The URL can be used to link to this page

Home My WebLink About07-4979Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION ~+. NO . ~7 - yCl7~ ~f~' IN DIVORCE N O T I C E T O D E F E N D You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 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 PA 17013 1-800-990-9108 717-249-3166 Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION NO. ~~-y979 ~-~ ~.~... IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the .,.availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION n N0. 0 7- y 9 ~! 9 l~uir.~ "T.,e...--- IN DIVORCE CON30LIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Bethann E. Keshish, a citizen of Pennsylvania, residing at 2413 Alder Way, York, York County, Pennsylvania. 2. Defendant is Justin A. Keshish, a citizen of Pennsylvania, residing at 1500 Dalkieth Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui 'uris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on October 2, 2004, in York County, Pennsylvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. COUNT I Request for a Fault Divorce Under 3301(x)(6) of the Divorce Code 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. 11. This action is not collusive. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, pursuant to 3301(x)(6) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. X14. The marriage of the parties is irretrievably broken. 15. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT III Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 17. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 18. The marriage of the parties is irretrievably broken. 19. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. 20. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. coUNT iv Request for Equitable Distribution of Marital Property Under 3104, 3323, 3501, 3502 and 3503 of the Divorce Code 21. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 22. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of said marriage until the date of their separation. 23. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to equitably distribute the marital property of the parties, pursuant to 3104 and 3502(a) of the Divorce Code. COUNT V Request for Alimony Pendente Lite and Alimony under 3104, 3323, 3701, 3702 and 3704 of the Divorce Code 24. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 25. Plaintiff is unable to sustain herself during the course of litigation. 26. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 27. Defendant has the means and ability to pay Alimony Pendente Lite and Alimony to Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an ,Order of alimony in her favor. COUNT VI Request for Counsel Fees, Costs and Expenses IInder 3104, 3323, 3502(e) and 3702 of the Divorce Code 28. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 29. Plaintiff has employed Mary A. Etter Dissinger, of the law firm of Dissinger and Dissinger to represent her in this matrimonial cause. 30. Plaintiff is unable to pay the necessary counsel fees, costs, and expenses and Defendant is more than able to pay them. WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and expenses, prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. Respectfully submitted, DISSINGER and DISSINGER Mary A. Etter Dissing r Attorney for Plaintiff Supreme Court ID # 27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Bethann E. Keshish, verify that the statements made in the Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. ~~ Bethann E. Keshish, Plaintiff ~~ CYO ~~ ~ ; ~~ ,. ^ C_~ r .. T ('4.~ ~. ~ ~ F Q _ --'-~ - ~ ail R __~ c.? ca e i BETHANN E. KESHISH, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.: 07-4979 TO THE PROTHONOTARY: Please enter my appearance as attorney in the above-captioned action for the Defendant, JUSTIN A. KESHISH, per his request. Date: C~ , 2007 submitted, ~" J ' C. Sluzis canngi & Scaringi, P.C. Attorney ID #43829 2000 Linglestown Road, Suite 106 Harrisburg, Pennsylvania 17110 (717) 657-7770 fr nk Sarin~ril_ a JUSTIN A. KESHISH, :CIVIL ACTION -LAW Defendant : IN DIVORCE i BETHANN E. KESHISH, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.: 07-4979 JUSTIN A. KESHISH, :CIVIL ACTION -LAW Defendant : IN DIVORCE I, Mary L. Snyder, Law Clerk for the Law Firm of Scaringi & Scaringi, P.C., hereby certify that I served a true and correct copy of the foregoing Praecipe for Entry of Appeazance by placing said Praecipe in the United States Regular Mail, postage prepaid to the following person at the following address and on the date set forth below: Kenneth F. Lewis, Esquire 1101 North Front Street Harrisburg, PA 17102 Date: ~ 1 , 2007 Mary L. der -v t~ t r ~._~ ~' ~~ -rt7 .... ~ try ~~, ~~ cs ~' ~~ °' ~ _ BETHANN E. KESHISH, Plaintiff v. JUSTIN A. KESHISH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION N0.07-4979 CIVIL IN DIVORCE DEFENDANT'S ANSWER TO CONSOLIDATED COMPLAINT IN DIVORCE Defendant, Justin A. Keshish, by and through his attorneys, Scaringi & Scaringi, P.C., respectfully answers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. It is denied that the marriage is irretrievably broken. 6. Admitted. 7. Admitted. 8. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. COUNTI 9. The answers to paragraphs 1 through 8 are incorporated herein as though set forth in full. 10. Denied. It is denied that Defendant has offered such indigtities to Plaintiff as to render her condition intolerable and life burdensome. It is further denied that Plaintiff is the innocent and injured spouse. On the contrary, Defendant is the innocent and injured spouse. By way of further answer, Plaintiffhas offered such indignities to Defendant as to render his condition intolerable and life burdensome. 11. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. 12. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. WHEREFORE, Defendant prays your Honorable Court to dismiss with prejudice Count I of Plaintiff s Complaint. COUNT II 13. The answers to paragraphs 1 through 12 are incorporated herein as though set forth in full. 14. Denied. It denied that the mamage of the parties is irretrievably broken. 15. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. 16. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. WHEREFORE, Defendant prays your Honorable Court to dismiss with prejudice Count II of Plaintiff s Complaint. COUNT III 17. The answers to paragraphs 1 through 16 are incorporated herein as though set forth in full. 18. Denied. It denied that the marriage of the parties is irretrievably broken. 19. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. 20. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment; therefore, said averment is denied and strict proof thereof is demanded at time of trial, if relevant. WHEREFORE, Defendant prays your Honorable Court to dismiss with prejudice Count III of Plaintiffs Complaint. COUNT IV 21. The answers to paragraphs 1 through 20 aze incorporated herein as though set forth in full. 22. Admitted. 23. Admitted. WI-~REFORE, Defendant prays your Honorable Court to enter an Order to equitably distribute the marital property of the parties. COUNT V 24. The answers to pazagraphs 1 through 23 aze incorporated herein as though set forth in full. 25. Denied. It is denied that Plaintiff is unable to sustain herself during the course of litigation. On the contrary, Plaintiff is gainfully employed and has been so employed throughout the course of the marriage. 26. Denied. It is denied that Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. On the contrary, Plaintiff is gainfully employed and has been so employed throughout the course of the marriage. 27. Denied. It is denied that Defendant has the means and ability to pay alimony pendent lite and alimony. On the contrary, because of the actions of Plaintiff, Defendant must pay for the entire mortgage and household expenses and other bills left by Plaintiff; therefore, Defendant lacks the ability to continue to pay for all of the marital bill left behind by Plaintiff. WHEREFORE, Defendant prays your Honorable Court to dismiss with prejudice Count V of Plaintiff s Complaint. COUNT VI 28. The answers to paragraphs 1 through 27 are incorporated herein as though set forth inr full. 29. Admitted. 