Loading...
HomeMy WebLinkAbout07-3309IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Wesley L. Bloser, Plaintiff, Civil Action - Law vs Saundra J. Bloser, No. 2007- ?302 (2t v d??..? Defendant, ) In Divorce a v.m. 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 other rights important to you, including custody or visitation of your children. When the ground for 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 of the Franklin County Courthouse, First Floor, Chambersburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABAOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA Only) or (717) 238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangement must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Wesley L. Bloser, vs Saundra J. Bloser, Plaintiff, Defendant, Civil Action - Law No. 2007 - 3 30 4 In Divorce a v.m. COMPLAINT UNDER SECTION 3301(a) OR 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT 1 DIVORCE 1. Plaintiff is Wesley L. Bloser, a sui juris adult, who currently resides at 20 Blain McCrea Road, Newville, Cumberland County, Pennsylvania, since 1987. 2. Defendant is Saundra J. Bloser, a sui juris adult, who currently resides at Western Village RV Park, 200 Greenview Drive, Carlisle, Cumberland County, Pennsylvania, since March 18, 2007. 3. Plaintiff and Defendant have been bona fide resident(s) in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 18, 1989. 5. There have been no prior actions of divorce or annulment of marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievable broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. Plaintiff has been advised that counsel is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. COUNT II DIVORCE 10. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 11. In violation of her marriage vows and laws of the Commonwealth, the Defendant, Saundra J. Bloser, has offered such indignities to the person of the injured and innocent spouse, the Plaintiff, as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. COUNT III EQUITABLE DISTRIBUTION - SECTION 3502 12. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 13. The parties have been unable to determine and equitably dispose of their respective rights and interests in the martial property, 14. Plaintiff will, within 60 days after service of this Complaint upon Defendant, cause to be filed an inventory and appraisement of all property owned or possessed at the time this Complaint is filed. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide, distribute and assign the martial property pursuant to the provision of Section 3502 of the Divorce Code. COUNTY IV ALIMONY 15. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set at large. 16. The Plaintiff is without sufficient property to provide for his reasonable needs, and is unable to adequately support herself. 17. The Plaintiff cannot support and maintain himself in the style he was maintaining prior to the separation of the Plaintiff and Defendant without continued financial assistance from the Defendant. WHEREFORE, pursuant to Sections 3701, et seq., of the Divorce Code, "Alimony", Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of service of this Complaint upon Defendant, a complete income and expense statement and to require the scheduling of a hearing to determine Plaintiff's entitlement to alimony, and if so, the amount. COUNT V ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES 18. The allegations of Paragraphs 1 through 8 hereof are incorporated herein as fully as though set out at large. 19. The resolution of the issues raised by this Complaint will require Plaintiff to incur considerable additional expenses and costs. 20. The Plaintiff is without sufficient means to adequately support himself and to meet the costs and expenses of this litigation and is unable to maintain himself during the pendency of this action. 21. The Defendant is presently employed as a secretary with Pennsylvania Banker's Association with a gross annual salary of approximately $50,000.00. 22. The Plaintiff is presently employed as a truck driver with Hammaker East with a gross annual salary of approximately $ 26,000.00. WHEREFORE, pursuant to Section 3702, et. Seq., of the Divorce Code, "Alimony Pendente Lite, Counsel Fees and Expenses", Plaintiff respectfully requests your Honorable Court to order Defendant to file within 30 days of service of this Complaint upon Defendant, a complete income and expense statement, and to require the scheduling of a hearing to determine Plaintiffs entitlement to alimony pendente lite, counsel fee and expenses, and if so, the amount. VERIFICATION I verify that the statements made in the foregoing document 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 unworn falsification to authorities. DATE: ? ? a -© 7 wLi VERIFICATION I verify that the statements made in the foregoing document 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: 5 d Mart a B. E tuWalker, ire Attorney I.D. # 15989 33 South Main Street Chambersburg, Pa 17201 (717)262-2185 Attorney for Plaintiff 7D P 0 W W b n FT-) v3 N -C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Wesley L. Bloser, ) Civil Action - Law Plaintiff, ) vs ) No. 2007- 3309 Saundra J. Bloser, ) Defendant, ) In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN SS: Martha B. Walker, Esquire, being duly sworn according to law, deposes and says that she is the attorney for the Plaintiff, Wesley L. Bloser, in the above-captioned matter; that she did service a true and attested copy of the Divorce Complaint Under Section 3301 (a) or 3301 (c) or 3301 (d) of the Divorce Code by mailing the same to Saundra J. Bloser, Defendant, by certified mail, restricted delivery, article number 7004 1350 0004 2491 7957 on June 8, 2007, to her mailing address of Western Village RV Park, 200 Greenview Drive, Carlisle, PA 17013; that said certified mail article was delivered to Defendant, Saundra J. Bloser, on June 9, 2007, all as appears from the receipt for certified mail and the return receipt attached hereto. By: l? Mart. Walker, Esqui Atto ey for Plaintiff Sworn and subscribed to before me this 1A day 2007. (hj_w? Notary Public y ??NOirMIM?1?IL IIAy Come"M son Mp 1 k W A NW- %Siam nw 01 r- FIED MAIL,,, RE CEIPT IT' (Domestic Only; No Insurance • Provided) (L r'9 Er r- r 17 _r __. .:a ...., ru Postage $ , 58 O certified Fee of ?l O C3 Retum Reciept Fee (Endorsement Required) a 1? Postmark Here Res Mcted Fee )el Nery JA,Q 4-/) m me (EndorsentRequ irad) V Total Postage & Fees q (? $ O S C3 Sent TO . ?......t'? .............. .l J . S heet, At 71/o: or PO BoxN?t6 = ^ i ?u1 : F_! . . .._..._..__. 1?"'.. L !?VL DY - _ _. . .