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HomeMy WebLinkAbout07-4221STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW KELLY L.MILLER, : N0.07 - ~(2 2 l CIVIL TERM Defendant : IN DNORCE AND CUSTODY NOTICE You have been sued in court. If you wish to defend against the clauns set fottll in the following pages, you must take prompt action. You are roamed that if you fail to do so, the case may proceed without you and a decree in divorce or annulment maybe 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 STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KELLY L.MILLER, Defendant CIVIL ACTION -LAW N0.07 - yaZ -2 / CIVIL TERM IN DIVORCE AND CUSTODY COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Bradley S. Miller, an adult individual residing at 312 West Main Street, Apt. 5, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is Kelly L. Miller, an adult individual residing at 2818 Boas Street, Harrisburg, Dauphin County, Pennsylvania 17103. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 6, 2002, in Harrisburg, Pennsylvania. 5. A prior action of divorce between the parties was filed but a praecipe to discontinue was filed and the case was dismissed. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the pasties to participate in counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 33010 OF THE DNORCE CODE 7. The averments of Paragraphs 1 through 6 hereof are incorporated herein by reference. 8. The marriage between the parties is irretrievably broken. 9. After ninety (90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days have elapsed from the filing and service of this Complaint, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(c) of the Divorce Code. COUNT II RE ,ZUEST FOR A NO-FAULT DNORCE UNDER SECTION 3301(~,~OF THE DIVORCE CODE 10. The averments of Paragraphs 1 through 9 hereof are incorporated herein by reference. 11. The marriage of the parties is irretrievably broken. 12. The parties are living separate and apart; and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in § 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(d) of the Divorce Code. 13. The averments of Paragraphs 1 through 12 hereof are incorporated herein by reference. 14. Plaintiff seeks custodyof the following child: Name Present Residence Awe Noah B. Miller 2818 Boas Street 5 years Harrisburg, PA 17103 D.O.B. 12/24/2001 15. A second child, Elijah Miller, was born during the marriage of the parties but pending the determination of paternity in Dauphin Countywhere a support action has been filed by Defendant, Plaintiff is not seeking custody of Elijah at this time but reserves his right to do so pending the outcome of blood tests. 16. Plaintiff and Defendant are the natural parents of Noah B. Miller. 17. The child was born prior to the marriage of the parties. 18. The child is presently in the custody of Defendant, who resides at 2818 Boas Street, Harrisburg, Pennsylvania 17103. 19. Since the child's birth, the child has resided with the following persons at the following addresses: ~~ ~ ; Defendant 2818 Boas Street 5/29/07-present Hamsburg, PA 17103 Plaintiff/Defendant 304 State Street, Apt. 1 7/2006-5/29/2007 Enola, PA 17025 Plaintiff/Defendant 2818 Boas Street 3/2005-7/2006 Harrisburg, PA 17103 Defendant 2818 Boas Street 12/2004-3/2005 Harrisburg, PA 17103 Plaintiff/Defendant 3814 Colonial Road 7/03-12/2004 Harrisburg, PA 17109 Plaintiff/Defendant 2818 Boas Street Birth-7/2003 Harrisburg, PA 17103 20. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 21. Plaintiff has no information of a custodyproceeding concerning the child pending in a court of this Commonwealth or any other state. 22. Plaintiff does not know of a person not a partyto the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 23. Father has been alienated from the child since the parties' separation on May 29, 2007 by not having telephone contact with him and Mother has denied Father any visitation with his child. 