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HomeMy WebLinkAbout01-0329 FXNANCY J. DEEDS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. Civil 0E-.32? WILLIAM P. DEEDS, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PENNSYLVANIA 17013. IF YOU DO NOT WISH TO FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOUR SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 240-6200 I' NANCY J. DEEDS, Plaintiff VS. WILLIAM P. DEEDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-3.29 CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I DIVORCE 1. Plaintiff is Nancy J. Deeds, who currently resides at 4901-B Wynnewood Road, Harrisburg, Dauphin County, Pennsylvania 17109 since June 1998. Plaintiff's Social Security Number is 176-34-8580. 2. Defendant is William P. Deeds, who currently resides at P.O. Box 264, Grantham, Cumberland County, Pennsylvania 17027 since 1983. Defendant's Social Security Number is 202-12-3741. .,,, 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 14, 1986, in Dauphin County, Pennsylvania. 5. The Plaintiff and Defendant separated on or about July 11, 1998.and have lived separate and apart since that date. 6. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. The Defendant is not a member of the Armed Services of the United States or any of its allies. 10. The Plaintiff and Defendant are both citizens of the United States. 11. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II ALIMONY 12. Paragraphs one through eleven are hereby incorporated by reference herein. 13. Plaintiff is unable to adequately support herself through appropriate employment. 14. Plaintiff lacks sufficient property, including but not limited to, any property distributed pursuant to the Divorce Code of 1980, as amended, to provide for her reasonable needs. WHEREFORE, Plaintiff prays that Your Honorable Court grant an order upon Defendant: (a) Compelling the Defendant to pay alimony to Plaintiff; COUNT III ALIMONY PENDENTE LITE, COUNSEL FEES AND COSTS 15. Paragraphs one through eleven are hereby incorporated by reference herein. 16. That by reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 17. That the Plaintiff's income is disproportionately lower than Defendant's income, and Plaintiff is without adequate funds to pay the costs and expenses of this litigation, and is, likewise, without adequate funds to maintain herself during the pendency of the litigation. 18. The Plaintiff is employed at Miller's Capital Insurance Company and earns approximately $694.00 net bi-weekly. 19. The Defendant is retired and is also employed part time at R.T. Dunn Insurance. Defendant's income is unknown to Plaintiff. Plaintiff prays that Your Honorable Court grant an order upon Defendant to pay Plaintiff alimony pendente lite and counsel fees and costs of litigation. COUNT IV EQUITABLE DISTRIBUTION 20. Paragraphs one through eleven are hereby incorporated by reference herein. 21. Plaintiff states that Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. 22. Plaintiff requests that this court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; (b) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Lor' erratelli, Esquire SER TELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statement made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ., Ja - U COMMONWEALTH OF PENNSYLVANIA H 105.157 REV, B80 DEPARTMENT OF HEALTH VITAL RECORDS RECORD OF STATE FILE NUMBER DIVORCE OR ANNULMENT COUNTY STATE FILE DATE CUMBERLAND O (CHECK ONE) ? SSN: 202-12-3741 HUSBAND i. NAME /First) (Middle) Last 2. DATE Month (DO)"i 'y ear WILLIAM PARKS DEEDS 07 - 28 - 28 BIRTH 2, RESIDENCE Street or R.D. City. BO(e. or Twp. County state 4. PLACE (State or orefgn untry Box 264 Grantham P O Cumberland Co.,L PA F Pennsylvania , , , . B 5. NUMBER 6. RACE ], USUAL OCCUPATION OF THIS 2 WHITE BLACK OTHEf(Spa cit yl I0 I Retired MARRIAGE SSN: 176-34-8580 WIFE & MAIDEN NAME (First) (Middle) (Last) 9. DATE (Month) DaYI Year KURTZ NANCY JANE DEEDS 03 - 24 - 42 81flTH 10. RESIDENCE Street or R.D. City BOro, or TWp. County State 11. PLACE (State or Foreign Country) 4901-B '-?Wvnnewood Road, Harrisburq, Dauphin Co., PA °F Pennsylvania 12, NUMBER 13. RACE WHITE BLACK OTHER (Specifyf 14. OCCUPATION O F THIS 2 IN ? ? Secretary /Tran scriptionist MqRRIAG gGE 15. PLACE OF /County) (State or Foreign Country) 16. DATE OF (Month) (Day) Year) OF THIS MARRIAGE Dauphin ia THIS 06 . - 14 - 86 MARRIAGE 17A. NUMBER OF CHIL 1]B. NUMBER OF DEPE iq O CREE DREN THIS OREN UNDER 18 n HUSBAND OTHER /Specify / HU58 AND WIFE OTHER (Specify) MARRIAGE 0 ? IPjJ(y eu. -- - HUSBAND WIFE SPLIT CUSTODY OTHER (Specify) 2 1. LEGAL GROUNDS FOR CHILDREN TO ? ? ? ? DIVORCE OR ANNULMENT CUSTODY OF Irretrievable Breakdown/3301 (d) 22. DATE OF DECREE (MOothl (Day/ (year) 23. DATE REPORT SENT (Month/ /Day) Year TO VITAL RECORDS 24, SIGNATURE OF TRANSCRIBING CLERK y'. C NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01 -,3?f C;(,t , G? WILLIAM P. DEEDS, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 OF 1. The parties to this action separated on or about July 11, 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning spousal support, alimony, division of marital property, attorney's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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 Dated: / -/.;? -U 1 NANCY J. DEEDS, Plaintiff vs. WILLIAM P. DEEDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 01-329 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, Esquire, being duly sworn according to law, depose and say that I served the Divorce Complaint and Notice to the Defendant/Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code in the above-captioned matter, by depositing it in the United States mail, Certified Mail, Restricted Delivery, Return Receipt Requested, addressed as follows: William P. Deeds P.O. Box 264 Grantham, PA 17027 The return receipt card is attached hereto. Dated: ? b/ Sworn and Subscribed to before me this ??day 2001. C r Lori erratelli, Esquire SE TELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9483 (717) 540-9170 Attorney for Plaintiff "vd Z ZODZ My Com fission this public Amy Rebecca road, Mary SusqueharmaTWP• ;Dauphin County ..:. n.....?,??e?,.? VX61res Sect. 2, 2012 ru S Postage $ 76 p Certified Fee ?.y V r ru Return Receipt Fee (Endorsement Required) /r S Postmark Here C3 (E domemmen R q Fee v 0 Total Postage & Fees $ / 36 n 111t . I7 C34 R?Ipeiat<k mele?asejtlnt Cl )(ttrb gFetl ymeller) 4 O o h1?_ . N.. Sf L N P ox No ... -_ ___._. . cL.! _ _ .?