__ ??: State. zt?.4 T . , v j3 PS Form :3800, June 2002 -wv tot instructions ¦ Complete items 1, 2, and 3. Also comPlete {tom 4 M Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we cam return the card to you. ¦ Attach this card to the back of the mailPiece, or on the front If space Permits. A. Strillmn X %?z by ( if YES? Agent 4iz D Addressee G Dote of Delivery r; L g rn Item 1? ? Yes ? No 1. Article Addressed to: ?ndra.j I ase r L? C? r ??lv ?•U 1? J r. 3 8011`000 Msil ? F.WIes Mail 0 RegtdKW ChQWm Recaipt for Merchandise D 3 ? insured mail E3 C.D.D. y! 4. > estt W-1 DeNvery? ODft Fee) >f 2. Article Number 7004 1350 0004 2 491 7957 frarr aervlce IabaQ tazssaot?t-tsao Ps Form 3811, February 2004 Domestic Ralum RaodPt r-.3 Q r C WESLEY L. BLOSER, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-3309 CIVIL TERM SAUNDRA J. BLOSER, IN DIVORCE Defendant/Respondent PACSES CASE NO: 706109244 ORDER OF COURT AND NOW, this 19th day of June, 2007, 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. Shadday on July 17, 2007 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 further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W2'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, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Martha B. Walker, Esq. Date of Order: June 19, 2007 It. J. Sha ay, Conference Officer F (r 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 cc361 S J a G WESLEY L. BLOSER, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-3309 CIVIL TERM SAUNDRA J. BLOSER, IN DIVORCE Defendant/Respondent PACSES CASE NO: 706109244 ORDER OF COURT AND NOW, this 22nd day of June, 2007, 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. Shadday on Au¢ust 15, 2007 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 W2'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 1910.1 I© (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, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Martha B. Walker, Esq. Theresa Barrett-Male, Esq Date of Order: June 22, 2007 R. J. S day, onference 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 cc361 c? G -y 100 ° n {, F 4_ . tv G In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION WESLEY L. BLOSER ) Docket Number 07-3309 CIVIL Plaintiff ) Vs. ) PACSES Case Number 706109244 SAUNDRA J. BLOSER ) Defendant ) Other State ID Number Order AND NOW to wit, this JULY 24, 2007 it is hereby Ordered that: THE PETITION FOR ALIMONY PENDENTE LITE BE CONTINUED GENERALLY AS THE PARTIES ARE WORKING OUT A STIPULATION AND AGREEMENT. THE MATTER CAN BE RESCHEDULED AT THE WRITTEN REQUEST OF EITHER PARTY. THE CONFERENCE SCHEDULED FOR AUGUST 15, 2007 IS CANCELED. XC: PLAINTIFF DEFENDANT MARTHA B. WALKER, ESQ. THERESA BARRETT-MALE, ESQ. BY THE COURT: EDWARD E. GUIDO JUDGE DRO: R.J. SHADDAY Form OE-001 Service Type M Worker ID 21205 CID DD ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Wesley L. Bloser, ) Civil Action - Law Plaintiff, ) vs ) No. 2007- 3309 Saundra J. Bloser, ) Defendant, ) PACSES NO. 706109244 MOTION TO CONTINUE AND, NOW comes the above-named Plaintiff, by and through his attorney, Martha B. Walker, Esquire, and avers the following: 1. An Alimony Pendente Lite support conference between the above-captioned individuals has been scheduled for Wednesday, August 15, 2007 at 9:00 a.m. 2. Plaintiff and Defendant are currently working out a stipulation and agreement. 3. Undersigned counsel has contacted Theresa Male, Esquire, counsel for Defendant, who concurs with this continuance. WHEREFORE, it is hereby moved that the Support Conference originally scheduled for August 15, 2007 at 9:00 a.m., be rescheduled to a time in November, 2007, which is suitable for all parties. Respectfially submitted, M 4a B. Walker, Es uire A rney I.D. # 15989 3 South Main Street Chambersburg, PA 17201 (717)262-2185 Attorney for Plaintiff { , ,.. I verify that the statements made in this Motion for Continuance are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: 0?4 ??' I_-- - M ha B. Walker, squire r .-- ?: ? r1 ?.__ ?,, '? v c ~ €?` `? ?= =? Cr ? ?.., ? ?a `?' t.-: In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION WESLEY L. BLOSER ) Docket Number 07-3309 CIVIL Plaintiff ) VS. ) PACSFS Case Number 706109244 SAUNDRA J. BLOSER ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 30TH DAY OF AUGUST, 2007 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or (D Other REQUEST FOR APL CONFERENCE filed on JUNE 18, 2007 in the above captioned matter is dismissed without prejudice due to: THE PETITIONER NOT PURSUING THE MATTER THROUGH THE DOMESTIC RELATIONS SECTION SINCE THE FILING OF THE REQUEST ON JUNE 18, 2007. ® The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COUR - ?I EDWARD E. 0UILt, -T JUDGE PRO: J. SHADDAY Form OE-506 Service'rype M Worker ID 21005 `J &t ?.' I- You , ham been sued In Court. If you wish to defend against the Ck*Tw silt forth in the b4awft papers, yt, must take prompt action. You are warned that if you fall-la-do so, the 89e'11M proea?ud without you and a Decree in Divorce or annulment may be entered against you by the Court. A Mdgment may also be entered against you for any other corn or relief mqu"W in these payers by the DOfendaht. You may lose' r hey or property or other rim Important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrabie bin of the marriage, you may request marriage counseling. A IM of marriage counts Is evalablo in the Office of the Prothonotary at" the Cumberland County Court House, One Courthouse Square, Carlisle, Pannsyl"nia, 17013. IF YOU DO NOT FILE A CLAIM FOR ALL NY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE `A LAWYER OR CANNOT AFFORD ONE, Gtr TO OR TELEPHONE THE OFFICE SET FORTH SLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Bar Association Lawyer Referral Service 1 800 692 7375 Phdn#ff -COW1VlY, N1tiMV04A V. NO.: 2 3W"** J Bkow, IL ACTM, • LAW t HM CORM, Defendant, Saundra J Bloser, by and # rough his ays, Minter Lips+itt LLC and James A. Miller, Esquire, and airs Plaintiff's Complaint as follows: 1. Admitted 2. Denied. Defendant's address Is 329 North Mountain Road, NeVMvQle' 17241. 3. Admitted 4. Admitted 5. Admitted 6. Admifted 7. Admitted . 8. No responsive pleading is required. 9. No responshm pleading is required. 10. No responsive pleading is required. 11. Denied. Defendant specifically, denies this allegation and ' by way of further response states:.that she is without knovAedge or Information wig regard to P tiffs averment and pro thereof is demanded at try. 12. No resonsive pleading is required. 13. Denied. The parties have engaged in lengthy, extensk* and ee0ensive collaborative efforts towards ? ring the financial natters pertinent to the subject divorce action and were able to reach set rrtent terms. Plaintiff however at the 11"' hour reneged and this litigadon has now ensued. 