HomeMy WebLinkAbout03-4276
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-Yil'l;.CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
NOTICE
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 in divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland 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 arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-47-14> CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the Plaintiff, Susan M. Hopkins, by her attorney, Marcus A. McKnight, III,
Esquire, and files this Complaint in Divorce against the Defendant, John W. Hopkins, representing
as follows:
1. The Plaintiff is Susan M. Hopkins, an adult individual residing at 2263 Walnut
Bottom Road, Carlisle, Cumberland County. Pennsylvania 17013.
2. The Defendant is John W. Hopkins, an adult individual residing at 2263 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on June 2, 1996.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the
two parties.
Respectfully submitted,
By:
Date: August 29, 2003
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
s~1:J.jlfb-
Date: August 29, 2003
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-
CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised ofthe availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: August 29, 2003
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SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JOHN W. HOPKINS,
Defendant
2003-4276, CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. ]920.4 (a)(l)(i)
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant, John
W. Hopins, on September 15, 2003, by certified, restricted delivery mail, addressed to him at
P. O. Box B93, Orrstown, Pennsylvania 17244, with Return Receipt Number 70012510 0009
2828 4234.
3. That the said receipt for certified mail is signed andl attached hereto and made a part
hereof.
false statements herein made are subject to the penalties of 1
unsworn falsification to authorities.
Date: September 17,2003
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or on ... front ff space permits.
1. ArIde AddI Hsed to:
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CARLISLE PA 17013
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Domestic Return Receipt
102595-01-M-1424
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SUSAN M. HOPKINS,
PlaintifffRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 2003-4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant/Petitioner
IN DIVORCE
ORDER OF COURT
AND NOW, this _day of , 2003, 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 on at
for a conference, after which the conference office 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 1910.22 (c)
4. verification of child care expenses
5. proof of medical coverage which you may hav(:, 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,
Judge
Date of Order:
Conference Officer
SUSAN M. HOPKINS,
PlaintifffRespondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
NO. 200:1-4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant/Petitioner
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, this 2nd day of October 2003, comes SUSlill M. Hopkins, by and through
his attorneys, IRWIN & McKNIGHT, and petitions this Honorable Court as follows:
1.
The Plaintiff/Petitioner is Susan M. Hopkins, an adult individual who resides at 2263
Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013.
2.
The Defendant/Respondent is John W. Hopkins, an adult individual with a current
address ofP. O. Box B93, Orrstown, Franklin County, Pennsylvania.
3.
The Petitioner and Respondent were married on June 2, 1996, in Liberty, New York, and
were separated on or about August 15,2003.
4.
The Plaintiff has filed a Divorce Complaint in Cumbf:rland County Court of Common
Pleas at 2003-4276 on August 29, 2003.
2
5.
The Petitioner is without ability to earn income suffici'~nt to meet his reasonable needs
and pay for her legal expenses.
WHEREFORE, Petitioner, Susan M. Hopkins. respectfully requests that this Honorable
Court order alimony pendente lite in an amount equal to the Pennsylvania State Support
Guidelines.
Respectfully submitted,
Mareu A. Me
60 West Pomfret
Carlisle, P A 17013
Supreme Court J.D. No: 25476
(717) 249-2353
Attorney for the Petitioner
Susan M. Hopkins
By:
Date: October 3, 2003
3
VERIFICATION
The foregoing Petition for Alimony Pendente Lite is based upon information which has
been gathered by counsel and myself in the preparation of this action. I have read the statements
made in this document and they are true and correct to the best of my knowledge, information
and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unsworn falsification to authorities.
I
/ !.~'dhv
SU~AN M. HOPKI
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Date: OCTOBER 3, 2003
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SUSAN M. HOPKINS,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
JOHN W. HOPKINS,
Defendant/Respon ent
NO. 2003-4276 CIVIL TERM
IN DIVORCE
Pacses# 056105885
ORDER OF COURT
AND NOW, this 23rd da of October, 2003, based upon the Court's determination that Petitioner's
monthly net income/earni g capacity is $1,832.09 and Respondent's monthly net income/earning
capacity is $2,303.47, it i hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disburse ent Unit, $627.00 per month payable bi-weekly as follows; $289.38 for
alimony pendente lite an $0.00 on arrears. First payment due on or before November 1,2003 in the
amount of$627.00. Arre s set at $627.00 as of October 23,2003. The effective date of the order is
October 3,2003.
Defendant is to make a I payment in the mount of $627 .00 directly to the Petitioner on or before
November I, 2003. Both parties are to report to DRO that said payment has been paid and the
Alimony Pendente Lite a count will be given credit for the amount paid.
Failure to make each pa ent on time and in full will cause all arr,ears to become subject to
immediate collection by 11 of the means as provided by 23 Pa.C.S.s 3703. Further, ifthe Court
finds, after hearing, that t e Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil c ntempt of Court and its discretion make an appropriate Order, including,
but not limited to, comm' ment of the Respondent to prison for a period not to exceed six months.
Said money to be turned
check or money order.
to:
ver by the P A SCDU to: Susan M. Hopkins. Payments must be made by
I checks and money orders must be made payable to P A SCDU and mailed
P A SCDU
P.O. Box 69110
Harrisburg, PAl 71 06-911 0
Payments must include t e defendant's P ACSES Member Number or Social Security Number in
order to be processed. D not send cash by mail.
Unreimbursed medical ex~enses that exceed $250.00 annually are 1:0 be paid 56% by the respondent
and 44% by petitioner. Tl/1e petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical ex*enses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry or-this order, the Respondent shall submit written proof that medical
insurance coverage has bqen obtained or that application for coverage has been made. Proof of
coverage shall consist, at' minimum, of: I) the name of the health care coverage provider(s); 2) any
applicable identification umbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a des ription of any restrictions on usage, such as prior approval for hospital
admissions, and the ma er of obtaining approval; 6) a copy of the: benefit booklet or coverage
contract; 7) a description fall deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become mal ten days after the mailing of the notice of the entry of the Order to the
parties unless either part files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
10-24-03 to: <
Petition r
Respon ent
Marcus cKnight, Esquire
Carol Li dsay, Esquire
BY THE COURT,
Q7J1~
Edgar B. Bayley
J.
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State I
Co./City/Dist. of CUMBER
Date of Order/Notice 10/2
Tribunal/Case Number (See
I
OfDER/NOTlCE TO WITHHOLD INCOME FOR SUPPORT
I
/03
ddendum for case summary)
@Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
DFAS CLEVELAND C NTER*
C/O DFAS CODE L
GARNISHMENT OPS
PO BOX 998002
CLEVELAND OH 441 9-8002
))/:J e::0Zl:j. <!d-7iP {7;///c..
/')f(!S?S {)5'(pIDSyJ~
RE: HOPKINS, ,JOlIN W.
Employee/Obligor's Name (last, First, l)
071-46-1565
Employee/Obligor's Social Security Nu ber
8165101056
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, Ml)
EmployerMlithholder's Federal EIN umber
See Addendum
ORDER INFORMA TlON: Thi
from CUMBERLAND
amounts from the above-nam
issued by your State.
$ 627.00 per month n current support
$ 0.00 per month n past-due support
$ 0.00 per month in medical support
$ 0 . 0 0 per month r genetic test costs
$ per month i other (specify)
for a total of $ 627.0 per month to be forwarded to payee below.
You do not have to vary your ay cycle to be in compliance with the suppol1 order. If your pay cycle does not mat h
the ordered support payment ycle, use the following to determine how much to withhold:
$ 144.69 per weekly ay period.
$ 289.38 per biweekl pay period (every two weeks).
$ 313.50 per semimo thly pay period (twice a month).
$ 627.00 per monthl pay period.
REMITTANCE INFORMATlO :
You must begin withholding n later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment ithin seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost f withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total ithheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly e rnings. For the purpose of the limitation on withholding, the following information i
needed (See #10 on pg. 2).
r dependent names and birth dates associated with cases on attachment.
is an Order/Notice to Withhold Income for Support based upon an order for suppo
County, Commonwealth of Pennsylvania. By law, you are required to deduct the e
d employee's/obligor's income until further notice even if the Order/Notice is not
Arrears 12 weeks or greater?
Oyes @ no
If remitting by EFT/EDI, please all Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676 9580 for instructions.
Make Remittance Payabl to: PA SCDU
Send check to: Pennsylva ia SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS M ST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligo ~~C~Jcf!m!.jfi';f).oB SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED,
DO NOT SEND CASH BY M. '1ft;" A,~' 't' LJ -" ["-0)
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BYTHECO~ ..,. \
C'j)(~~)3 MlfC6Y
Date of Order:
Service Type M
OMBNo,;097(}-()154
Form EN-028
Worker ID $IATT
ADDITIOrllAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are req~'red to provide a copy of this form to your employee. If your employee works in a state that is
different from the state at issued this order, a copy must be provided to your employee even jf the box is not checked.
1. V:Ve appreciate the voluntary ~o pliance of Fede~ally rec?gnized Indian t~ibes, .tribal!v.owned businesses, and lndian-owned !,
businesses located on a reservation hat 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 re eipt of this order have priority. tfthere are Federal tax levies in effect please contact the requesti g
agency listed below.
3. Combining Payments: You can ombine withheld amounts from more than one employee/obligor's income in a single payment 0
each agency requesting withholding You must, however, separately identify the portion of the single payment that is attributable to ach
employee/obligor.
4. * ..... -' . I"" 'thl,old;..g nLel, Sella iJ ,g tl,~ (Jayll,eht. f-he---
~,' . .~, .~" . ee'; ,,'gb. You must comply with the law f the
state of the employee's/obligor's prirlcipal place of employment with respect to the tim~ periods within which you must implement t e
withholding order and forward the s pport payments.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support agai st
this employee/obligor and you are u able to honor all support Order/Notices due to Federal or State withholding limits, you must foil w
the law of the state of employee's/ob igor's principal place of employment. You must honor all Orders/Notices to the greatest extenl
possible. (See #1 0 below)
6. Termination Notification: You m~st promptly notify the Requesting Agency when the employee/obligor is no longer working for ou.
Please provide the information reque ted and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S 10: 249 016300
EMPLOYEE'S/OBlIGOR'S AME: HOPKINS , JOHN W.
EMPLOYEE'S CASE IDENTI IER, B165101056 DATE OF SEPARATION,
LAST KNOWN HOME AD RESS:
NEW EMPLOYER'S NAME/ DDRESS:
7. Lump Sum Payments: You may b required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any ques ons about lump sum payments, contact the person or authority below.
8. liability: If you fail to withhold in ome as the Order/Notice directs, you are liable for both the accumulated amount you should h ve
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania Stale law governs unle s
the obligor is employed in another St te, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination, You are subj ct to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplin 'Y action against any employee/obligor because of a support withholding. Pennsylvania State I w
governs unless the obligor is employe in another State, in which case the law of the State in which he or she is employed governs.
10. * Withholding limits: You may n t withhold more than the lesser of, 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)1: pr 2) the amounts allowed by the State of the employee's/obligor's principal place of employme t.
The Federal limit applies to the aggre! te disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, lac I taxes; Social Security taxes; and Medicare taxes.
11, Additional Info,
*NOTE: If you or your agent are ierved 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 oreier with respect to these items.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS Sli; ION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at j717) 240-6225 or
P.O. BOX 320 by FAX at lZ1..ZL240-624R or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker ID $IAT
I
I
I
OMB No.: 097Q..0154
O~DER!NOTICE TO WITHHOLD INCOME FOR SUPPORT
State I
Co./City/Dist. of CUMBER
Date of Order/Notice 10/2 /03
Tribunal/Case Number (See ddendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
DFAS CLEVELAND C NTER*
C/O DFAS CODE L
GARNISHMENT OPS I
PO BOX 998002
CLEVELAND OH 441 9-8002
))!i ~Z;3.. </~7tfl {'If/lc..
;J JI(!. <;? S 05{" I C; S y f-r-
RE: HOPKINS, JOHN W.
Employee/Obligor's Name {Last, First,
071-46-1565
Employee/Obligor's Social Security Nu
8165101056
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, MI)
EmployerANithholder's Federal EIN umber
See Addendum r dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: Thi 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 the
amounts from the above-nam d employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 627.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes <Xl no
$ 0.00 per month i medical support
$ 0 . 00 per month r genetic test costs
$ per month i other (specify)
for a total of $ 627.0 per month to be forwarded to payee below.
You do not have to vary your ay cycle to be in compliance with the support order. If your pay cycle does not mat h
the ordered support payment ycle, use the following to determine how much to withhold:
$ 144.69 per weekly ay period.
$ 289.38 per biweekl pay period (every two weeks).
$ 313.50 per semim thly pay period (twice a month).
$ 627.00 per monthl pay period.
REMITTANCE INFORMATlO
You must begin withholding n later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment ithin 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 ithheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly e mings. For the purpose of the limitation on withholding, the following information i
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer SelVice at 1-877-67 9580 for instructions.
Make Remittance Payabl to: PA SCDU
ia SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
ST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
:~CiJje"(cW!Jifi"")PR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED
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Send check to: Pennsylv
IN ADDITION, PA YMENTS
above as the Employee/Oblig
DO NOT SEND CASH BY M
Date of Order:
SelVice Type M
OMB No.; 0970-0154
Form EN-028
Worker ID $IATT
ADDITION f.\L INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I(lihecke~ you are requ r ed, to provipe a copy of this form to your'd~loyee. If your employe~ works in,a state tha1is
d I erent rom the state t at Issued this order, a copy must be proVI to your employee even If the box IS not chec ed.
1. We appreciate the voluntary com liance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation t at choose to withhold in accordance with this notice.
2. Priority, Withholding under this prder/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before ree ipt of this order have priority. If there are Federal t.ax levies in effect please contact the requesti g
agency listed below.
3. Combining Payments: You can c mbine withheld amounts from more than one employee/obligor's income in a single payment t
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to ac
employee/obligor.
4.* " :'?' I ,,",u:.LLoldillg nLeh Kndihg tire p8ylllehl:--ffte-
v' ,,;u ,,' -0-' You must comply with the law ( th
state of the employee's/obligor's prin ipal place of employment with respect to the time periods within which you must implement th
withholding order and forward the su pport payments.
5.' Employee/Obligor with Multiple upport Holdings: If there is more than one Order/Notice to Withhold Income for Support agai st
this employee/obligor and you are ur jab Ie to honor all support Order/Notices due to Federal or State withholding limits, you must foil w
the law of the state of employee's/obi gor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #1 0 below)
6. Termination Notification: You m st promptly notify the Requesting Agency when the employee/obligor is no longer working for ou
Please provide the information reque ted and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID, 2491 ~16300
EMPLOYEE'S/OBlIGOR'S ~ AME, HOPKINS, JOHN W.
EMPLOYEE'S CASE IDENTI IER: 8165101056 DATE OF SEPARATION,
LAST KNOWN HOME AD[ RESS:
NEW EMPLOYER'S NAME/ DDRESS:
7. Lump Sum Payments: You may b required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay, If you have any quest ons about lump sum payments, contact the person or authority below.
8. liability: If you fail to withhold in orne as the Order/Notice directs, you are liable for both the accumulated amount you should h ve
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unle s
the obligor is employed in another St e, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination: You are subj ct to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplin ry action against any employee/obligor because of a support withholding. Pennsylvania State I w
governs unless the obligor is employe in another State, in which case the law of the State in which he or she is employed governs,
10. * Withholding limits: You may n t withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)1; Dr 2) the amounts allowed by the State of the employee's/obligor's principal piace of employme t.
The Federal limit applies to the aggre1 te disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, loc I taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
* NOTE: If you or your agent are ~rved 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 ore er with respect to these items.
Submitted By: If you or your employee/obligor have any questions,
nOMESTIC RELATIONS SEC ION contact WAGE ATTACHMENT UNIT
11 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) ,'40-6248 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 $IAT tr
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e
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HOPKINS, JOHN W.
PACSES Case Number 056105885
Plaintiff Name
SUSAN M. HOPKINS i
Docket Attachment Amou,/!