24. Plaintiff seeks shared legal custody and partial custody of the child on an ever other-weekend basis from Saturday at 12:00 p.m, until Sunday at 12:00 p.m., every Tuesday from 4:00 p.m. unti18:00 p.m., and the third full week each July. 25. Plaintiff seeks the establishment of a specific location for the exchange of custody between the parties at a public place that is not at either party's residence. 26. The best interest and permanent welfare of the child will be served by granting the relief requested because the child needs to continue to have a relationship with his Father, and because Father is concerned that Mother will not allow him to have partial custody of the child without an order of court based on her actions since the separation. WHEREFORE, for the reasons set forth herein, Plaintiff, Bradley S. Miller, respectfully requests that the Court enter an order granting him shared legal and partial custody of the child. WOL & WOLF ~U ~ ` , 2007 BY: ''~+ - STACY B WOLF, ESQUI Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff VERIFICATION I verifythat the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.GS. Section 4904, relating to unsworn falsification to authorities. ~ , zoos Bradley S. Mill ,Plaintiff r: ~ , .,~, .a ~, ~ Z O~ ~ ~' ~` `~- ~~ ~- ,~ _` `~' O ~ ~ :,~ ~ ~. ~: ^C G~ ~ <n G `~'' BRADLEY S. MILLER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KELLY L. MILLER DEFENDANT • 07-4221 CIVIL ACTION LAW 1N CUSTODY ORDER OF COURT AND NOW, Monday, July 23, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at ____ 4th Floor, Cumberland Coun Courthouse, Carlisle _ on Tuesday, August 14, 2007 at 9:30 AM -~---- - - for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard. by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Is/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NO'T' HAVE AN ATTORNEY 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 Carlis]e, Pennsylvania 17013 Telephone (717) 249-3166 ~ '` L~ ~~°~, C ~a1 ~• L ~'~" ~~ _ _ _, ~~ r =.~ ;~,~ ~~ . L~ ~ pp :; ~~ JUL t02~7~ STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, Plaintiff' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KELLY L.MILLER, Defendant CIVIL ACTION -LAW N0.07 - _ CIVIL TERM IN DIVORCE AND CUSTODY PLAINTIFF'S 1VLA~Ri_AGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of mamage 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 mamage counselors in the Prothonotar~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 unswom falsification to authorities. [ ~ 2007 Bradley S. M' r, Plaintiff _ ~ ~ ` ~ ~, ~ = c- c= -~ r` ~~ -~ -. r _ . -nr~° _ j r'~ _ _..... l .'.J C. J'7 .~7 ~~ °'C BRADLEY S. MILLER, Plaintiff v. KELLY L. MILLER, Defendant :IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4221 CIVIL ACTION -- DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kelly L. Miller, Defendant, to proceed In forma pauperzs I, Nora F. Blair, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party in her support matters having been appointed by MidPenn Legal Services. submi i1V a F. Blair -' S reme Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 ~ ~ ~ rT'? y ~ ~..., ~ ~ r ~: f J ~ : ~ fTl _:~J {'-7 'S" , -,C ,. ~ ~ ~ ~'~...- ..',. 7~~ ~ ~ >~~ Ef ,. ~ _ _ ; BRADLEY S. MILLER, Plaintiff v. KELLY L. MILLER, Defendant :IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4221 CIVIL ACTION -- DNORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EKPENSES 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 23 South Bedford Street Carlisle, PA 17013 (717) 249-3166 BRADLEY S. MILLER, Plaintiff v. KELLY L. MILLER, Defendant :IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4221 CIVIL ACTION -- DNORCE ADDITIONAL COUNTS TO DNORCE COMPLAINT And now comes Kelly L. Miller and by and through her attorney, Nora F. Blair, Esquire files these Additional Counts to Divorce Complaint and in support thereof avers as follows: 1. A Complaint in Divorce Pursuant to Section 3301 of the Divorce Code was filed in the above-captioned matter on July 18, 2007. 2. Defendant now desires to file additional counts to the Divorce Complaint. COUNTI ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 3. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 4. Defendant is unable to sustain herself during the course of litigation. 5. Defendant lacks sufficient property to provide for her reasonable needs and is unable sustain herself through appropriate employment. 6. Plaintiff has sufficient resources available to sustain himself, pay his counsel fees, costs and expenses and provide assistance to Defendant for her support, counsel fees, costs and expenses. 7. Plaintiff is in a better position to provide for Defendant than Defendant can provide for herself. 8. Defendant desires that the Court enter an award of Alimony Pendente Lite, Counsel Fees, Costs and Expenses after considering all relevant factors. WHEREFORE, Defendant respectfully requests thatYour Honorable Court enter an award of Alimony Pendente Lite until final hearing and that the Court enter an Order directing Plaintiff to pay Defendant's reasonable counsel fees, costs and expenses pursuant to Section 3702 of the Divorce Code. COUNT II ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 9. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 10. Defendant lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 11. Plaintiff has sufficient property and resources to provide for himself and Defendant. 12. Defendant desires that the Court enter an award of permanent alimony after considering all relevant factors. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an award of alimony to be paid to Defendant by Plaintiff pursuant to Section 3701 of the Divorce Code. DATED: ~- ~ _ a Respectflx,~Yy submitted, F. Blair Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFI%ATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904. relating to unsworn falsification to authorities. Dated: ~` 3 0 BRADLEY B. MILLER, Plaintiff v. KELLY L. MILLER, Defendant :IN THE COURT OF~ COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4221 CIVIL ACTION -- DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Additional Counts to Divorce Complaint on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Stacy B. Wolf, Esquire 10 West High Street Carlisle, PA 17013 Date: August 3, 2007 Respec, y submitte - _--- ~ _s i~ r' r ra F. Blair C ~ ~ -... ~ yS{1' ~ _ C`i r"' , rf? . . ( "t,7 ~ F it .~ fJ7 :~7 ~~ ,,,~ STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KELLY L.MILLER, Defendant CIVIL ACTION -LAW N0.07 - ~a~~ CIVIL TERM IN DIVORCE AND CUSTODY DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being dulysworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotar~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 verifythat 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. .3 , 2007 - elly L. er, Defendant Cs ~ p ~: ~ -n ~.. '.~ ~~r: :r;~ ~ ~ rn~ v;, '; , ~ ~ _ r~ ~ `~ ~1 ` " : f.. .j t` ..,~ Q ~:~ f7 'rte ~_ .CMM1 ~,'Y ~ STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KELLY L. MILLER, Defendant CIVIL ACTION -LAW N0.07 - ~~ ( CIVIL TERM IN DIVORCE AND CUSTODY ACCEPTANCE OF SERVICE I, Kelly L. Miller, certify that I am the defendant in this matter. Furthermore, I hereby certifythat on ~-~ J , 2007, I received a certified copy of the divolre complaint filed in this action. 3 , Zoos Kelly L. Defendan o ~ _-~-~ r ~ ' ~ ~ _ ~ ~ ~ tf, - : Cri `~~ ~ 7 .,. - _ ~_ ~ _ f. ='~ J-- ~r y ~:. N ~ .~G i~EP Ad 20~,u ~~~ BRADLEY S. MILLER, Plaintiff VI. KELLY L. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4221 IN CUSTODY ORDER OF COURT CIVIL ACTION -LAW AND NOW, this Std day of S E ~~ t M 4k ~. , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Bradley S. Miller and the Mother, Kelly L. Miller, shall have shared legal custody of Noah B. Miller, born December 24, 2001. Each parent shall have an equal right, to be exercised jointly with the other pazent, to make all major non- emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regazding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to medical, dental, religious or school records, the residence address of the child and the other pazent. To the extent one parent has possession of any such records or information, that pazent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in alI educational and medicaUtreatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regazd to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the Like. 2. Mother shall have primary physical custody of the child. 