14. Denied. Plaintiff, contrary to his averment, has not filed his Inventory as required pursuant to the Pennsylvania Rules of Civil Procedure. 15. No responsive pleading is required. ? `it 0, 7 16. Denied. Plaintiff Is full well and able to support himself ttmwgh appropriate employment. Plaintiffs earnings and eaming capacity provides him with a suf lent basis for appropriarte wnpiany erd for which he could. provide for his reasonable needs. Moreover, Plaintiff is in possession of significant and substantial marital assets. 17. Denied. Defendant hereby incorporates preceding paragraph 16 as if fully set forth herein. Moreover, Plaintiff voluntarily chooses to remain unemployed for approximately one-half (1/2) 6f each year when in fact, he could obtain employment for all twelve (12) months of each and every year. 18. No responsive pleading is required. 19. Denied. Defendant is without krK*Aedge or'irdorma k n as =to the truth of the averment and proof thereof is demanded. By way of further response, Defendant hereby incorporates preceding, Answer 13 and had Plaintiff simply followed through with such terms,, a resolution will have been reached and no further expense by either party would have been incurred. 20. Denied. Defendant hereby incorporates precedlrrg Answer 19 as if fully set forth herein. 21. Denied. Defendant is employed with PACE as Director of Conventions. 22. Admitted in part and denied in part. Defendant annual earnings are in excess of $38000.00. ViMEREF, Defendant request your Honor" Court to: A. enter a Decree dissolving the mares betweeh the parties; B. equitably distributing the marital property between the parties; C. denying PlainttFPa request fear Alimony Alimony Pendente Lite, Counsel Fees, Costs/Expenses; D. and for such further relief as the Court may determine. Respectfully submitted, Da:A r? ?7 . Miller, Esquire tLLER L". 4TT LLC 3W North 210 Stmt Camp Hill, PA 1,7011 (717) 737-6400 ?.+ . l t ENUMM I verify that the $te"le(ft made in the foregoing are true and cur t. i understand that %Ws mw tffi.herein and nixie subject to the pena?Wm of 18 Pa.C.S. Section 4904 refuting to unworn faiin to authorities. Date: ' O:lb 6 . C`Z AV7 q?t I'l a7?dxl Saundra j Blower ?r? `?? ? ?? ? ? ?? !~ L Bloser Plaintiff I I Saundra J Bloser Wesley L Bloser Plaintiff V. Saundra,`J Bioser In the Court of Common Pleas Cumberland County, Pennsylvania No 2007-3309 Civil Civil Action - Law in Divorce AND 11. y IN THE COURT `OF COMMON PLEAS Cumberland County, Pennsylvania Docket No 00455 S2007 In Support PACSES Case # 1721 INCO .- 2006 W-2 $33.02 Month Year BRIM 1 140.00 t GIM 41.61' 500.00 Boot 154.00 1 .00 Coal 50.00 3000.00 Water _ Trash Public TranWqation Lunch 110.00 1,380.00 Ins"ce Honneowrtees a§.33 400.00 AutaKriobile 106.33 1,300.00 Life 25.00 300.00 Heakh 5.00 60.00 eats Fuel .00 2.640.00 irs 33.33 400.00 madidiffil 16.67 200.00 aen ist 8.33 100.00 t Hospital e 16.67 200.00 Special needs (glasses, braces, orthopedic devim) Subtotal 2,123.33 12,280101D Expenses c,?ntinued Month Year Privats School Parochial Schoo l R •( 300.00 Food 160.00 1. 00 terse tEdresser 4Q.00 480,00 Credit Gard 160.00 1,820.00 Charge -Membersh Loans rad Union 238.00 2,832.00 * to 183.33 2,200.00 Het C Care fMerta r xtt 100.00 1.200.00 TV ' le 35.00 420.00 Vala?tiart 83.33 1,000.00 CMie 41.67 500:00 feats 541.67 61500.00 Chw fft Coe4lbYI bm 41',67 .00 comer Child 5 775.00 9,300.00 Allmony Paymwft Subil 2,412.67 28,952.00 Total Expenses: 4,536.00 44,232.00 : r' s I verify that the statemords made in the f ng are true ~and 'correct. I understand them user staWrw is : herein are made subject to the pe r of la Pa.C.S. Semen 4904 reW tlr to unswom falsACOVon to authorities. Date: Gd 9 7 S2146a, k-P., Saundra J r .?''. ?? ?+ .?- ??' CR ??: f ?-.-' :. ?? ? c::. a `? f Wesley L. fir, IN THE COURT O COW NON PLEAS Puff Cu erland COUNTY, POMY4whWW? V. NO.: 200743t1li Civil Sera J , CIVIL ACTION • LAAw DPJ1ORCE Defentlant f the foiiowing inventory, and appra boment of ait arty owned or possessed, by either party at the time this action was commenced and all- property transferred within the preceding three (3) years. Defendent v w tes that the statements made in this inventory and air ent are trtm and canect. Desfendanf understands t fatse statements 11009in arse made sui t e the penaMes of IS Pa.C.S. Section 4904 relating to unswom faisMcWw to authorities. j I Defendant on the list below t os@ i iS ble to the case at bar and denim the assets on the *ft pages. Ifan item has been app(~, a copy of the appraisal report Is cached. 1. Real PTPWtY 2. Motor vehicles 3: Stocks, bonds, aesprtges and options 4. CoMeates of Deposit 5. Chec*in acvour cash . 6. ST± nts, rrione m - ktt 7. Contents of safe` deposit boxes 8. Trusts 9. Life Wince policies (indicate face value, cash surrender value and current bw ies) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyAghts, inventions, royalties 14. Perscl outside gnpLq the home 15. Businesses (list ail owners, including penaontage of ownership. and ~/director sins held a party with a co 16. Employment '`tem anion beneflts - severance pay, workman's compensation claimlaward 17. Profit sharing plans 18. onsion irnflic a employee contrlbution and date plan rests 19. Retirement plans, lndWWual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and unmatured) 22. MI .A. benel"rts 23. Education benef 24. D+ due, indud ` loans, moqg?M held 25. Household furnishings and personr (include as a total category and attach itemized list If distribution of such assets is in dispute) 26. Other Defendant Fists al marital property in which either or both spouses have, a kQM or egluit a irderest indi Iaily or with any other person as of the date this action was commenced: Item Property Description Owner Date Value at DOS Present Number Names Acquired Acquisition Vale Value - 1 Stain McCrea Road, Wesley & 1989 $44,000 $195,000 $105,550 ON _01 _1 Saundra 1 P" ty - Pipeline Itad, Ne*v* Wesley & 1998 $35?000 $44,000 $44,000 Saundra 1 Properly - Enaie Road, NewMe WWner & $15,000 $15,000 Peggy Skew , Wes4y & 2 19W Ford Expedttlon Saundra 2001 $19,000 $4,300 $4,300 2 19951 am Saundra IM $12,000 $000 $600 2 1960 Comm Saundra 20094 $1,300 $15,000 $15,040 2 2006 Chewaksee Camper Wesley & SauOdFa 2006 $22,000 $20,004 $20,004 2 190 ti+CUN% Four=Wheeler Wesley & 1992 $5,000 $2,000 $2,000 Saundra 2 Pots Four-Wheeler Not Sure Gift $5,000 $1,5d0 $1,500 2 2004 Polaris Four Wheeler Saundra Gift $2,3030 $1,M0 $1,5W 5 Cheol Account Weaaayr & $143 $143 Saundra 9 Erica Life Insurance Policy (As of Wesley Fad \Wue - Cash ? 6/28P05) - Beneficiaries Saundra, $60,060 Surrender - Cody $ Cotton $3870 9 Aiflanz Life Insurance Policy (As of Saundra Fade Value - Cash Current 6/30107) - SwOlIciaries Wesley, $50,000 Surrender - Cash Cody &Cahn $2,111 Surrender $2.126 19 401(k) Wesley $35,750 ? 