03-4276 CIVIL$ 627.00,
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
you are required to en II the child(ren)
in any health insuran e coverage available
employee's/obligor's emp oyment.
Docket Attachment Amount
$ 0.00
Child(ren)'s ~'ame(s):
DaB
you are required to enroll the child(ren)
in any health insurance coverage availabl
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amou
$ 0.00
Child(ren)'s Name(s):
DaB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
D B
If checked, you are required to en 011 the child(ren)
in any health insuran e coverage available
employee's/obligor's em layment.
D If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage availabl
through the employee's/obligor's employment.
Docket Attachment Amo nt
$ 0.0
Child(ren)'s Name(s):
DaB
PACSES Case Number
Plaintiff Nam'~
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s),
PACSES Case Number
Plaintiff Name
you are required to e roll the child(ren)
in any health insura ce coverage available
employee's/obligor's em layment.
If checked, you are required to enroll the child(ren)
in any health insurance coverage availabl
employee's/obligor's employment.
Addendum
Form EN-028
Worker ID IATT
Service Type M
OMBNo.:0970-0154
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SAIDIS
SHUFF, FLOWER
& LINDSAY
AlTORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
SUSAN M. HOPKINS,
Plaintiff/Petitioner
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - DIVORCE
:NO. 2003-4276 CIVIL TERM
:IN DIVORCE
vs.
JOHN W. HOPKINS,
Defendant/Respondent
:Pacses # 056105885
DEMAND FOR HEARING
DATE OF ORDER:
October 23, 2003
AMOUNT:
$627.00 PER MONTH
FOR:
Alimony Pendente Lite
REASON(S):
Incorrect calculation of obligation. Appeal preserved letter to Domestic
Relations Office of October 31S\ 2003 upon which the incorrect Pacses Number
was affixed.
PARTY FILING DEMAND FOR HEARING:
Saidis, Shuff, Flower & Lindsay,
By:
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Dat
Carol J. Linasay,
,
ID # 44693 f
26 We~t HigH S et
Carlisle, PA 17013
(717) 243-6222
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SUSAN M. HOPKINS,
Plaintiff/Petitioner
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION. DIVORCE
:NO. 2003-4276 CIVIL TERM
:IN DIVORCE
vs.
JOHN W. HOPKINS,
Defendant/Respondent
AND now, this
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2003, I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER &
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LINDSAY, Attorneys, hereby certify that I served the within Demand for Hearing this
day by depositing same in the United States Mail, First Class, Postage Prepaid, in
Carlisle, Pennsylvania, addressed to:
Marcus A. McKnight III, Esquire
W. Pomfret Professional Building
60 W. Pomfret Street
Carlisle, PA 17013-3222
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Respon ent,
By:
Carol ,iJ. Li
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26 We igh Street
Carlisle, PA 17013
(717) 243-6222
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SAIDlS
SHUFF, FLOWER
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ATrORNEYS-AT-LAW
26 w. High Street
Carlisle, P A
SUSAN M. HOPKINS,
Plaintiff/Petitioner
vs.
JOHN W. HOPKINS,
Defendant/Respondent
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION. DIVORCE
:NO.2003-4276 CIVIL TERM
:IN DIVORCE
:Pacses # 056105885
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Defendant, John W. Hopkins, in the
above captioned case.
By:
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SHUFF, FLOWER
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ATTORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
II
SUSAN M. HOPKINS,
Plaintiff/Petitioner
vs.
JOHN W. HOPKINS,
Defendant/Respondent
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - DIVORCE
:NO. 2003-4276 CIVIL TERM
:IN DIVORCE
:Pacses # 056105885
PRAECIPE TO WITHDRAW DE NOVO HEARING
TO THE PROTHONOTARY:
Please withdraw request of the Defendant, for a hearing de novo. Counsel for the
Plaintiff concurs as set out in his letter to me of November 18, 2003 in paragraph two
(2) attached hereto.
SAlOIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys fo - PJaintifffA,
I .
By:
Car 'J. L.:'ndsay, Esquire
ID#
26 West High Street
Carlisle, PA 17013
(717) 243-6222
LAW OFFICES
NOV 1 9 lUl/j
IRWIN & McKNIGHT
ROGER B. IR WIN
MARCUS A, McKNIGHT. 1/1
DOUGLAS G, MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYLVANIA /70/3-3222
(717) 249-2353
FAX (717) 249-6354
E-MAIL: OFFICES@jMHLAW.COM
HAROLDS. IRWIN (1925-1977)
HAROLDS./RWIN. JR. (/954-1986)
IRWIN, IRWIN & IRWIN (1956-/986)
IRWIN.IRW/N & McKNIGHT (1986-1994)
IRWIN, McKNIGHT & HUGHES (l994-2()()3)
IRWIN & McKNIGHT (2()03- )
November 18, 2003
Carol J. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, P A 17013
Re: Hopkins v. Hopkins
Dear Carol:
You have requested a comprehensive settlement proposal from us before Mr. Hopkins
pays any alimony or any contribution toward the Agreement of Sale. I need to emphasis that the
real estate is still under foreclosure, and your client has failed to pay the court -ordered alimony
as well as refused to make any contribution toward the Agreement of Sale payments.
My client's position is as follows:
1. Susan is covered by her own medical insurance effective November I, 2003.
Mr. Hopkins was to drop his coverage effective November 1,2003. I have
enclosed a copy of Susan's insurance card.
2. Mr. Hopkins needs to drop his appeal and pay the arrearages owed to Susan
based upon the Order of Court. Ifhe does so immediately, we should be able
to catch up the payments on the Agreement of Sale.
3. My client had to replace the pump for the water supply of her home. I have
enclosed a copy of that bill. Mr. Hopkins should pay at least 60% of the bill.
4. With regard to your client's retirement, Susan seeks 60% of the value of the
retirement account for the eight years of marriage. A Qualified Domestic
Relations Order will be needed to disburse the retirement.
5. Susan wants 60% of the cash/retirement accounts which Mr. Hopkins has
accumulated during the marriage.
6. My client requires 60% of the equity in the real estate.
Carol 1. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay
Page Two
November 18, 2003
Please let me know your client's position as soon as possible regarding the above-
referenced proposal.
Very truly yours,
MAM/mln
Encl.
cc: Ms. Susan Hopkins
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a4-20-'04 09:39 FROM-Salzmann, Hughes 7172497334
~11-I9-DZ 13141 FROM-Cu_blrllnd County DO.lltIG Rllations 7t1Z4'0&24B
T-049 P03/04 U-343
T-547 P. DDVID! He5
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No. 03-L/Z71o Civil
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Date of Application:
APR21.
IJ.k fllrERLAND COVN1lY DOMESTIC BELA nONS
0, 6 Request fOl' Support Record Search
Name: Ii~ rt8
Address:
Soc:iI1 Security Number: 0; I - '-fID -/5115 D.O.B.;
DOIDIlmc Relations Case NumberjfKnown: ~) GeB~
PartyRequestiDglDfurmation: 5fJJzma.nIJ, ~ p; t. ....:...5h1YlP1
(PIiDt oJrFImI Namr:)
~3 fl51J1~tIu1 ,SPJt) Ylfj #<<ti 1St .3J ~/i8f(J J
O'eIeplIllaBNumbcr) ~ (~ ' , /7013
.117- aLf.q~ 73?A PJ4r7 ~7/YU.rJ '
(Fax NUIIIbct) (S~
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A ~eDty DoU.r (520.00) Fee is Due per SOlciaJ Sec:urity Number
Make dleck or moaey oreler payable to: DRS/LieJI Search
'f- INITIAL REQUEST
\
,..' ') Has no R.ec:ord in Domeme Relations, as of: (Data)
Support Arrears as ofBDd of Month Prior to Date of App,lication: S 135,;l. 73,
MoII!hly Total SUppolt ObIlption: S /c:n, 00 / moo 1h .
,
n. Ammmt shown above: is reflected in the Domestic &~lations Section Office of
CUmberllPld County, PllIlIISY1vlUlia. mV'YIbu-::t!. ~I IPS i 0 I oS to
DOIDIlsticRelAtions Case Number: _P /lese..') ~ 05 /;11 OS 3'gS
Slped: ~ fiJ. t)~
(l..itII SardI Coozdinator)
if .. 20 .. 0 L{
(IlD)
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BRING-DOWN REQUEST
Support Arrears; $
Aa Of:
(Dam)
Siped:
(Lieo. CoordiDaIor)
(Date)
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*** Lien Satisfisfaction Receipt Available Upon Request.........
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SUSAN M. HOPKINS,
Plaintiff /Petitioner
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
2003-4276 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
JOHN W. HOPKINS,
DefendantJRespondent
PETITION FOR SPECIAL RElm
AND NOW, this 11th day of May 2004, comes the Plaintiff/Petitioner, Susan M.
Hopkins, by her attorneys, IRWIN & McKNIGHT, and makes the following Petition for Special
Relief against the Defendant/Respondent, John W. Hopkins, as follows:
1.
The Petitioner is Susan M. Hopkins and is the Plaintiff in a divorce action filed at 2003-
4276 in Cumberland County, Pennsylvania. Her address is 2263 Walnut Bottom Road, Carlisle,
Cumberland County, Pennsylvania 17013.
2.
The Respondent is John W. Hopkins and is the Defendant in this divorce action. His
address is P. O. Box 93, Orrstown, Pennsylvania 17244.
3.
The parties were married on June 2, 1996, and purchased the marital residence located at
2263 Walnut Bottom Road, Carlisle, PA using proceeds from a settlement they received.
4.
In July of 2003, the Respondent left Petitioner without assisting with payment of the
expenses of the marital residence.
2
EXHIBIT "A"
A, B, TYPE OF LOAN:
1DFHA 20FmHA 3, ~]CONV UNINS 4 OVA 5,OCONV INS,
U.S. DEPARTMENT OF HOUSING & URBAN DEVELOPMENT 6, FILE NUMBER: \7, LOAN NUMBER:
SETTLEMENT STATEMENT PALMERJ04-04 1010033093
8, MORTGAGE INS CASE NUMBER
C, NOTE: This form is furnished to give you a statement of actual settlement costs. Amounts paid to and by the settlement agent are shown,
Items marked ~[POC]" were paid outside the closing: they are shown here for informational purposes and are not included in the totals.
1.0 3198 (PAlMERJ04-04PFDIPALMERJ04-04/33)
D, NAME AND ADDRESS OF BORROWER: E, NAME AND ADDRESS OF SELLER: F NAME AND ADDRESS OF LENDER
JESSE L. PALMER, SR: JOHN V, HOPKINS MORTGAGE LENDERS NETWORK USA,
JESSICA R, PALMER SUSAN HOPKINS 213 COURT STREET
11 ROBYN DRIVE 2263 WALNUT BOTTOM ROAD MIDDLETOWN, CT 06457
NEWVILLE, PA 17241 CARLISLE, PA 17013
G, PROPERTY LOCATION H, SETTLEMENT AGENT: 25-1894310 1. SETTLEMENT DATE:
2263 WALNUT BOTTOM ROAD Salzmann, Hughes & Fishman, P.C.
CARLISLE, PA 17013 April 29. 2004
CUMBERLAND County, Pennsylvania PLACE OF SETTLEMENT
95 Alexander Spring Road, Ste. 3
Carlisle, PA 17013
J, SUMMARY OF BORROWER'S TRANSACTION K, SUMMARY OF SELLER'S TRANSACTION
100. GROSS AMOUNT DUE FROM BORROWER: 400. GROSS AMOUNT DUE TO SELLER:
198,900,00 401. Contract Sale$ Price , 198,900.00
101. Contract Sales Price I
102. Personal Pronertv 402. Personal Pro[lerty I
103. Settlement Charnes to Borrower Line 1400 I 9,086,60 403,
104, I 404, I
105, I 405, I
Adiustments For Items Paid Bv Seller in advance Adiustments For Items Paid By Seller in advance
106. Countv/Twn. Taxes 04/29/04 to 12/31/04 ' i 267.43 406, Countv/Twn. Taxes 04/29/04 to 12/31/04 , 267.43
,
107, School Taxes 04/29/04 to 07/01/04 I 349,64 407, School Taxes 04/29/04 10 07/01/04 I 349.64
108. Assessments to , 408, Assessments to I
109, 409, I
110 410, I
111, 411, I
112, 412. I
120. GROSS AMOUNT DUE FROM BORROWER 208,603,67 420, GROSS AMOUNT DUE TO SELLER i 199,517,07
200. AMOUNTS PAID BY OR IN BEHALF OF BORROWER: 500. REDUCTIONS IN AMOUNT DUE TO SELLER'
201. Oeoosit or earnest money I 500,00 501. Excess DeoClsit (See Instructions) I
202. Princioal Amount of New Loanls) I 159,120,00 502. Settlement Charges to Seller (Une 1400) 14,932,23
203. Existina loan's' taken subiect to 503. Existina loan(s) taken subject to I
204. 504, Payoff of first Mortgage to ORRSTOWN BANK/19335390 150,758,99
205, I 4,823,16
505, Pavoff of second Mortgage to WILLIAM L, SCHREIBER I
206. 506 I
207. 507. (Oeoosit disb. as proceeds) I
208. 508, !
209, 509, I
Adlustments For Items UnDeid Bv Seller Adiustments For Items Unpaid By Seller
210, Countv/Twn. Taxes to I 510, CountvlTwn. Taxes to I
211. School Taxes to I 511, School T aXE!S to
212, Assessments to I 512, Assessments 10 I
213 513, I
214 SELLER ASSISTANCE 11.000,00 514, SELLER ASSISTANCE I 11,000,00
215, 515 I
216, 516, i
217, 517,
218, 518, I
219, 519,
,
220, TOTAL PAID BY/FOR BORROWER 170,820,00 520, TOTAL REDUCTION AMOUNT DUE SELLER I 181,514,38
300. CASH AT SETTLEMENT FROMITO BORROWER: I
600. CASH AT SETTLEMENT TO/FROM SELLER:
301. Gross Amount Due From Borrower (Line 120\" 206,603,67 601. Gross Amclunt Due To Seller (Une 420) I 199,517,07
302, Less Amount Paid By/For Borrower (Line 220\ ( 170,620,00) 602. Less Reductions Due Seller (Une 520) '( 181,514,38:
303. CASH ( X FROM) ( TO) BORROWER 37,983,67 603, CASH ( X TO) ( I
I FROM) SELLER , 18,002,69
I
/' ) , , , .