-- . r . - C efe, ZIP+4 _... ___ .... 4 ........... d? T O 3 rm S n c 3 9 n m a S ? v N N J W SERVICE OF DIVORCE COMPLAINT AND NOTICE TO DEFENDANT AND PLAINTIFF'S AFFIDAVIT UNDER 3301(D) NANCY J. DEEDS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 01-329 CIVIL TERM WILLIAM P. DEEDS, IN DIVORCE Defendant(Respondent DR# 30,408 Pacses# 826103027 ORDER OF COURT AND NOW, this 31" day of January, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on February 20, 2001 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are farther ordered to bring to the conference (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Miul,popips op Petitioner k Ul tai < Respondent Lori Serratelli, Esquire Date of Order: February 1, 2001 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND~ REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Cn rr. Z << G7 CCi - i 7D C : n NANCY J. DEEDS, IN THE COURT OF COMMON PLEAS OF PlaintifflPetitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 01-329 CIVIL TERM WILLIAM P. DEEDS, IN DIVORCE Defendant/Respondent DR# 30408 Pacses# 826103027 ORDER OF COURT NOTICE OF RESCHEDULED CONFERENCE AND NOW, this 21'` day of February, 2001, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on March 22.2001 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail: copies on Petitioner 2-21-01 to: < Respondent Lori Serratelli, Esquire Timothy Colgan, Esquire Date of Order: February 21, 2001 R. Shadday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 C-I 1 tit .. iPRfry _.rt&R?-x ?:F b'af a+ee??midwSAaNSrr?w 3?pag, ??:' e DR 30408 PACSES ID 826103027 NANCY J. DEEDS, Plaintiff/Petitioner Vs. WILLIAM P. DEEDS, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - LAW NO. 01-329 CIVIL TERM ORDER OF COURT AND NOW, this 22"d day of March, 2001, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,541.13 per month and Respondent's monthly net income/earning capacity is $3,815.67 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $910.00 per month payable monthly as follows; $910.00 per month for alimony pendente lite and $0.00 on arrears. First payment due on or before April 17, 2001. Arrears set at $0.00 as of March 22, 2001. The effective date of the order is April 17, 2001. The Effective date is based upon the fact that Husband will pay a total of $2,625.00 to Wife, directly, within five days of this date. This sum represents a retroactive arrearage from the date of filing of January 17, 2001. Wife is to report to the Domestic Relations Section that she has received said sum. Thereafter, the montly amount of APL is to be paid on or before the 17th day of each month. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Nancy Deeds. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 i Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either parry files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday Mailed copies on 3 11? D/ to: < Petitioner Respondent Lori Serratelli, Esquire Timothy Colgan, Esquire BY THE COURT, C _ 3 T, Jj -n I? l: V , N __ ^ y C: .. 4 I I 4 NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No.: 01-329 Civil WILLIAM P. DEEDS, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 Plaintiff. Nancy J. Deeds certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served; (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate; (3) no objection to the subpoena has been received; and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: r7- 1 -02' I //? n n „ 0, Lori K/Seh-dtelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road, Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant deb/subpo a NANCY J. DEEDS, Plaintiff VS. WILLIAM P. DEEDS, Defendant To: William P. Deeds c/o Timothy J. Colgan, Esquire 1 South Baltimore Street Dillsburg, PA 17019 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No.: 01-329 Civil : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Nancy J. Deeds (Plaintiff) intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. '?. Dated: bl "/ F " 0 Z-- Lori K../ e elli Attoryiey for Plaintiff NANCY J. DEEDS, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Plaintiff V. WTLTI M P. DEEDS, File No. Defendant 01-329 Civil SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: PNC Bank, 130 Old York Road, New Clnnberland, PA 17070 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Attached SERRATFLLI, SCHIMVIAN, BROWN & CALHOON at Attn: Lori K. Serratelli, Esq., 2080 Linglestown Road, Suite 201, Harrisburg, PA 17110 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name Lori K. Serratelli, Esq. Address: 2080 Linglestown Road Suite 201 Harri aburcr PA 17110 Telephone: (717) 540-9170 Supreme Court ID # 27426 Attorney For.. Plaintiff Date: jd.,La.?e /6? Seal of the C rt BY THE COURT: Prothonotary/Clerk, Division Deputy (Eff. 7/97) Attachment to Subpoena (PNC Bank): In conjunction with Mortgage/Home Equity Line of Credit in which you are named Lender and William P. Deeds is named Creditor, Account #4001008011720024 or any other account number, dated September, 1998, please provide any and all appraisals which were secured by PNC for said transaction. C ) am- _-1 m 1 c 2 fn T o C.s S m ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennslivania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/16/03 Tribunal/Case Number (See Addendum for case summary) EmployerNVithholder's Federal EIN Number NATIONWIDE LIFE INSURANCE CO C/O OF AMERICA 1 NATIONWIDE PLZ 202-12-3741 Employee/Obligor's Social Security Number 5307100090 Employee/Obligor's Case Identifier (See Addendum for plaintiff names COLUMBUS OH 43215-2220 \?/ 3 (7/ 1/1L associated with cases on attachment) Custodial Parent's Name (Last, First, MI) ?S'?'s ????03oa? See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 910 . 00 per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater/ Oyes ® no $ o. oo per month in medical support $ o . 00 per month for genetic test costs $ per month in other (specify,), for a total of $ 910.00 per month to 'be forwarded to payee below. You do not have to vary your pay cycle to begin compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 210.00 per weekly pay period. $ 420. oo per biweekly pay period (every two weeks). $ 455.0o per semimonthly pay period (twice a month). $ 910. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BYMAIL. BY THE COURT: it Date of Order: SEP 1 7 2003 Q Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: DEEDS, WILLIAM P. Employee/Obligor's Name (Last, First, MI) J, Service Type M OMB No:o97oo15a Form EN-028 Worker ID $OINC ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hecke? you are required to provide a copy of this form to your ¢m?ployee. If your employee works in a state that is dierent from the state that issued this order, a copy must be provideo to your employee even if the box is not checked. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* Reporting the Payd-late'Date of Withholding. You must report the paydaWdate 0'withl-told,rig when sending the payment. The You must comply with the law of the paydate/date of withholding is the date on which amount nas vvithheld from the employee's wages. state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2730100175 EMPLOYEE'S/OBLIGOR'S NAME: DEEDS. WILLIAM P. EMPLOYEE'S CASE IDENTIFIER: 5307100090 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type m by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Worker ID $oINC N ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEEDS, WILLIAM P. PACSES Case Number 826103027 PACSES Case Number Plaintiff Name Plaintiff Name NANCY J. DEEDS Docket Attachment Amount Docket Attachment Amount 01-329 CIVIL $ 910.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s); DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT state Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of order/Notice 09/16/03 Tribunal/Case Number (See Addendum for case summary) Employer/withholder's Federal FIN Number NATIONWIDE LIFE INSURANCE CO C/O OF AMERICA 1 NATIONWIDE PLZ 202-12-3741 Employee/Obligor's Social Security Number 5307100090 Employee/Obligor's Case Identifier (See Addendum for plaintiff names COLUMBUS OH 43215-2220 associated with cases on attachment) Custodial Parent's Name (Last, First, MI) Pgz°s?S ?aZ,1030a-7 See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 910.00 per month in current support $ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no $ o.00 per month in medical support $ o . 00 per month for genetic test costs $ per month in other (specify) for a total of $ 910.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 21o . oo per weekly pay period. $ 420. oo per biweekly pay period (every two weeks). $ 455. oo per semimonthly pay period (twice a month). $ 91o. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case /de,, ' AL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. -alp 0 Y THE COURT: Date of Order: e., J a'u 3 Insley O1 r. r Form EN-028 Service Type M OMB N., 0970-0154 Worker ID $OINC O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: DEEDS, WILLIAM P. Employee/Obligor's Name (Last, First, MI) ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? If hecke l you are required to provide aSopy of this form to your geuloyee. If yoyr employee %rks in a state tha?is di erent rom the state that issued this or er, a copy must be provi to your emp oyee even if t e box is not chec ed. 1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employeelobligor. 4.* Repo tiig the-PaydatefBate OtWitlilrald ..g. You intist report the paydate/date ot withholding when sending the payment. fhe You must comply with the law of the 1111 Ul 1 11 U n nhoeh amount was withheld Fnin the employee's oages. state of the employee's/obligofs principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.* Employeelobligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2730100175 EMPLOYEE'S/OBLIGOR'S NAME: DEEDS, WILLIAM P. EMPLOYEE'S CASE IDENTIFIER: 5307100090 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amountyou should have withheld from the employeelobligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeetobligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of. 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employeelobligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Service Type M Page 2 of 2 OMB No, 0970-0154 Form EN-028 Worker ID $OINC ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEEDS, WILLIAM P. PACKS Case Number 626103027 PACKS Case Number Plaintiff Name Plaintiff Name NANCY J. DEEDS Docket Attachment Amount Docket Attachment Amount 01-329 CIVIL $ 910.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ?if checked you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligors employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. c ° o c+c n --4 E?1 jN) On ,[: cn ?L G^ m C ? ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 01- 5,o c.,V State Commonwealth of Pennsylvania Co./City/Dist. of CUMBERLAND Date of Order/Notice 09/16/03 Tribunal/Case Number (See Addendum for case summary) EmployegWithholdees Federal EIN Number NATIONWIDE LIFE INSURANCE CO C/O OF AMERICA 1 NATIONWIDE PLZ COLUMBUS OH 43215-2220 @ Original Order/Notice O Amended Order/Notice O Terminate Order/Notia RE: DEEDS, WILLIAM P. Employee/Obligor's Name (Last, First, MI) 202-12-3741 Employee/Obligor's Social Security Number 5307100090 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 910 . oo per month in current support $ o. oo per month in past-due support Arrears 12 weeks or greater? Dyes ® no $ 0.00 per month in medical support $ o. oo per month for genetic test costs $ per month in other (specify) for a total of $ 910.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 210.00 per weekly pay period. $ 420. oo per biweekly pay period (every two weeks). $ 455, o0 per semimonthly pay period (twice a month). $ 91o. oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #10 on pg. 2). If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH SY MAIL; -7 t BY THE COURT 9-? 03 Date of Order: J eSley Oler r Form EN-028 Service Type M OMBN0,09M0154 Worker ID $OINC ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? heckel you are required to pmo ide agopy of t is form to yyour3moloy e. If yorry employee arks in a state that is 1 'rent rom the state that issued t is o er, a copy must be rovi a to our emp o ee even if tie box is not checked. 1. We appreciate the voluntary compliance of federally recognized Indian tribes, tribally-owned businesses, and Indian-owned businesses located on a reservation that choose to withhold in accordance with this notice. 2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 3. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 4.* paydate/date You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 5.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee%bligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits; you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #10 below) 6. Termination Notification: You must promptly notify the Requesting Agency when the employeelobligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. WITHHOLDER'S ID: 2730100175 EMPLOYEE'S/OBLOGOR'S NAME: DEEDS, WILLIAM P. EMPLOYEE'S CASE IDENTIFIER: 5307100090 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (15 U.5.