30. Denied. It is denied that Plaintiff is unable to pay the necessary counsel fees, costs and expenses and that Defendant is more than able to pay them. On the contrary, Plaintiff is gainfully employed and has been so employed throughout the course of the marriage and is more than able to pay for her own counsel fees, costs and expenses. By way of further answer, because of the marital debt left behind by Plaintiff to be paid by Defendant, Defendant lacks the financial means to even pay the joint marital debts. WHEREFORE, Defendant prays your Honorable Court to dismiss with prejudice Count VI of Plaintiff s Complaint. Respectfully submitted, P.C. C. Sluzis, Esquire ev for Petitioner PA ID# 43829 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: (717) 657-7770 Fax: (717)657-7797 Email: frank(u,scaringilaw.com I verify that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~-~J ,, ~G Date: ~ ~ ~ ` ~ `~ '~l~''L~ BETHANN E. KESHISH, Plaintiff v. JUSTIN A. KESHISH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION N0.07-4979 CIVIL IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ~ ~~ day of September, 2007, I, Frank C. Sluzis, Esquire, do hereby state that I served a true and correct copy of the foregoing document upon the following individual in the manner indicated: ViA FIRST CLASS U.S. MAIL. POSTAGE PRE-PAID Mary A. Etter Dissinger, Esquire 28 North 32"d Street Camp Hill, PA 17011 ~~~ ~~~ cis .w. ~`~~ ~-- cfJ ~:y .~: a ~~, -c3 - `,. IlBethann E. Keshish, Plaintiff vs. ''Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4979 IN DIVORCE MOTION FOR HEARING ON PLAINTIFF'S PETITION FOR ALIMONY PEIITDENTE LITE AND NOW comes Mary A. Etter Dissinger, Esquire, counsel for Bethann E. Keshish, and requests the Court to schedule a hearing on her Petition for Alimony Pendente Lite. Respectfully Submitted, DISSINGER & DISSINGER ~. _~~-~- a y A. tter Dissinger, Attorney at Law Supreme Court ID #27736 28 North Thirty-second Street Camp Hill, PA 17011 (717)975-2840 • - -. Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant, Frank C. Sluzis, Esq., by First Class United States mail addressed as follows: Attorney Frank C. Sluzis 2000 Linglestown Rd. Suite 106 Harrisburg, PA 17110 Date:.. _.3/~7 ~~~' Mary A. Etter Dissinger ~a ' ~~ J ~ d__, ..~- .', ~, .- ~ __ 4 -.i ~ b ~ ~~ '~"'~ ~~ BETHANN E. KESHISH, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO. 07-4979 CIVIL TERM JUSTIN A. KESHISH, IN DIVORCE Defendant/Respondent PACSES CASE NO: 931109870 ORDER OF COURT AND NOW, this 10th day of March, 2008, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on Aaril 1.2008 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (l) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11 c0 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Mary A. Etter Dissinger, Esq. Frank C. Sluzis, Esq. Date of Order: March 10, 2008 ,.~ . . Sh day, onference Officer ~E YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717} 249-3166 cc361 Q -~ ""R C.~" ~ ~`~ ' ~E''' r:r ~ ~::, G' -~ .: p ,- --~ }.~. ':~.; ~ r ` i:- r Y BETHANN E. KESHISH, Plaintiff/Petitioner VS. JUSTIN A. KESHISH, DefendantlRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 07-4979 CIVIL TERM IN DIVORCE PACSES Case No: 931109870 ORDER OF COURT AND NOW to wit, this 1st day of April 2008, it is hereby Ordered that the Petition for Alimony Pendente Lite is dismissed, without prejudice, pursuant to the parties' incomes and the Respondent having an obligation of payment on the mortgages of the newly purchased marital home. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either party files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: M. L. Ebert, Jr., J. DRO: R.J. Shadday xc: Petitioner Respondent Mary A. Dissinger, Esq. Frank C. Sluzis, Esq. Form 0E-001 Service Type: M Worker: 21005 y~ry S,-~} 51 "~i~ ~~ ~ trv _ c'~~ E i .,-~- "`; ~' , ~- s~~ G '~C1 ;~ ~.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETHANN E. KESHISH Plaintiff Vs. Docket No.O 7- 4 9 7 9 JUSTIN A. KESHISH Defendant MOTION FOR APPOINTMENT OF MASTER ,7 u G t ; n F _ K P cl, ; c h (Plaintiff) (Defendant), moves the court to appoint a master with respect to the following claims: ~~ Divorce () Annulment () Alimony () Alimony Pendente Lite and in support of the motion states: (~ Distribution of Property ()Support OCounsel Fees ()Costs and Expenses (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) Thee' ~ (has not) appeared in the action (personally) (by his attorney, ~Y A• ~~' ,Esquire). (3) The Staturory ground (s) for divorce (is) are 33c~ 1 tai tR~ , ~~3a 1 C c~ , 33~ t Ccl) (4) Delete the inapplicable paragraph(s): c. The action is contested with respect to the following claims: 'tom i Jc~eC. ~You~CIS Gt,-'tC( ~~~ i~t 10%~ ~ (~ iS3-tri b u ~2.e~ (5) The action (involves) (does not involve) com iex issues of law or fact (6) The hearing is expected to take (hours) a s (7) Additional information, if y, relevant to r,~e ~ motion: Date: October 28, 2008 Atto ey fo (Plaintiff) (Defendant) Print Attorney Name ......... F r n k S l u z i s AND NOW, , 20 , is appointed master with respect to the following claims: Esquire By the Court: t , } t~.~ =-`»~ i....} .:~} ~~ ~.~ ~.; . r `~. ,- Z f ~ t BETHANN E. KESHISH Plaintiff v. JUSTIN A. 1CeESndant IN THE COURT OF COMMON PLEAS OF ZUMBERLAND COUNTY, PENNSYLVANIA NO.: 07-4979 CIVIL ACTION -LAW ° ~ ~~ IN DIVORCE INVENTORY OF .~, ~, c-; . ;_ ~, -., ..: F ~ e.~ z~ . -=~. ;' __ ~~ Q C"'7 0 ~~ c....> cv Defendant files the following Inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. I verify that the statements made in this inventory are true and correct. I understand that false statements herein are made subject to the penalties of 18Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: ~ l ~~~G ~ `- ~~ _~ ~'t'1 1 -~- ~~ <-~ ~~~ ASSETS OF PARTIES "Defendants . ,marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages: (><j 1. Real Property ~C) 2. Motor Vehicles () 3. Stocks, bonds, securities and options () 4. Certificate of deposit (~ 5. Checking accounts, cash (~ 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts () 9. Life Insurance policies (indicate face value, cash surrender value and current beneficiaries) O 10. Annuities O 11. Gifts O 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits -severance pay, workman's compensation claim/award () 17. Profit sharing plans ~ 18. Pension plans (indicate employee contribution and date plan vests) ~Q 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22.Military/VA benefits () 23. Education benefits (Xj 24. Debts due, including loans, mortgages held 1125. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute () 26.Other MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced. Asset Value Date of Marital Lien Amount Valuation Portion of Lien Marital Home $290,000 $15000.00 Wells Fargo $231,458.00 located at 1500 Home Mortgage Dalkeith Drive, Acct No. Mechanicsburg, PA 0065222358 17050 Wells Fargo $28292.00 Home Equity Account Acct No. 65044645741998 Commerce Bank $1483.92 9/30/2007 Savings Account Acct No. 626805543 Commerce Bank $1071.78 10/18/2007 Checking Account Acct No. 39754596 Husbands 401 K $20,192.60 9/30/2007 Loan Held by ADP Husband's Legg $1158.94 9/30/2007 Mason Partners Fund Husbands RMA $5580.38 9/2007 Acct No HK66765 Husband Roth IR.A $2668.36 9/2007 Acct No HK67453 Husbands Pfizer $1520.40 8/31 /2007 Savin s Plan Capital One Bank $2451.66 9/7/2007 Mastercard Acct No 5291492237204447 Chase Mastercard $2991.20 9/7/2007 Acct No 4266841056884404 Wife's Command $30550.08 8/31/2007 Asset Program Acct No 8881947545 Wife's 2005 Honda $13,800.00 6/2008 Honda Financial $9987.09 Accord Services Acct No. 70445271 Bank of America $556.08 9/2007 Acct No. 4313081102129453 Commerce Bank $2871.80 10/2007 Checking Account (joint acct) Acct No. 0536290885 Wife's Citigroup $17888.68 9/30/2007 401 K lan Citi Dividend $11.06 9/11/2007 Platinum Select Acct No. 5424181011006744 Wife's Highmark $8715.88. 8/19/2007 Investment Plan Wife's Legg Mason $4732.59 1/29/2008 Partners Fund Acct No 0009- 9084890111 Household furnishin s ASSET NON-MARITAL PROPERTY VALUE DATE OF REASON FOR VALUATION EXCLUSION LIENS AMOUNT OF LIEN ___.