The underSigned hereby acknowledge r,ie I:: of ~ eom~~.eopy of pages 1 &2 of thiS slatement & any allaehments referred to herein,
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OMB NO. 2502-0265 qr
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L. SETTLEMENT CHARGES
700. TOTAL COMMISSION Based on Price $ @ % 11,27'1,00 PAID FROM PAID FROM
Division of Commission (fine 700) as Follows: BORROWER'S SELLER'S
701. $ 11.274,00 to RE/MAX STERLING ASSOCIATES FUNDS AT FUNDS AT
702, $ to SETTLEMENT SETTLEMENT
703. Commission Paid at Settlement 11,27400
704, to
800. ITEMS PAYABLE IN CONNECTION WITH LOAN
801. Loan Origination Fee % to
802. Loan Discount 0,3750 % to MORTGAGE LENDERS NETWORK USA, INC 596,70
803. Appraisal Fee to JOSEPH p, BEDDIA 275.00
804, DOC PREP FEE to MORTGAGE LENDERS NETWORK USA, INC, 250,00
805, MORTGAGE BROKER FEE to A LENDING HAND MORTGAGE RESOURSES 2,406,10
806. UNDERWRITING FEE to MORTGAGE LENDERS NETWORK USA, INC, 449,00
807, PROCESSING FEE to A LENDING HAND MORTGAGE RESOURSES 400,00
808,
809,
810,
81L
900. ITEMS REQUtRED BY LENDER TO BE PAID IN ADVANCE
901, Interesl From 04/29/04 to 05/01104 @ $ 24276500/day ( 2 days %) 48,55
902. Mortga!Je Insurance Premium for months to
903. Hazard Insurance Premium for 10 vears 10 ERIE INSURANCE POC $586.00b
904,
905,
1000. RESERVES DEPOSITED WITH LENDER
1001. Hazard Insurance months $ per month
1002. Mortaaae Insurance months $ per month
1003. CountvJTwp. Taxes months $ per month
1004. School Taxes months $ per month
1005. Assessments months @ $ per month
1006, monlhs If!) $ per month
1007, months @ $ per month
1008. months @ $ per month
1100. TITLE CHARGES
1101, Settlement or ClasinQ Fee to
1102, Abstract or Title Search 10
1103, Title Examination to
1104, Title Insurance Binder to
1105 Document Preparation 10 Salzmann, Hughes & Fishman, P,C. 250,00
1106, Notarv Fees to Salzmann, Huahes & Fishman, P.C. 1000
1107, Attorney's Fees to
(includes above (tern numbers: )
1108, Title Insurance to Stewart Title Guarantv Comoanv/SHF PC 1 353,75
(includes above item numbers:1101-1105; 1107-1111 )
1109, Lender's Coverage $ 159,100,00
1110, Owner's Coverage $ 198,900,00 '1,353,75
1111. Endorsements 100/300/900 to Stewart Title Guaranty Company/SHF, PC 150,00
1112, Insured Closing Protection Ltr to Stewart Title Guaranty Company/SHF, PC 35,00
1113,
1200. GOVERNMENT RECORDING AND TRANSFER CHARGES
1201. Recording Fees: Deed $ 38,50 ; Mortgage $ 64,50; Releases $ 103,00
1202. CitY/County Tax/Stamos: Deed 1,989.00' Mort a e 1,989,00
1203, State Tax/Slamps Revenue Stamos 1,989,00; MortaaQe 1,989,00
1204.
1205,
1300. ADOITIONAL SETTLEMENT CHARGES
1301, Survev to
1302. Pest lnsnection 10
1303. Overninht Mail Fee to Salzmann, Huohes & Fishman, P.C. 20,50 4{;,50
1304, DEMOSTIC RELATIONS SEARCH to SALZMANN, HUGHES & FISHMAN 20,00
1305. See addit'l disb. exhibit to 1,000,00 1,352,73
1400. TOTAL SETTLEMENT CHARGES (Enter on Lines 103, Section J and 502, Section KI ./ ) 9,08660 14,932,23
By signing page 1 Oflhisstaternent.lheslgn..toriesackno~edgereceiplofacolDpleted copy of page 2 01 this
/0 ~I 'fJ_
Salz an ~he'lrll Fishman, P,C,
Settl gent
Certified to be a true copy.
I
Page 2
ADDITIONAL DISBURSEMENTS EXHIBIT I
Borrower: JESSE L. PALMER, SR.
JESSICA R. PALMER
Seller: JOHN V. HOPKINS
SUSAN HOPKINS
Lender: MORTGAGE LENDERS NETWORK USA,
Settlement Agent: Salzmann, Hughes & Fishman. P.C.
(717)263-2121
Place of Settlement: 95 Alexander Spring Road, Ste. 3
Carlisle, PA 17013
Settlement Date: April 29, 2004
Property Location: 2263 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
CUMBERLAND County, Pennsylvania
PAYEEIDESCRIPTION
NOTE/REF NO
BORROWER
SELLER
CUMBERLAND COUNTY DOMESTIC RELATIONS
DOMESTIC LIENS DUE
RE/MAX STERLING ASSOCIATES
REALTOR AGENCY FEE
1,352.73
1,000.00
Total Additional Disbursements shown on Line 1305
$
1,000.00
$
1,352.73
EXHIBIT "B"
I:i'lANl1AIW AtIl{l<;l<;lVmNT L'UI{ nUl; ~ALI~ Ulf l{l<;AL l~~TAn,
Thi~ fLlrm rCL"ummcll,k,llllnl UppfllVCI! [m, hUl nol rC.'ilri.;lcd 10 use by,lhe members oCthe PCllllsylvunia AS$odaliOll (II I(EAITORSw (PAR),
i\J:;.2K
Jj,UYER'S ,B,USINESS RE TIO I$HlP ~ITH PA LICENSED BROKEH
IlRO[{ER(Co~any) ~ Jc (.sl 1 e 'h1r _ P, HONE 7tfll-4-..toc!
ADDRESS 3')15 . ,t < ' em J . ill n II FAX 7~ / -/'-IC/.S__
RROKER IS THE AGENT FOR IlUYER. Designated Agent(s) for Ilnyer, if applicahle,.JS'r",d IJ./e I. - ~1d. _'___
OR
Broker is NOT the Agent for Hnyer and is alan: 0 AGENT .FOR SELLER 0 SUBAGENT FOR SELLER 0 TRANSACTION LICENSE.E
o AGENT FOR BUYER
o TR~NSACTION LICENSEE
When the same Ul'Oker is Agent for Seller and Agent for Bl,yer, Broker is a Du~1 Agent. All of Broker's licensees arc also Ouol Agents UNLESS
there arc sepanltc Designaft!d Agents fot" Buyer and Seller. If the same licensee is designated for Scllcl" und Buyer, the Licensee is a Oual Agent.
t. \Ebis ~llree11tetlt, dated f!;ZJtJ If _. is between
SELLEn(S), "\)<2 b, A b:J:1e_. k::. 2
3
HUYEll(S): ~C;lA"A.,-r\
fl..[
f-Io:pJeN\ C,
. call(~d "Seller," and
2.
, called "Buyer."
5
6
I
a
,
10
11
12
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iuthe or n},,-fh f-Ilr:iJTe]iy\. '__,
County or.G, I" \:),1"'/,4...",;1 in the Commonweatth of'iPennsylvauia, Zip Code /7(J;3 ___
Identification (e.g.) Tax ID #j Parcel #j Lot, Blode; Deed Book, Page, Recording Date)_
3. TERMS (1-02) ~ '-I-oO~11
0t Pn"'~asePrice One- hil.1'-j,.ed.J;Ji;;.l '1~-=H14;+h6'1C~:IX)"
'\)~'f- / ~ rr()()
. 41;;<?("hiCh will be paid to Seller by Buyer as follows: .'
J. Cash or check at signing this Agreement:
2. Cash or check within _ days of the execution of this Agreement
3,
4,
15
U.S. Dollars
16
17
tc
19
2(1
21
n
23
24
25
2G
27
$
$
$
Cash, cashier's Of certified check at time of settlement: mOy--1~~ts.. $
TOTAL $
Deposits paid on DeCOun! of purchase price to be held by Broker for Seller~ unless otherwise staled here:
(.ODO,UO
JLI q, ()()(). 00 :---
) "')V, ClVo .llrL___
(B)
(e) S~ller's wriuen approvul to be on or before: 4 / 2~
(D) Sdtlclllcnt 10 be on ~U Y\12.. 25 ZCx:Jz.f ,or before if Buyer and Seller agree.
(E) Conveyance from Seller will he by fee simple deed of special warranty unless otherwise stated here;
18
(F) PuymcBl of Inlllsfcr tuxes will be divilled equally between Duyer and Seller unless olhcl.wise stated here:
29
30
"
(G) At time or settlement, the following will be adjusted pm-rata on a daily basis between Buyer and SeUer, reimbursing where ilpplicl.lble: taxes 32
(see lnfonnution Regarding Tax. Pronllion); rents; interest on mortgage assumptions; condominium fees and homeowner association fees, if 33
rmy; water and/or sewer fees. if any, together with any other lienable municipal servkt:. The charges are to be pro-rated for Ihe period(s) 34
covered: Sellcr will pay up to and including the date of seUlement; Buyer will pay for al:l days following settlement, unless olherwise stated 35
here:
4. FIXTURES & PERSONAL PROPERTY (1-00) '.,
(A) INCLUDED in lills sale and purchase price are all existing items permanenily installed in the Property, free 01' liens, including plumbing;
hC<lting; lighting fixtures (including chandeliers and ceiling fans); water treatment'syste:ms; pool and spa equipment; garage door openers
and transmitters; television antennas; shrubbery, plantings and unpotted trees; any remaining healing and cooking fuels slored 0/1 the
Properly at the time of settlement; wall to wall carpeting; window covering hardware, shades and blinds; built-in air condiUoners; built-in
appliances; and the range/oven unless otherwise stnlCd. Also included:
36
37
38
39
40
41
~2
43
44
(B) LEASED items (not owned by Seller):
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IAl
WAIVED. Tllj~. :-'ilk i:; NOT ":Uillillgl.'llt 011 llll.lrlgagc financing.
ELECTED
This sale is contingentnpon Bu)'ertttg mortgage financing as follow^,
1. Amounluf mortgage loan $ L L Yc.Yl
2. Minllllum Term ~"__'ye:1rs
J, l'ypeofmortgage-(\'\Y)VCI'l--ttav'1.t'\-"( , ____"
4, interest rale (('>. ')'0; however\.Il.uyer agrees to aecept the interest rate lIS may he cummitted by the mortgage leuder, nolto
exceed u mUXllnUITl mlerest rate 01 fi 70. .
5. Di;;counl pl);nlS, loun origination, loan phu;cmcnl ,llld olher fees chargeJ by tilt: lender J.IS a percenlage of the morlgage loan (excluding
<lilY mortgage insurance premiums or VA fUllding fee) not to exceed _70 (tJl}"o if nol spcl:iried) of the Illort!:uge. loan.
TIlt: interest rate und fees provisions required by Bllyer J.lre salisfied if 11 mortgage k:nder makes available to Buyer lbe right In guaHlIllce an
interest rate at or below the Muximulll Interest Rale spccifieu herein with the pen..:elll:age fees nt or below lhe umount specifieu hereill. 13uyer
gives Seller the right, at Seller's sol~ oplion Hnd as permiucu by tbe morlgag~ Icuuer <IOU applicable laws, to cOlltribllle fillOlllcially, without
promise of reimbursement, to the Buyer uno/or the mOl1gage lender to make the above terms aV::lilahle to Buyer.
Within -- DAYS (10 Jays if not specil'led) of lhe execution of lhis Agreemellt, Buyer will make a completed, written mortgage application
for the mortgage terms specified l.Ibove to a responsible mortgage lender. The BI'OI((~r for Bllyer, if an,)', otherwise the lJroli.cr (01' ,seller, is
uuthorized to cnmmunicute with l!!s.>>lOrtga~e lender lOl' the Plll"l)Oses of assisting in the mortgage loan process,
I. MOI"tgnge commitment date ~ UY\....t I I 2Ct::' 'I- . If il written c:ornlllitlllcnt is nol rCl.:cived by Seller by th~ above dale, BUJ'er
anti Seller agree to extend the mortgage commitment datc until Seller tcrminates this Agi"eCment in wriling by nolil'c to Buyer.
Upon receipt of a mortgage commitment, Buyer will prol11plly deliver a copy of tht:: COlll111itment t() Seller.
Seller has the option 10 terminale this Agreement in writing, after the mortguge commilment oale if the mOrlgagc: cOllltl1itment:
a. Is not valid until the dale of settlement, OR
b. Is comlitioneJ upon the sale and settlement of any other properly, OR
c. Contains any other condition not specified in this Agreement that is not sati;'ified and/or removed in writing by the mortgage lender
within ~ DAYS ,.\Eter the mOl'tg~'ge commitment date in paragr<lph (I (C) (I).
4. If this Agreement is termimlteu as speclfieu in paragraphs 6 (e) (I) or (3), or the mortg.lge loan is nOI obtained for settlement, all deposit monic!;
paid on nccounl of purchase price will be retumeu to Buyer. Buyer will be responsible fur any premiums for mechanics'lien insurance anu/nr
title search. or fee for cancellation of same, if any; AND/OR any premiums for flood insurance, min~ subsitlencc insuJ'unce anu/nr fire insur..
ance with extended coverage, or clincellal'ion fee, if any; AND/OR any appraisal fcc:s ami charges pilid in adv.mce 10 lhe mongage lender.
If the morlgage lendcr requires repairs to the Properly, Buyer will, upon n;:ceipt, deliver a copy of thc mortgage lender's rcquilTmenls to Seller.
Seller will, withio -L DAYS uf receipt of the mortgage lender's requirements, notify Buyer whether Seller willl11llke the required repair',
at Seller's expense.
I. If Seller chooses (0 make Ihe required repairs, Buyer will accept the Property and agree to the RELEASE set fonh in paragraph 25 of this
Agl"eemenf.
2, tf Seller chooses lUll to moke the required repllirs, or iC Seller Cails to respond within the time given, Buyer will. wllhill _L, DAYS,
Ilmify Seller in writing of Buyer's choice to terminate.lhis Agreement OR make the required rerairs at Buyer's expense and with Seller's
permission, which will nO( be unreasonably withheld. If Seller denies Buyer permission to make tbe requircd repairs, Buyer may, withill
~ DAYS of Seller's denial, terminate Ihis Agreement, in which case "n ueposit lllnnies paid all al.:counl of purchase pricr. will be
returned promptly to Buyer and this Agreemenl will be YOLO.
Sell cr' Assist
j;'l( NOT APPLiCABLE
o APPLICABLE, Seller will pay:
o $
o
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FHA/VA, IF APPLICABLE
(F) It is expressly agreed that notwithstanding .ny other provisions of this contract, Buyer will not be oblig'"ed to conlplete the purchase nl the
Propeny described herein or to incur uny penulty hy forleiture of em'nestmoney deposils or <>Iherwise unlm Buyer has hcen given, in aCCor-
daoce with IIUD/FHA or VA requirements. 0 written statement hy the Federnl Housing Commissioner. Veternns Administration. or a Dil'ec!
Endorsement Lender selling I,wth the appnlised value 01 the Property of not less than $ Ithe dollar aOlOl'nt to be
inserted is the sales price as stated in this Agreement), Buyer will h.ve the privilege ond option or proceeding Wilh conslnmn"ion or the cnn.
tracl withoul rcgord to the amount or the apprnised valuation. 111e apprnised v.lllution is arrived at to determine the maximum morlg.ge the
Departmcnt 01 Housing .nd Urhan Development will insure. HUD docs not WnrT.nt the v.lue 1I0r the condition or Ihe Prol""ty, Buyer should
satisfy himself/herself thaI the price andl.:ondition of the Properly arc acceptuble. ~
Warning: Section 1010 01 Title 18, U,S,c., Oep.nment or Housing and Urban Del'el<>pment and Federal Housing Administratinn
T,an""tions, provides, "Wh<>ever 1(", the purpose of, . , influencing in .ny w'y the actinnor such Dep.rtment, makes, passes, utte" or pub-
lishes any slatement, knowing the Silllle to be false. . . shall be fined under this title or ill1prisoncu not more than two years, or both."
IG) U.S. Department of Housing and Urban Development (HUll) NOTICE TO PURCliIASERS: Uuyer's Acknowledgement
o Boye,. ha, received the IIUD Notice "1'0,. Your Protection: Gct Il Home Inspection" (sce Notices Ilnel Inlarmlltion on Property Condition
Inspections), Buyer underst.nds the importance 01 getting au independent home inspectiou and hilS t!rought about this before signIng this
Agreemcnt.
Unyer's Initials - Ilate______
(H) CertilicationVfe the undersigned. Seller(s) .nd Buyer(s) part)' tu this transaction ellch certify that the tel'lllS of this contract I",. purehllse arc
lme to the best of our knowledge and belief, and llmt any olher agreement entered into by J.IlIY <,)f Ihese p<trtics in connel:tioll with this transac~
tion is atlached to this Agreement.
7. INSPECTIONS (1'02)
(A) Seller .grees to pelll1it inspectious hy authorized .ppruisers, reputable certifiers. insurer's ,.epresentlltives. surveyors, muoiClpal officials r",d/or
Buyer liS m.y be required by the mortgage lender, if ony. or insuring agencies, Seller lurth,r .grees to permit any other inspections I~quired by
. or provided for in the terms of this Agreement. Buyer hllS the tight fn attend all inspections~
(13) Buyer reserves The right to make u pre-settlement walk~(hrough inspection of the PropCl1y Buyer's right (0 m.lke this insDcction it; nnl U,,,;\,,~t1
by any other provision of this Apref>lllf'nt
, maximum, toward Buycr's costs as permilled by the mortgage lenuer.