3. Father shall have the following periods of partial physical custody of the child: A. Beginning September 15, 2007 alternating weekends from Saturday at 1:00 p.m. to Sunday at 1:00 p.m. B. Every Tuesday from 5:30 p.m. to 5:00 p.m. C. The third week in June, from Sunday at 1:00 p.m. to Sunday at 1:00 p.m. ~~,~: t~;~ti;'4 ~j~ , :;~CJ~d ~.~~~t~ a ~ ~= ~~an~ 0'~ .~, ~~d S- d~S tQOI A~`dl~iC~~~'-i.~t~`~' a~ ~Ml ~C~ D. The second week in July, from Sunday at 1:00 p.m. to Sunday at 1:00 p.m. E. The second week in August, from Sunday at 1:00 p.m. to Sunday at 1:00 p.m. 4. Memorial Day, July 4~' and Labor Day shall be alternated at times agreed by the parties with Father having physical custody of the Child for Memorial Day 2008. 5. Thanksgiving shall be shazed such that Mother shall always have physical custody of the child from 9:00 a.m. to 3:00 p.m. and Father shall always have physical custody of the child from 3:00 p.m. to 9:00 p.m. 6. Christmas shall be divided into two Blocks. Block A is from Christmas Eve at 2:00 p.m. to Christmas Day at 2:00 p.m. Block B shall be from 2:00 p.m. Christmas Day to December 26 at 2:00 p.m. Mother shall always have Block A and Father shall always have Block B. 7. Mother shall have physical custody of the child on Easter from 9:00 a.m. to 2:00 p.m. and Father shall have physical custody of the child from 2:00 p.m. to 8:00 p.m. 8. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 5:00 p.m. and Father shall always have physical custody of the child on Father's Day from 9:00 a.m. to 5:00 p.m. 9. Transportation shall be shazed such that the parties shall exchange custody at the Commerce Bank on Union Deposit Road in Harrisburg. 10. Father shall continue to participate in pazenting classes and anger management classes with his current counselor until successfiilly dischazged. Father shall sign a release so that Mother can be assured that Father continues to participate in counseling. 11. 'This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, . J. ~, ccy B. Wolf, Esquire, Counsel for Father ~,~?dora F. Blair, Esquire, Counsel for Mother ~ ~~~ ~ -6 0~ 0~~ BRADLEY S. MILLER, Plaintiff V. KELLY L. MILLER, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-4221 CIVIL ACTION -LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Noah B. Miller December 24, 2001 Mother 2. A Conciliation Conference was held in this matter on September 4, 2007, with the following in attendance: The Father, Bradley S. Miller, with his counsel, Stacy B. Wolf, Esquire, and the Mother, Kelly L. Miller, with her counsel, Nora F. Blair, Esquire. 3. The parties agreed to an Order in the form as attached. Date acq ine M. Verney, Esquire Custody Conciliator STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, Plaintiff v. KELLY L. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-4221. IN CUSTODY STIPULATION AGREEMENT, made this / ~fh day of ~G~.-~ UGC ~'' y , 2008, by and between BRADLEY S. MILLER, hereinafter referred to as "Plaintiff," and KELLY L. MILLER, hereinafter referred to as "Defendant." WHEREAS, the parties have reached an agreement concerning the issue of custodywith respect to their child, Elijah Miller, age 2 years, born December 29, 2005, and desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland County, Pennsylvania; NOW, THEREFORE, intending to be legally bound, the parties hereby agree that: 1. The best interests and permanent welfare of the child require that the parties have joint legal custody of the child, with the defendant having primary physical custody of the child and the plaintiff having periods of partial physical custody of the child pursuant to the same schedule as that of the parties' other child, Noah B. Miller. 