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. 11. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. Submitted By: If you or your employee/obligor have any questions, DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT 13 N. HANOVER ST by telephone at (717) 240-6225 or P.O. BOX 32Q by FAX at (717) 240-6248 or CARLISLE PA 17013 by internet www.childsupport.state.pa.us Page 2 of 2 Form EN-028 Service Type M OMB No.: 0970,0154 Worker ID $OINC ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEEDS, WILLIAM P. PACKS Case Number 826103027 PACKS Case Number Plaintiff Name Plaintiff Name NANCY J. DEEDS Docket Attachment Amount Docket Attachment Amount 01-329 CIVIL $ 910.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ?ifchecked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ?if checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. e C Gi 'TJ ? tl3 l -`mac vs Case No. © / - 52-'? Statement of Intention to Proceed To the Court: ///n? GG/Wwei ( 14 /?0e-oA4 intends to proceed with the above captioned matter. Print Name " JL' L I AM F•-IkaIDj Sign Name U 7 ` 0 [&" Date: 4!t .3, z o D)'O Attorney for Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case maybe dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, lie or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Ru1e230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. err o 31 _? rry _jY "'C? P47 Linn 6 Wolin NANCY J. DEEDS, Plaintiff/Petitioner VS. WILLIAM P. DEEDS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01-329 CIVIL TERM IN DIVORCE PACSES CASE: 826103027 ORDER OF COURT AND NOW to wit, this 13th day of August, 2009, it is hereby Ordered that the Order for Alimony Pendente Lite is terminated, effective July 31, 2009, pursuant to the parties' Marital Settlement Agreement. The Alimony Pendente Lite account is closed with a credit in the amount of -$1401.15. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either party files a written demand with the Domestic Relations Section for a hearing de novo before the Court. DRO: R.J. Shadday xc: Petitioner Respondent Cara A. Boyanowski, Esq. Courtney Kishel Powell, Esq. Form OE-001 Service Type: M Worker: 21005 BY THE COURT: R-E€}-CIFFICE OF THE Fr, FH,1 P',,9TARY 2009 AUG 17 PM 2, 3 4 rc,v,1S? Vni t JAMEs SMITH DIE I'FmclC & CONNELLY LLP Courtney Kishel Powell ckp(a isdc.com FAX 717.298.2025 August 12, 2009 VIA FACSIMILE (717) 240-6248 AND U.S. MAIL Domestic Relations Attn: Rikki Shadday P.O. Box 320 Carlisle, PA 17013 Re: Deeds v. Deeds PACSES Case No. 826103027 Dear Ms. Shadday: As you know, this office represents William Deeds in the above-referenced matter. Attorney Cara Boyanowski represents Nancy Deeds. I am writing to advise you that the parties have reached an agreement as to the economic issues surrounding their divorce. Pursuant to the terms of the Marital Settlement Agreement, the support award issued to Mrs. Deeds shall terminate effective July 31, 2009. Pursuant to the attached e-mail, Ms. Boyanowski concurs with this request. Kindly issue an Order terminating the award. Any credits due to Mr. Deeds will be recouped in equitable distribution. If you have any questions, please feel free to contact me at the telephone number listed above, or Attorney Boyanowski at (717) 540-9170 extension 2925. Very truly yours, Courtney Kishel p. well CKP/mbl GARY L. JAMES MAX J. SMITH.. JR. JOI IN J. CONNELLY. JR. SCOTT A. DIETTERICK JAMES F. SPADE MATTHEW CHABAL III NEIL W. YAHN EDWARD P. SEEBk_H RONALD T TOMASKO SUSAN M. KADEL JARAD W_HANDELMAN COJHINEY K. PoWELL KIMBERLY A. BONNER KAREN N- CONNELLY JOHN M. HYAMS CHRISTINE T. BHANN JESSICA E. LoWE SEAN M.CONCANNON OIL COUNSEL: GREGORY K. RIC[ ANDS BERNARD A RYAN, JH cc: Cara A. Boyanowski, Esquire (VIA FACSIMILE (717) 540-5481) William P. Deeds Courtney K. Powell From: Cara Boyanowski [CBoyanowski@ssbc-law.coml Sent: Monday, August 10, 2009 2:48 PM To: Courtney K. Powell Subject: Re: [BULK] Deeds v. Deeds I concur ----- Original Message ----- From: Courtney K. Powell <ckp@jsdc.com> To: Cara Boyanowski Sent: Mon Aug 10 11:22:27 2009 Subject: [BULK] Deeds v. Deeds Hi Cara, I am writing to confirm that in this morning's mail, I received the Marital Settlement Agreement which your client executed. I intend on meeting with Mr. Deeds this afternoon to have him sign everything. I am preparing a letter to Ricky Shadday advising that the parties have reached an agreement and requesting she issue an order terminating the support order effective July 31, 2009. 1 will use this email as confirmation you concur, if you don't mind responding back. Thanks, Courtney ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania Co./City/Dirt. of CUMBERLAND Date of Order/Notice 08/13/09 Case Number (See Addendum for case summary) Employer/Withholder's Federal EIN Number NATIONWIDE LIFE INSURANCE CO 1 NATIONWIDE PLZ COLUMBUS OH 43215-2220 202-12-3741 Employee/Obligor's Social Security Number 5307100090 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 0.00 per month in current child support $ o . oo per month in past-due child support Arrears 12 weeks or greater? Oyes ® no $ 0.00 per month in current medical support $ 0.00 per month in past-due medical support $ o . oo per month in current spousal support $ o.oo per month in past-due spousal support $ o . oo per month for genetic test costs $ 0.00 per month in other (specify) $ one-time lump sum payment for a total of $ o . o o per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ 0.00 per weekly pay period. $ 0. 00 per semimonthly pay period (twice a month) $ o . 00 per biweekly pay period (every two weeks) $ o . 00 per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). Pennsylvania law (23 PA C.S. § 4374(b)) requires remittance by an electronic payment method if an employer is ordered to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00 Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR S IAL SEC RITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: I 2001 DRO: R.J. Shadday Service Type M OMB No.: 0970-0154 01-329 CIVIL OOriginal Order/Notice OAmended Order/Notice (2 Terminate Order/Notice OOne-Time Lump Sum/Notice RE: DEEDS, WILLIAM P. Employee/Obligor's Name (Last, First, MI) J.