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101
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176
177
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160
161
182
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186
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.._~ ... .- ..... _....v..~_ ".... ...'- -~..~.~~........ ........ .'-'l'......'} .... '"'''''''' "' UII)' ...ll'...." '....I'u", LH'Y"" H"'.
o Option 1. Wilhinlhc time given for complcling inspcdiwls:
1. AccCpllhc Properly with the illfOl111UtioJl stukd in the report(s) ilud agree lo lhe RELEASE .\ieL forth ill paragmph 2S of thili Agreement, OR
2. Terminate this Agreement in writing by notice Lo Seller, in which case all deposit monies paid on accoul\t of purchasl: price will be returned 'I so
promptly to Buyer amltJlis Agreement will be YOID, OR
3. Enter into a mutually ucccptable wriuen agreement with Seller providing for any repairs or improvemcnts lu the Property and/or any credil I~)
to Buyer at senlemcnt, as may be acceptable to the mortgage lender, jf any.
Sllould clIorts to rCHch n mutually acceptable agreement fail, Buyer must choose to accept the Property or terminate Illis Agreement within
Ule time givcn for complcting inspections and according to the provisions in paragraph S(e) (Option J) I and 2.
o Option 2. Within the time given for completing inspections:
J - Accept the Property with the information sLated in the rcPOJ1(s) and agree to tbe RELEASE sel forth in paragraph 25 uf this Agreement,
UNLESS the tolal cost to correct the conditions contained in the report(s) is marc than $ ~__~__
2. If the total cost to correct the condirions contained in the report(s) EXCEEDS the t1mount specified in paragraph 8(C) (Option 2) I,
Buyer will deliver the report(s) to Seller within the time given for inspection.
a. Seller wilJ, within ~ DAYS of receiving the report(s), inform Buyer in wliting of Seller's choice 10:
(I) Make repairs before settlement so thal the remaining cosl to repair conditions contained in the repon(s) is less than or equal to Hi:!
Lhe amount specified in puragraph 8 (C) (Oplion 2) I. Hi:.l
(2) Credit Buyer :It settlement for the difference between the estimated cost of repairing lhe cunditions contained in the report(s) 1M
illld lhe amount specified in paragraph 8 (e) (Option 2)"1. This option must b~ accep[uble to the mortgage lelld(~r, if any. 165
(3) NO{ muke repairs and Ilot credir Buyer at seHlement for any costs to [I.~pair conditions contained in the report(s). 1(,6
b. If Seller chooses to make repairs or credit Buyer at settlement as specified in paragruph 8 (C) (Option 2) 2, Buyer will accept the 167
Property and agree to the RELEASE set forth ill paragraph 25 of this Agm~ment.
c. [f Seller chooses not to make repairs and not to credit Buyer at settlement, or it. Sellel' fuils tu choose any oplion within the time
given, Buyer will, within -L DAYS:
(I) Accept the Property with the infOlmaLion stated in the report(s) and ,~gree to the RELEASE set forlh iu paragraph 25 of this
Agreement, OR
(2) Terminate this Agreement in writing by notice to Seller, in which case all deposit monies paid on acc.:ount of purchase price will 173
be retllrned promptly to Duyer and this Agreement will be YOID. 174
9. WOOD INFESTATION INSPECTION CONTINGENCY (1-02)
o WAIVED. Buyer understands that Buyer has the option to request that the Property be inspected for wood infestiltion by a certified Pest Control
r1loperator. BuYER WAIVES THIS OPTION and agrees to the RELEASE set forth in paragraph 25 of this Agreemenl.
ELECTED
A) Within _ DAYS (15 days if not specified) of the execution of Ihis Agreement, Buyer, at Buyer's expense, will obtain it written "Wood-
Destroying Insect Infestation Inspection Report" from a certified Pest Control Operator and will deliver it and all SllPP0l1ing documents nnd
drawings provided by the Pest Control Operator to Seller. The report is to be mnde satisfactOlY to Dud in compliance with applicable laws, mort-
gugc lenders, and/or Federal Insuring and Guaranteeing Agency requirements, if any. The inspection will include all readily visible and
accessible areas of all structures on the Property except the following structures, which will not be inspected:
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155
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171
172
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170
179
169
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184
10.
(n) If the inspectiun reveals evidence of active infestation(s), Seller agrees, at Seller's expense and before settlement, to treat for active infesta.
lion(s), in accordance with applicable laws. .
(C) If the inspection reveals damage from active infestation(s) or previous infestation(s), Buyer, at Buyer's expense, hi.\S the option to Obl[lin a writ-
len report by a professional contracror, home inspection service, or structural engineer that is limited to structural damage to the Propelty caused
by wood-destroying organisms and a proposal to repair the damage. Buyer will delive:r the structural dumage report and corrective proposal to
Seller within ----.L-.-. DAYS of delivering the original jnspeclion report.
(0) Within ~ DAYS of receiving [he struct~lral damage report and correclive proposal, Seller will advise Buyer whether SeHer will repair, at
Seller's expense and before settlement, any structural damage from active 01' previous infestation(s).
(E) If Seller chooses to repair structural damage revealed by the report, Buyer agrees 10 accept the Property as repaired and agrees to the RELEASE
set forth in paragraph 25 of Ihis Agreement.
(F) If Seller chooses nOI to repair structural damage revealed by the report or falls to respond within the time given, Buyer, within ~ DAYS,
wil! notify Seller in writing of Buyer's choice to;
I, Accept tbe Properly with the defects revealed by the inspection, withoUL abatemenl of price, and agree to the RELEASE l;ct forth in para-
graph 25 of this Agreement. OR . ,
2. M;:lke the repairs before seLtlement, if required by the mortgage lender, if any, at Buyer's expense and with Seller's permission, which wjll
not ue unreasunably withheld, in which case Buyer accepts the Propelty and agre~ to (he RELEASE set fonh in paragraph 25 of Ihis
Agreement. If Scller denies Buyer permission to make the repairs, Buyet may, within --L DAYS of Seller's deniul, tenninate Lhis 201
Agreement in writing, in which case all deposit monies paid on account of purcllHse price will be returned promptly 10 Buyer and this
Agreement will be YOID, OR
3. Terminate this Agreement, in which case all deposit monies paid on account of purchase price will be returned promptly to Buyer nnd
this Agreement will be YOID.
RESIDENTIAL LEAD-BASED PAINT HAZARf) REDUCTION ACT NOTICE IUlQUfllED FOR PROPERTIES
BUn:r R1CFORE 1978 (1-02)
~ NOT APPLICABLE
o APPLICABLE
(A) Seller represe.Iils that Seller hus no knowledge concerning Ihe presence of lead-bused paint and/or lead-based paint hazards in or about the
Propeny, unless checked below.
o Seller has knowledge of the presence of lead-based paint and/or lead-based paint hazards in or about lhe Pl'Operty. (Provide the basis for
delermining that lead-based paint and/or hazards exist, the !ocation(s), tbe condition of the painted surfaces, and other available informa-
tion concerning Seller's knowledge of the presence of lead~based paint and/or lead-based paint hazards.)
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200
202
203
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(n) Records/Reports: Seller has no reports or records pertaining to I,ead-based painl and/or lead-based paint hazards in or about the Properly,
unless checked below.
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Within the lillle...e1 forth dllOVC 1'111" IllJtail1iug nil:: dsl~ llS-<;C1,SIlICllt iIIuJ/ur ius[JcdillJl uf the l'lill}criy I'm" Jcad-lHl~t'd p~lillt and/or
k'l.I(I-hascd paint h:.\;.:.u'us, l.IUYCI. llIay dclil CI" to Selic," a wfill~n lLit of the sp~cilJc hill.urdulls conditiuJls cilo.::d ill the rcpurt amI t1lO~C
cllrr~cLiollS fCljllcsLcJ by 1311y~r. ..dung wiLh i..l copy of the risk assesslllclllllnJ/nr ill!ipection rcport.
3. S~l1cr may, within -L DAYS of rcceiving Ihe li::;t ami reporl(s), submit a wriHen corn:ctivc proposal 10 Buyer. The corrective pmpos:iJ
will include, but nOl ilL: limited In. lhc llHllle of tbe remediation company and (] projectl:d completion uale for corrcc!ive measures, Seller
will pruviuc certificUlinn from II ri:-;l~ a!isessor or inspector that correl.:livl:;; IllCa:illre:-i havc been sillisfaclorily cOl1lp1cL~tl on or bl~fon~ thc
pl'Ojccted complcLion d.lIc,
4. Upon receiving the corrective pr()p('~al. Buyer, within ~ DAYS, will:
H. ACl:epl the corrective propo:;.iI ,.110.1 the Property in writing, anu agree to th~ RELEASE set fonh ill paragraph 25 or this Agrcement, OR
b, Terminate [his Agreement in "riling, in \""hich case all uepos!t moniesp,lid'OllllcCollnt of Plln.:hase price will be returned promptly
to Buyer and Ibis Agreement ,..ill be VOID.
5, Should Sellcr fail to submit a \\'J.:ucn con-ective proposal within lhe time ,set forth in paragraph IO(D)] of this Agrecment, Buyer,
wiLhin _L._ DAYS, will:
;I, Accepl lhe Properly ill wrililll:. lInd agree to the RELEASE set furth in paragfilph 25 o( this Agreement, OR
b. Terminme tllis Agreement in ',Tlting. in which ca:-;e <.Ill deposlI monies paid on m:COl1nl of pun.:hasc prit.:e \vill be returned promptly
10 Buyer alld Ihis Agreemcllt vilJ be VOID.
6. nU}'~r's failure to eXcl"dse :my oj" Buyer's options. within the time limits spedfied in this pnragruph will constituh~ a WAIVER of
this contingency find Buyer aceel ,Is the Property and ~grces. tn the RELEASE set forth in pl.ll'agrnph 25 of this Agreement.
(E) Certification: By ,igning thi, Agreem,,,,. Boyer and Seller certify the occnmey of their respective statemeats. to the best of their knowledg."
II. STATUS OF RADON (1-02)
(A) Seller represenls that Seller has no kncwkdgc concerning the presence or <lbsCIll.:e of radon unless cbeck~d below.
o I. Seller has knowlcdge that the [''''[lcrty was tested on the dates. h)' the method, (c,g,. dmreo"1 eani"er, alph" track, etc.), and with
the rCbulls of all Lests inuicaleu below:
DATE TYPI!OFTEST
157
~jiJ
f.~C,
t.31
~:iU
~~.!)
W)
2'11
lit:
;:ii
";:14
24:;
216
;:~7
~115
::!'1!.l
2~O
;'<-':1
::~t.
'c:~j
::;-1
;':~iS
i5<:
RESULTS (picocuries/liter or working levels)
:!58
259
-~._---_.
~ED
COPIES OF ALL AVAILABLE TEST REPORTS will be dclivereJ 10 Buyer with Ihis Agreement SELLER DOES NOT WAR- 261
RANT EITHER THE METHODS OR RESULTS or THE TESTS. ''''
o 2. Selle, has knowledge that the Property nnderwent radnn redoction measllres on the datc(s) and hy the methodes) indicated below: 23)
DATE RADON REDUCTION METHOD '04
265
2Gll
26.,
1[j1i
;<5'3
Uti
271
27'-
UJ
m
'Wi
Uti
277
27ll
219
ZeD
2111
2112
dlJ
'IH
2€5
Jlt
,
o
RADON INSPECTION CONTINGENCY
WAIVED. Buyer underst:lllds that Buyer hilS the opliolllo rt::que:o;t Ihntlbc Properly be inspected for radon by a cenificu inspeclor (sec Environ-
mentul Notices: Radon), BUYER WAIVES THIS -Op'nON illlU agreeli to the RELEASE set forLh in paragraph 25 of Ihis Agreement.
ELECTED, Buyer, al Buyer's expense. has the option to obtain. fmm a certified in'pectOl', a radoll ,est of the Properly, and will dcliver a copy
of the test report to Seller within _ DA YS (15 days if not specified) of the execlItion 01 this Agrecment. (See Environmental Notices:
Radon)
I. If the lest report reveals the presence of radon below 0.02 working levels (4 [licocllries/liler), Buyer accepts the Property and ogrees to the
RELEASE set forth in paragraph 25 of Ihis Agrc::emcnt.
2, II the te" report reveals the presence of radon at or excceding 0.Q2 wmking levels (4 picocuries/liter), Buyer will, within -2- DAYS
of rec(~ipt of the lest results:
Option 1
u, AccepL the ProperlY in wriling <lnd <lgree to the RELEASE set furth in paragmph 25 oj' this Agreement, OR
b. Terminate this Agreement in wriling. in which case oil deposit monies paid on account of [lnrchase price will be retllrned promptly to Buyer
and this Agreement will be YOlO, OR
c. Submit a wrilten, corrective proposal 10 Seller, The corrective Proposul will include, but not be limited to, the name of the certified mill-
g:Hion company; provisions for paymcnt, including retests; und a prqjected completion dute for corrective measures,
(I) Within ~ DAYS ofreeeiving the cori.eclive proposal, Sellcr will:
(a) Agree to the terms of the corrective proposal in writing, in which Ctlse Buyer a{.:cepls lhe Property and agrees 10 the
RELEASE sel forth in paragraph 25 of tbis Agreement, OR
{b) Not Clgrce to the terms of the c01Tective p'roposal.
(2) Should SelicI' not agree 10 the terms of [he corrective proposal or if Seller fnils tu.respond within the time given, Buyer will, within
__L DAYS, elect to:
{it} Accept the Propeny in writing and ugree to the RELEASE sel forth in paragraph 25 of this Agreement, OR
(b) Terminate this Agreement in writing, in which case all deposit monies paid on account of purchase rrice \vill be returned
pJ'Olllplly to Buyer and this Agreemenl will be YOlO.
2~ili
-~--
o
::!ilb
:.!bi
led
2&!i
o
Optiou2
;;u;
a, Accept the Property in writing and agree to the RELEASE "t furth in paragraph 25 of thi, Ag,~ement, OR '90
b, Submit a written, corrective proposal to Seller, The correet;ve propo,al will include, but not b< limited to. the name of the certified mili- ".:
gat ion company; provisions for payment. inelnding '~te't': and a projected completiott <late If,r corrective me"ores, Seller will pay a max- ""
imom of $ toward the total CI,it of remediation and retests. which will be completed by 'ettlement. '"
I I) If the lutal cost of ,<mediation and retest, EXCEEDS the amount specified in pamgraph II IB) (Option 2) b, Seller will. within m
-~ DAYS of receipt of the CO:-it of remedialion, notify Buyer in writing of Seller's choice Lo: 258
I,,) [lay for the total cost 01 remediation and retests. in which e",c Buyer accepts the Propel'lY and agree' to the RELEASE set forth '"
in pilragraph 25 of lhis Agreement, OR 30U
(ll) ContribuLe toward the tDlal cost of remediation and retests only tbe amount .'ipecified in paragraph J 1 (B) (Option 2) b, 301
(2) If Selb chooses not tu pay fOl' rhe total cost of remedialion and retest" or if Seller fails 10 choose eitlu:r option within the lime ';0'
given, Buyel" will, wilhin---L DAYS, notify Seller in wriling of Buyer's choice to: :WJ
(a) Puy the uiff~rence between Seller's COl1lribulion 10 remedil.l1ion and n~lests lInd Ihc>. :lI't",", ,.",,0 ,1.....___.'
RIJVI~I. tit',..."", ,I,~ n..~___._
:::!J<!
Jl..l L ~eller ,1gICC": to lOcale anll pmVldl.: accCliS Lo 1IlC Oil-sUe (or i.lldJVidwd) wilter .sy.slclIl, if upplkJblc, at Seller's expense, if Iccjuiled by the
:J24 inspedioll company. Seller also agrees Lu restore the Property, at Seller's expense, Plior to selllelllem.