__ _ _____ INCOME STATEMENT -_---- __ __ _ ___ EMPLOYER: _ ADDRESS: __ TYPE OF WORK: --- PAYPERIOD: Pfizer Inc New York, New York Pharmacuitcal Sales -- -Weekly Bi-Weekly - - onthly ------- Semi I---_----~ -------- Monthly ____~ GROSS PAY PER PERIOD- -~--- I $2,670.83 Semi-Monthly _ - ~ _ _ f -- _ ------- _____ -- ---- DESCRIPTION SEMI MONTHLY YEARLY _ _-_ _ _ _ Federal Withholding 445.07 --- - - --_ _ __ - - Social Security 210.31 _ _ Loca Wage Tax 35.38 ---------- _ _ ___ - State Income Tax 82.13 _ ____ ___ Retirement 267.08 ------ _________ Savings Bonds $0.00 ____ Union Dues $0.00 _ _ __ Charitable Donations $0.00 _ _ _ Medicare $ 0.00 ------ -- ----------- -_--- ___ _ i NET PAY PERIOD - ---------- ---- - ---- OTHER INCOME $1,630.86 --- ------ --- ------ ---- - - _ ___ -- - ~II - - -- I ~ ~_ ------ ------ +-- -- --- DESCRIPTION MONTHLY. YEARLY' ------- ------ _____ Interest - --- Dividends -------- _ __ Pension --~------ _ _ Annuity - --- __ ___ _ ___ Social Security _-- - ______ Rents ------ ___ Royalties _-- _ Expense Account ------ _ _ _ Gifts --- - -- _ _______ _ Unemployment Comp. - - ---- Workers Com. -- -- TOTAL INCOME: $1,630.86 EXPENSES ' DESCRIPTION MONTHLY` YEARLY ---- -- ---- ---. HOME ___- _-- Mortgage/Rent $1,900.00 ------ aintenance $250.00 _ - Electric $75.00 ----- - - -- -_ ---- - Gas $100.00 ------- _ Oil ---- ------- ---- Telephone $85.00 __ _ __ ___ Water/Sewer $100.00 __ ----- _- __--- Garbage Removal $50.00 _ - - --- EM'PLOYM'ENT - _ Public Transportation $0.00 ------ - __ -- - -- Lunch $0.00 - ----- ----- TAXES ----------- Real Estate $0.00 __ __ _ _- Personal Property $0.00 --------_ Income $0.00 -------- ---- INSURANCE ------------- - Homeowners $440.00 ------ Renters $0.00 ----- --- -- ____- Automobile $0.00 -- - - Life $0.00 _- --- ---- -------- --- Health $0.00 --- ---- - - AUTOMOB#LE - ------ __ _ Payments $85.00 - -- _ ------- Fuel $0.00 ---- -----_--_ Repairs $0.00 -- -- --- MEDiCAL ------------ _ Doctor/Counseling $47.00 _ _ __ __ Dentist $11.00 _ --_ Medicine $0.00 ____- _ Special Needs (i.e. glasses) $0.00 EDUCAT1ONAt _ -------- _ Private/Parochial School - ---- _ _ College $0.00 ---~---- ___- Religious $0.00 TOTAL $2,703.00 $440.00 _ PERSONAL MONTHLY YEARLY _ Clothing $100.00 _________ Food $130.00 _ ___ ____ Barber/Hairdresser $75.00 ________ Dry Cleaning $70.00 ___ ___ _ Incidentals/Cosmetics $0.0 0 -- Memberships $0.0 0 CREDIT PAYMENTS ----- _ _ Charge Accounts $0.00 __ _ _ _ _ _ _ Credit Cards $200.00 _ LOANS _ - --- ___ Credit Union $0.00 M1SCI=LLANEOUS' ____ Household Help $0.00 __ Pet Supplies & Vet Bills $0.00 ______ Child Care $0.00 _____ Papers/Books/Magazines $25.00 __- Entertainment $100.00 _______ Pay TV $140.00 ___ ___ Vacation $0.00 _______ Gifts $0.00 _ Legal Fees $0.00 ____ _____ _ Charitable Contributions $0.00 _ Other Child Support $0.00 _____ Alimony Payments $0.00 --- ~ ______ TOTAL:__ _ _- $840.00 - __ __ MONTHLY YEARLY ___ TOTAL EXPENSES: _ $3,548.00 $440.00 Items In The House Here is the basic agreement we decided on in regazds to the items in the house (11/17/07} Family Room- Justin- The couch and oversized chair with ottoman, flat screen TV Beth- The Stand up lamp Kitchen- Beth- The kitchen table and 6 chairs, the new sets of dishes, cups, and serving dishes, the mixer, electric can openerpapertowel holder and drain boazd, new set of utensils, duplicate knife set, all spices, all cooking utensils Justin- The old set of dishes and cups, toaster, coffee maker, wooden cutting boazds, knife set, old set of utensils, blue serving and cooking dishes. Spare Bedroom- Justin- Whicker Bed room set, including all furniture and mattress Master Bedroom- Beth- Entire Bedroom set and red curtains Justin- Mattress and Box Spring and TV Basement- Beth- Elliptical Machine, Christmas tree, Futon, TV, all glass ware in blue boxes Justin- Blue couch and Ottoman, Tables, wine rack, computer and desk, china set Outside Deck- Justin- Bazbecue and patio table and chairs Garage- Beth- Lawnmower Other agreements- Justin has agreed to pay Beth for her Whicker Bedroom set, all furniture and Mattress and they agreed on $1,200 that will be paid before our divorce is final and once all debts are assessed. Justin has also agreed to pay half of Beth's moving costs (est. at aprox $500 total, so $250, and that check will be provided by moving day which is set for Nov 19~' 2007. Qde both have agreed to these terms and conditions and have no issues with what was decided between us G~i~~ii'~/G Beth Ann Keshish Justin Keshish ®2007 P(¢er ire. All Rigttts~ I verify that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: C ~~~ ~G ,, NOV p 3 2008 BETHANN E. KESHISH Plaintiff Vs. JUSTIN A. KESHISH IN THE COURT OF COMMON PLEAS 4F : CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 0 7- 4 9 7 9 Defendant MOTION FOR APPO NT OF MASTER „i] u R t ; n F. _ K P C }~ ; C h (Plaintl~ {Defendant}, moves the court to appoint a master with respect to the following claims: ~~ Divorce (x) Distribution of Property () Annulment ()Support () Alimony ()Counsel Fees (} Alimony Pendente Lite ()Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) Theme; ~ (has not) appeared in the action (personally) (by his attorney, Nt~y A. Et~' Di~rr~ ,Esquire). (3) The Staturory ground (s) for divorce (is) 33b 1 (u~ l~~ , 3301 C~~ , 33o1~ca~. (4) Delete the inapplicable paragraph(s): c. The action is contested with respect to the following claims: i~iJct,c~, ~YOU~C~s a,~Ll v~~i.Uf~b1e jJiS~}-ri bu~su~ (5) The action (involves) (does not involve) com lez ssues of law or fact (6) The hearing is expected to take (hours) (7) Additional information, if y, reievant/~ to ~e ~ motion: Date: October 28, 2008 Print Attorney Name ........ . Atto~ey fo~ (Plaintiff) (Defendant) / \ Fr nk Sluzis t ) AND NOW, ~~_. 3 , 20 D~ , ~,~~ is appointed master with respect to the following claims: Esquire By e(~ourt: ' ,, ~ Gv~ [ ' J. ~l V •~ « /~~r, 7 ~' V~t• ~~ -~ ~, ,~._ ~_ ~, ~ -'' ~ ~ x -.,.. .. ~ . r" 4i E ~ ~` ~"~ .~"-, r... `~ - .. C.*~ f7. ;~ I1 BETHANN E. KESHISH : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA v. NO.: 2007-4979 JUSTIN A. KESHISH :CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mary L. Snyder, Law Clerk for Scaringi & Scaringi, P.C., do hereby certify that the Property Inventory, Income and Expense Statement and Motion to Appoint Master in the above- captioned action has been duly served upon Plaintiff's attorney, Mary A. Etter Dissinger, Esq., on November 4, 2008 via United States First Class mail and addressed as follows: Mary A. Etter Dissinger Dissinger and Dissinger 28 North 32°d Street Camp Hill, PA 17011 Date: November 4, 2008 ~. Mary L. Sn er ~ rv ~ Cd ~'_ ~~ ~.~'..' ~ o ~ ~ ^~ r -- ~ ~+ t ~ ' ~'' .z ~ ~_. _,~,% ~ ,~ Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4979 IN DIVORCE MOTION FOR LEAVE TO WITHDRAW APPEARANCE And now comes Petitioner, Mary A. Etter Dissinger, Esq., and requests this Honorable Court grant her Motion for Leave to Withdraw Appearance, and in support thereof avers as follows: 1. Petitioner is Mary A. Etter Dissinger, Esq., of the law firm of Dissinger & Dissinger, who currently represents Plaintiff, Bethann E. Keshish. 2. The Honorable Edgar B. Bayley has signed an Order in this matter, appointing the Divorce Master on 11/3/08. 3. Petitioner is unable to work with Plaintiff because she will not return calls in an effort to communicate effectively with Petitioner regarding her case. 4. Defendant's counsel has been notified, via fax, of Petitioner's intentions to file this Motion and does/does not object to the same. Wherefore, Petitioner requests that she be permitted to withdraw as counsel for Plaintiff in this matter. __~~_ ~~ Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID 27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 (717)975-3924 - fax Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esq., do hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person below listed, by First Class United States Mail, postage prepaid, addressed as follows: Frank C. Sluzis, Esquire 2000 Linglestown Rd. Suite 106 Harrisburg, PA 17110 AND Bethann Keshish 1446 Timber Brook Dr Mechanicsburg, PA 17050 Date : 2 ~ S~ii /! c=~^.-t `~ ..~-~-~-i~ f D Mar A Ett r Dissinger, Esq. ~ t .-~ } G ~, ~i` '~ r>~.., T~' ~+ r _~ : ,.: a --•C {~ f e~~ ~ $ 2C1~.3 Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. , CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE RULE TO SHOW CAUSE And now this ~~ day of December, 2008, a Rule to Show Cause why Petitioner's Motion for Leave to Withdraw Appearance should not be granted is served upon Plaintiff, Bethann E. Keshish, and upon Defendant's counsel, Frank C. Sluzis. Rule returnable 10 days from the date of the service hereof. J. 'stribution: Frank C. Sluzis, Esq. - 2000 Linglestown Rd., Suite 106, Harrisburg, PA 17110 Bethann E. Keshish, Plaintiff - 1946 Timber Brook Dr., Mechanicsburg, PA 17050 ary A. Etter Dissinger, Esq.- 28 N. 32"d St., Camp Hill, PA 17011 ~-C~ ~ ~ -'YL~ 1. P ~~~~v8 ~ '~ ~' ~~ ~ "_~ t"° . ~ " { ~t.a.