- Wesley Oler, Jr., Form EN-028 Rev.5 Worker I D $OINC ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS If hhecketl you are required to provide a copy of this form to your?mployee. If yorr employee works in a state that is di erent rrom the state that issued this order, a copy must be provi eeccii to your emp ogee even if the box is not checked 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employee/obligor. 3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 2730100175 THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ED THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: ED EMPLOYEE'S/OBLIGOR'S NAME: DEEDS, WILLIAM P. EMPLOYEE'S CASE IDENTIFIER: 5307100090 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: LAST KNOWN PHONE NUMBER: FINAL PAYMENT AMOUNT- NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673 (b)); or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section. Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health care premiums in determining disposable income and applying appropriate withholding limits. 10. Additional info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Send Termination Notice and other correspondence to: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 Service Type M OMB No.: 0970-0154 Form EN-028 Rev.5 Worker ID $OINC ADDENDUM Summary of Cases on Attachment Defendant/Obligor: DEEDS, WILLIAM P. PACSES Case Number 826103027 PACSES Case Number Plaintiff Name Plaintiff Name NANCY J. DEEDS Docket Attachment Amount Docket Attachment Amount 01-329 CIVIL $ 0.00 $ 0.00 Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB DOB PACKS Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB Addendum Form EN-028 Rev.5 Service Type M OMB No.: 0970-0154 Worker ID $0INC! E{t.EQ?+-riC T OF THE p!?. O.C ARY 2009 AUG 20 AM 11: G 5 GUmk- r a,?r MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN NANCY J. DEEDS AND WILLIAM P. DEEDS Courtney K. Powell, Esquire JAMES, SMITH, DIETTERICK & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 Telephone: (717) 533-3280 Counsel for Husband Cara A. Boyanowski, Esquire LAW OFFICES OF SERRATELLI & SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Harrisburg, PA 17110-9670 Telephone: (717) 540-9170 Counsel for Wife MARITAL SETTLEMENT AGREEMENT v?- Lk THIS AGREEMENT, made this U day of MJy,009, by and between Nancy J. Deeds and William P. Deeds, WITNESSETH: WHEREAS, Nancy J. Deeds (hereinafter called "Wife") who formally resided at 5364-A Manayunk Road, Pennswood Apartments, Harrisburg, Dauphin County, Pennsylvania 17109; WHEREAS, William P. Deeds (hereinafter called "Husband") currently resides at 806 Division Street, Grantham, Cumberland County, Pennsylvania 17027; WHEREAS, the parties hereto are husband and wife, having been lawfully married on June 14,1986; WHEREAS, the parties have lived separate and apart since on or about July 11, 1998; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of these premises, and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 2. ADVICE OF COUNSE.L. Each party acknowledges that he or she has had the opportunity to receive independent legal advice from counsel of his or her selection. Husband has secured legal advice from Courtney Kishel Powell, Esquire, and the law firm of James, Smith, Dietterick & Connelly LLP, his counsel. Wife has secured legal advice from Cara Boyanowski, Esquire, and the Law Offices of Serratelli, Schiffman, Brown, & Calhoon, P.C., her counsel. Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence. and that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs of litigation. 3. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or she has had the opportunity to discuss with counsel the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, 2 earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge that there has been full and fair disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly, in the name of one party alone or in the name of one of the parties and another individual or individuals. Each party agrees that any right to further disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. Specifically, each party waives the need for copies of bank statements, insurance policies, retirement plan statements or any other documentation. Each party warrants that he or she is not aware of any marital asset that is not identified in this Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue influence or that there was a failure to have available full, proper and independent representation by legal counsel. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and thus any divorce action with respect to these parties shall be limited to a claim for divorce only. Wife has filed a Divorce Complaint in the Court of Common Pleas Cumberland County, Pennsylvania. The parties agree that they will each execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree in order that counsel for Wife may finalize the divorce action in a timely fashion. Upon completion of the divorce action, counsel for Wife shall supply counsel for Husband with a copy of the Decree. 3 5. EQUITABLE DISTRIBUTION. A. Real Estate 1. 1499 Baltimore Road, Dillshurg, York County. During the marriage, the parties acquired an interest in real estate situated at 1499 Baltimore Road, Dillsburg, York County, Pennsylvania. The parties sold the home in 2006 and placed the proceeds from the sale in an escrow account with M&T Bank. From time to time, the parties took like distributions from this account as they mutually agreed. As of March 13, 2009, the balance on the escrow account was $47,024.86. As part of equitable distribution, the parties mutually agree that they shall equally divide the money remaining in the escrow account. The funds shall be disbursed to the parties within ten (10) business days of the date of execution, pursuant to paragraph 18 of this Agreement. The parties also agree that they will equally share in any tax liability that may arise from the interest accrued on the escrow account. Husband's counsel shall provide Wife's counsel a copy of the 1099 upon receipt of same. 2. Franklintown Borough. Franklin Township, York County. In addition to the above, Husband purchased a one-half interest in the property located in Franklintown Borough and Franklin Township, York County, Pennsylvania in 1995. The parties understand that this property is marital property subject to equitable distribution. Each party further understands that they each have the right to appraise the property to determine the current fair market value of the property, and specifically waive the right to do so. The parties agree that Husband shall keep his one-half interest in said property and any equity therein, as his sole and exclusive property, free and clear of any right, claim, title or interest of Wife. Wife hereby specifically relinquishes all claims and rights she has in said property and any equity therein, and shall cooperate in executing any and all documents necessary to effectuate the purpose of this paragraph. 