325 3. If the report rcvenls thallhe wllter service does not rn~et the minimunl standards of 'lny applicable governmental authority <IllJ/or fails 10
:J2ii satisfy the requirements fur quality anti/or quantity set by the mortgage lender, if any. then Sellcr will, wilhin_l_ DAYS of receipt 01'
327 the report, notify Buyer in wriling of Seller's choice to:
J23 a. Upgrade the water service to the minimum acceptable levels, before settlement. in which case Buyer accepts the Property and agrees
329 to Ule RELEASE set forth in paragrnph 25 of this Agreement; OR
3Jll b. Not upgrade the water service.
331 l/.. If ~ellcr chooses not to upgrade the service to minimum acceptable levels, or fuils to respond wilhin the time gi\lcn, Buyer will, within
332 _2- DAYS, either:
3JJ a. Accept the Propcrty and rhe water service and. if reqnired by dIe mortgage lender, if any, and/or any govellUllental authority, upgrade
334 the water service hefore settlement or within the time required by the mottgage lender, if any, and/or arlY governmental authority, at
JJ5 Buyer's expense and willI Seller's permission, which will not be unreasonably withheld. and agree to the RELEASE set forth in para-
336 graph 25 of this Agreement. If Seller denies Buyer permission to upgrade lhe waler service, Buyer may, within~ DAYS of
337 Seller's denial, terminare lI1is Agreement in writing, in which case all deposit monies paid on aCCOnnt of purchase price will be
]36 returned promptly to Buyer and Ihis Agreement will be VOID, OR
33D b. Terminate this Agreemenr in wriring, in which ease all deposil monies pail! on aCConnt of pnrchase price will be returned promptly
1;0 to Guyer ami this Agreement will be YOrD.
',\1 13. STATUS OF SEWER (1-02)
1.1::! (A) Seller represents Ihnt the Property is served by:
l13 0 Public Sewer
JH ~ Individual On-lot Sewage Disposal System (See Sewage Notice 1)
};. 0 Individual Oil-lot Sewage Disposal System in Proximity to Well (See Sewage Notice I; see Scw;:Jge Notice 4, if applicable)
H6 0 Con;humity Sewage Disposal System
l'17 .:s rJ tJ t\ 0 Ten-acre Permjt Exemption (See Sewage Notice 2)
148 ')Q; ~ Holding Tank (See Sewage Notice 3)
349 t.1... ~y ... ~ - None (See Sewage Notice I)
150 ~/-- b None Available/Pcnnit Limitlltions in Effect (See Sewage Notice 5)
t5t Lff;:;.'?
IS' (B) INDIVIDUAL ON-LOT SEWAGE DISPOSAL INSPECfION CONTINGENCY
153 J'l WAIVED. Buyer acknowledges Illat Buyer has the option to request an individnal on-;lot sewage disposill inspection of the Propelty. BUYER
151 WAIVES THIS OPTION and agrees to the RELEASE set forth in paragraph 25 of this Agreement.
1S5 0 ELECfED ,
1S6 1. Buycr has the option, within ~ DAYS (15 days if not specified) of dIe execution of this Agreement and at Buyer's expense. to
157 deliver to Seller a written inspection report by a qnalified, professional inspector "fthe individual on-lot sewage disposal system.
,oa 2. Seller, at Seller's expense. agrees, if and as required by the inspection company, tu locate, provide access to nnd empty Ihe individual on-
39 lor sewage disposul system. SeHer also agrees to restore the Property, at Seller's eltpcnse, prior to settlement.
50 3. If the report reveals defects thut do not require expansion or replacement of the existing sewage disposal system, Seller will. within
61 -'1- DAYS of receipt of the report, notify Buyer in writing of Seller's choice to:
" a. Correct the defects before settlement, including t~tests, ar Seller's expense, in which case Buyer accepts the Properly ,,,,d ag"ccs lo
6,1 Ihe RELEASE set forth in paragraph 25 of this Agreement, OR
64 b. Not COlTcct the defects.
" 4, If Seller chooses not to correct the defects, or if Seller fails to respnnd within the time given, Buyer will, within -L DAYS, cithcr:
" a. Accept the Property and the system and, if requi,'cd by the mortgage lender, if nny, and/or any govemmental authorily, correct the
" dcfecls beforc settlement or within the time rcquired hy the mortgage lender, if any, and/or an)' governmentnl authority, at Bnyer',
G8 sole expense and with Seller's pennission, which will oot be nnreasonably Withheld, and agree to the RELEASE Sct forth in para-
;9 graph 25 of this Ag,'Cement. If Seller denies Buyer permission to Correct the defects, Buyer may, will1in -L DAYS of Seller',
10 denial, terminate tlris Agreement in writing. in which case all deposit monie, paid on account of pnrchase price will he retullled
71 promptly lo Buyer and this Agreement will be VOID, OR
'1 b. l\,rminate this Agreement in writing, in which case all deposit monies pailj on account of purchase price will be wlurned
r3 promptly to Buyer and this Agreement will be VOID.
" 5, If the repolt reveals the oeed to expand or replace the existing individual on-lot sewage disposal system. Seller may, will1in ,.....1L. DAYS
'5 of l'Cceipt of the report. submit a corrective proposal to Buyer. The corrective proposal will include. but not he limited to, Ihe name of the
., remediation company; provisions for payment, includiug retests; and a projected' completion date for cOITective measures. Within
"/ ...2.._ DAYS of I'eceiving Seller's corrective proposal, or if no corrective propnsal is "eceived within the time given. Buyer will:
'0 a. Agree to the tennsDf tlte con~ctive proposal, if any, inlVriting, in whiclr case Bnyer accepts the Property and agrees to the RELEASE
'9 set fortb in paragraph 25 of this Agreement, OR
iO b, Accept the Property and the system and, if required by the mortgage lender, if any, and/or any govemmental authority. eorrect the
It defects before settlement or will1in the time required by the mortgage lender, if any, and/or any governmental authority. at Buyer's
" sole expense and with Seller's permission. which will not be unreasonably withheld, and agree to the RELEASE set forth in pill'a-
" graph 25 of this Agreement. If Seller denies Buyer permission to con'Cct the defects, Buyer may. within -L DAYS of Seller's
' denial, terminate Ihis Agreement in writing..;n which case all deposit monies paid on account of purchase price will be retumed
5 promp!!y to Buyer and this Agreement will be VOID, OR
, c. Tenninate IIlis Agreement in writing. in which case all deposit monies paid on account of purchase price will be returned promplly
7 lo Buyer and this Agreement will be VOID.
, 14. NOTICES, ASSESSMENTS & CERllFICA TES OF OCCUPANCY (1-02)
(A) Seller represents. as of Seller's exeeulion of this Agreement, that no public improvemeut, condominium or homeowner associortion assessments
have been made against the Propelty which remain unpaid, and that no notice by any government or public authority has been served upon
Seller or anyone nn Seller's behalf. induding notices relating to violations of zoning, huusing, building, safety or fire, ordinances which remain
uncorrected, and that Seller knows of no condition lhat wouJd constitute violation of any such ordinances which rem;lino.: llnr-"r'"I>r't..rl ....1___
otherwise specified here:
323
3201
:125
326
317
326
329
330
S31
332
333
334
335
336
337
:no
339
:liD
J4t
3-12
343
3,)'1
315
.------.
346
347
34'
349
"0
351
352
353
354
355
356
357
1SlJ
359
3GO
361
31)2
363
364
:!35
3E3
367
36a
"9
370
371
372
373
3'"14
375
376
J77
Ji'8
379
380
391
301
3!l3
384
385
38'
387
388
S89
390
391
112
113
It'
:15
,16
17
18
,"
"
21
"
23
"
.. .-'1....-~....J ...... ...."", ~ ......,.,~.... v~ w,.... ..."........UUUIl Ul lIU....l'\gll..:\;III\:.Hl .,lo,;;UGI Will UIUI;;J IUl UL:UVL.:lY llJ UUYL:I. lJlllJl Ul.:1UlL: :'L:lll\.:llll.:-Jll.
I. A cCrlillcation fmlll tilt'. appropriate municipal dep:lI1ment or d~par!mellls disclosing notice uf any uncunceled yiubtjOllS tJt" zollillg, 11OUS-
iog. building, safety or fire ordinances, AND/OR
2. ^ CCl1ificale permitting occupancy of the Property. In the event repairs/improvements are required for Ihe issuance of tile certificate, Seller
will, within ~ DAYS of Seller's receipt of tile requirements, notify Buyel~ of Ule requirements and wllcther Seller will make the
required repnirslimprovements at Seller's expense.
If Seller chooses to make tne required repail's/improvements, Buyer agrees to accept [he Properly as repaired and agrees to the RELEASE set
forth in paragraph 25 of this Agreement. If Seller chooses not to make the required repairs/improvements, Guyer will, within ~ DAYS,
notify Seller in writing of Buyer's choice to tenninate tllis Agreement OR make the repairs/improvements at Duyer's expense and with Seller'~
pennission, which will not he unreasonably widlheld, If Seller denies Guyer permission to make the required repairs or if Seller fails to respnnd
within the time given, Buyer may, within -L DAYS, terminate Ihis Agreement in wriling, in which case all deposit monies paid on account
ofpurcnase price will be returned promptly to Buyer and this Agreement will be VOID.
IS. 'OTLE, SURVEYS & COSTS (l-02)
(A) The Property is to be conveyed free and clear of all liens, encumbrances, and easements. EXCEPTING HOWEVER the following: ex"tmg
deed restrictions, historic preservation resiric,tionsor ordinances, bnilding restriclions, ordinances. easements of roads, easemenls visible upon
the gmund, easements of record, ptivileges or rights of public service companies, if any; otnerwise the title to lhe above described real estate:
will be good and marketable and such as will be insured by a reputable Title Insurance: Compuny at the regular rales.
(Il) Iluyer will pay for the following: (I) Tille search. litle insurance and/or mechanics lien insurance, or fee for cancellation of same, if any;
(2) Flood insurance, fire insurance with extended coverage, mine subsidence insurance. or fce for cancellalion of ,<ame. if any; (3) Appraisal
fees and chiu.ges paid in advance to mortgage lender, if any; (4) Buyer's ~ustomary seUlcmcnt costs and accruals.
(C) Any surveyor sm.veys which may be "~qui,'ed by the Title Insurance Company or Ihe absoacling attorney for Ihe preparation of an adequate
legal desc>iption of the Property (nr Ihe correction drereol) will be secured and paid for by Seller. Any surveyor surveys desired by Buyer or
required by the mortgage lender will be secured and paid for by Duyer.
(D) In the evenl Seller is unable lu give a good and marketable title and such as will be insured hy a reputable Title Company at the legular rates, as
specilied in paragraph 15(A),lluyerwill have the oplion nf: (I) taking such Ii lie as Seller can give willl no change 10 the purcbase price; or (2) being
repaid all monies paid by Buyer to Seller on aecounl of purchase price and being reimbUl.ed by Seller for any costs incurred by Iluyer for any inspec-
lions or certifi.:a1i"ns ob1ained according to the lerms of the Agreement, and for those items specificd in pon'agraph 15(B) items (I), (2), (3) and in
paragraph 15(C), in which case there will be no funher liability or obligation on either of the parties herem and this Agreement will become VOID.
16. ZONING CLASSIF1CATlON (1-02)
Failure of dris Agreement to contain dIe zoning classitlca1ion (except in cases where 1he proporty [and each parcellhereof, if subdividable J is zoned
solely or prim.uily to permit single-fanlily dwellings) will render this Agreement voidable allhe option of the Bnyer. and, if voided. any dcposits
tenderetl by lhe Buyer will be return d to e Buy r without allY requirement for COUl1 action.
Zoning Ch,ssHication: .fSJ.
o ELECTED. Within -1L DAYS of the execUliun of this Agreement, Buyer will verify drat Ihe existing use of the Property as
is permitted. In the evelllt the use is not permitted, Buyer will, within the timc
given ror verification, ootify Seller in writing Ihat dre existing nse of dle Property is not permiued and this Agreement will be VOID. in which
case HIl deposit monies paid on account of purchase price will be returned promptly to Buyer. Uuyer's failure to respond within the time
given will constitute a WAIVER of this conlingency and all other tenns of tillS Agn~ement remain in full forcc and effect.
17. COAL NOTICE
E NOT APPLICABLE
o APPLICABLE
TfIls DOCUMENT MAY NOT SELL, CONVEV. TRANSFER, INCLUDE OR INSURE THE TITLE TO TlIE COAL AND RIGHTS OF SUPPORT UNDERNEA'rtl TilE SURFACE LAND
DESCRIBED OR REPERRED TO HEREIN, AND Tim OWNER OR OWNERS OF SUCH COAL MAY HAVE TIlE COMPLETE LEGAL nrOllTTO REMOVE ALL SUCH COAL AND
IN TIlAT CONNECTION, DAMAGE MAV RESlILTTO TIlE SURFACE OF ruE LAND AND ANY HOUSE, BlITLDlNO OR UTIlER smucrURE ON OR rN SUCIl LAND. (This
notice is set forth in dIe manner provided in Section I of the Act of July 17, 1957, PL. 984.) "Buyer acknowledges 1hal he may nol be obtaining the
right of protection against subsidence resulting from coal mining' operations, and thal1he pro>~rty described herein may be prolected from damage
dne to mine suhsidcnce by a privale contracl with the Owners of the economic interests in the coal. This acknowledgement is made for the pU'1'ose
of complying with U,e provisions 01 Section 14 of the Bituminous Mine Subsidence and the Land Conservation Acl of April 27, 1966." Iluyer agrees
to sign the deed from Seller which deed will contain Ule aforesaid provision,
18. POSSESSION (1-02)
(A) Possession is to be delivered by deed, keys and:
I. Physical possession to vacant Properly free of debris. with all structures broom-clean, at day and time of seUlement, AND/OR
2. Assignment of exis1ing lease(s), together widl any security deposits and interesl, at time nf seltlement, if Propel1y is leased at the
execution of this Agreement or unless otherwise specitied hetein. Buyer will acknowledge existing lease(s) by initialing said lease(s) at
time of execution of this Agreement.
(Il) Seller will not enter into any new leases. wriuen exlension of exisling leases, if any. or additional leases for the Property wIII,OUt the written
consent of Buyer.
19. RECORDING (3-85) This Agreement will not be recorded in the Office for the Recording of Deeds or in any other office or place of public record
and if Buyer causes or permits this Agreement to be recorded, Seller may elect to treat such ac!: as a breach of this Agreement.
20. ASSIGNMENT (3-85) This Agl~emenl will be binding upon dle parties, their respective heirs, pemonal representatives, guardians and successors,
and to the extent assignable, on the assigns of the parties hereto, it being expressly understood, however, Ihat Buyer will nol transfer or assign this
Agreement without the written consent of Seller.
21. DEPOSIT & RECOVERY FUND (1-02)
(A) Deposits paid by 'Buyer within....JL DAYS'of seltlement will be by cash, cashier's or certified check. Deposits, regardless of the form of
payment and the person designated as payee. will be paid in U.S. Dollars to Broker or party identified in paragraph 3(B), who will retain them
in an escrow acconnt until consummation or lerminaliou Oflhis Agl~ement in conformity witil all applicable laws and regulations, Any uncashed
check tendered as deposit monies may be held pending lhe acceptance of this offer.
(Il) Upon termination of dlis Agreement, the Ilroker holding the deposit monies will release 1I1,e deposil monies in aceordonce wilh the lerms of 0
fuUy executed written agreemenl between Buyer and .Seller.
eC) In tile cvenl of a dispule over entitlement to deposit monies. n broker holdiug the deposit monies is required by dle Rnles and Regulatinns of
the State Real Estate Commission (49 Pa. Code ~35.327) to n~l::lin 111.. ....."..:D~ :.. _n__
'"
19
10
11
"
13
t.
IS
16
17
IB
19
'IL!
4t3
'14
415
416
417
418
419
420
421
422
423
42.
425
426
427
'"
429
430
431
m
433
'"
435
436
437
'38
439
4<10
"1
'"
."
'"
445
'"
'"
'"
."
"0
'"
'"
453
45.
45S
'"
457
"B
459
460
461
462
463
."
465
."