# ~ ~ r°.r U BETHANN E. KESHISH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY v. : N0.07-4979 CIVIL JUSTIN A. KESHISH, : IN DIVORCE Defendant PRE-TRIAL STATEMENT OF DEFENDANT. JUSTIN A. KESHISH PURSUANT TO PA.R.C.P. 1920.33(6) I. STATEMENT OF CASE The parties were married on October 2, 2004 and were separated on August 14, 2007. Wife filed a Complaint in Divorce on August 21, 2007. No children were born of the marriage. II. MARITAL ASSETS Description DOM Value DOS Value Marital Portion Marital real estate nia Situate at 1500 Dalkeith Drive, Mechanicsburg, PA (Jt.) 290,000 290,000 High Mark Invest- 5,687.87 9,589.67 3,901.80 Ment Plan (W) Legg Mason 7,990.24 10,434.18 2,443.94 Partners Fund Roth IRA (W) Lien 231,457.28 Wells Fargo Home Mtg. Acct. No. 0065222358 29,291.55 Wells Fargo Home Equity Acct. No. 65044645741998 none none Citigroup 401k 11,088.71 16,914.90 5,826.19 none Plan (W) 2005 Honda n/a 13,845.00 3,857.91 9,987.09 Accord (W) Honda Financial Services Commerce Bank n!a 5,224.58 5,224.58 none Checking acct. 0536290885 (Jt.) • Wife withdrew 2,200.00 after DOS for which Husband seeks creditloffset. Commerce Bank n/a 1,431.90 1,431.90 none Checking acct. 0039754596 (H) Commerce Bank nia 342.96 342.96 none Savings acct. 0626805543 (H) Pfizer Savings n/a 1,520.40 1,520.40 none Plan (H) RMA acct. n/a 5,460.57 5,460.57 none HK66765 (H} Roth IRA acct. nia 2,450.38 2,450.38 none HK67453 (H) Legg Mason n/a 1,158.94 1,158.94 none Partners Fund acct. 9084818211 (H) ADP Retirement unknown 20,192.60 unknown none Savings Acct. 598000 (H) *Husband to provide DOM and marital portion amounts at later date. III. NON-MARITAL ASSETS Description DOS Value Reason for Exclusion Wachovia Securities 33,613.73 pre-marital CAP Acct. (W) ADP Retirement 20,192.60 pre-marital portion Savings Acct. 598000 (H) IV. MARITAL DEBTS Description DOS Balance Wells Fargo Home Mtg. 231,457.28 Acct. 0065222358 (Jt.) Wells Fargo Home Equity 29,291.55 Acct. 65044645741998 (Jt.) • Husband has paid both mortgage and home equity loan payments from DOS until present. From DOS to 1109 H has paid a total of 31,110.72. Husband seeks credit/offset for one-half the total (15,555.36) which represents Wife's share of the joint debt. Capital One Master Card 2,544.57 Platinum acct. 5291492237204447 (H) Chase Visa acct. 4260841056884404 (H) 2,991.20 Bank of America credit acct. 26.23 4313081102129453(W) Citi Dividend Platinum Select Card 11.06 Acct. 54241810 (W) Honda Financial Services (W) 9,987.09 V. EXPERT WITNESSES Defendant (H) does not anticipate calling any expert witnesses in his case in chief. Defendant reserves the right to retain additional expert witnesses as may be required prior to trial and to cross-examine any expert witness retained by Plaintiff (W) for trial. VI. LIST OF FACT WITNESSES Defendant (H) anticipates calling only the parties as witnesses. Defendant reserves the right to cross-examine any witness called by Plaintiff (W) at time of trial and to offer rebuttal witnesses at time of trial in response to Plaintiff's presentation. Defendant reserves the right to supplement this response prior to trial. VII. LIST OF EXHIBITS (ALL ATTACHED HERETO) 1. High Mark Investment Plan statement (W) 2. Legg Mason Partners Fund Roth IRA statement (W} 3. Citigroup 401k Plan Statement (W) 4. Blue Book Value Statement for 2005 Honda Accord (W) 5. Commerce Bank Checking Acct. 0536290885 statement (Jt.) 6. Commerce Bank Checking Acct. 003975496 statement (H) 7. Commerce Bank Savings Acct. 0626805543 statement (H) 8. Pfizer Savings Plan statement (H) 9. RMA Acct. HK66765 statement (H) 10. Roth IRA Acct. HK67453 statement (H) 11. Legg Mason Partners Fund Acct. 9084818211 statement (H) 12. ADP Retirement Savings Acct. 598000 statement (H) 13. Wachovia Securities CAP Acct. statement (W) 14. Wells Fargo Home Mtg. Acct. 0065222358 (Jt.} 15. Wells Fargo Home Equity Acct. 65044645741998 (Jt.) 16. Honda Financial Services statement (W) 17. Capital One Master Card Platinum Acct. 5291492237204447 Statement (H) 18. Chase Visa Acct. 42608410568$4404 (H) 19. Bank of America Credit Acct. 4313081102129453 statement (W) 20. Citi Dividend Platinum Select Card Acct. 54241810 (W) 21. DRS Summary of Trier of Fact PACSES Case No. 93 1 1 009870 To establish income of Wife VIII. PARTIES' INCOMES See Defendant's (H) Income and Expense Statement filed in the case. Plaintiff (W} failed to file an Income and Expense Statement; however her gross annual income as assessed by DRS is 50,650.69. IX. PARTIES' EXPENSES See Defendant's (H) Income and Expense Statement filed in the case. Plaintiff (W) failed to file an Income and Expense Statement. X. VALUATION OF RETIREMENT ASSETS The retirement assets listed are capable of valuation by reference to the statements for said accounts without the need for expert valuation. Statements of the retirement assets will be presented at time of trial. XI. COUNSEL FEES Each party should be responsible for his/her own counsel fees and expenses. XII. PERSONAL PROPERTY Items of personalty have been divided by the parties previously. XIII. PROPOSED ECONOMIC RESOLUTION The various accounts and debts presently in the name of the party shall become sole property/debt of said party. The marital real estate shall be sold and Defendant (H) shall receive a credit in the amount of 15,555.36 from proceeds of sale. Respectfully submitted, SCABdN~Y&~CARINGI, P T ~ ~ By: ~ Fr C. Sluzis, Esquire ornev for Defendant iD# 43829 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: (717) 657-7770 Fax: (717) 657-7797 Email: frank(a~scaringilaw.com RETIREMENT SAVINGS STATEMENT HighMark Investment Plan i~GHl~~RK~ to/ol/zoo~ to ti/31/200~ Page 1 of 4 0001284 11411457 BETHANN E KESHISH 1446 TIMBER BROOK DRIVE MECHANICSBURG PA 17050 ACCOUNT SUMMARY Beginning Balance on 10/01/2007 $9,589.67 Contributions 1,029.12 Transfers Into Funds 4,181.01 Transfers Out of Funds - 4,181.01 Dividends & Interest 1,708.33 Unrealized Gain/LoSs - 2,020.92 Ending Balance on 12/31/2007 $10,306.20 Net Change $716.53 Vested Balance $10,306.20 Year to Date Contributions $4,429.58 Your Personal Rate of Return - 3.1090 All the data you need to track your retirement ineestment is here. This statement is deigned to keep you up to date on the status of your account so you can effectively plan and irnest for your future. Take a minute to revrew your statement carefully and repoR any incorrect information rmmedrately. ACCOUNT GROWTH t~,aoo ~soe 2,600 oe/ae iz(ae oe/m u/a~ ~- Acconat Bal~ce Account Internal Rate of Return from Ol /01/2007 to 12/31 /2007: 2389'0 06/3o/zoo6 12131[2006 06/30/zoo? 12/31/2007 $3,465.83 $5, 87.87 $8,434.69 $lo, 06.20 The growth of your account con be influenced by a number of factors, including the specrfic irnresiment options selected, the daersrficahon of your investment among asset classes and the contributions to your account. Post perfoimonce does not gugrantee future resuhs if ou would like to make changes to any of these areas, contact a representotNe orgo online to wwwwachovia.com~myretiieplan. CONTRIBUTION SUMMARY toatrfinfion Rate Tb~ Period Year-to-oats By saving throw your plan you can odd to the finarx~al nest egg you wrll need rn the future All Contribution 5ourees EE PreTax 6.009'0 $663.96 $2,857.84 Total Contributions 1 v yrt ti ~ BEiH/WN,€I~SHISH 0134 AMP 11+11145% CON 000045785 200801142108 C .101058 20080115 NNNNI~JN DFLI'' ACTV `~r $1,029.12 $4,429,58 Legg Mason Partners Funds SBSSBS3PA12 PFPC TRUST COMPANY CUST FBO BETHANN E LAU BOTH IRA 1139 HEARTHRIDGE LN YORK PA 17404-7811 Questions about your account? Please call your Servicing Branch or Shareholder Services at (800) 451-2010. Client Statement January Ol, 2007 through Jane 30, 2007 Page 1 of 3 i METLIFE SECURITIES INC ' 485 US HIGHWAY 1 SOUTH BLDG E 4TH FLOOR ISELIN NJ 08830 Account Number: 9084890111 Rep Name: House Rep Rep #: 9975011 PORTFOLIO SIJNIl~IARY Account Value on Jan Ol, 2007 $9,916.23 Purchases/Reinvestments $0.00 Redemptions $0.00 Account Value on Jun 30, 2007 $10.434.18 SUMMARY OF ACCOUNT BY FUND . '~.i F., ~~ .9 ~ ~.~.. ~. ~.. "r} ,~ n~J 'i ' /" SBS-SBS3PA12 SH 84 3 1 111619 37207 0484 997 9084890111 0 ~~ ~_ ~~~mith Barney 1~ viutual Funds ;k~~ .• i ~ Client Statement January 1 -December 31, 2004 YoraFb~»Gal Consst~t Bethann Lau 004703 Citistreet Equities L L C 998 Old Eagle School Rd 03810 Suite 1205 SE CARP TRUST CUST Wayne, PA 19087 05700 FED BETHANN E LAU RO i'H IRA 11 39 HEARTHRIDGE LN Please call Smith Barney Shareholder Services at 1.800.356.5966 YO~ZK PA 17404-7811 Your Pers~o~rallnformaston Account Number: 908-48901-1-1 Tan ID or SSN: On File ACCOUNT SUMMARY Ps °vvious Market Value: Saoo Grota~b F;ptds Aggres:dve Growth Fund Class A SHRAX 42263 ;95.17 $4,02216 50.3496 :~ Fundau~ental Value Fund Cass A SHFVX 263.485 515.06 53,968.08 49.b696 ~ Growth :?ands Subtotal 305.748 87,990.24 8~ Cn:7ent Market Value: ;7,990.24 100.0096 s~ ss~ ~~ YEAR TO-DATE FINANCIAL SIfMMARY ABgreseivt. Growth Fund Class A Fundamental Value Fund Class A Total Dist~3bntiams to Date 80.00 $0.00 80.00 80.00 50.00 50.00 50.00 80.00 ;0.00 50.00 80.00 80.00 ;0.00 50.00 80.00 RETIREMENT ACCOUNT SUMMARY Date of Birth: 12-29-75 Beneficiary: ON FILE Roth Conversion: $0.00 Rollover Amount: 80.00 Prior 'Fear Ca~ntribution: 80.00 Employee Contribution: 80.00 Current 'Tan Camitribation: 8800.00 Employer Contribution: 50.00 Set Up Fee: 510.00 Anneal l~iaintenance Fee: 515.00 FOR YOUR INFORMATION The FatrMarket Yglue ofyoierlRA as ofDecember 31, 200$ !s bebeg furnlsrbed Ao #re htAer>•tal8enenus Servio~ fialtra snsac~ons~~on tbetbe~qu ~ ~ ~~~~ - ':; ;`' : ~,b~ar~e any gw~fo»s fe~el,~i+ee m canton Smtzb Barney MurirarFunds sb~arebolder Si ar(800) 451-201 .~ ,;1:~:~3 f ' t' .'; .~ SMITH B.A~CNE~ Page 1 of 2 sm~ ,u ~ ~:~» ~~>~ c~a~r n~~ ~ ~ CitICJrOII~ ... ~ J 05700 9084890111 ' 88,435 3 ~ 109,303 YNNNN .