3. Grantham, Cumberland County. The parties also acknowledge that Husband owns a rental property located in Grantham, Cumberland County, Pennsylvania, which was purchased by Husband prior to the parties' marriage. The parties understand that the increase in 4 value of this property is marital property subject to equitable distribution. The parties further understand that they each have the right to hire an appraiser to obtain a fair market value of the property at the time of marriage and at separation to determine the increase in value of this property, and he or she specifically waive that right. The parties mutually agree that Husband shall keep as his sole and exclusive property the real estate located in Cumberland County, all rents received from this property any all equity therein, free and clear of any right, claim, title or interest of Wife. Wife specifically relinquishes her rights to the property, her right to receive a portion of the rents, her right to receive a portion of any increase in value of the property, as well as all equity remaining in the property. Wife agrees to cooperate in executing any and all documents necessary to effectuate the purpose of this paragraph. B. F jr1 nichings and Personalty. The parties agree that they have divided by agreement between themselves all furnishings and personalty located in the Marital Residence, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. Accordingly, Husband shall retain sole and exclusive ownership of all furnishings and personalty currently in his possession, free and clear of any right, title, claim and/or interest of Wife and Wife shall retain all items of furnishings and personal property currently in her possession as her sole and separate property free and clear of any right, title, claim and/or interest of Husband. C. Motor Vehicles. During the marriage, Husband and Wife each acquired various motor vehicles, including but not limited to cars, and a boat. Each party understands that they have the right to have these motor vehicles valued, and specifically waive the right to do so. As part of equitable distribution, the parties mutually agree that they will each retain ownership in the vehicles they kept at separation, free and clear of any right, claim, title and interest of the other, and free to use, trade, sale or otherwise dispose of as he or she deems appropriate. Each party further relinquishes and waives any claim or interest they may have in the other's vehicle. 5 D. Life Insurance. Each party shall keep as their sole and exclusive property, any life insurance policies he or she may have in their own name. E. Pension and Retirement R n fi c, 1. Hushand's Pension and Retirement Account-,: Husband has a pension with Pennsylvania Farm Bureau Association Retirement Income Plan, which is administered by Nationwide. A portion of this pension was acquired prior to marriage and a portion was acquired during the marriage. At the time of executing this document, the pension was in pay status. Husband also has a pension with Farm Family; however, that pension was acquired prior to the parties marriage and both parties agree that it is not subject to equitable distribution. In addition, at separation Husband had three IRA accounts including a Rollover IRA with VanGuard, which had a balance of $87,384.07 as of May 16, 2006, an IRA Account with Kaufmann Fund t/b/a Federated Kaufmann Fund, which had a balance of $50,175.31 as of May 10, 2006, and an IRA with Oakmark, which had a value of $4,061.75 as of December, 2000. The parties acknowledge that they have the right to obtain updated values on these accounts, and he or she specifically waives the right to do so. As part of equitable distribution, the parties mutually agree that Husband shall keep as his sole and exclusive property all of his retirement and pension accounts as they are identified herein, free and clear of any right, claim, title or interest of Wife, and Wife specifically waives and relinquishes forever any right, claim or interest she may have in Husband's retirement and pension accounts. 2. Wife's Pension and Retirement Account.,;: Wife has a retirement account, by virtue of her employment with Miller Mutual, Inc. The value of this account at separation and currently is not known. Each party understands that they have the right to have this account valued to determine the marital portion of this asset which would be subject to equitable distribution; however, each party specifically waives their right to do so. The parties mutually agree that Wife shall keep as her sole and exclusive property, this retirement account, free and clear of any right, claim, title or interest of Husband. Husband specifically waives and relinquishes forever any right, claim or interest he may have in Wife's retirement account. 6 F. Rank Accounts. The parties have divided their bank accounts as they mutually agree. Accordingly, each party shall keep all the monies located in their respective accounts, free and clear of any right, claim, title or interest of the other. In addition, each party waives any right they may have in the other's accounts. G. Investment Accounts. The parties had numerous investment accounts with various brokerage firms when they separated in 1998. Some of these accounts were all marital property, including but not limited to accounts with The Kaufmann Fund, Fidelity Investments, JBS Sutton, Prudential Financial, and T. Rowe Price. The parties understand that all investment accounts acquired during the marriage are marital property subject to equitable distribution. Other investment accounts that existed at the time of the parties' separation were pre-marital property owned by Husband. The pre-marital accounts included but are not limited to accounts with Fidelity, Fidelity Mutual, Franklin Templeton, Quick Reilly, Scudder, T. Rowe Price, Van Guard, and Wells Fargo. The parties understand and agree that any increase in value of these non-marital accounts is marital property subject to equitable distribution. Post-separation, Husband maintained, converted and/or liquidated these investment accounts. While the parties were able to acquire values for some of these investment accounts