'67
'"
,169
470
47t
'"
473
.7.
415
'"
on
47'
479
460
25
26
27
28
2lJ
JU
31
32
3.)
3'1
35
36
)7
33
;0
;1
"
;3
"
5
6
7
8
9
o
1
,
,1
.
5
6
,
,
'"0 (1\) Willi,n -.JL DAYS uf llie e,eoulion of tbis Agreement, Seller will submit a reqncsllo Ihe associaliulI lur a Certilkale O( Ro,ale and Ihe doc- 'IiO
5<11 ument, neoessary 10 enable Sellor to comply wilh Ihe Act. The Ael provides Ihatlhe nssocialion is required to provide Ihc,c ducumenls withio 501
';02 10 days of Seller's reque,t. 502
50,1 (B) Seller will promptly deliver to Buyer all documents received from the ""oeinlion. Underlhe Act, Seller is not liahle to Buyer for the failnre or 503
504 delay of Ule association to provide the Certificate in a timely manner, nor is Seller liable to BuyeJ' for any en-oneous informillion provided hy 504
505 UJe association and included in UJe Certificate. 505
506 (C) Buyer may declnre Ihis Agreement VOlO at any time hefore Buyer's receipt of the ".ssociution documenls and for 5 days dlcreafler, OR nlllil 506
507 settlcment. whichever occurs first. Buyer's nolke declaring lhi, Agreement void must bc in Writing; thereaf1er all deposi' moni,,, will be 507
500 relume" 10 Buyer, 506
509 (D) tn 'lie eventlhe "",ociation has Ule right 10 huy the Properly (right of fir" refu,al), and the assoeiation e<ereises Il,., right, Seller will reimhurse 509
510 Buyer for all monies paid by Buyer on aceount ufpurchase priee and for any costs incurred hy Buyer for: (I) Tille seareh, tiUe insmance and/or SID
511 mechanics lien insw'ance. or fee for eaneellation of same, if any; (2) Flood insuranee and/or fire insnronce wilh ex'ended eoverage. mine sub- 51t
5t2 sidence in,urance, or fee for cancellation of same, if any; (3) Appraisal fees and eharges paid in advance to mortgage lender. if any, 512
513 23. MAINTENANCE & RISK OF LOSS (1-02) 513
51-1 (A) Seller will mainlain the Propcrty, grounds, fixtnre" and any personal property specifically scheduled herein in its present eondition, normal 514
m weaJ'lUld tear e,cepted, 515
'" (B) In the event any system or appliance included iu tile sale of the Proper'y fails and Seller does not repair or replace the item. Seller will prompUy 5tO
517 notify Buyer in wri'ing of Seller's choice '0' 5t7
'Ir, I, Repair or replace tile failed system or appliance befure seUlement or credit Buyer at seUleme", for the fllir nllu'ket value of 'he failed sy'- 510
51g tem or applianee (this option must be accep'able to the mOJtgage lender, if any), In CllCh case, Buyer accepts the Property and agrees to Sl9
no Ute RELEASE set for'h in pamgraph 25 of thi, Agreement, OR 520
','I 2, Not repair or replace the failed system or appliance, and not credit Buyer at setUemenl fur the fair murke' value of lhe failed 'Iystcm or '"
'2' appliance. If Selle. does not repair. replace or offer a credi, for the failed system or applianee, 01' if Seller fails to notify BUYel' 522
523 of Seller's choice, Buyer wiil nO'ify Seller in writing within ~ DAYS or before seUlemenl, whichever is 'ooner. thaI Buycr 523
524 will: 524
52' a, Aceep' tllC Property and agree to the RELEASE sel forlll in puragraph 2S of thi, Agreemen', OR 525
526 b. Terminate tllis Agreement, in which case all deposil monies paid on aceount of purchase price will be returned promptly to Buyer 526
527 and this Agreement will be VOID. 527
52. (C) SeUer will bear risk of loss from fire or other casualties until time ~f selllement. la theevenl of damage hy fire or other casualties to any prop- 528
5" erly included in 'hi, sale that i, not ,'epaired or replaced prior to selltement, Buyer Will have the option of rescindiug lhi, Agreement and 52'
530 promptly r'eceiving all monies paid on aCCOunt of purchase price or of accepting tI.e Proper'y in its 'hen condition togelller wi'h 'he proeeeds 530
531 of any insurance recovery ohtainable by SeUer. Buyer is hereby notified tha' Buyer ma)! insure Buyer's equilable interest in thi, Property"" of 531
532 tbe time of execution of this Agreement. OJ2
533 24. WAIVER OF CONTINGENCIES (1-02) 533
531 If 'hi, Agreement is eontingent on Buyer', ,ight lu inspect and/or repair Ute Properly, Buyetr', fnilul'e to exel'dse any of Du)'er's options wiUlin 534
53' the time limits set fOl'tb in tbis Agreement will eoustitote a WAIVER of tbat contingency and Dnycl' accepls tbe Pmpel't)' and agcees to Ihe 535
136 RELEASE sel forth iu pal'llgl'aph 25 of this Agreement. 536
;37 25. RELEASE (1-02) S37
;" Dnyel' hecehy releases, quit claims and forevel' diseharges SELLER, ALL BROKERS"their LICENSEES, EMPLOYEES, and any OFFl- 53B
;og CER 01' PARTNER of anyone of tbem nnd any otbel' PERSON, FIRM, or CORPORATION who may be liable by or through them, from '"
140 'Ill)' and all claims, losses or demands, including, but not limited to, personal injuries and property damage and all of the consequences Ulel'e- 5<0
., I. nf, whether now known 01' not, which may arise from the p.'esence of lel'mites 01' other wood-boring insects, l'lIdon, tead-based paint haz- 54t
'" ards, envil'olllnental hazards, nny defects inlhe individnal on-lot sewage disposal sy,'em or deficiencies in the on-site water seniee system, '"
;" or aoy defects or ennditiuns on the Property. Should Seller he in default under lhe tel'lIls of Ihis Agreement, this release does nol depl'ivl: ',13
." Bnyel' of any right to pUl'sne any I'emedies that may be available nnder Jaw 01' e'loit)'. This release will sn!'Vive settlement. 544
." 26. REPRESENTA nONS (1-02) 045
.j; (A) Buyer und..-s<und, tha' any representations, claim" adveJ1ising, promotional aClivi'ies, hrochores or plan, of any kind made by Seller. Brokers, 546
47 their lieen,ees, employees, olficers, or partners arc not a pllJ1 of this Agreement nnless expressly incorporuted or slated in this Agreement. It j, 547
48 I\lllher nndmtood tlmt this Agreemen' contains the whole agreement between Seller and Buyer and there m'e no other terms, obligations, '"
49 covenanls. represent"tion" "atemen', or eonditions, oral or otherwise of any kind whatsoever eoncerning tlti, 'ale., Furthermore, this 549
50 Ag.'eement will no' be altered, amended, ehmlged, or modified except in writing execnted by Ule parlie,. 550
" (B) It is ondel'stood that Buyer has inspected the Pml'el'ty before signing this Agl'eemenl (inclnding fixtnl'es "nd any personal pl'OJlerty 551
52 specilically scheduled herein), or has waived lIlel'ight to do so, and has agreed to purchase the Pmperly in its present conditionnnless 551
53 ntbemise slated in tllis Agreement. Buyer acknowledges that Bl'Okel's, theil' licensees, employees, ollicel's 01' pal'h,el'S i,ave not made "3
5.t "n independent examinati"n or determination of Ihe stl'uetUl'al sounrlness of the P,'opel'ty, the age 01' condition uf the componenls, envi- '54
15 ronmental conditions, the permitted uses, 01' of eonditions existing in the locale whell'e lhe I'l'Opel'ty is situated; nOlO have they macle a 555
" mechaniclll inspeetiou of any of the systems contained therein. 556
;7 (C) Any repairs required by 'hi, Agreement will be completed in a workmanlike marmer. 557
;6 (D) Broker(,) may perfoffil services to assist unrepresenled parties in COmplying with Ihe 'erms ofthi, Agreement. 556
;9 (E) 111e headings, caplions. and line numhers in 'his Agreement are meant only to make it ea,ier '0 find the paragmphs. 559
10 27. DEFAULT (1-02) 560
I' (A) Seller has UJe option of retaining all sum, paid by B'Jy~r, including the deposil monies, should Buyer: 561
12 1. Fail to make any additional payments as specified in paragraph 3: OR' 562
,3 2, Furnish false or incomplete infollnation to Seller. Broker(s), or the mortgage lender, if any, eoncerning Boyer's legal or fillaneial stalus, 503
4 or fail '0 cooperate in tlte processing of the mortgage loan application. which aets would resolt in 'he I.ilure '0 obtain the approval of a 564
mortgage loun eommilment; OR 565
6 3. Vlolate or fail to fulfill and perform any other terms or conditions of this Agreement. 566
7 (B) Unless olherwise checked in paragraph 27 (C), Seller may eJect to retain those sums paid by Buyer. inclnding depo,itmonie" in one of lhe 567
' following manners: '"
I. Oll account of purchase price; OR
'1 A..__
".-."" "-- - ---- -,~ - .----. _~u....~.... ...H.... '-LU,a.:.. .n,~.... .......' a. LVl'''''''''''H'l''.-'IU """"'n."-I..dl.J'H'Il':"U '-.-UH'Jl\lUI'ilJ. I.
1:j:J
:itilJ
(A)
The following <.Ire llaJ:t of thi.'t At:rcclIlcnt if t.:hct.:kcd:
o Sule & Settlement of Olher 'Property
Contingency Addendum (PAR Form SSP)
o Sale & Settlement of Olher Property Contingency
with Right to Continue Marketing Addendum
(pAR Form SSP-CM)
5aa
5U9
5!;l9
.[i~ll
59t
592
5S0
591
592
593
594
593
594
595
595
596
597
598
60'/
600
0", jilt Bllyer hus received the Cons\lJner Notice as adopted by the State Real Estate Commission at 49 Po. Code ~35.336.
"0 %: !luyer has received a statemellt of !lllyer's estimated closing cosls before signing this Agreement.
61 1 )it Bllyer has read aod nnderstllnds the notices alld explllnatory informatioll set forth in this Agreement.
612 ftK Bllyer has received a Seller's Property Disclosllre Statement before slgllillg this Agreement, if wjuired by law (see Information Regarding
613 the Real Estate Seller Disclosure Law).
011 .yz Bnyer has received the Deposit Money Notice (for cooperative soles whell Brolter for Seller is holding deposit mon.'y) before siglling this
015 Ag",ement. )
::: "~X",^~"G,"""", 04) (, J/tf~'~J &!tl Pel
616 !!_L S ~L/1~ Q ;-2{)-~
619 !lUYER'SCONTACTNUMBER(S):_._ ~
::: WI1'NESS_ B:VER _~~ 121~h-
622 SS#
r.gg
600
130'(
602
603
b04
6{JS
UDS
507
608
609
610
611
612
613
614
615
616
617
60~
[jU5
!jOG
NOTICE TO PARTIES: WilEN SIGNED, THIS AGREEMENT IS A BINDING CONTRACT. Retllrn by facsimile trollsmisslon (FAX) of this
Agreemellt, and all IIddenda, hem'iug the signatll,'es of 1111 porlies, eoustillltes acceptance of this Agreement. ParUes to this transaction are advised
to consult nn attorney hefoi.e signing if tbey desire legal advice,
-~----
6'18
523
5.24
i25
)26
,27
328
i29
iJO
)31
i32
,33
;34
;35
,36
37
DATE
'"
CI--6':f.]vQ/ :::
'"
WITNESS
BUYER
SS#
DATE____
BuYER
SS#
DATE,
623
614
'"
616
627
628
62'
630
631
632
633
634
635
636
637
638
6JS
WfTNESS
Seller hereby approves the above eOlltractthis (date) ____
and in colI,ideration of the service, rendered in procuring the Buyer, Seller .grees to pay the named Broker for Seller a fee of _'____
of/from the herein specified sale price. In the event Buyer defaults hereunder, any manics paid on account will be divided
Seller. '- , Broker for Seller, but In no event will the sum paid [0 [he Broker for Seller exceed tile above specificd Broker's fee,
41
"
43
44
"
"
17
18
19
;0
;1
SELLER'S CONTACT NUMnER(S):
WITNFSS-cr /) l1A..tu )
WITNESS
o Seller hll.' ,'eceived the Consume,' Notice as adopted by the State Real Estate Commission at 49 Pa. Code ~35.336.
o Seller hus received a stalernent of Seller's estimated closing costs bcfOl'e signing this Agreement.
o Seller has read and understauds the notices and exPlanato/1nformation set forth in this Agree~nt
SELLER'S MAILING ADDRESS: r;. G" ~~ '~ -&L~
- , U_ !~~=====
58a - 9 '77
- cJ0eJL DATE______
.'
-)
640
38
J9
40
SELLER
SS#
DATE____
6-11
642
6.13
644
645
"6
647
648
649
650
651
WITNESS
SELLER
SS#
DATE____
;2 !lmlrer'slLlcellS"es' Certifications (check all that are applicahle): 652
;3 0 negarding Lead-Based Paint Hazards Disclosllre, Reqllired if Property was built h"lore 1978: The undersigned Licen,ees involved in 653
;4 Ihi, transaction, on behalf of themselves ,nd their brokers, certify thar their statements arc tme to the best of the;" knowledge and belief, 654
;5 Acknowledgement: 111e Licensees iavolved in this transaction hove infonned Seller;~!)'c1l~r's obligations under The Resitl"n';,,] r "MLP"..A
i6 Paint Hllzard Reduction Act, 42 V.S.C. S4R<:;?(,n nn...! "'-n n'..~__ _.r.. . __
VERlFICATlOr~
The foregoing document is based upon information which has been gathered by
counsel and myself in the preraration of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
su~~s !I~
Date: May 11, 2004
SUSAN M. HOPKINS,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
2003-4276 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
JOHN W. HOPKINS,
Defendant/Respondent
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, Ill, Esquire, hereby certify that a copy of attached Petition was
served upon the following by depositing a true and correct copy of the same in the United States
mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Carol J. Lindsay, Esq.
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
7t~
By: Me . , II~' uire
et Street
Carlisle, 013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: MAY 12, 2004
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MAY 1 3 2004
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SUSAN M. HOPKINS,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2003-4276 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
JOHN W. HOPKINS,
DefendantIRespondent
ORDER OF COURT
AND NOW, this ~ day of ~ ' 2004, upon consideration of the
attached Petition for Special Relief, a Rule is hereby issued and is returnable at a hearing
scheduled forr ~ , 2004, in Courtroom No, ~, at JO " ')0 o'clock
C<.. .m., Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013.
By:
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.UW
26 W. High Street
Carlisle. P A
SUSAN M. HOPKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO.2003-4276 CIVIL TERM
IN DIVORCE
vs.
JOHN W. HOPKINS,
Defendant
Pacses # 056105885
PETITION FOR REDUCTI,ON
NOW comes John W. Hopkins, by and through his attorneys, Said is, Shuff, Flower &
Lindsay, P.C., and petitions this Court as follows:
1. The parties hereto were joined in marriage on June 2, 1996 and separated on or
about July 1, 2003.
2. On October 23, 2003 this court entered an Order for Alimony Pendente Lite, a
copy of the order is attached hereto as Exhibit "P,;'. According to the order,
Petitioner was required to pay $627.00 per month for the support of Respondent.
3. Of the amount owed in Alimony Pendente Lite $438.67 per month was for
mortgage support. A copy of the ORa statements for mortgage are attached
hereto as Exhibit "8",
4. The marital home was sold on April 28, 2004. A copy of the settiement sheet is
attached hereto as Exhibit "e"
WHEREFORE, Petitioner prays this Honorable Court to reduce the Alimony Pendente
Lite by $438.67.
Date:
6f ~/~,+
SAIDIS
SHUFF, FLOWER
& LINDSAY
AlTORNEYS.AT-LAW
26 W. High Street
Carlisle. P A
SUSAN M. HOPKINS,
Plaintiff
vs.