~ Citigroup 401 (k) Plan PO, ox 5166 oston, MA 02206 Citigroup 401 (k) Plan ~•~.I, Statement Period July 1, 2007 -August 31, 2007 DOM124 BETHANN E RESHISH 1139 HEARTH RIDGE LANE YORK, PA 17404 YourTotalAccount Value Opening Value On July1, 2007 + Employee Contributions + Employer Contributions + Other Credits/Payments(a) + Dividends + Investment Galn (Loss) - Distrtbutlons/Debtts(b) S17,607.00 $0.00 $0.00 $0.00 $44.85 $-736.95 $0:00 Questions? ~Aufomated /nformaSon Line Participant Services Representatives are available Monday through Friday, 8 a.m. to 8 p.m. ET at 100-881-3938, 401 (k) option ftom the main menu. /ntemetAccess at: - https:i/mybenefits.csplans.com Participant Profile Status Terminated Account Balance History Y rA Allo ati & B l nd ~ F ou sset on.: c ance a y u Values as of August 31,.2007 Investment TypelFund Name Measure. Units/Shares X Price m Market Value Your curent asset alloralion based on your total . ,. ' ' ~ _ -dosingbatarices witrneachassettypa: '-.. ` - - ~. .. ... `_ !0% Short Term Investments 8%! Bond Funds LMP Global High Yell Bond Units: 24.6527 . $56.923370 $1;403:31 0%, Balanced Funds 68%~ .Stock-Funds LMP Aggressive Growth Fund Units 51.0295 $64.520518 ~ $3,292.45 LMP Laige Cap Growth Fund Units 20.0294 $63214218 $1,266.14 Templeton Fund Units 31.5582 $221.438312 $6,913820 24%~ Employer Stock" Citigroup Common Stock Units 2927709 $13.542331 ar' ,.. f Total Fund Balances Share Equivalent of Empbyer Stodc(d) Citigroup Common Stock Shares cifistreeC Aptll'~~ 84.5734 $46.880000 _ $3.964.80 $3,964.80 $16,914.90 Page 1 of 3 Opening value va. closing value Cfigroup 401(k) Plan Po Box 5166 Citigroup 401 (k) Plan citigroup'~' Boston, MA 02206 DOM1119 BSTHANN S KSSHISH 1139 HEARTH RIDGE LANE YORK, PA 17404 Statement Period October 1, zoo4 . December 3'l, 2004 Questions? Automated InformaiJon Une ~~.•ii~~ Partiapant Services Represerttatives are available Mortdaythrough Friday, S a.m. to S p.m. ET at 100-881938, 401(k) optlon Trarrtthe main menu. ~lntemetAccess at: - httpsJ/mybenetits.csplans.com Your TotalAccount Value Opening Value On October 1, 2004 + Employee Contribtriions + EmployerContribtfions + Other CreditslPayments(a) + Dividends + Investment Ga1n (Loss) - Distributions/Debits(b) $11,088.71 $156.70 $0.00 $0.00 $29.99 $1,190.48 $0.00 Participant Profile Soaal Security Number 143.62"" Status Terminated MartagingCompanyCode COP -Account Balance History sto,ooo ss,ooo Closing Value Onbecember 31,2004 $12,465.88-'- ao Yourtotai change in value during his period1,377.1 ~ YourPersonallnvestmentPertonnance(e)= =~ o _.: ~ ;' ~ ' 10-..91".l0 VaHres as of December3l, 2004 Your anent asses allaca0on based on your total dosing balances within each asset type: YourAssetAllocation & Balance by Fund - Investment Type/Fund Name Measure Units/Shares x 0%`;`:` Short Term Investments 10%: Bond Funds High Yield Bond Fund 0% Balanced Funds 61°/a~ Stock Funds Large Cap Growth Fund Aggressive Growth Fund Templeton Fund 29°/a~ EmployerStock* CiGgroup Common Stock Fund Price = Market Value Units 24.6527 $49.854068 $1,228.03 Units 20.0294 $65.077679 $1,103.18 Units 51.0295 $52.662024 $2,687.32 Units 31.5582 $120.000075 $3,786.98 Units 262.9297 $13.917704 $3.659.37 Total Fund Balances 'Share Equivalent of Empbyer Stock(d) Citigroup Common Stock Fund e t~street A state Street ana Grgroup Company $12,465.88 Shares 75.9522 $48.180000 Page 1 of 2 $3,659.37 zoao Txr 2oa¢ 2aaci ~oAtliao~t tti3lnooa Compedson or yourprevious year-end total Opening valor vs. values at gtSheet since 07/01/u101. closing value. Kelley Blue Book -Suggested Retail Pricing Report -Honda, Accord -Official Kelley Bl... Page 1 of 3 ~~ rEO ~ou~r~ Home > U~ed_C_ar, > ~OQS. > HgO~ > A~~or~ > DX Sedan 4D 2005 Honda Accord DX Sedan 4D Trade-In Value ------- --.- .~--._______._______..._._._~ Private Party value ___ g~E ~(~~~~ SU~~STE~ ~ifTJ~I YA~.1~E ~wMers r~xs, m Suggested Retail Value_ i Photo Gallery Compare vehicles Mew! Review Consumer Ratings Find Your Next Car More Photos Specifications , Shopping Tools Free CARFAX Record Chetk Auto Loan from 6.09°1a APR Compare Insurance Rates Payment Calculator Extended Warranty Quote on Blue Book Classifieds"" Honda i _._ __ __ _... Accord ~_ _. . 30 Miles or less ,z_ ___ _ _ ZIP Code17110 To View Ads, Click SELI Ytilll; USED GAR on Blue Book ClassifiedsTM' NtXI STEPS: Condition <waer~-nt~s, Value Excellent $13,845 Suggested Retail Value Assumes Excellent Condition... More Free CARFAX record check Sell Your Sedan Average Consumer Rating (721 Reviews) 4.7 out of 5 Read Reviews Review This Vehicle Similar New Vehicles K l~t+rv//zznznv U~1, ~nm/TtT2R/TTnca!'~+-../D,.........~.D,....,...i ..,._._.~1~~...._T.~-~nnc o_z~_~_._i_r~__ ~rr_. r r+ i r..n.... Home New Cars Used Cars Research & Explore News & Reviews Classifieds Auto L Used Car Values I Classifieds I Certified Pre-Owned I Compare Vehicles 1 Perfect Car Finder I Most Researched Used V Welcome Back I MyKBB ZIP Code 171101 Change Recently Viewed ~O/7~/1f@/ZCe ~~n~ 0104021NY2N000OJ90/ JUSTIN A KESHISH BETHANN E KESHISH 1500 DALKEITH DR MECHANICSBURG PA Transactions By Date Commerce Bank/Harrisburg N.A. P.O BOX 4999 Harrisburg, Pennsylvania 17111-0999 1-888-937-0004 `-' 17060 We're here 7 days a week, 24 hours a day at 1-888-937-0004. TOTALLY FREE COMMERCE BANK OFFERS STUDENT LOAN ASSISTANCE THROUGH CAMPUS DOOR. VISIT US AT COMMERCEPC.COM AND CLICK ON PERSONAL BANKINGICONSUMER LOANSIEDUCATION. 0536290885 011 Cycle Page 1 of 1 Coonmerce Bank f}-cc-~- ~ D~ 3 4 ~ ~`~S ~ ~ Transactions E3y Date Date Description Debit Credit Balance 08MOM7 AC-CAPRAL ONE ARC -CHECK PYMT 5200.00 5996.27 CK-000000000000754 08/10/07 POS DEBIT 08!10 58.99 5987.28 Staples, Ine. CAMP HILL PA 08H3107 POS DEBIT 08111 SOU GLAI4T 517.40 ;969.88 FOOD #2692621 CAMP HILL PA 08/13107 CKCD DEBIT 08110 APPLEBEE S 532.49 5937.39 MEC0720MECHANICSBURGPA 08/13/07 CKCD DEBIT 08N1 VZYYRLSS-IVR 5150.42 5786.97 VE B00-0220204 CA OSH6/07 AC-PFIZER INC -~R DEP 5828.91 51,615.88 08!15107 POS bEBI'I' 0$115 SOU GIANT S10.98 57,604.90 .FOOD STOR0617 MECHANICSBURG PA 08M7/O7 POS DEBIT OBH7 HAMPDEN CL 523.00 51,581.90 EANERS MECHAN MECHANICSBURG PA 08/20/07 A SE -Ct1ECK PYIIAT 5150.00 51,431.90 CK-000000000000758 Number Date Amount Number Date Amount Number Date Amount 733 07!26 560.00 750 07130 541.00 754 08H0 5200.E E 747' 07!27 5128.53 751 07126 5133.39 758• 08120 5150.00 E 748 07/26 5300.00 E 752 08103 530A0 7465713' 07/23 5250.00 749 07/26 534.64 753 08109 557.30 E Items denoted with an "E" are electronic entries and will not have a check image. ~~ 39754596 ~~ Page 2 of 3 Commerce .Bank 015{04NNY1N00010015 JUSTIN A KESHISH 1500 DALKEITH DR MECHANfCSBURG PA 17050 Commerce BanklHarrisburg N.A. P.O BOX 4999 Harrisburg, Pennsylvania 17111-0999 1-888-037-0004 We're here 7 days a week, 24 hours a day of 1-888-997-0004. PERSONAL STATEMENT SAV{NGS Transactions By Date s~~ 0626805543 Date Description Debit Crodit Balurce .~.w. ,b~ -.. :~~.. 07(18607 NIT410RL SAV 9454 07(12 14:27 ;HOAO >i342.94 742 WERTZVILLE RD ENOLA PA 07131/07 AC-PFIZER INC -DIR DEP ;126.00 ;427.96 08/01!07 SDB TRANSFER ;36.00 ;393.03 TO SD-0010000000000098 08/16/07 AC-PFIZER INC -DIR DEP ;126.00 ;438.03 '*' 08/29107 WTFIDRL SAV 8437 08!29 15:11 ;60.00 ~ ;2,6`f8.03 742 WER7ZVILLE RD ENOLA PA 08/31/07 INTEREST PAYMENT Interest Summary ;0.20 000 REG E Snapshot Page 1 of 2 • / Pfizer Savings Plan JUSTIN A KESHISH 1500 DALKEITH DR MECHANICSBURG, PA 17050- Your Account Summary Baginnlny Balance Employee ConMbutions Employer Contributions Change in Account Value Ending Balance Additional IMormation Vested Balance Account Statement g Customer Service: (866) 476-8723 Fidelity Investments Institutional Services Co. 82 f7evonshire Street Boston, MA 02109 Statement Period: 08/01/2007 to 08/31/2007 $727.91 $520.84 $234.40 #37.25 $1,520.40 $1,520.40 Your Personal Rate of Return This Period 2.5X Your Personal Rate of Return is calculated with atime-weighted formula, widely used by financial analysts to calculate investment earnings. Tt reflects the results of your investment selections as well as any activity in the plan account(s) shown. There are other Personal Rate of Return formulas used that may yield different results. Remember that past performance is no guarantee of future results. Your Asset Allocation Statement Period: 08/01/2007 to 08/31/2007 Why is This Important? e-Learning: Learn about asset allocatign i hops://workplaceservices400.fidelity.corn/netbenefits/savings2isod/soddetail?sodPrevievcT... 11 /3/2007 ~ . d O V A g ~ a i 0 3 a ~ ~ 3 a A 0 N A ~ O ~ m C C ~ ~ a'S W ~ } D N _.~h x~~ ~i~ ~ w ~~~~o~, ~.~h N P ~s N N ~ O ~~~~~ M N O i~ ~= M N N N 3~°~ 4 M N ~ ~ ~~ Y Y 2 ~ fAwtr ~ ~ r0 Q r d' ~' ti v ~ ~ m m Y Y G gw 4 n ~ N O S ~ r W N N ~; ~ 0 ., ~- o •~ M O O G O ~ ~ .