post-separation, some values were unable to be determined, and some accounts were valued as recently as 2006. Each party understands that they have the right to have an accounting of all investment accounts, and to have them traced and valued to determine the marital value of each of the accounts. Each party specifically waives his or her right to do so. As part of equitable distribution, the parties mutually agree that Husband shall keep as his sole and exclusive property each and every investment account that existed at separation, any increase in value thereon, and any subsequent conversion or liquidation of the account that may have occurred post-separation. Wife specifically waives and forever relinquishes any right, claim, title or interest she may have in these investment accounts, any increase in value on these accounts, any conversion of the accounts and any monies received from liquidating said accounts. Husband shall assume all tax liability associated with these accounts. 7 H. Lump-Sum Cash Payment. In consideration of and for Wife's waiver and relinquishment of all rights arising from the martial relationship, including but not limited to the conveyance of her interest in marital property to Husband, Wife shall receive $25,000.00 in cash within ten (10) business days of the date of execution, pursuant to paragraph 18 of this Agreement. Wife shall keep this money as her sole and exclusive property, free and clear of any right, claim, title and interest of Husband. The parties acknowledge and agree that this disbursement is part of equitable distribution, and as such, has no tax consequence to Wife. 1. Miscellaneous Pro en rbv.. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. J. Property to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of Husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. K. Property to Hushand. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. L. Marital Debt. The parties warrant and represent that the only marital debt that existed at separation was the mortgage encumbering the marital residence, which was fully 8 satisfied. Any other debt or liability that existed at separation shall remain the sole responsibility of the party who incurred it. M. i.iahili not Usted. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, for which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all debts, obligations and liabilities. N. Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. 0. Indemnification of Husband. If any claim, action or proceeding is hereafter initiated -seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including,. but not limited to, costs of court and actual attorney's fees incurred by Husband in connection therewith. P. Warranty as to Future Obligations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, 9 loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach hereof. 6. INCOME TAX. The parties have heretofore filed joint federal and state tax returns. Both parties agree that, in the event any deficiency in federal, state or local income tax is proposed or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 7. SUPPORT. A. AT,TMONV, AT.TMONV PENDF.NTE LITE, SPOUSAT. SUPPORT. Currently, Husband is paying Wife spousal support and/or alimony pendente lite in the amount of $910.00 per month, which is monitored through the Cumberland County Domestic Relations Office. The parties mutually agree that Husband's monthly support obligation to Wife shall terminate effective July 31, 2009, or upon the entry of the divorce decree, whichever occurs first. Husband's counsel shall notify the respective Domestic Relations office of said termination. At the time of termination, Husband hereby agrees to immediately pay any arrears owed to Wife. Likewise, Wife hereby agrees to immediately reimburse Husband for any overpayments, by paying him directly within ten (10) business days of terminating the support order. By terminating Husband's support obligation to Wife, Wife hereby relinquishes and forever waives her right to continue receiving spousal support and/or alimony pendente lite from Husband. Except as provided herein, Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. Except as provided herein, the parties further release and waive any rights they may have to seek modification of the terms 10 of this paragraph in a court of law or equity, it being understood that the foregoing constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. $. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waive all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said parry has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania or any other jurisdiction. 9. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each parry hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay checks or any other post-death distribution scheme, and each parry expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 10. RELEASE OF CLAIMS. A. Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to §3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces and 11 forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds thereof in the future. The parties have divided between them to their mutual satisfaction, personal effects, household goods and furnishings and all other articles of personal property which have heretofore been used in common by them, and neither party will make any claim to any such items which are now in the possession or under the control of the other. Should it become necessary, each party agrees to sign any title or documents necessary to give effect to this paragraph, upon request. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the execution date of this Agreement, with full power in him or her to dispose of the same fully and effectively for all purposes. B. Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. C. Except as otherwise set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now 12 existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. D. Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 11. PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date of their Divorce Decree all financial records relating to the marital estate, and each parry will allow the other party access to those records in the event of tax audits. 12. MODTFTCATinN. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 13. SF.VERABTLiTY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 14. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 13 15. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other parry will not be deemed a waiver of any other breach or any provision of this Agreement. 16. NOTICE, Any notice to be given under this Agreement by either party to the other shall be in writing and may be accomplished by registered or certified mail, return receipt requested. Notice to Husband will be sufficient if made or addressed to the following: William P. Deeds 806 Division Street Grantham, PA 17027 and to Wife, if made or addressed to the following: Nancy J. Deeds c/o Steve Harris 1808 Blue Heron Lane Palmyra, PA 17078 Notice shall be deemed to have occurred upon the date received by the recipient. Each party may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. 17. AULICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 18. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 19. REFECTIVE DATE,. This Agreement shall become effective and binding upon both parties on the execution date. 14 20. EFFECT OF RECONCILIATION, COHABITATION OR DIVORCE,. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 21. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 22. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties hereto. 23. ENTIRE, AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 24. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable, to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses actually incurred as a result of such failure. 15 25. AGREEMENT NOT TO HE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and, in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the date hereinabove set forth. jj? 0MQ WITNESS Nancy J. Deeds i 1?1r? r/./lion.^I[IP ?/1 WITNESS William P. Deeds 16 COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF? ??rt On this 3r"_-? day of 6 A. , 2009, before me, a Notary Public, the undersigned officer, personally appeared Nancy J. Deeds, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. EMY I o sE M(SEAL) " M f DOWRY ft" hoe MI?IIIMMEpNaIMID6, 2012 My Commission Expires: a$?Olol? COMMONWEALTH OF PENNSYLVANIA :ss. COUNTY OF luk On this 0 day of , 2009, before me, a Notary Public, the undersigned officer, personally appeared William P. Deeds, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Tl? - '_10 '0 (SEAL) Notary, Public ?r 0O?iVtiFC?•i.Tr?- - i Notarial Seal My Commission Expires: Maria B. LaRue, Notary Public Derry Twp., Dauphin County My Commission Expires Nov. $, 2009 Member, Pennsylvania Association of Notaries 17 OF THE FP,--) vNf3TARY 2001 AUG 19 P? 1: 27 ??rV Y.f±sa?a s1, Air.: Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 01-329 CIVIL WILLIAM P. DEEDS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on January 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: k /C (,% By: William P. Deeds, Defendant FILE --C-Wr CE OF THE PRM'HONOTARY 2009 AUG 19 Phi 1: 2 7 IIINTY F'ENNSYL11, ,, VI Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 01-329 CIVIL WILLIAM P. DEEDS, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: /0 BY William P. Deeds, Defendant APT: TAR`t e%F ? .. 21 PM t zoo AUK 19 Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 171 10 (717) 540-9170 Attorney for Plaintiff NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. . NO. 01-329 CIVIL WILLIAM P. DEEDS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT I . A Complaint in Divorce under §3301(c) of the Divorce Code was filed on January 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: 1-24-ZOOg By: -- Nancy J. Deeds, Plainti"" a Social Security No. OF THE Prrri f')lNoaTAAY 2009 AUG 19 Ph 1: 2 7 .Jw : ...1 +?'Jv ?E ^,N SYLVAN', IA Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 01-329 CIVIL WILLIAM P. DEEDS, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: I_ -24_4009 -- By: ej- Nancy J. Deeds, Pl ntiff? EILED-O'--ILE OF THE PR ?T?6MOTARY 1004 AUG 19 PM 1: 2 7 CUME; EL-J` :.? JNTY Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 Attorney for Plaintiff, Nancy J. Deeds NANCY J. DEEDS, Plaintiff V. WILLIAM P. DEEDS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 01-329 CIVIL : IN DIVORCE PRAECIPE TO WITHDRAW ADDITIONAL COUNTS To the Prothonotary: Kindly withdraw Plaintiff's additional claims for Alimony, Alimony Pendente Lite, Counsel Fees and Costs, and Equitable Distribution, under the Complaint in Divorce filed on January 17, 2001, as the parties have reached a comprehensive settlement agreement and now.wish to finalize their pending divorce action through this Honorable Court. Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON nktau.......L Cara A. Boyanowski, squire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 RLE 'SCE jE rj?TFI ZQQ9 AUG 19 pM l 2 1 PENNSYLVANIA .+t _41f ? Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 Attorney for Plaintiff, Nancy J. Deeds NANCY J. DEEDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 01-329 CIVIL WILLIAM P. DEEDS, 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: Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: A copy of the Divorce Complaint was served on Defendant, William P. Deeds, by United States first class, certified mail, restricted delivery, return receipt requested, on January 24, 2001, at P.O. Box 264, Grantham, Pennsylvania 17027. A copy of the Affidavit of Service signed by Defendant has been filed of record with this Honorable Court on January 29, 2001. 3. (Complete either paragraph (a) or (b).) (a). Date of execution of the affidavit of consent required by §3301(c) of * - r- r, the Divorce Code: by Plaintiff. July 24, 2009; by Defendant: August 10, 2009. (b) (1). Date of execution of the affidavit required by §3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: N/A. 4. Related claims pending: None. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: N/A. (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 19, 2009 (anticipated) Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 19, 2009 (anticipated). Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff Fil FD-OFFICE OF THr PR OT P "VOTA?Y 2009 AUG 19 PM 1: 28 s: PFMN,SYL\/AN;A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NANCY J. DEEDS V. WILLIAM P. DEEDS NO. 01-329 CIVIL DIVORCE DECREE AND NOW, u c? _ 24 D D , it is ordered and decreed that NANCY J. DEEDS , plaintiff, and WILLIAM P. DEEDS , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The provisions of the Marital Settlement Agreement entered into by the parties on August 10, 2009, shall be incorporated by reference, but shall not be merged into this decree in divorce. By the Court, ? "fig "os' ?a? ;ua? ? ??? i°d?? a ,: _. ? .'s ?1 F ?'1?, ? ; .