2. Both parties, as evidenced by their joint execution of this stipulation, have mutually agreed upon an amicable arrangement for the legal and physical custody of the child and request that the Court enter an order as provided below without the necessity of a hearing: A. The parties shall have joint legal custody of their minor child, Elijah Miller (born December 29, 2005, age 2). B. The Mother shall have primary physical custody of the child. C. The Father shall have periods of partial physical custody of the child as follows: 1. Alternating weekends beginning Saturday at 1:00 p.m until Sunday at 1:00 p.m 2. Every Tuesday from 5:30 p.m unti18:00 p.m 3. The third week in June, from Sunday at 1:00 p.m until Sunday at 1:00 p.m 4. The second week in July, from Sunday at 1:00 p.m until Sunday at 1:00 p.m 5. The second week in August, from Sunday at 1:00 p.m until Sunday at 1:00 p.m D. Memorial Day, July 4`s, and Labor Day shall be alternated at times agreed by the parties with Father having physical custody of the child for Memorial Day 2008. E. Thanksgiving shall be shared such that Mother shall always have physical custody of the child from 9:00 a.m until 3:00 p.m and Father shall always have physical custody of the child from 3:00 p.m until 9:00 p.m F. Christmas shall be divided into two Blocks. Block A is from Christmas Eve at 2:00 p.m until Christmas Day at 2:00 p.m Block B shall be from 2:00 p.m Christmas Day until December 26 at 2:00 p.m Mother shall always have Block A and Father shall always have Block B. G. Mother shall have physical custody of the child on Easter from 9:00 a.m until 2:00 p.m and Father shall have physical custody of the child from 2:00 p.m unti18:00 p.m I-i Mother shall always have physical custody of the child on Mother's Day from 9:00 a.m. until 5:00 p.m and Father shall always have physical custody of the child on Father's Day from 9:00 a.m unti15:00 p.m. I. Transportation shall be shared such that the parties shall exchange custody at the Commence Bank on Union Deposit Road in Harrisburg. J. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorneyfees incurred bythe successful patty in anylitigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered bythe court. K. Any modification or waiver of arty of the provisions of the agreement of the patties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. WHEREFORE, the plaintiff and defendant respectfully request that the Court enter an Order providing for the legal and physical custody of the child as aforesaid. January ~, 2008 STACY B. W F Attorney fot Plaintiff VERIFICATION AND CONFIRMATION OF AGREEMENT We do herebyverifythat the acts set forth in this stipulation are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. COMMONW]EA]LTH OF PENNSYLVANIA: :SS: COUNI"Y OF CUMBERLAND ~ On this, the / `r dayof ,%,G~v~ , 20~, before me, the undersigned officer, personally appeared BRADLEY S. MILLER, known me (or satisfactorily proven) to be the person whose name is subscrrbed to the within instrument and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto se y and official seal. COMMONWEALTH OF PEN~lSYLVANIA N~ seal (SEA,L) Nathan c. wdf, N~ery Put~c Care ~, ,~„ ~My try Public My Gaon Expires Apr.19,2008 ~ t R~O.~~~! PENNSYLVANIA COUNTY OF CUMBERLAND Y On this, the day of ~~, 200, before me, the undersigned officer, personally appeared KELLY L. MILLER, known to me (or satisfactorily proven} to be the person whose name is subscribed to the within instrurrrent and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto se y hand and official se (SEAL) a ub ' ~,'tx of ev~- N07'ARI N~ Pablic ppR/- F, BLAIR+ 1~ -, - _. ~~~ ~~~ c.- ~~. ~~~'~~, t ". ~fi ~ ~ 1 .. a . - ; -S~, ~° 3. ,~~. S, ~,,,,,' r`- ::L. .C., .~ _' 3 $ 3 Z00 BRADLEY S. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW KELLY L. MILLER, : N0.2007-4221 Defendant IN CUSTODY ORDER OF COURT Bch AND NOW, this ~`1 day of ~ a~ v A r y 2008, upon presentation and consideration of the attached Stipulation, it is hereby Ordered and directed that the Stipulation be entered as an Order of Court. BY THE COURT, ,. Distribution: /Stacy B. Wolf, Esquire For the Plaintiff /Nora F. Blair, Esquire For the Defendant l.."0 tES /ri~tc~~.