19 401(k) Saarldfa $106,305 $115,514 19 Erie IRA Saundra $918 $930 19 TIAA-CREF Saundra $297 $301 25 Household Items (See Attached) Wesley & Saundra 25 Guns Wesley $20,040 $20.000 26 Gun Safe Wes* Gift $3,600 $3,500 It. Defendant lists all property in which a spouse has a legal or equitabe interest which claimed; to be excluded from marital property: ttem Number f'r ip9on Owner Names Date Acquired Vaku at Acquisklon DOS value Preaertit value 19 401(k) Wesley $35,730 ? 19 401(k) Saundra $106,305 $115,514 19 Erie IRA Saundra $919 $930 19 TIAA-CREF Saundra $297 $301 25 Guardlan Service Cookware Saundra Gift $300 $300 25 Craftsman Toots Wesley ? ? 25 Hope Cheat Saundra G#I $100 $100 Defendant lists all property in which either or both '!iti had a or equ tt Me interest indhrid?r or with any other person and which has beery trarmferred within the preceding three years: Hem P+opeR7y [ cript{on Owner Date acq d Date of Trw*W To whom Amount Number Names 2 2004 Ford 1=250 Trek Westay S 2004 May, 2007 ? ? Saundra 25 Hot Tub Wesley & 2001 June, 2007 Randy $300 Saundra W'gert r • Qi l"rcl nt aN liabiNes of either -or bath spouses alone or wM any person as of the data this sodon was corn nenced. Number Liability Description Debtors names EWO Inaared Creditors Names DOS value Print value 24 Mort Wesley & Saundra 1982 Adams County Nationat Bank $90,000 $78,987 24 Camper Loan Saundra 2006 Bank of America $20,460 $19,599 24 Creel Card Saundra Washington Mutual t Pa P $4,654 $4,425 24 Cm& Card Wesley Capital one $4,371 34,241 24 Credit Card Wesley Chase $3,060; $3,567 24 CredR Card Was* Bank of Amefics $2,153 $2,026 24 Credit'Card Saundra Bon Ton' $424 $240 25 Personal Loan Wesley & Saundra Doris Smorrman $27,000 $27,000 ?+ i verify that the statements made in the forming "+ U are true and correct. I underiland' that f +e staterrmts heroin are made sett to the penalties of 18 Pa.D.S. Section 49041 relating to unswom falsification to auftwitiers. Date: to f r,. 07 Saundra J Bloser r a a a Wesley L Bloser, IN THE COURT OF COMMON PLEAS Plaintiff Cumberland COUNTY, PENNSYLVANIA V. NO.: 2007-3309 Civil Saundra J Bloser, CIVIL ACTION - LAW Defendant DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing Answer upon Plaintiff, Wesley L Bloser by personally delivering same to him on Thursday, October 18 2007, 10:30 AM at the Cumberland County Domestic Relations Office, Carlisle, Pennsylvania. Date: Ja A. Miller, Esquire MILLER LIPSITT LLC 356 North 21St Street Camp Hill, PA 17011 (717) 737-6400 r-z-l 0 C5 C: WESLEY L. BLOSER, Plaintiff V. SAUNDRA J. BLOSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3309 : CIVIL ACTION -LAW DIVORCE PRAECIPE TO ENTER AND WITHDRAW APPEARANCE Kindly withdraw the appearance of Kristopher T. Smull, Esquire and Maria P. Cognetti and Associates on behalf of the above-named Plaintiff, Wesley Bloser, in connection with the above captioned matter. Date: S Kindly enter the appearance of Kristopher T. Smull, Esquire and Robinson & Geraldo, on behalf of the above-named Plaintiff, Wesley Bloser, in connection with the above captioned matter. Date: st er T. mull, Esquire ROBINSON & GERALDO Attorney I.D. No. 69140 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 Telephone No. (717) 232-8525 CERTIFICATE OF SERVICE gfll\ I, Kristopher T. Smull, Esquire, do hereby certify that on the day of May, 2008,1 caused a true and correct copy of the Praecipe to Enter and Withdraw Appearance to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. James Miller, Esquire 765 Poplar Church Road Camp Hill, PA 17011 ROVoer GERALDO By. Smull, Esquire Cra 2:, ? 1?d`T1 Q Wesley L Bloser, Plaintiff V. Saundra J Bloser, Defendant IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA NO.: 2007-3309 Civil CIVIL ACTION - LAW DIVORCE MOTION FOR APPOINTMENT OF MASTER Saundra J Bloser Defendant , moves the court to appoint a master with respect to the following claims: X Divorce X Distribution of Property Annulment Support X Alimony X . Counsel Fees Alimony Pendente Lite X Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The defendant has appeared in the action by his attorney, Kristopher T Smull Esquire, (3) The Staturory ground s for divorce are 3301 a, c and d (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: c. The action is contested with respect to the following claims: all claims except divorce it is believed are contested (5) The action ' 'does not involve complex issues of law or fact (6) The hearing is expected to take one (1) (7) Additional information, if any, relevant to the ?Y motion: Date: rney. for Defendant Z'Esquire Print Attorney Name .. James A ORDER APPOINTING MASTER AND NOW, , 20 Esquire is appointed master with respect to the following claims: By the Court: J. MAY E 9200$,"",,, a I Wesley L Bloser, IN THE COURT OF COMMON PLEAS Plaintiff Cumberland COUNTY, PENNSYLVANIA V. NO.: 2007-3309 Civil Saundra J Bloser, CIVIL ACTION - LAW Defendant DIVORCE MOTION FOR APPOINTMENT OF MASTER Saundra J Bloser 'Defendant , moves the court to appoint a master with respect to the following claims: X Divorce X Distribution of Property Annulment Support X Alimony X . Counsel Fees Alimony Pendente Lite X Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The defendant has appeared in the action by his attorney, Kristopher T Smull . Esquire, (3) The Staturory ground s for divorce are' 3301 a, c and d (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: c. The action is contested with respect to the following claims: all claims except divorce it is believed are contested (5) The action ' 'does not involve complex issues of law or fact (G) The hearing is expected to take one (1) (7) Additional information, if any, relevant to the 2?'f 17 Print Attorney Name ...James AND Now, , zo 6)r e % is appointed master 4th resp to the following clai ?Y motion: Esquire By the o 1- ? Gv? c J. Defendant G'# LU C 0 M WESLEY L. BLOSER, Plaintiff VS. SAUNDRA J. BLOSER, defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3309 CIVIL . IN DIVORCE TO: Kristopher T. Smull James A. Miller Attorney for Plaintiff Attorney for Defendant DATE: Monday, June 9, 2008 CERTIFICATION [ I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. lb (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR 15-LAINTIFF () COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. N c?_ :- ? c...- ..,? :-?-s'. ? ? ? .. i= ? '-? ?-? ^_- .? ?