JOHN W. HOPKINS,
Defendant
AND now, this
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - DIVORCE
:NO.2003-4276 CIVIL TERM
:IN DIVORCE
:Pacses # 056105885
day of
, 2004, I, Carol J.
CERTIFICATE OF
rf
1
Lindsay, Esquire, of the law firm of Saidis, Shuff, Flower & Lindsay, P.C., Attorneys, hereby certify
that I served the within Petition for Reduction this day by depositing same in the United States
Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Marcus A. McKnight III
W. Pomfret Professional Building
60 W. Pomfret Street,
Carlisle, PA 17013-32:22
Carol
ID#4
26 West High Street
Carlisle, PA 17013
(717) 243-6222
SUSAN M. HOPKINS,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUl'iTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
JOHN W. HOPKINS,
Defendant/Respondent
NO. 2003-4276 CIVIL TERM
IN DIVORCE
Pacses# 056105885
ORDER OF COURT
AND NOW, this 23rd day of October, 2003, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,832.09 and Respondent's monthly net income/earning
capacity is $2,303.47, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $627.00 per month payable bi-weekly as follows; $289.38 for
alimony pendente lite and $0.00 on arrears. First payment due on or before November 1,2003 in the
amount of$627.00. Arrears set at $627.00 as of October 23,2003. The effective date of the order is
October 3, 2003.
Defendant is to make a full payment in the mount of $627.00 directly to the Petitioner on or before
November I, 2003. Both parties are to report to DRO that said payment has been paid and the
Alimony Pendente Lite account will be given credit for the amount paid.
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.s 3703. Further, ifthe 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 ofthe Respondent to prison for a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Susan M. Hopkins. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, P A 17106-911 0
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to. be paid 56% by the respondent
and 44% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage:; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice ofthe entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
10-24-03 to: <
Petitioner
Respondent
Marcus McKnight, Esquire
Carol Lindsay, Esquire
BY THE COURT,
Q7J1~
Edgar B. Bayley
J.
:unc:
'[
Mortgage Expenses SummalY
SHADDARJ
10115.'03 11:52
;,ASE ID
,EQ NO
1056105730 I
101021
N
SUSAN M. HOPKINS
,Active: N Worker:
V JOHN W. HOPKINS
21005 Date 10115.103
Sel:
Plaintiff Paid Expenses:
Defendant Paid Expenses:
Total Mortgage Expenses
25 % Pit Total Income:
Mortgage Amount in Excess of25 % of Plaintiffs Total Income:
Mortgage Support Limit:
Mortgage Support Limit - Defendant Paid Expenses:
Plaintiffs Net Income:
Support due Plaintiff:
Plaintifs Total Income:
1832.09
188.55
2020.64
Pint Seq
iDef ~IO ____________________mu Description ____________m__________
P 1 MORTG, TAXES, & INSU
1382.50
0.00
1382.50
505.16
877.34
438.~
~.)
Montlily'"
Amount
1382.50
3ACK PREV NEXT,
, B TYPE OF LOAN:
A 10FHA 20FmH~ 3, C~CONV UNINS 4,DVA 5,DCONV INS
U.S. DEPARTMENT OF HOUSING & URBAN DEVELOPMENT 6, FILE NUMBER: , \ 7, LOAN NUMBER:
SETTLEMENT STATEMENT PALMERJ0404 , 1010033093
8, MORTGAGE INS CASE NUMBER:
C, NOTE ThiS form is furnished 10 give you a slalemenl of actual selllement cosls AmounlS paid to and by the selllemenl agenl areshown,
II k d "[POC)" were paid outside the closing: they are shown here for mformatlonal purposes and are nol mcluded m Ihe lolals
ems mar e 1.0 3/9B (PALMERJ04_04,PFDIPALMERJ04.04IJJ)
D, NAME AND ADDRESS OF BORROWER E, NAME AND ADDRESS OF SELLER: F, NAME AND ADDRESS OF LENDER:
,
JESSE L, PALMER, SR JOHN V, HOPKINS I MORTGAGE LENDERS NETWORK USA,
JESSICA R: PALMER SUSAN HOPKINS I 213 COURT STREET
11 ROBYN DRIVE 2263 WALNUT BOTTOM ROAD MIDDLETOWN, CT 06457
NEWVILLE, PI'. 17241 CARLISLE, PA 17013 !
!
G, PROPERTY LOCATION: H, SETTLEMENT AGENT: 25-1894310 I. SETTLEMENT DATE:
2263 WALNUT BOTTOM ROAD Salzmann, Hughes & Fishman, P,C.;
CARLISLE, PA 17013 April 29, 2004
CUMBERLAND County, Pennsylvania PLACE OF SETTLEMENT i
95 Alexander Spring Road, Ste. 3 I
Carlisle, PA 17013 ,
J SUMMARY OF BORROWER'S TRANSACTION K, SUMMARY OF SELLER'S TRANSACTION
100. GROSS AMOUNT DUE FROM BORROWER: 400. GROSS AIVIOUNT DUE TO SELLER:
101 Contract Sales Price 198,90000 401 Contract Sales Price I 198,900,00
102 Personal Procertv 402. Personal Property I
103 Settlement Charqes to Borrower (Line 1400\ 9,086,60 403, I
104 404, I
105 405, \
Adlustments For Items Paid By Seller in advance , Adjustments For Items Paid By Seller in advance
106 COllntvlTwD Taxes 04/29/04 to 12/31104 267.43 406, Countv/Two. Taxes 04/29/04 to 12/31104 267.43
107 School Taxes 04/29104 10 07/01/04 34964 407, School Taxes 04/29/04 to 07/01/04 349,64
108 Assessments to 408 Assessments 10
109 409
110 410,
111 411.
112 412 :
120 GROSS AMOUNT DUE FROM BORROWER 208,603,67 420, GROSS AMOUNT DUE TO SELLER 199,517,07
200. AMOUNTS PAlO BY OR IN BEHALF OF BORROWER: 500. REDUCTIONS IN AMOUNT DUE TO SELLER:
?01 oeOoslt or earnest money 50000 501, Excess Deoosit (See Instructions)
202. Principal Amount of New loan(s) 159,120,00 502. Settlement Charaes to Seller IUne 140m 14,932,22
203 Existina loan(s) taken sllbiect to 503, Existina loan(s) taken subiect to
204 504, Payoff 01' first Mortgage to ORRSTOWN BANK11933539 150,758m
205 505, Pavoff of second Mortgage to WILLIAM L. SCHREIBER 4,823,1'
206 506, ; I
207 507. ! (Deoosit disb. as proceeds) I
208 508, , I
209 509,' I
Adiustments For Items Unoaid BVSeller Adjustments For Items Unpaid Bv Seller
210 CountvlT;;; Taxes to 510 ; COllntvlTwo. Taxes to
211 School Taxes to 511, School Taxes to
212 Assessments 10 512, Assessments to
213, 513"
214 SELLER ASSISTANCE 11,000,00 514,' SELLER ASSISTANCE 11,000,[
215 515,
216. 516'
217, 517'
218 518'.
219 519',
220, TOTAL PAID BY/FOR BORROWER 170,620,00 520, TOTAL REDUCTION AMOUNT DUE SELLER \ 181,514,
300. CASH AT SETTLEMENT FROM/TO BORROWER: 600. CASH AT SETTLEMENT TOIFROM SELLER:
301. Gross Amount Due From Borrower ILine 120) 208,603,67 601. Gross Amount Due To Seller (Line 420) I 199,517,
302 Less Amount Paid By/For Borrower (Line 220) ( 170,620,00) 602. less Reductions Due Seller (Line 520) ( 181,514
303, CASH ( X FROM) ( TO) BORROWER /l r-. 37,983,67 603, CAS" [ X TO) ( FROM) SELLER 18,002,
The undersigned hereby acknowledge 1tei of a mrfete copy of pages 1 &2 of this statement & any attachments referred to herein.
/ '
\
OMB NO. 2502-0285 q.:
II
L. SETTLEMENT CHARGES
@ % 11,274,00 PAID FROM PAID FROM
700. TOTAL COMMISSION Based on Price $
Division of Commission (line 700) as Follows' BORROWER'S SELLER'S
FUNDS AT FUNDS AT
701 $ 11,274,00 10 REIMAX STERLING ASSOCIATES
SETTLEMENT SETTLEMENT
702, $ 10 11,274,01
703. Commission Paid at Settlement
704, 10
BOO. ITEMS PAYABLE IN CONNECTION WITH LOAN
801 Loan Oriaination Fee % 10
aD? Loan Discount 0,3750 % to MORTGAGE LENDERS NETWORK USA, INC, 596,70
803 Appraisal Fee to JOSEPH P BEDDIA 275,00
804, DOC PREP FEE to MORTGAGE LENDERS NETWORK USA, INC, 250.00
805 MORTGAGE BROKER FEE 10 A LENDING HAND MORTGAGE RESOURSES 2,406,10
806 UNDERWRITING FEE to MORTGAGE LENDERS NETWORK USA, lNG, 449,00
807 PROCESSING FEE to A LENDING HAND MORTGAGE RESOURSE3 400,00
808
809,
810 I
811 T
900. ITEMS REQUIRED BY LENDER TO BE PAID IN ADVANCE
901. Interest From 04/29/04 10 05/01/04 @ $ 24276500/day ( 2 days %) 48.55
902. Mortga e Insurance Premium for months to
903. Hazard InsLlrance Premium for 1,0 vears to ERIE INSURANCE POC $586oob
904
905
1000. RESERVES DEPOSITED WITH LENDER
1001. Hazard Insurance monlhs IiiJ $ ner month
1002. Mortaaoe Insurance months IiiJ $ ner month
1003. CounlvlTwn. Taxes months ffi) -- $ ner month
1004 Schoal Taxes months -'6)- $ ner month
1005 Assessments months @ $ per month
1006 months Ifj} $ ner month
1007 months @ $ per month
1008 months @. $ per month
1100. TITLE CHARGES
1101. Seltlementor Closino Fee 10
1102 Abstract or Title Search to
1103. Title Examination 10
1104 Title Insurance Binder to
1105 Document Preoaration to Salzmann, H-unhes & Fishman, P.C, 250,OC
1106 Notarv Fees to Salzmann Hl'l;"hes & Fishman, P.C. 10,00
1107. Attorney's Fees to
(includes above item numbers: )
1108 Tille Insllrance to Stewart Tille Guarant~, Comaanv/SHF PC 1 353,75
(includes above item numbers:11 01-1105; 1107-1111 )
1109, Lender's Coverage $ 159,100,00
1110, Owner's Coverage $ 198,900,00 1,353,75
1111 Endorsements 10013001900 to Stewart Title Guaranty Company/SHF, PC 150,00 ,
1 t 12, Insured Closing Protection Ltr to Stewart Title Guaranty Company/SHF, PC 35,00
1113
1200. GOVERNMENT RECORDING AND TRANSFER CHARGES
t201 Recording Fees: Deed $ 38,50 ; Mort9age $ 64,50; Releases $ 103,00
1202 Citv/COllntv Tax/Stamos: Deed 1 989,00' Mort"aae 1,98900
1203 Slale Tax/Stamos Revenue Stamps 1 ,989oo; Mortna"e 1,989,00
1204
1205,
1300, ADDITIONAL SETTLEMENT CHARGES
1301, Survev 10
1302. Pest Insaeetian 10
1303 Overnioht Mait Fee 10 Salzmann Huahes & Fishman, P,C. 20,50 46,50
1304 DEMOSTIC RELATIONS SEARCH to SALZMANN, HUGHES & FISHMAN 20,00
1305 See addil'l disb exhibit 10 1,000,00 1,352,73
1400. TOTAL SETTLEMENT CHARGES (Enter on lines 103, Section J and 502, Section K) .....-, 9,086,60 14,93223
By signing page 1 or this statement, the slgn~tO(ie5 acknowledge receipt ot a completed copy of page 2 of this , /-
/4,(ir/ ___
~~ hesTFlshman, PC,
Certified to be a true copy. SeW e Agent
Page
ADDITIONAL DISBURSEMENTS EXHIBIT I
Borrower: JESSE L, PALMER, SR.
JESSICA R. PALMER
Seller: JOHN V. HOPKINS
SUSAN HOPKINS
Lender: MORTGAGE LENDERS NETWORK USA,
Settlement Agent: Salzmann, Hughes & Fishman, P.C.
(717)263-2121
Place of Settlement: 95 Alexander Spring Road, Ste. 3
Carlisle, PA 17013
Settlement Date: April 29, 2004
Property Location: 2263 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
CUMBERLAND County, Pennsylvania
PAYEEIDESCRIPTlON
NOTE/REF NO
BORROWER
SELLER
CUMBERLAND COUNTY DOMESTIC RELATIONS
DOMESTIC LIENS DUE
RE/MAX STERLING ASSOCIATES
REALTOR AGENCY FEE
1,352.73
1,000,00
Total Additional Disbursements shown on Line 1305
$
1,000.00
$
1,352.73
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SUSAN M. HOPKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
JOHN W. HOPKINS,
Defendant
NO. 03-4276 CIVIL TERM
ORDER OF COURT
AND NOW, this 3rd day of June,. 2004, this matter
having been called for a hearing this date, the parties having
reached an agreement as per the attached colloquy, said
agreement as reflected by that colloquy is made an order of this
court.
Edgar B.
Sheriff
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~arcus A. McKnight, Esquire
For Plaintiff
vearol J. Lindsay, Esquire
For Defendant
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1 June 3, 2004, 10:55 a.m.
2 Carlisle, Pennsylvania
3 THE COURT: I understand there is a
4 stipulation.
5 MS. LINDSAY: Yes, YOul: Honor, there is a
6 settlement here.
7 MR. MCKNIGHT: Your Honor, we have petitioned
8 the Court. From the marital home sale, the proceeds check
9 of $16,202.69 has been issued, and we were seeking to have
10 it distributed as a credit towards her ultimate equitable
11 distribution now so that my client could purchase a new home
12 for her and five kids from a previous marriage.
13 We have agreed to divide this money equally
14 so that each party would get half of the proceeds. We won't
15 have to put it in escrow. It would be credit towards the
16 final distribution of the marital assets.
17 In addition to that, because the marital home
18 has been sold, the defendant, Mr. Hop'dns, had been paying
19 alimony pendente lite to my client, and part of that was
20 towards the mortgage payment on the marital residence.
21 We have agreed to retroactively reduce the
22 alimony pendente lite giving credit to the husband from the
23 date of the settlement which occurred April 29th. So April
24 29th retroactive from then until now he will get a credit
25 for the amount of the mortgage assistance, and we will tell
1
1 Domestic Relations.
2 THE COURT: You are going to tell Domestic
3 Relations that figure and let them calculate that out?
4 MR. MCKNIGHT: Yes.
5 MS. LINDSAY: And the credit will, of course,
6 proceed into the future.
7 MR. MCKNIGHT: Yes.
8 MS. LINDSAY: The amount of APL will be
9 reduced from April 29th by the amount of the mortgage
10 assistance.
11 THE COURT: Now, they are going to take and
12 divide the money on hand right now, the 16,000, and that
13 will be money that will be applied to each of their awards
14 in equitable distribution?
15 MR. MCKNIGHT: That's correct.
16 MS. LINDSAY: That's correct.
17 THE COURT: But it will not necessarily
18 determine what the actual equitable distribution of that
19 money and all the other assets are, is that correct?
20 MS. LINDSAY: That's correct. That's without
21 prejudice, and this compromise does not prejudice either of
22 their claims. The money is really non-marital in nature.
23 It is an accommodation on account of the parties' needs at
24 the present time.
25 THE COURT: That is the agreement?
2
1 MR. MCKNIGHT: That's the agreement.
2 MS. LINDSAY: That's the agreement.
3 THE COURT: Enter this order. This matter
4 having been called for a hearing this date, the parties
5 having reached an agreement as per the attached colloquy,
6 said agreement as reflected by that colloquy is made an
7 order of this court.
8 (Whereupon, the stipulation was concluded
9 at 11:00 a.m.)
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
3
SUSAN M. HOPKINS,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VS.