~. ~ ~ i ~a o 0 w~ ~~ Y 3 ~~ ~= w ~ ~~ s ~~ M b A A 1 r M _~ M e i 1 M N ~ ~ ~ ~ O ~ ' i O' ~ ~~ E ~ ~ ~ e E , ~ ~ m ~ S ~ geg p 3 w .. fD 10 Y Y r r u°i -N C ~ ~~ A _ O Rn S M ~ 7. N O h ~, ~. L' C:; i=` F, i i Legg Mason Partners Funds Client Statement SH-000630SBSSB54PA02 PFPC TRUST COMPANY CUST FBO JUSTIN A KESHISH ROLLOVER IRA 1.139 HEARTHRIDGE LN YORK PA 17404-7811 Qneations about your account? Please call your Servicing Branch or Shareholder Services at (800) 451-2010. PORTFOLIO VALUE Portfolio Value on Jan Ol. 2007 $1,117.30 Purchases/Reinvestments $0.00 Redemations $0.00 Portfolio Value on Sen 30, 2007 $1,158.94 January 01, 2007 through September 30, 2007 Page 1 of 3 METLIFE SECURTI'IES INC 485 US HIGHWAY 1 SOUTH BLDG E 4TH FLOOR ISELIN NJ 08830 Account Number: 9084818211 Rep Name: House Rep Rep #: 99J5011 PORTFOLIO ALLOCATION *~~• ~~~' t~ ~ ~ , 4~~h }9~ ~4~ ~h~ . . Legend Growth SUMMARY OF ALL ACCOUNTS BY FUND/ACCOUNT NUMBER Account Number. 9084818211 PFPC TRUST C011~ANY CUST FBOJiJSTINAKESHISI~ __.._._..._ .._.__. _......__...... _ .. _....... _ ROLLOVER IRA 100 % 3:. ;' ~~ ~ S '4yR 1J Vc }, { ~ ^ Gb i. .~ ~ ,.uv 1. Sv`t' q'f'. _ ~~ TS~~ ~ ~.}Yep. ': V 4 ~} ~ 5 ~ ~ ' a p K i4 ~ ~ '.v 'i ~ NRA~O~ a eF ~8I•.~~~ .. a....d .... .... ... ....iS.. z! 2 .ss_. £ ._.u_.1 _F_ .: .v+r~.._.. .._. .... .d u{y ~h.h 'iw r~i4ar..2 .n, _ 3S.{dY:u_ ...,u.... '~5 '.uT btsi+a. , f4._ _:..: .....~'i.'v.~ r.. Growth AGGRESSIVE GROWTIi FUND CL B $552.34 $0.00 $0.00 $571.03 FUNDAMENTAL VALUE FUND CL B $564.96 $0.00 $0.00 $587.91 Growth Subtotal $1,11730 $0.00 $0.00 $1,158.94 Total Account Number 9084818211 1117.30 .00 0.00 $1,158.94 L~ i~ Legg Mason Investor Services, LLC, Member NASD, SIPC SBS-SBS4PA02 SH 42 4 1 12514 4129 (1dRd ooi rwuis~~m n 598000 - A - 0000003840 - - 8362 AUTOMATIC DATA PROCESSING, INC. ADP 401(K) SERVICE CENTER P.O. •BOX 22229 LOUISVILLE, KY 40252-0229 003540 AASTA221 JUSTIN KESHISH 1500 DALKEITH DR MECHANICSBURG, PA 17050 J ~ For the period July 1, 2007 -September 30, 2007 Every effort has been made to report information accurately. ' Should you notice any error, please advise the ADP 401(k) Service Center within 10 days so that records can be corrected. To access your account via the automated phone line, call 1-877-401V(ADP (1-877-401-5237). "1'm~' Visit the Web at www.401kadp.com ==For transactional details, please visit the web site. Plan Number: 598000 AUTOMATIC DATA PROCESSING, INC. RETIREMENT AND SAVINGS PLAN Date of Hire: 06/07/2004 As of September 30, 2007 This Year to Period pate The cash balance (inciuding interest) Beginning Balance 20,125.80 13,379.47 of your noncontributory pension on Contributions 0.00 5,181.07 12/31/2006: $1,778.35 DMdends and Earnings 0.00 0.00 Market Value Change 66.80 1,632.06 Total Ending Balance 20,192.60 20,192.60 Vented Balance 20,192.60 The 'Current Asset Allocation' illustration is how your account balance was invested as of the end of the statement period. For Future Contribution Allocations, see page 2. Account Allaation As of September 30, 2007 Investment Type Aggressive $0.00 0.00% Income & Income $8,682.44 43.00% Growth do Ineotne $2,334.27 11.56% Growth $9,175.89 45.44% Aggrosslve Growth $0.00 0.00% Other S20,192.60 Totai JUSTIN KESHISH ',~ ~ Page 1 of 6 o g cn g m V c J D z Z m n N z 3 m W O~ w v W 'D c w a c` W O 0 0 m f7 c m 3 m m~ A ro A $ N o w ~ rn io ~ ' 0 c m 3 O d 0 m f s N f 0 ca m a ~ F ~' a o rt c ~ 3 'a ma ~ ~ v ..~ N m 3 d O ~ o r I ~ ~ Ot 3 N a a - < N m ~' o n `.< O r Q N i i O; ± , d ..` ~~ 1 i r ~. . os O w ,~~.a , W C Q b z r BETHANN E LAU 2413 ALDER WAY YORK PA 17406-1970 m D r ~ zo a m ~ v~o ir -n mm~ 3 m~m n r z <~D~ ~ o D m ~~ c Z~?m ~m~ ~ DrDCm tD ~ 7 c~D; m O ~~C ZN~ a ~ -i m ' ~~Z ~ mpyD O ~w rt ~~ _. y Zzc ip ~o~ ~ -nom ~ -+z?O 3 o yN rn~ m ~r ~~OZ Z~pC ~ GG OZrq C ~ui n ~Z~~ "i<y C m ? rv ~ c)° ~ 7 a oo~~ ~~m m om~~ ~ ~ z N °',~- ~ m ar '~ ~?~ ~ m m c z ~mo~ o~ ~ i ~, n oo{ ~ ~ a D G) ~ Z m ~ h ~ tD -~ ~. D ~ zlh~m 0= p Z~~~ ~ ~ fA b ~ ~ cm ~C ~mm 3 C7 C~Cc oai z~ ~v m~'~~> Dxp° ~ ni o -ama~Z DD ~ Z ZpG ~_~. C ~n O cn<ox om G7C~ c~ w co ~ D+mmo cDno to ~ rnm m ~ o=p cTm ~ o. ~. ~ ~ iN ~D ~ ~° W m ~m m -~ .o ~ m o D nT~°m G]~ ~ D+tnC y ~ rn °~m~ m mc~ ~ ~ ~ D~n r ~ ~ O ~ ~. Q. o ~= c ~vm~ ~ m `-° m ~~Cg~O ~ N~zz~ o W~~o•n ~ ~~~zm -• rncZ..~m~ m°oO~n ~Dpnm n °:,oD IP fn c ~ TZ{ ~ °o r rn ., W p0 `.. ~ ~ Z m O ~ ~ N x ~ A 'a r~. ~ ~ A ~. "' d ~ fD „~ ~ ~ m l a (D 3 m `D I3 m 3 i~ ,Nv W yI A W 0 0 w 69 W 0 v V1 A ~', n g~ G N m n g r q~ X w` a a z N' NI IV D n n c a om~ °~ ~ Z ~cc Z ~ D~ ~_~ ~ i C "t m i w . ~ rt ~ ~ m ? -~ ~D W ~ ~ N ~- rt N O1 V O 69 o> N m 7 ~m M n E S„~ Y ~ A O a Z 'i ~' v m ~~ ~Qa N d ~ b f0 m `~ y ~3 W t~ '/F`1 i ~o~ ra ' ~ 0 3 B '~? ~, 0 ~~ 7 ~ =• g ~ ~. ~ ~~ .Q v d K ~ a ~ o w ~ m N m v .i i ~ V Efl fA ffl O O V ~1 b9 N O N O W 0 0 0 W O W ~~CSo > mN^,o o 0 E ~ ~ ~ n o c Tv~ ~'a~~ o~~~~~ ~.qa• n m -~ ~ 3 ~~~a, $ m C= « og am;m m r ~' S g ~ N O ~ W f~fiq ~N Oo ~ w ~ m A N o- ~ V tD ~ ~ t D N O gym"' m ~ ~ W ~ O m ~~ m DDDZN.r Z r v~i~mm~- ~-~~(q0 - csm=w= ~Otncn .0~==~ '~ Df<<1S ~ ~~ ...~ V ~_ ~ w ~~ N m A m D ~ ~~~. ~o~ m ~ d ~ ~ ~. ~ 0 a ~~ N 8.=~~~c ~ ~~ 9' O ~~ ~~ ~ ~o ~?~~, ~~ ~~~ ~ ~ ~ d n ~~.' Q.~ O ~g~--gym ~~~ ~ o ~~~~~ 3 ~ ~ ~p c m ~,L7g o~~c,°'~ ~ B ~`~ ~ ~ ~ ~ ~o~ d a.aa ~ ~~ 3 ~ ~. .` ~ ~_ ~ c$ ~ ~ _ ~ a~O~ ~ F~ ~ ~ ~ ~ G, m ~ m p 0 7 ~ y 0Q e`~S.'~m3 ~wa`e~'~`° .y w~ pp 4.m 31~~.-n~rn o~m~~~ $ ~ ~~~~~ ~ 3 `~ 3v~ vi'~in ~ ~ ~ S"D o a o°ot°y c m Ok9l ~a °' °D• g~ n ~ ~ ~ ~ ~ ~ 01 ~ ~ X ~ L V '7'i N: ~x ~ O ~ O B C O R r.y' } ~~ Q ~ ~ 0 ~ ~ f~ ' ~ ~ ? ~ , ~ ~ O ~ O ~ ~~ ~ o !D g ~' o g~ a a a ~D 0 a ~ e C ~ r ~ 7 .a ~ ~ m ~ W ~ fD i ° D v Q. ~ ~ ~, rn s ~'* a m ~.. Account Statement Statement Date: Au{;ust 31, 2UU7 Page 1 of 4 6S0 4464574 1998 173,181 (C065U) JUSTIN A KESHISH BETH ANN E KESHISH 1500 DALKEITH DR MECHANICSBURG PA 17050-8324 Customer Service Telephone 888-567.6059 Online Banking www.wellsfargo.com Correspondence Wells Fargo Bank, N.A. PO Box 4233 Portland, Or 97208-4233 Co not send payment to this address Smartfit Home Equity Account Justin A Keshish Beth Ann E Keshish Accoucd Number: 650 4464574 1998 Payments By mail Wells Fargo Bank, N.A. P O Box 54780, Los Angeles, Ca 90054-0780 Overnight mail Wells Fargo Bank, N.A. Attn:Payment Services 2324 Overland Dr. Billings, MT 59102-5401 Activity summary Approved line of credit $29,IUU.00 Credit in use: Line 650 4464574 1998 $U.UU FIXD*+* 65O 4464574 1001 $29,]00.00 Total credit in use $29,1 UU.00 Available credit $O.UO Begiruung balance owed** $29,291.54 Ending balance owed** $29,291.55 "These balancer include unpaid finance charges and other unpaid fees and charges. The Ending balance owed is not a payoff amount. Please contact Customer Service jor an accurate payoff. a o: w J LL 2 `HOrvr~~i. Financial Services Payment Information Payment Due Date September 03, 2007 Current Payment Due Total Amount Due Auto Debit Amount Payment Remaining Payoff Summary Payoff Amount Payoff Good Through Accormt Information $ 309.73 S 309.73 $ 309.73 $ 0.00 $ 9,987.09 September 03, 2007 Account Number trehicle Dest,7fption'-~ VIN Number Regular Payment Amount Maturity Date Payments Remaining __ 704.45271 2005 HONDA ACCORD 1 HGCM56835A024467 $ 309.73 June 03, 2010 34 A payment of $309.73 will be debited from account XXXXXXX)UCXXXX-8545 on September 03, 2007. Acti!!rity Since Last Statement Date Description Amount Total 08/03/2007 Payment Received -Thank You! S 309.73 Principal $ 275.84 Interest $ 33.89 >03969 4980343 004 008161 STMT 8 JUSTIN A KESHISH BETHANN E KESHISH 1500 DALKE TH DR MECHANI~~BIdRG, PA 17050-8324 ~: . *: . ' :, 7'r. 4r Let your computer rev your engine. Owner Link® is an online vehicle management system and a convenient way to keep your car in top shape. You can shop for genuine Honda and Acura accessories, view maintenance schedules, receive tips for keeping everything running at its best, and even get valuable dealer offers and discounts. So, set up your free Owner Link account today and enjoy the convenience of having your car's care just a computer click away. Statement Date: August 12, 2007 MONTHLY STATEMENT w s FINANCE Previous Balance Payments b Credits CHARGE Transactions New Balance Minimwtl Payment Due Dab • $2,815.42 ,-' $300.00 '+~ $29.15 `+ • $0.00 ~ $2,544.57 Aug. 07, 20071 ; ~ $50.00 ~ ~ ~ ~ ~ \ i ~ _l ~. ~ti~ Jun. 14, 2007 -Jul. 13, 2007 Page 1 of 1 ~ PLEASE FYO' AT (FAST TIeS AMOUNT ~~ Rewards Summary MasbrCand Platlnum Account Previous available balance: 175 i 491-4922.3720.4447 ~~~1bHffi;sle' I Eamed this period: 0 a e ~ Your Account Informatlon REWARDS I (reflects transacbore posmd daring tis Eiging cycle) N Available Balant~: 175 ~ I TOTAL CREDIT LINE $7,000.00 TOTAL AVAILABLE CREDIT 54,455.43 p~~, Credits ~ Adjustments a ~ CREDIT LINE FOR CASH $3,500.00 1 06JUL PAYNIENfE ~-~' a % ~ AVAILABLE CREDIT FOR CASH 53,500.00 0 a Finance Charges (Please see reverse for important intormaUon) Balance rate Perlodlc Corresaortding FlNANCE applied b rate AAPPRR CHARGE " ' N • .. ___. ___ Purchases 52 749.19 0.4353496 12.90% 529.15 _ __ mortgages, retlnance an first Capital One Herne Loans offers a~variety bf iro hassle fame loeil'producls, includirig cash ' X0.00 0.0353496 12.9096 So.oo debt oonsoNdallon loans, as well as home equity loans and lines of rxedit Our ~m of e>glerleneed protlsssbnals ANNUAL PERCENTAGE RATE applied this period: 1290% u~ that your situation is unique so your ban salupon sflould be bo. Yau~ have the one~onn-ale attenion of the same personal ban consultant from call b dose. Visit www.cepitabnehomeloans.com br more irdorma6on. Capital One fs an Equal Housing Lender. ® AtYourSsMo 1-tI0lF9SS7070 To coq Customer Relagons err m report a lost or stolen card: ® Send payments to: Capihd One Bank • P.O. Box 70884 • ChOrbtES, NC 28272.0884 A Sand inquiries to: Capital One • P.O. Box 30285 • Salt Lake Gty, LIT 84130-0285 ® Far more infartltaUan on your Rewards: INit wrrw,rapllalaieramlpointsler~ds Ca11:1-800-228-3001 6058 506 1 07 13 070773 PACE 1 of 2 O1p16056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO WWW.CAPITALONE.COM TO MAKE YOUR PAYMENT ON LINE Cap//1a/~!e' I whaYs in your wallet?' 