_ t 4% WESLEY L. BLOSER, Plaintiff VS. SAUNDRA J. BLOSER, defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3309 CIVIL IN DIVORCE TO: Kristopher T. Smull James A. Miller , Attorney for Plaintiff , Attorney for Defendant DATE: Monday, June 9, 2008 CERTIFICATION [ ] I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. t (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. )Va' ( ? Zev <? DATE COUNSE FOR PLAINTIFF ( ) COUNS FOR DEFENDANT ( X NOTE: PRETRIAL DIRECTIVES W L NOT BE ISSUED FOR THE FILING OF PRETRIAL S TEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DIS VERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S SCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. C? ? ?-? `?- fT .-?, iY. , ? nrt ??: ' t . Y `• ?i E....' r,,.? t Wesley L Bloser, IN THE COURT OF COMMON PLEAS Plaintiff Cumberland COUNTY, PENNSYLVANIA V. NO.: 2007-3309 Civil Saundra J Bloser, CIVIL ACTION - LAW Defendant DIVORCE ORDER AND NOW, this J? day of (2A4,dz&Jt' , 20Of5, the appointment of E Robert Elicker, Esquire, as Master in the above-captioned proceeding is hereby revoked. BY THE COURT: Q" w1c, m ,A? J. ,t _ y i 7 Wesley L Bloser, Plaintiff V. Saundra J Bloser, Defendant IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA NO.: 2007-3309 Civil CIVIL ACTION - LAW DIVORCE PETITION TO REVOKE APPOINTMENT OF MASTER 1. E Robert Elicker, Esquire, was appointed Master on May 30, 2008, in the above-captioned matter to consider the issues raised in the proceedings. 2. A settlement was reached between the parties. 3. The undersigned therefore requests that the appointment of E Robert, Esquire, be revoked. Date: 130 0 James . Miller, Esquire 765 plar Church Road mp Hill, PA 17011 (717) 737-6400 Wesley L Bloser, IN THE COURT OF COMMON PLEAS Plaintiff Cumberland COUNTY, PENNSYLVANIA V. NO.: 2007-3309 Civil Saundra J Bloser, CIVIL ACTION - LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, James A. Miller, Esquire, hereby certify that I have served a copy of the Petition to Revoke Master upon the following person(s) by United States First Class Mail on the date indicated below: Kristopher T Smull, Esquire Robinson & Geraldo 2505 North Front Street Harrisburg, PA 17110 E. Robert Elicker, II 9 N. Hanover Street Carlisle, PA 17013 Date: 13 J 6 9' dames A. Mille , squire 765 Poplar urch Road Camp ' , PA 17011 (717f737-6400 PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made thisU day of 2008, by and between Wesley L. Bloser of Cumberland County, Pennsylvania (hereinafter referred to as "HUSBAND") and Saundra J. Bloser of Cumberland County, Pennsylvania (hereinafter referred to as "WIFE"): WITNESSETH: WHEREAS, the parties were married on February 18, 1989, in Newville, Pennsylvania; and WHEREAS, two (2) children have been born of this marriage, namely, Cody L. Bloser, born April 1, 1990, and Colton L. Bloser, born February 22, 1993; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of WIFE and HUSBAND to live separate and apart, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. r NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby covenant and agree as follows: 1. SEPARATION: HUSBAND and WIFE shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference whatsoever by the other. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an admission on the part of either HUSBAND or WIFE of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, and each of the parties hereto completely understands and agrees that neither shall do or say anything to the children of the parties at anytime which might in any way influence the children adversely against 2 the other party, it being the intention of both parties to minimize the effect of any such separation upon the children. 3. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not be considered to affect or bar the right of HUSBAND or WIFE to a divorce on lawful grounds as such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 4. SUBSEOUENT DIVORCE: The parties hereby acknowledge that HUSBAND has filed a Complaint in Divorce in Cumberland County, Pennsylvania to Docket No. 2007-3309, claiming that the marriage is irretrievably broken under Section 3301(c) of the Pennsylvania Divorce Code. Both parties hereby express their agreement that the marriage is irretrievably broken and express their intent to execute any and all Affidavits, Waivers or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code at the same time as they execute this Agreement. The parties hereby waive all rights to request court ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties 3 are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. INCORPORATION IN DIVORCE DECREE: It is further agreed, covenanted and stipulated that this Agreement or the essential parts hereof, shall be incorporated in any decree hereinafter entered by any court of competent jurisdiction in any divorce proceedings that have been or may be instituted by the parties for the purpose of enforcing the contractual obligations of the parties. This Agreement shall not be merged in any such decree but shall in all respects survive the same and be forever binding and conclusive upon the parties. 6. EFFECTIVE DATE: The effective date of this Agreement shall be the "date of execution" or "execution date," defined as the date upon which it is executed by the parties if they have each executed this Agreement at the same date. Otherwise, the 4 I ' ) "i. "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7. DISTRIBUTION DATE: The transfer of property, funds and/or documents provided for herein, shall only take place on the "distribution date", which shall be defined as the date of execution of this Agreement unless otherwise specified herein. However, the support and/or alimony payments, if any, provided for in this Agreement shall take effect as set forth in this Agreement. 8. MUTUAL RELEASE: HUSBAND and WIFE each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situated, which he or she now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as a testamentary gift, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any country or any rights which 5 i ?) 1 either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, division of property, costs or expenses, whether arising as a result of the marital relationship or otherwise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE to give each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 9. ADVICE OF COUNSEL: The provisions of this Agreement and its legal effect have been fully explained to the parties by their respective counsel; Kristopher T. Smull, Esquire, for HUSBAND and James Miller, Esquire for WIFE. HUSBAND and WIFE acknowledge that this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that 6 IL I I) they waive any specific enumeration thereof for the purpose of this Agreement. Each party agrees that he or she shall not, at any future time, raise as a defense, or otherwise, the lack of such disclosure in any legal proceeding involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. 