> as o 8 ~~ _~ ., ,. ~ .. i~ ,-. w ~» r.,u, W. STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BRADLEY S. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~, :CIVIL ACTION -LAW KELLY L.MILLER, : N0.07 -4221 CIVIL TERM Defendant : IN DIVORCE AND CUSTODY PRAECIPE TO WITHDRAW DIVORCE COUNTS OF DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly mark the matter withdrawn solely as to Divorce Counts I and II of the Divorce Complaint filed by Plaintiff on July 18, 2007, in the above-captioned matter. WOLF & WOLF `/~ _ . September , 2008 BY: STAGY B. LF, ESQUIRE Supreme Co ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff t:. ~ ~ -~ i ~~ t`- ~ ad~~~ ~~ s~ -` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION File No. 08-4221 WASHINGTON MUTUAL BANK, ~ Amount Due $127,399.51 Plaintiff, Interest from 08/25/2008 to date of sale $6,793.01 vs. MICHELLE CLAYTON Defendant. TO THE PROTHONOTARY OF THE SAID COURT: Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Ezhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pend ain ~ of the defendant(s) described in the attached exhibit. DATE: September 4, 2008 Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: Kimberly A. Bonner, Esquire Richard P. Haber, Esquire Eric Santos, Esquire Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 _ Plaintiff 908-233-8500 55650 89705 202567 201493 Zucker, Goldberg & Ackerman, LLC FRP-104983 ~. _, -,._ w ~ c ~ "'' x' a, `~ ' a '` v °m t1y tea` ~` ..- t-.~ '~ --: ..- ~ ~ Cif x-' ~ r~' .`. a.> ~~ ~ `` ~ ~~ EXHIBIT "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PACEL OF LAND AND PREMISES, SITUATE, LYING, AND BEING IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POST, CORNER OF LOT FORMERLY OF MARY FISHEL, NOW OR LATE OF HARRY SNYDER, AND THE BUILDING LINE OF SAID SOUTH YORK STREET; THENCE SOUTHWARD ALONG THE BUILDING LINE OF SAID SOUTH YORK STREET 69 FEET TO A FORMERLY OF W.E. HOOPES, NOW OR FORMERLY OF MRS. JOHN NALLOR; THENCE WESTWARD ALONG THE LINE OF SAID LOT 118 FEET, MORE OR LESS, TO THE CENTER OF A 20 FOOT ALLEY; THENCE NORTHWARD ALONG THE CENTER OF SAID ALLEY 69 FEET TO A LOT NOW OR FORMERLY OF HARRY SNYDER; THENCE EASTWARD ALONG THE SAID LOT 120 FEET, MORE OR LESS TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 426 SOUTH YORK STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH NOEL SCOTT CLAYTON AND MICHELLE CLAYTON, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 18, 2004 AND RECORDED DECEMBER 1, 2004 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 266, PAGE 2508, GRANTED AND CONVEYED UNTO MICHELLE CLAYTON. TAX MAP NO.: 20-24-0785-314. Zucker, Goldberg & Ackerman, LLC FRP-104983 a ° f ~' ~~' ~c- ~ ~ ~~ t~` ..... ~`. £,... pE ~ ,~ _-, ~;~ x~ G ~ =~,. =~ ~4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4221 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK Plaintiff (s) From MICHELLE CLAYTON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $ 127,399.51 L.L.$0.50 Interest FROM 8/25/08 TO DATE OF SALE $6,793.01 Atty's Comm % Due Prothy $2.00 Atty Paid $ 157.00 Plaintiff Paid Other Costs Date: SEPTEMBER 11, 2008 (Seal) Curti .Long, onotar By: Deputy REQUESTING PARTY: Name SCOTT A DIETTERICK ESQ ZUCKER GOLDBERG & ACKERMAN LLC Address: 200 SHEFFIELD STREET, SUITE 301 MOUNTAINSIDE, N J 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 55650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, N0.:08-4221 vs. MICHELLE CLAYTON Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 426 South York Street, Mechanicsburg, PA 17055. Name and Address of Owner(s) or Reputed Owner(s): MICHELLE CLAYTON 426 South York Street Mechanicsburg, PA 17055 2. Name and Address of Defendant(s) in the Judgment: MICHELLE CLAYTON 426 South York Street Mechanicsburg, PA 17055 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WASHINGTON MUTUAL BANK Plaintiff NORTH STAR CAPITAL ACQUISITION, LLC C/O DAVID J. APOTHAKER 2417 WELSH ROAD, SUITE 21 #520 PHILADELPHIA, PA 19114 Zucker, Goldberg & Ackerman, LLC FRP-104983 iy PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 426 South York Street Mechanicsburg, PA 17055 UNKNOWN SPOUSE 426 South York Street Mechanicsburg, PA 17055 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to u~sworn falsi~fi~e~tie~ to authorities. ZUCKER LLC Dated: September 4, 2008 BY: ~ v Scott A. Die Brick, A I.D. #55650 Kimberly A. Bonner, esquire; PA.LD. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 Z00 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FRP-104983 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FRP-104983 EXHIBIT "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PACEL OF LAND AND PREMISES, SITUATE, LYING, AND BEING IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POST, CORNER OF LOT FORMERLY OF MARY FISHEL, NOW OR LATE OF HARRY SNYDER, AND THE BUILDING LINE OF SAID SOUTH YORK STREET; THENCE SOUTHWARD ALONG THE BUILDING LINE OF SAID SOUTH YORK STREET 69 FEET TO A FORMERLY OF W.E. HOOPES, NOW OR FORMERLY OF MRS. JOHN NALLOR; THENCE WESTWARD ALONG THE LINE OF SAID LOT 118 FEET, MORE OR LESS, TO THE CENTER OF A 20 FOOT ALLEY; THENCE NORTHWARD ALONG THE CENTER OF SAID ALLEY 69 FEET TO A LOT NOW OR FORMERLY OF HARRY SNYDER; THENCE EASTWARD ALONG THE SAID LOT 120 FEET, MORE OR LESS TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 426 SOUTH YORK STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH NOEL SCOTT CLAYTON AND MICHELLE CLAYTON, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 18, 2004 AND RECORDED DECEMBER 1, 2004 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 266, PAGE 2508, GRANTED AND CONVEYED UNTO MICHELLE CLAYTON. TAX MAP NO.: 20-24-0785-314 Zucker, Goldberg & Ackerman, LLC FRP-10A983 ~~ c' cn mt ~! - ~ v -rs r _ d " {' a-- as IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, N0.:08-4221 vs. MICHELLE CLAYTON; Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Michelle Clayton 426 South York Street Mechanicsburg, PA 17055 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 03/04/2009 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 426 South York Street, Mechanicsburg, PA, 17055 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 08-4221 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Michelle Clayton A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10} days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990.9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff s Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLI~j~G. 4r/AC~EF~MAN, LLC Dated: September 4, 2008 BY: V Scott A. iettenck, wire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, N7 07092 File No.: FRP-104983 (908) 233-8500; (908) 233-1390 FAX VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. EXHIBIT "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PACEL OF LAND AND PREMISES, SITUATE, LYING, AND BEING IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POST, CORNER OF LOT FORMERLY OF MARY FISHEL, NOW OR LATE OF HARRY SNYDER, AND THE BUILDING LINE OF SAID SOUTH YORK STREET; THENCE SOUTHWARD ALONG THE BUILDING LINE OF SAID SOUTH YORK STREET 69 FEET TO A FORMERLY OF W.E. HOOPES, NOW OR FORMERLY OF MRS. JOHN NALLOR; THENCE WESTWARD ALONG THE LINE OF SAID LOT 118 FEET, MORE OR LESS, TO THE CENTER OF A 20 FOOT ALLEY; THENCE NORTHWARD ALONG THE CENTER OF SAID ALLEY 69 FEET TO A LOT NOW OR FORMERLY OF HARRY SNYDER; THENCE EASTWARD ALONG THE SAID LOT 120 FEET, MORE OR LESS TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 426 SOUTH YORK STREET, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH NOEL SCOTT CLAYTON AND MICHELLE CLAYTON, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 18, 2004 AND RECORDED DECEMBER 1, 2004 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 266, PAGE 2508, GRANTED AND CONVEYED UNTO MICHELLE CLAYTON. TAX MAP NO.: 20-24-0785-314 Zucker, Goldberg 8r, Ackerman, LLC FRP-104983 Q ~' ~. ~`' p yy. ~~ .. ~{'f'! t'~, ~ r„ `~' G~ .G" :~, '~'