0 5291492237204447 13 2544570300000050007 nrw oarmi~r nmuinuiir ra~ulcu~ tic "va.c $2,544.57 ~ $50.00 ': ~ Aug. O7, 2007 PU:ASE PAY AT LEAST THIS AMOUNT Amount Enclosed Capital Ona Bank _ P.O. Box 70884 jrjrr~rrlrl~~rjflrl~~' CharlottQ, NC 28272-0884 t11111111t111111/III I111111111111111111111111111111r~~~l~rr Account Number: 5291-4922-3720-4447 Please print address or phone number changes below using blue or black ink. Address Nome Phone ARemate Phone >~mai! address #9019577607811194# MAIL ID NUMBER JUSTIN KESHISH 1500 DALKEITH DR MECHANICSBURG, PA 17050-8324 n~j~jm~~jiuijrjr~jur~ujm~~nr~ijijn~jjmjju~~jm Please write your account number on your check or money order made payable m Capital One Bank and mail with this coupon in the enclosed ernelope. New York Yankees Prepareefor. BETHANN E KESHISH 43130811 0212 9453 August 2007 Statement Crea6t Line: $13,200.00 Cash orCredKAvaJab/e: $13,173.77 Summary of Transactions Bid'mg Cyde and Paym ent Infom~ion Provious Balance $1,101.01 Days in Billing Cyde 29 Payments and Credits - $1,32822 Closing Data 08/09/07 Cash Advances + Purchases and Adjustments + $0.00 $'22721 Payment Due Date 08/29/07 Periodic Rate Finance Charges + $2623 Current Payment Due $2623 Transaction Fee Finance Charges + $0.00 Past Due Amount + $0.00 ~t623 Total Minimum New Balance Total Payment Due BankofAn~erica MaVPeymenlsfa' BANK OF AMERICA P.O. BOX 15721 WILMINGTON, DE 19886-5721 Mm76~-9ingLbias to.• BANK OF AMERICA P.O. BOX 15028 WILMINGTON, DE 19850-5028 Cab toA-free 1-800-826-2558 TDD hearing-impaired 1-800-346-3178 Posting Transaction Referonce Account P meats and Credits Date Date Number Number Cat o Amount PAYM - N ESS 08108 1,32822 C Purchases and 'ustmertts O F. E # .LANCASTER PA 07/18 07/14 0232 9453 C 88.97 CHARLOTTE RUSSE 253 CAMP HILL PA 07/19 07/17 8308 9453 C 49.81 000012 J.D. PREMO Al9.SOCIA7ES HARR188UR4 PA 07/20 07/19 0098 9463 C 71.54 BLOCKBUSTER ONLINE 888-892-2789 TX 07/25 07/24 8487 9453 C 15.89 WW9EN4HCAOUR • "PLEASE NOTE: YOUR DUE DATE HAS CHANdED. PLEASE ENSURE YOUR PAYMENT IS RECEIVED BY THE PAYMENT DUE DATE TO AVOID LATE FEES OR OTHER IMPACTS TO YOUR ACCOUNT. IF PAYINf3 BY MAIL, ALLOW 5-7 BUSINESS DAYS MAIL TIME. IF YOU USE A-BILL-PAYMENT SERVICE; NOTIFY THE SERVICES OF YOUR DUE DATE. 09 0000262300002623001328220004313081102129453 BANK OF AMERICA P.O. BOX 15721 WILMINGTON, DE 19886-5721 ~u~~~~~~u~~~~~~n~n~~u~~~~~~~uln~~~u~~~u~~~~ BETHANN E KESHISH 2413 ALDER WAY YORK PA 17406-1970-131 n Chsck here for a change of neiip addre~ or phone numba(a). ~-' Pbaas pmvkls a1 eorteotbm on Ur rowrN akM. ACCOUNT NUMBER 43130811 0212 9453 NEW BALANCE TOTAL• $2623 PAYMENT DUE DATE.• 08/29/07 Eafr Py/wwrt NeR.e G.olsa Me~i Nis pisymeM coupon ebng wiNr a checkormoneyorofsrpeyet~le to: BANKOFAMERICA ~~ ~~ m m °, A 1:5 240 2 2 2 501: 094LLL02L2945311a A Balance Transfers, Checks 0.024830% DLY " 8.99% $0.00 B. ATM, Bank 0.083534% DLY" 30.49% $0.00 C. Purchases 0.083534% DLY" 30.49% $1,082.87 Annual Percentage Rate for this Billing Period: 30.49% [Includes Pariod'~c Rate Finance Charges and Transaction Fee Finance Charges.l Periodio to y ary Vi s: www.citicards.com ^ ~'~ 1424181011006744001106011061102 ~•r~ 5424 1810 1100 6744 09/11/07 $11.06 $11.06 00 R1 1096 1 MC 4 CITI CARDS BETHANN E KESHISH PO BOX 183062 1446 TIMBER BROOK DRIVE COLUMBUS, .6H MECHANICSBURG PA 43218-3062 ..~ 17050 Citi® Dividend Platinum Select® Card AeeouM Numfxr 5424 1810 1100 6744 Customer Service: 1-800-950-5114 Total Cre41t Llne AvaiW0le Credk Line Cash Advanee Limit AvallaEle Cash Limit New Balance $11600 $11588 $300 $300 $11.06 BOX 6500 Statement/ Amount Over Pureh/Adv Minimum SIOUX FALLS, SD Closing Date Credit Line Psst Due ~ Minimum Due Amount Due 57117 08/17/2007 $0.00 + $0.00 + ' $11.06 = $11.06 Sap Data Post Data Refaranca Num6ar ActMty Since Last Statamant Amount Payy~ents, Credits & Ad ustnents ~ 7/30 CLICK-TO-PAY PAYMENT, l HANK YOU -1,789.25 Standard Purch 8/17 PURCHASES*FINANCE CHARGE*PERIODIC RATE 11.06 ****Dividend Dollars Summary**** Previous Statement Dividend Dollars Total 174.05 Base Dividend Dollars Earned 0.00 , Total Dividend Dollars Earned this period 0.00 Total Dividend Dollars Available 174.05 Bonus Cash Back may take,one to two billing cycles to appear on your statement. Please refer to the specific terms and conditions pertaining to the promotion for further details. If your 'Total Div Dollar Available' balance is at least $50, call us at 1-866-676-4672 or go to www.citicards.com, so that we may send you a check. If you have not received your new card, please call the Customer Service number on this statement. We calculated the finance charges you owe us using the Previous Balance shown on this billing statement. You owe us these finance charges because we assess finance charges daily on all your balances (including your finance charge balances) until we receive payment in Pull. Congratulations on your recent credit line increase! Please note your new total credit line. GO PAPERLESS AND PLANT A TREE. Help the environment - switch to Paperless . Statements and Citi will plant a tree on your behalf. Get an email notice when your statement is ready. Sign up at plantatree.citicards.com Account Summary revlous (+ urc ases -) aymen s + Balance 5 Advances & Credits CHARGE = ew Balance PURCHASES $1,789.25 0.00 $1,789.25 $11.06 ' $11.06 ADVANCES '''" ~'1"~~~ , _., ~. ~ ~ $o.oo o.oo $o.oo $o.oo ~ ' $o.oo _ .~ TOTAL Y~.a,:..p^1;~ $1,789.25 0.00 $1,.789.25 $11.06 $11.06 Da s This Blllin Period: 29 Rate Sutii any a ante u )ec o ergo a omina ANNUAL m «~ ri„i ,~ Finance Charge Rate APR PERC ENTAGE RATE PURCHASES ''~s 91 ! S N ? .~ ' ~ # _ Standard Purch '~ $625.88 0.06093%(D) 22.240% 22.240% ADVANCES Standard Adv $0.00 0.06367%(D) 23.240% 23.240% k;: _ .. '-.i - .. ^:ti; 'ter}~~'~;''~ _ SEND PAYMENTS T0: ~~ °' 1064 PLEASE REFER TO THE REYERSE SIDE OF THE ORIGINAL STATEMENT FOR PAYMENT INFORMATION. ...~ • In the Court of Common Pleas of CUI~ERI,AND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: 9 3110 9 8 7 0 Docket Number: 07-4979 CIVIL Other State ID Number: Please note: All correspondence must include the PACSES Case Number. APRIL 1, 2008 SUMMARY OF TRIER OF FACT Plaintiff Information BETHANN E. KESHISH Address: 1446 TIMBER BROOK DR MECHANICSBURG PA 17050-9163 Employer: UNITED CONCORDIA COMPANIES INC C/O ATTN: PAYROLL 1800 CENTER ST CAMP HILL PA 17089-0001 Attorney: MARY A. DISSINGER, ESQ. Defendant Information JUSTIN A. KESHISH Address: 1500 DALKEITH DR MECHANICSBURG PA 17050-8324 Employer: PFIZER INC* PAYROLL GARNISHMENTS 100 ROUTE 206 NORTH PEAPACK NJ 07977 Attorney: FRANK C. SLUZIS, ESQ. ^ Complaint for Support ^ Petition for Modification Filed ®Other Reason for Conference: WIFE FILED FOR DIVORCE ON 8/21/07, WITH A CLAIM FOR APL AND FILED FOR AN APL CONFERENCE ON 3/7/08. HUSBAND CONTENDS THAT THERE IS NO NEED FOR. APL. Dependent(s) Current Order: $ o . 0 0 Service Type M /per month NEW ACTION Form CM-022 Rev.3 Worker ID 21005 ,~CESHISx v• KESHISH PACSES Case Number: 931109870 Plaintiff Information Defendant Information Current Income: $47,953.00/A GROSS SALARY $62,000.00/A GROSS SALARY $2698.00/A GROSS BONUS (2007) $3,757.51/M NET $50,650.69/A GROSS (2007 W2) (NO BONUS INCLUDED AT THIS TIME) $3,59.61/M NET Tax Return: P-1 P-1 Medical Coverage: HAS HER OWN COVERAGE HAS HIS OWN COVERAGE. Child Care/Tuition: Additional Obligations: 1ST & 2ND MORTGAGE AND ESCROW PAYMENTS OF $1,900.00/M ON THE MARITAL HOME THAT WAS PURCHASED 3/9/07 Other Information: 10/2/04: PARTIES WERE MARRIED 3/9/07: MARITAL HOME WAS PURCHASED. THE PURCHASE PRICE WAS $291,000.00 AND THE PARTIES FINANCED $262,000.00 8 19/07: PARTIES SEPARATED. HUSBAND REMAINED IN THE MARITAL HOME. WIFE MOVED INTO HER PARENTS HOME UPON SEPARATION AND NOW RESIDES ALONE IN A RENTAL. 