10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 11. WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 12. PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, 7 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, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. The parties agree to the distribution of personal property as set forth on the attached list which is marked as Exhibit "A." HUSBAND and WIFE agree that they shall arrange a mutually agreeable time for WIFE to come to the marital home and remove those items on Exhibit "A" which have not yet been removed. HUSBAND shall have all items placed neatly in the garage for WIFE to remove. HUSBAND shall be permitted to be present at the premises at the time that WIFE removes her items; however, HUSBAND shall not interfere or interact with WIFE in any way. WIFE shall be permitted entrance into the garage only and no other areas of the marital home. WIFE shall not interact or communicate with HUSBAND in any way while she is present at the marital home. By these presents, each of the parties hereby specifically waives, releases, renounces and forever abandons whatever claims he or she may have with respect to any personal property which is in the possession of the other, and which shall become the sole and separate property of the other from the date of execution hereof. 13. DEBT OF THE PARTIES: The parties agree that their joint and marital debts shall be divided as follows: WIFE (a) Camper Loan with Bank of America. (b) Washington Mutual Credit Card (Pay pal). (c) Bon Ton Store Credit Card. 8 I J X. WIFE hereby indemnifies HUSBAND against, and agrees to assume sole liability and responsibility for, all debts, obligations or liabilities of any nature whatsoever heretofore or hereafter incurred by WIFE for the benefit of herself, except as provided herein. WIFE shall not and will not hereafter incur, or cause to be incurred, for the benefit of herself, except as provided for herein, any debts, obligations or liabilities of any nature whatsoever, whether for necessaries or otherwise, upon the credit of HUSBAND. WIFE shall remove HUSBAND's name from any debts which are currently held in joint names within sixty (60) days of the signing of this Agreement; however, WIFE shall have thirty (30) days from the receipt of the cash payment from HUSBAND, more specifically set out below in paragraph 14(a), in which to remove HUSBAND's name from the camper loan with Bank of America. HUSBAND (a) Mortgage on Marital Home with Adams County National Bank. (b) Chase MasterCard Credit Card. (c) Capital One Credit Card. (d) Bank of America Credit Card. HUSBAND hereby indemnifies WIFE against, and agrees to assume sole liability and responsibility for, all debts, obligations or liabilities of any nature whatsoever heretofore or hereafter incurred by HUSBAND for the benefit of himself, except as provided herein. 9 ` + L I HUSBAND shall not and will not hereafter incur, or cause to be incurred, for the benefit of himself, except as provided for herein, any debts, obligations or liabilities of any nature whatsoever, whether for necessaries or otherwise, upon the credit of WIFE. HUSBAND shall remove WIFE's name from any debts which are currently held in joint names within sixty (60) days of the signing of this Agreement. 14. DIVISION OF REAL PROPERTY: a. Marital Home. WIFE agrees to transfer all her right, title and interest in and to the real estate situated at 20 Blain McCrea Road, Newville, Cumberland County, Pennsylvania, now titled in the name of HUSBAND and WIFE as tenants by the entireties, to HUSBAND and agrees to immediately execute now, and in the future, any and all deeds, documents or papers necessary to effect such transfer of title upon request. WIFE further acknowledges that she has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. Wife agrees to execute a deed conveying her interest to HUSBAND, said deed to be held in escrow by WIFE's attorney and to be delivered to HUSBAND's attorney prior to the closing on HUSBAND's refinance of the mortgage currently encumbering the marital home. If not already done, HUSBAND shall remove WIFE's name from all utilities for the 10 marital home after the receipt of the Deed transferring WIFE's interest therein. As set forth above in paragraph 13, HUSBAND shall refinance the mortgage on the marital home within sixty (60) days of the signing of this Agreement. Upon the completion of said refinance, and after the expiration of the three (3) day right of rescission, HUSBAND shall pay to WIFE the sum of THIRTY-NINE THOUSAND NINE HUNDRED AND 00/100 DOLLARS ($39,000.00). Said payment shall be made to HUSBAND's attorney and forwarded to WIFE's attorney. b. Pipeline Road Property. WIFE agrees to transfer all her right, title and interest in and to the real estate situated adjacent to Pipeline Road, Newville, Cumberland County, Pennsylvania, and more specifically set out at Deed Book 184 Page 867 in the Cumberland County Recorder of Deeds Office, now titled in the name of HUSBAND and WIFE as tenants by the entireties, to HUSBAND and agrees to immediately execute now, and in the future, any and all deeds, documents or papers necessary to effect such transfer of title upon request. WIFE further acknowledges that she has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. Wife agrees to execute a 11 ' ( I L- deed conveying her interest to HUSBAND, which shall be prepared by HUSBAND's attorney and forwarded to WIFE's attorney. Said deed to be executed and returned to HUSBAND's attorney within seven (7) days of its receipt by WIFE's attorney. c. Enola Road Property. WIFE agrees to transfer all her right, title and interest in and to the real estate situated adjacent to Enola Road, Upper Frankfort Township, Cumberland County, Pennsylvania and more specifically set out at Deed Book 150 Page 130 in the Cumberland County Recorder of Deeds Office to HUSBAND and agrees to immediately execute now, and in the future, any and all deeds, documents or papers necessary to effect such transfer of title upon request. Said property is now titled in the name of HUSBAND and WIFE with an undivided one-half interest as tenants by the entireties, and Wilmer S. Bloser, Jr. and Peggy K. Bloser with an undivided one- half interest as tenants by the entireties, as joint tenants with the right of survivorship as to their respective one-half interests. WIFE acknowledges that she has no claim, right, interest or title whatsoever in said property and further agrees never to assert any claim to said property in the future. Wife agrees to execute a deed conveying her interest to HUSBAND, which shall be prepared by HUSBAND's attorney and forwarded to WIFE's attorney. Said deed to be executed 12 t f % and returned to HUSBAND's attorney within seven (7) days of its receipt by WIFE's attorney. d. All transfers from WIFE hereunder shall not be subject to capital gains tax. In the event such is assessed against WIFE for such transfers at anytime, then HUSBAND shall indemnify and hold WIFE harmless thereon. 