CIVIL ACTION - DIVORCE
JOHN W. HOPKINS,
Defendant/Respondent
NO. 2003-4276 CIVIL TERM
IN DIVORCE
Pacses# 056105885
ORDER OF COURT
AND NOW, this 22nd day of June, 2004, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,832.09 and Respondent's monthly net income/earning
capacity is $2,303.47, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $189.00 per month payable monthly as follows; $189.00 for
alimony pendente lite and $0.00 on arrears. First payment due next pay date. Credit set at $276.39 as
of June 22, 2004, The effective date of the order is April 29, 2004
This Order is based upon stipulation of the parities pursuant to the marital residence being sold on
April 29, 2004.
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.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 P A SCDU to: Susan Hopkins. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid 56% by the respondent
and 44% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten 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 Prothonotary for a hearing de novo before
the Court.
DRO: R. J, Shadday
Mailed copies on
6-23-04 to: <
Petitioner
Respondent
Carol lindsay, Esquire
Marcus McKnight, Esquire
BY THE COURT,
Edgar B. Bayley
J.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 06/22/04
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
DFAS CLEVELAND CENTER*
C/O DFAS CODE L
GARNISHMENT OPS
PO BOX 998002
CLEVELAND OH 44199-8002
hil .;>OO?! '~)'7L:' {'V
/J/C'S'Z s t?5&,/OS-Jv't's
RE: HOPKINS, J'OIIN W.
Employee/Obligor's Name (last, First, MI)
071-46-1565
Employee/Obligor's Social Security Number
8165101056
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Ml)
Employer/Withholder's Federal EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: 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.
$ 189.00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes (X) no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 189.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the SUPPOlt order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 43.62 per weekly pay period.
$ 87.23 per biweekly pay period (every two weeks).
$ 94.50 per semimonthly pay period (twice a month).
$ 189.00 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 #1 0 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 &9112, Harrisburg, Pa 1710&-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case l~en'tifi1r)qR "SC'C/AL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. "'-..,~.~C .,L,o<.-'__,'.., '
(1'4:3 ,or BY THE COU
ecx;,
r-
Date of Order:
jUN 2 3 20lJlt-
Service Type M
OMB No.: 097Q-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If ~hecked you are required to provide a ~opy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided 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 Ihan 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
em ployee/ob I igor.
4. * Repo,Jc;"g lL~ Payddl~'Dd~ ci'lIitkholding. You ",ust lepolt tLe paydateldAtc.: of yy;tII,l,old;l,g nLCl1 ~el ,ding the paylllellt. Ti,e
pCl.ydateldate of yv;ll,l,old;"g;.3 U,e dale Oil vvl,;(h 31T10Ul,t nas nitltl,eld ft011l ti,e elllploYI~e'3 vvAgO. 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
Ihis 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, 2491016300
EMPLOYEE'S/OBlIGOR'S NAME,
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS,
NEW EMPLOYER'S NAME/ADDRESS,
HOPKINS, JOHN W.
B165101056 DATE OF SEPARATION,
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. Anti'iliscrimination: 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 olf 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 (1 5 U.s.c. 91673 (b)l; or 2) the amounts allowed by Ihe 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 taxesi Social Security taxesi 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:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. 80X 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 QlZl.240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form E N-028
Worker ID $IATT
Service Type M
OMBNo,;0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HOPKINS, JOHN W.
PACSES Case Number 056105885
Plaintiff Name
SUSAN M. HOPKINS
Docket Attachment Amount
03=4276'CIVIL$ 189.00
Child(ren}'s Name(s):
PACSES Case Number
Plaintiff Name
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s ''oJame(s),
DOB
If you are required to enroll the chiid(ren)
in any health insurance coverage available
through the employee's/obligor's employment.
If
you are required to enroll the child(ren)
in any health insurance coverage available
ernployee's/obligor's employment.
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
PACSES Case Number
Plaintiff Name
D If checked, you are required to enroll the child(ren)
identjfied above in any health insurance coverage available
through the empioyee's/obligor's employment.
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
through the employee's/obiigor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name;
Docket Attachment Amount
$ 0.00
Child(ren}'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
If you are required to enroll the child(ren)
above in any health insurance coverage available
the employee's/obligor's employment.
Addendum
Form E N-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
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LIEN SATISFACTION
Name: John Hopkins
Social Security Number: 071-46-1565
Judgment Lien Satisfied as of: 05-04-04
Amount Paid: $ 1352.73
Signed: f}~i. /J; ib~A--
(Lien Coordinator)
:Pacses# 056105885
No. 03-4276 CV
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SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 29,
2003.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing ofthe complaint.
3. I consent to the entry of a final decree in 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
~
Date: :3 -1~ cdo05
~ ~
sUSA~~KI S
Plaintiff
~iI)
(
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003- 4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 verity that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: !! ~~&tf:..
,
rvt~ . rftj, ;ri~., ~-
StrSAN M. HOPKINS grtJ
Plaintiff
--------
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
2003.
1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on August 29,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date: 1 fVl Pr u /.42006'
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~N W. HOPKINS
Defendant
---I
SUSAN M. HOPKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-4276 CIVIL TERM
JOHN W. HOPKINS,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:-:7 fI1v1d I G ,~
C~.~ ~
J N :- HOPKINS
Defendant
/-------
SUSAN M. HOPKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 4276 CIVIL
JOHN W. HOPKINS,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
~
day of
~'-
2006, the parties and counsel having entered into an agreement
and stipulation resolving the economic issues on March 7, 2006,
the date set for a Master's hearing, the agreement and
stipulation having been transcribed, and subsequently signed by
the parties and counsel, the appointment of the Master is
vacated and counsel can conclude the proceedings by the filing
of a praecipe to transmit the record with the affidavits of
consent of the parties so that a final decree in divorce can be
entered.
BY TH://f......OU R'F,
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Edga~. BaYle~p.J.
cc: ~rcus A. McKnight, III
Attorney for Plaintiff
-
--
SUSAN M. HOPKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 4276 CIVIL
JOHN W. HOPKINS,
Defendant
IN DIVORCE
THE MASTER: Today is Tuesday, March 7, 2006.
This is the date set for a hearing in the above captioned
divorce proceedings.
Present in the hearing room are the
Plaintiff, Susan M. Hopkins, and her counsel Marcus A.
McKnight, III, and the Defendant, John W. Hopkins, and his
counsel Carol J. Lindsay.
A complaint in divorce was filed on August
29, 2003, raising grounds for divorce of irretrievable
breakdown of the marriage. The Master has been provided
affidavits of consent and waivers of notice of intention to
request entry of divorce decree which documents have been
signed by both parties today and dated with today's date.
The affidavits and waivers will be filed with the
Prothonotary by the Master's office. The divorce can then
go forward under Section 3301(c) of the Domestic Relations
Code.
The complaint did not raise any economic
claims; however, on December 23, 2003, the Plaintiff filed a
petition raising claims of equitable distribution, alimony,
alimony pendente lite, and counsel fees and costs.
1
.
..-
The parties were married on June 2, 1996, and
separated July 1, 2003. There were no children born of this
marriage.
The Master has been advised that after
negotiations today and previously the parties have reached
an agreement with respect to the outstanding economic
claims. An agreement is going to be placed on the record in
the presence of the parties. The agreement will be
considered the substantive agreement of the parties not
subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. After the agreement has been transcribed
this morning, the parties and counsel will return to review
for typographical errors, make any corrections as necessary,
and then sign the agreement affirming the terms of
settlement as stated on the record. However, even if the
agreement is not signed, the parties are bound by the
agreement when they leave the hearing room after it has been
stated on the record.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
decree in divorce. Mr. McKnight.
MR. McKNIGHT:
2
,
1. The parties have, after extensive negotiation, agreed
that all of the assets in their own possession will remain
their own with the exception of some personal belongings of
John Hopkins that Susan Hopkins has in her basement. She
has been storing them since separation and within ten days
he will make arrangements to pick those up. In all other
respects, the personal property has been distributed and is
now their own and each waive interest in the others personal
property. (Personal property referred to includes the
tangible personal property and all bank accounts.)
Husband is going to stop by, after notice, within ten
days to pick up some items of tangible personal property
which would include some boots, clothes, photographs of his
children from a previous marriage, and any other items which
wife finds in the basement which she believes are husband's
property. A third party may be permitted to pick up these
items and wife has provided a phone number where that person
can call in order to make arrangements to pick up.
2. With regard to the New York State Retirement Plan,
which husband, John Hopkins, is the beneficiary of, the
parties agree that wife will maintain her survivor interest
in said plan and that husband will sign all documents
necessary to confirm that that indeed is the case with the
New York State Retirement System. Wife waives any interest
she has in husband's New York State Retirement Plan with the
exception of the survivor annuity.
In all other respects, the parties waive all interest
in any employee benefits that each has in the other and
wife's own benefits with her current employer are her own;
husband's benefits with his current employer are his own and
likewise his TSP plan are solely his interest. Wife waives
all interest in husband's TSP plan.
3. In addition, husband agrees to pay within ten days the
sum of $3,000.00 to wife.
4. In other respects, the parties waive all claims for
counsel fees and costs. With this exception the initial
retirement valuation with Harry Leister was incurred or paid
by husband. The secondary valuation of the retirement plan
will be wife's responsibility and she will pay that to Harry
Leister. I think the amount is $550.00.
5. Upon vacation of the appointment of the Divorce Master,
counsel for the wife will immediately file a praecipe to
finalize the divorce and upon the finalization of the
divorce all alimony pendente lite will end with the
3
.
exception of any arrearages due on that date and the
praecipe will be filed on or before March 17, 2006, with
the Court.
6. Wife further waives any claim she has to alimony after
the entry of the divorce decree from husband.
7. All marital debt has been paid. Any other debts
incurred after the separation are the responsibility of the
person incurring said debt and they, of course, hold
harmless any claims for post-separation debt from the other
so to the best of our knowledge there should be no claims
about debt to either party.
8. 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
may now have or hereafter acquire under the present or
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, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MS. LINDSAY: John, you've heard the
agreement that we reached today as recited by Mr. McKnight?
MR. HOPKINS: Yes.
MS. LINDSAY: Is this the agreement you want
to make?
MR. HOPKINS: Yes.
MS. LINDSAY: You understood the agreement as
he recited it?
MR. HOPKINS: Yes.
MS. LINDSAY: Do you have any questions or
4
r
concerns.
MR. HOPKINS: No.
MR. McKNIGHT: Susan, do you understand the
agreement today?
MS. HOPKINS: Yes.
MR. McKNIGHT: And do you understand that the
divorce is going to become final here shortly and at that
point your alimony will end; there will be no further claims
for alimony or anything else except for what he is paying
you and the survivor annuity?
MS. HOPKINS: Yes. Exactly.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
4~
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tusan M. Hop ins
L'ndsay
r Defendant
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Jc6h W. Hopkins
5
SUSAN M. HOPKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JOHN W. HOPKINS,
Defendant
2003-4276 CIVIL TERM
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:
I. Ground for Divorce: Irretrievable breakdown under Section 330 I (c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, John W. Hopkins, on September IS, 2003, by certified, restricted delivery mail, addressed to him at P.
O. Box B93, Orrstown, Pennsylvania 17244, with Return Receipt Number 7001 2510000928284234.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 330 I (c) of the Divorce
Code: by plaintiff: March 7, 2006; by defendant: March 7, 2006.
(b)(1) Date of execution of the affidavit required by Section 330 I (d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiff's affidavit upon the defendant:
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:
(b) Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: March 7, 2006.
Date
Prothonotary: March 7, 2006.
the
T, III, ESQUIRE
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
SUSAN M. HOPKINS,
PENNA.
STATE OF
Plaintiff
No. 2003-427 6 CIVIL TERM
CIVIL ACTION - LAW
VERSUS
IN DIVORCE
JOHN W. HOPKINS,
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DECREE IN
DIVORCE
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AND NOW,
2006 ,IT IS ORDERED AND
-""'a.,d1
SUSAN M. HOPKINS
DECREED THAT
, PLAINTIFF,
JOHN W. HOPKINS
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marriage Settlement Agreement dated March 7, 2006 and signed by the
parties is hereby incorporated into this Decree, but not merged.
By TH
04iL
~~~P"OT"ONOTA"~
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,,~ b :2 ~nP '~ llO.$'- ['"'
~4'.?j4/ jw ft- ~??W~,7 ',)'?9 f)(/.~ei
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
SUSAN M. HOPKINS ) Docket Number 03-4276 CIVIL
Plaintiff )
Ys. ) PACSES Case Number 056105885
JOHN W. HOPKINS )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
31ST DAY OF MARCH, 2006
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
o Terminated without prejudice or (i) Terminated and Vacated,
effective
MARCH 21, 2006
, due to:
THE PARTIES' MARITAL SETTLEMENT AGREEMENT BEFORE THE DIVORCE MASTER ON
MARCH 7, 2006 AND THE PARTIES' DECREE IN DIVORCE ON MARCH 21, 2006.
THE ABOVE CAPTIONED CASE IS CLOSED WITH A CREDIT BALANCE OF $188.57.
BY~
' v \ \AbA
.- ., \ . \ JUDGE
Service Type M
Form OE-504
Worker ID 21005
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 03/31/06
Case Number (See Addendum for case summary)
056105885
03-4276 CIVIL
o Original Order/Notice
o Amended Order/Notice
(2) Terminate Order/Notice
DFAS CLEVELAND CENTER'
C/O DFAS CODE L
GARNISHMENT OPS
PO BOX 998002
CLEVELAND OH 44199-8002
RE: HOPKINS, JOHN W.
Employee/Obligor's Name (Last, First, MI)
071-46-1565
Employee/Obligor's Social Security Number
8165101056
Employee/Obligor's Case Identifier
(See Addlmdum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mil
EmployerMlithholder's Federal EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: 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 support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 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:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0 . 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 SS% 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).
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, PA YMENTS 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 BY MAIL.
Date of Order: APR 0 3 2006
BYTH~URT: :u
\ VI \?~
wgar. y, \ \Jl.X1ge
..
Form EN-028
OMBNo.:0970-0154 Worker ID $IATT
DRO: R.J. Shadday
Service Type M
.
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~hecked you are required to provide a copy of this form to your employee. If your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
,. 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 idenflfy the portion of the single payment that is attributable to each
employee/obligor.
3.* Repurtiflg tl,e--Payd-atef8-a--of--VVitl,l,oIJ;lIo' YOu fllu:.llepult tl,t:::payJole/Jate uf-withhotding-wl'd' sellding-the--pa:YIIlt:::Ilt. Tile-
payJate!Ja~ uf vv;tlll\oIJ;\l5 ;yth-e-date-oll vv\,;d, d.1I10Ulll vVa~ vvill,lu;:IJ f,u",-theemp~~ages. 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 forvvard the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
Ihis 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 Ihe 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.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR, 2491016300
EMPLOYEE's/OBlIGOR'S NAME: HOPKINS , JOHN W.
EMPLOYEE'S CASE IDENTIFIER: 8165101056 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
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 wilhhoJd more than the lesser of: 11 the amounts allowed by the Federal Consumer Credit
Protection Acl (15 U.S.c. 91673 (bl1; or 2) the amounts allowed by Ihe 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. 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 amounts allowed under the law of the state that issued the order.
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 respecl to these items.
11. Submitted By:
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
Form EN-028
Worker ID $IATT
Service Type M
OM8 No.: 0970-0154
.
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: HOPKINS, JOHN W.
PACSES Case Number 05610588S
Plaintiff Name
SUSAN M. HOPKINS
Docket Attachment Amount
03-4276 CIVIL$ 0.00
Child(ren)'s Name(s):
PACSES Case Number
Plaintiff Name
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o 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.
o 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
PACSES Case Number
Plaintjff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amounl
$ 0.00
Child(ren)'s Name(s):
DOB
o 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.
o If checked, you are required to enroll the child(ren)
identjfied above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If you are required to enroll the child(ren)
above in any health insurance coverage available
the employee's/obligor's employment.
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
the empJoyee's/obJigor's employment.
Service Type M
Addendum
Form E N-028
Worker ID $IATT
OMB No.: 097Q.-0154
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