, and expenses need not have been incurred. WHEREFORE, Respondent respectfully requests that this Honorable Court dismiss the Petitioner's Petition. Respectfully submitted, Reichard Law Offices, LLC Douglas R. Roeder, Esquire ID #80016 70 West King Street, Suite B Chambersburg, PA 17201 (717) 267-2288 Attorney for Defendant/Respondent VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING ANSWER TO RULE TO SHOW CAUSE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES Date: t' Zti..?JN"' Shane A. K - .-• ?- -= -- ?:i ':'? t- _, ESEL"ESL UW MIP-LLOLL Vd'IIIH dWV3 133F11S 13HHVW LEEL MVI iV SA3NHO11V 'Od 'H31OV R W30V3H . , NPR 2 6 2002 A019, 2002 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEPHANIE A. KEEBAUGH, Plaintiff V. SHANE A. KEEBAUGH, Defendant 1n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE NO. 99-4843 CIVIL QUALIFIED DOMESTIC RELATIONS ORDER THIS CAUSE coming on to be heard for the purpose of entry of a Qualified Domestic Relations Order as defined in 26 U.S.C. Section 414(p); the court on April 20, 2001, having entered a final settlement agreement relating to the provision of marital property rights of a former spouse of the Participant; THE COURT FINDS AND IT IS HEREBY ORDERED AS FOLLOWS: A. For purposes of this Order, the tern "Participant" means Shane A. Keebaugh, an employee of Exel Logistics; the term "Alternate Payee" means Stephanie A. Keebaugh; the term'Plan" means Exel Retirement and Savings Plan; the tern "Account Balance" means the balance the Participant had credited to his account under the Plan; and the term `Benefits Cormuittee' means the Benefits Conunittee of the Exel Retirement and Savings Plan. B. On April 20, 2001, the parties entered a Final Settlement Agreement of Record, which Agreement relates to the provision of the marital property rights of Alternate Payee, as the former spouse of the Participant. C. The last known mailing address of the Participant is 66 Rustic Drive, Shippensburg, Pennsylvania 17257. The date of birth of the Participant is 6/22168, and his Social Security Number is 199-56-1194. ApA19,2002 D. The last known mailing address of the Alternate Payee is 44 Montgomery Avenue, Shippensburg, Pennsylvania 17257. The date of birth of the Alternate Payee is 4112/73, and her Social Security Number is 208-54-3033. E. The Plan Administrator is Bob Kolp of Exel with an address of 501 W. Schrock Road, Westerville, OH 43081 F. The Participant and the Alternate Payee were married on 6/29/92, and said marriage is registered in Cumberland County, Pennsylvania. G. Under the terms of the Agreement of Record, the Alternate Payee is to receive payment from the Plan in the amount of $4,200.00 from the Participant's vested account balance. H. The portion of the Account Balance payable to tite Altemate Payee (1) shall be segregated for accounting purposes under the Plan, and (2) shall not be credited or debited with any earnings or losses attributable to such segregated account calculated through the valuation date immediately preceding the date of distribution. I. Nothing in this Order shall: (1) require the Plan to provide any type or form of benefit, or option, not otherwise provided in the Plan; or (2) require the payment of benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a qualified domestic relations order. Both the Participant and the Alternate Payee shall have the duty to notify the Benefits Committee in writing of any changes in his or her respective mailing addresses subsequent to the entry of this Order. April 9,2W2 K. The Court retains jurisdiction to establish or maintain this Order as a qualified domestic relations order; provided, however, no amendment of this Order shall contain a requirement with respect to the Plan of a type described in Paragraph I above. DATED this day of2002. JUDGE `lr Approved as to form and content: Jo son CIO g , Esquire Attorney for the Peti ' ner (4o,,L ?, L__ Douglas R. Roeder, Esquire Attorney for the Respondent