15. BANK ACCOUNTS: HUSBAND and WIFE acknowledge that they each possess certain bank accounts and the like in their respective names. They hereby agree that each shall become sole owner of their respective accounts and they each hereby waive any interest in, or claim to, any funds held by the other in such accounts. 16. PENSIONS, ANNUITIES AND/OR RETIREMENT BENEFITS: WIFE agrees that any monies which HUSBAND has acquired through his interests in pensions, 401(k), profit sharing, savings and thrift plans, annuities and/or retirement benefits through his present or past employers shall remain his sole and exclusive property. WIFE agrees to waive any interest she may have in such property and further agrees that she will not assert any such claim in the future. HUSBAND agrees that any monies which WIFE has acquired through her interests in pensions, 401(k), profit sharing, savings and thrift plans, annuities and/or retirement benefits through her present or past employer shall remain her sole and 13 . f 1 S_ exclusive property. HUSBAND and further agrees that he will not assert any such claim in the future. 17. LIFE INSURANCE: HUSBAND is the owner of an Erie Life Insurance whole life policy with a cash balance of approximately $4,104.00. WIFE agrees to waive any interest she may have in said policy and cash balance and hereby acknowledges that she has no further claim, right, title or interest whatsoever in said policy and cash balance, and further agrees never to assert any claim to the asset in the future. WIFE is the owner of an Alianz Life Insurance whole life policy with a cash balance of approximately $2,126.00. HUSBAND agrees to waive any interest he may have in said policy and cash balance and hereby acknowledges that he has no further claim, right, title or interest whatsoever in said policy and cash balance, and further agrees never to assert any claim to the asset in the future. 18. MOTOR VEHICLES: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (a) The 1995 Saturn, presently titled in WIFE's names, shall become and remain the sole and exclusive property of HUSBAND. Any costs associated with the transfer of said vehicle shall be HUSBAND's sole responsibility; (b) The proceeds from the sale of WIFE's 1999 Ford Explorer, and any vehicle purchased subsequently by WIFE, shall be and remain the sole and exclusive property of WIFE; 14 e ' 1 L (c) The 2004 Polaris four-wheeler, presently titled in WIFE's name alone, shall become and remain the sole and exclusive property of HUSBAND; (d) The 1992 Polaris four-wheeler, presently titled in joint names, shall become and remain the sole and exclusive property of HUSBAND; (e) The 1968 Chevy Camaro, presently titled in WIFE's name alone, shall remain the sole and exclusive property of WIFE; (f) The Cherokee Camper, presently titled in joint names, shall become and remain the sole and exclusive property of WIFE; The titles to the said motor vehicles shall be executed by the parties, if appropriate for affecting transfer as herein provided, on the date of execution of this Agreement, and said executed title shall be delivered to the proper party on the distribution date. Each parry agrees to be solely responsible for the amounts presently due and owing against his or her respective automobile. 19. AFT ER-ACOUIRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 15 I f ; 20. WAIVER OF ALIMONY: HUSBAND and WIFE recognize and acknowledge that the foregoing provisions for their individual benefit are satisfactory with regard to their support and maintenance, past, present and future. The parties release and discharge the other absolutely and forever for the rest of their lives from all claims and demands, past, present or future, for alimony or for any provision for support or maintenance, except as specifically provided for herein. The parties further acknowledge that in consideration of the transfers made herein each completely waives and relinquishes any and all claims and/or demands they may now have or hereafter have against the other for alimony, alimony pendente lite, spousal support and counsel fees, except as specifically provided for herein. 21. HEALTH INSURANCE - WIFE: HUSBAND shall have no responsibility to provide WIFE with health insurance after the entry of a final Decree in Divorce. 22. HEALTH INSURANCE - CHILD: HUSBAND shall be responsible for and shall maintain health insurance benefits for the parties' minor child, Colton, so long as it continues to be provided as a benefit through his employer at a reasonable cost. HUSBAND agrees to continue to cover the child for as long as he is able to do so under the terms of his employer provided health plan. Should HUSBAND be without health insurance benefits through his employer, and should WIFE have benefits available through her employer, at a reasonable cost, both parties agree, in the best interests of the child, that he be placed under WIFE'S policy, with an appropriate credit to WIFE in child 16 I # t S support. If at any time both parties are without employer provided health care benefits, the parties agree to share equally in the cost of health insurance for the child. 23. COUNSEL FEES: HUSBAND and WIFE hereby agree that they each shall be responsible for their own counsel fees. Each party hereby indemnifies and agrees to indemnify and hold the other free and harmless against the claims of any attorney or person who rendered or claims to have rendered services to him or her in connection with the divorce proceeding and the negotiation of this Agreement or otherwise. 24. DEPENDENCY EXEMPTIONS: The parties agree that the tax dependency exemptions for Colton, shall be taken by HUSBAND for as long as the he is eligible under the current law and for as long as HUSBAND has primary physical custody of Colton. The parties agree to execute Internal Revenue Service Form 8332, and any other documents which may be required in order to allow HUSBAND to claim the dependency exemptions. The parties are hereby authorized to file the said form (or copies thereof) with their future income tax returns and to make such other use of the said form or other documents as is reasonably necessary to effectuate the provisions of this Paragraph. 25. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint Federal and State tax returns. Both parties agree that in the event any deficiency in Federal or State 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 17 s 0 f S 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. 26. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 27. TAX ADVICE: Both parties hereto hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or tax attorney with reference to the tax implications of this Agreement. HUSBAND has not been given any tax advice whatsoever by his attorney. Both parties hereby acknowledge that they have been advised to seek their own independent tax advice by retaining an accountant, certified public accountant, tax attorney or tax advisor with reference to the tax implications involved in this Agreement. 18 A 0 t Further, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgement that they have read this particular paragraph and have had the opportunity to seek independent tax advice. 28. EFFECT OF DIVORCE DECREE: The parties agree that, except as otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 29. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 30. WAIVER OF CLAIMS: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shall now have or hereafter acquire, under the present and future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, widower's allowance, right to take in intestacy, right to take against the Will of the other, and the right to act as administrator or executor of the other's estate. Each party will, at the request of the other, execute, acknowledge 19 I " and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 31. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 32. FINANCIAL DISCLOSURE: The parties confirm that they have relied on the completeness and substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. The parties acknowledge that there has been no formal discovery conducted in their pending divorce action and that neither party has filed an inventory and Appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, that party shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of said asset. The non-disclosing party shall be responsible for payment of counsel fees, costs or expenses incurred by the other party in seeking equitable distribution of said asset. 20 t 1 t Notwithstanding the foregoing, the Agreement shall in all other respects remain in full force and effect. 33. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 34. ADDITIONAL INSTRUMENTS: Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 35. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 36. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent Agreement. 37. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict 21 t ' s performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent defaults of the same or similar nature. 38. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no affect whatsoever in determining the rights or obligations of the parties. 39. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980 and any amendments thereto. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. W S WITNESS (.l .? ? ? ??,c??? (SEAL) Wesley L. oser \??. kAQja LQ-? (SEAL) Saundra J. Moser 22 I " t • COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ) On this, the j11 0 day of 2008, before me, a Notary Public, the undersigned officer, personally appe d Wesley L. Bloser, known to me (or satisfactorily proven) to be the person ose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public NOT/1MIAt OL 1Q0 A. KUB N0tyPAk abiftw ?? bou API 30 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF C w" L ) On this, the ? "day of je A 2008, before me, a Notary Public, the undersigned officer, personally appeaSaundra J. Bloser, known to me (or satisfactorily proven) to be the person wise name is subscribed to the foregoing Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Public NOIt'. all. SIX 1AMES A. MILLE€'., ;40tzry PUNIC MO HID pp'? /? rim! County 30,2M 23 WESLEY L. BLOSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-3309 SAUNDRA J. BLOSER, CIVIL ACTION -LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. 11?_, I 1 0, Date: /? 2$' jitSi7 Saundra J. Bloser iT? FVi ,y W ? WESLEY L. BLOSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-3309 SAUNDRA J. BLOSER, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed on June 4, 2007, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. 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. § 4904 relating to unsworn falsification to authorities. Date: ?/G Z v O Saundra J. Bloser Fr. r L r 1 I-T;. 7 l.A.Z hJ CiZ WESLEY L. BLOSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-3309 SAUNDRA J. BLOSER, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce code was filed on June 4, 2007, on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. 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. § 4904 relating to unworn falsification to authorities. Z?tQ? Date: 1 Wesley L. Iffoser to::' c G ? 4-= . f .... ?'?.. 4: WESLEY L. BLOSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-3309 SAUNDRA J. BLOSER, CIVIL ACTION - LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $ 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final 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. §4904 relating to unworn falsification to authorities. Date: 2 C Q Wesley L. loser C7 c?-..a MOP f WESLEY L. BLOSER, Plaintiff, V. SAUNDRA J. BLOSER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3309 CIVIL ACTION- LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under section 3301(c) of the Divorce code. 2. Date and Manner of service of the Complaint: United States First Class Mail on or about June 2, 2007. 3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by Plaintiff on July 28, 2008; and by Defendant on July 28, 2008. 4. Related claims pending. The economic claims have been settled by Agreement dated July 28, 2008. 5. Date the Plaintiffs Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: Waiver of Notice being filed simultaneously herewith. 6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed with the Prothonotary: Waiver of Notice being filed simultaneously herewith. Respectfully submitted: ROBINSON "ERA Date: August 11, 2008 By: KRIS Elk! , ESQUIRE Attorney .D. No. 69140 2505 North Front Street P.O. Box 5320 Harrisburg, PA 17110 Telephone No. (717) 232-8525 Attorney for Plaintiff v r . w ? 73 . cr" "'1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. WESLEY L. BLOSER Plaintiff nx, A No. 07-3309 VERSUS SAUNDRA J. BLOSER Defendant DECREE IN DIVORCE ?J ,-7 AWS'dA.. AND NOW, l IT IS ORDERED AND DECREED THAT WESLEY L. BLOSER AND SAUNDRA J. BLOSER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the parties' Property Settlement Agreement dated July 28, 2008, is hereby incorporated as if set forth at length but shall not mere in the final Divorce Decree. Bt TH ATTEST: J. PROTHONOTARY T14? ??? fic - -3 'Oro"