8/21/07: WIFE FILED FOR DIVORCE. WIFE HAS BEEN EMPLOYED WITH UNITED CONCORDIA CURRENTLY IN MARKETING SINCE 2007 HUSBAND HAS BEEN EMPLOYED WITH PFIZER SINCE 6/18/07, AS A SALES REPRESENTATIVE HE WILL RECEIVE QUARTERLY BONUS AND HAS NOT RECEIVED ONE FOR 2008. HE RECEIVED ONE QUARTERLY BONUS IN THE LAST QUARTER OF 2007 IN THE AMOUNT OF $4,000.00. DUE TO THE LENGTH OF TIME EMPLOYED WITH PFIZER, DRO WOULD NOT INCLUDE A BONUS AS INCOME AND WOULD CONSIDER HUSBAND PAYING A ~ OF ANY NET BONUS. Page 2 of 3 Service Type M Form CM-022 Rev.3 Worker ID 210 0 5 . ~_, KESHISH ~• KESHISH PACSES Case Number: 931109870 Other Information (continued): Facts Agreed Upon: THE LENGTH OF MARRIAGE THE PARTIES PURCHASED THE HOME IN 3/9/07. Facts in Dispute and Contentions with Respect to Facts in Dispute: WIFE'S NEED FOR APL Guideline Amount: $ 239.18 /MONTH DRS Recommended Amount: $ o . o o /MONTH DRS Recommended Order Effective Date: MARCx 3 , 2 0 0 8 Parties to be Covered by Recommended Order Amount: WIFE Guideline Deviation: ®YES or Q NO Reason for Deviation: HUSBAND BEING RESPONSIBLE FOR THE MORTGAGE(S) & ESCROW ON THE MARITAL HOME $3757.51/M X 250 = $939.25 HOUSING ALLOWANCE FOR HUSBAND $1900/M - 939 = 961 / 50~ _ $480.50/M (CONSIDERATION FOR WIFE'S CONTRIBUTION) 5480.50 > 5239.18 Submitted by: R. J. SHADDAY Date Prepared: APRIL 1, 2008 Page 3 of 3 Service Type M Form CM-022 Rev.3 Worker ID 21005 .. , BETHANN E. KESHISH, Plaintiff v. JUSTIN A. KESHISH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY N0.07-4979 CIVIL IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this day of January, 2009, I, Frank C. Sluzis, Esquire, do hereby state that I served a true and correct copy of the foregoing document upon the following individual in the manner indicated. VIA FIRST CLASS U.S. MAIL. POSTAGE PRE-PAID Mary A. Etter Dissinger, Esquire Dissinger &Dissinger 28 North 32°a Street Camp Hill, PA 17011 E. Robert Elicker, II, Esquire Divorce Master Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 ~ 4v ~ C.. ~ ° ~ ~ . ~ i_ ~ j. . / '+..K.: _ 1 ( !. ~ ~.. r ~ i s :~ ~ ~ r. ~' ~"E f,~ T Bethann E. Keshish, Plaintiff vs. . Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4979 IN DIVORCE INCOME AND EXPENSE STATEMENT OF BETBANN E. KESHISH, PLAINTIFF INCOME (a) Wages/Salary Employer: Public Consulting Group Address: 148 State St., Boston, MA 02109 Job Title/Description: Title IV-E Specialist Pay Period .................... Bi-weekly Gross pay per pay period.......$ 1,923.08 Payroll Deductions: Federal Withholding........ $ 221.24 Social Security............ $ 26.05 Medicare Tax ............... $ 111.39 State Income Tax........... $ 55.16 Local Wage Tax ............. $ 0.00 Retirement ................. $ 0.00 Health Insurance........... $ 57.35 Dental ..................... $ 16.11 U.C ........................ $ 1.16 Net Pay per period......... (b) Other Income Child Support ............. Interest & Dividends...... Pension/Annuity........... Social Security........... Rents/Royalties........... Expense Account........... Gifts ..................... Unemployment Compensation. Worker's Compensation..... $ 1,434.62 Week Month Year $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ TOTAL ...................... $ EXPENSES Household Child Week Week Home Mortgage\Rent..... $ $ Maintenance....... $ $ Utilities-Electric $ $ Heat.... $ $ cell phone $ $ Water, Sewer, Refuse $ $ Employment Transportation.... $ $ Lunches........... $ $ Taxes Real Estate....... $ $ Personal Property. $ $ Insurance Homeowners........ $ $ Automobile........ $ $ Life .............. $ $ Accident.......... $ $ Health............ $ $ Other ............. $ $ Automobile Payments.......... $ $ Fuel .............. $ $ Repairs........... $ $ Medical Doctor ............. $ $ Dentist............ $ $ Orthodontist....... $ $ Hospital........... $ $ Medicine........... $ $ Special needs...... (Glasses, contacts) $ $ Education Private School.... $ $ Parochial School.. $ $ College........... $ $ Personal Clothing.......... $ $ Food .............. $ $ Barber, Hairdresser $ $ Household Supplies $ $ Credit Cards...... $ $ Household Month $ $ $ $ $ 71.00 $ $ $ $ 100.00 $ $ 55.00 $ $ $ $ $ $ $ $ $ $ $ $ 70.00 $ $ $ $ $ $ $ $ $ $ 309.00 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ 30.00 $ $ $ $ $ $ $ $ 150.00 $ $ 300.00 $ $ 55.00 $ $ $ $ 400.00 $ Child Month Loans ............. $ $ $ $ Miscellaneous Household help.... $ $ $ $ Child care........ $ $ $ $ Papers, Books, Magazines......... $ $ $ $ Cable ............. $ $ $ 117.00 $ Vacation.......... $ $ $ $ Entertainment..... $ $ $ 200.00 $ Gifts ............. $ $ $ 60.00 $ Contributions..... $ $ $ $ Legal fees........ $ $ $ 250.00 $ Other child support $ $ $ $ Alimony payments.. $ $ $ $ Other ............... $ $ $ $ TOTAL EXPENSES...... $ $ $ $ PROPERTY OWNED DESCRIPTION VALUE OWNERSHIP H W J Checking Account $ _ X _ Savings Account $ _ _ _ Credit Union $ _ _ _ StockslBonds $ _ _ _ Real Estate $ _ _ _ Other $ _ _ _ TOTAL PROPERTY $ INSURANCE COMPANY POLICY # COVERAGE H W C Medical _ _ _ Health/ Accident _ _ _ Disability Income _ _ _ Other _ _ _ (H=Husband W=Wife C=Child/Children) VERIFICATION I, Bethann E. Keshish, verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. Date: January 20, 2009 Bethann E. Keshish Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the Income and Expense Statement upon the attorney for the Plaintiff, by First Class United States Mail addressed as follows: Frank C. Sluzis, Esquire 2000 Linglestown Rd. Suite 106 Harrisburg, PA 17110 Date: January 20, 2009 _. Mary A. E ter Dissinger Attorney for Plaintiff Supreme Court ID # 27736 28 North Thirty-Second Street Camp Hill, PA 17011 (717) 975-2840 ,~.a ~~_. ..rte ~ ~'il ~ ~' ~ 3 a ._;- q ~ ~ t:.. ~ :> _ ~ ~ ~c;` ~;3 . ' ~ r~ [r;f Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4979 IN DIVORCE INVENTORY AND APPRAISEMEN'li OF BETHANN E. KESHISH, PLAINTIFF Plaintiff files the following Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three (3) years. I, Bethann E. Keshish, verify that the statements made in this Inventory and Appraisement are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. INVENTORY AND APPRAISEMENT UNDER RULE 1920.33 Docsi ccrl -- l (1 /`~ Q x(17 ITEM A. B• C• D• # MARITAL PROPERTY IN IS PROPERTY BASIS FOR PERSON OR WHICH EITHER SPOUSE EXCLUDED FROM CLAIMED ENTITY WITH HAS LEGAL OR MARITAL EXCLUSION WHOM INTEREST EQUITABLE INTEREST PROPERTY IS HELD ON DATE OF SEP. 1. Marital residence Joint 2. '05 Honda Accord - Joint Wife's 3. W's Retirement YES all pre- W (CitiGroup 401K) marital 4. W's Retirement W (Highmark/ United Concordia) 5. W's Roth IRA YES all pre- W Less Mason marital 6. H's IRA w/ partially part pre- H SmithBarney marital 7. H's IRA w/ Legg Mason 8. H's Pfizer Sav. plan 9. H's ADP stock 401K H 10. W's Wachovia partially part pre- W account marital 11. H's Commerce chkg H 4596 12. H's Commerce saving H 5543 13. Jt Commerce chkg J 0885 14. W's Bank of America W 15. W Citi Card 6744 W 16. H credit cards H Capital One 4447 (list individual) 17. H's Chase Visa 18. household oods J 19. living room set J 20. Sharp flat screen tv J 21. Family room furniture yes all pre- marital W 22. Kitchen Set (table +6 chairs) J 23. Bedroom set + mattress J 24. Guest bedroom set yes all pre- marital W 25. Office desk J 26. Futon J 27. Dell computer/printer J 28. Sharp Fax machine J 29. ProForm eliptical trainer J 30. Whirlpool washer J 31. Whirlpool dryer J 32. Toro Lawnmower J 33. Lenox China (service for 12) J 34. Oneida Flatware J 35. MiKasa Barware J 36. Cuisinart pots & pans J 37. Kitchen Aide stand mixer J 38. Cuisinart Food processor J 39. DeLonghi Coffee maker J 40. Serving pieces J 41. Pfaltzgraff dishes yes all pre- marital W 42. Linens J 43. Inheritance after house bou ht H INVENTORY AND APPRAISEMENT UNDER RULE 1920.33 ITEM E. F. G. H. I. J. K. # DATE COST OR VALUE ON DATE AMT OF LIEN NATURE DATE OF LIEN ACQUIRED ACQUIRED OF SEPARATION ON DATE OF OF LIEN LIEN HOLDER VALUE SEPARATION 1. 293,000.00 231,457.28 on 1st/2nd Wells 10/1/07 mortgage Fargo 29,291.55 2. $12,305.00 $9,987.09 Honda Am. Fin. 3. 3/8/00 $16,914.90 Minus (-) DOM Balance 4. $8,715.88 5. $10,434.00 $7,458.00- premarital= $2,976.00 growth during marriage--need current bal. 6. $7,910.95 7. $1,158.94 8. $1,520.40 9. $20,192.60 10. 12/31/95 90,000.00 30,581.90 value on DOM was 52,562.23 11. $1,581.90 12. $438.03 13. $3,824.58 14. ($82.84) 15. ($11.06) 16. (2,451.66) 17. ($2,046.82) 18. 5/07 1800.00 19. 2006 1,100.00 20. 21. 12/06 22. 12/06 2,500.00 23. 24. 2003 200.00 25. 2003 400.00 26. 2003 1,000.00 27. 2003 100.00 28. 8/05 700.00 29. 2003 300.00 30. 2003 300.00 31. 6107 500.00 32. 10/04 1400.00 33. 10/04 960.00 39. 10/09 400.00 35. 10/04 350.00 36. 10/04 350.00 37. 10/04 100.00 38. 10/04 100.00 39. 10/05 1000.00 40. 41. 10/05 1500.00 42. 4105 10,000.00 43. 44. 45. 46. 47. 48. 49. Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. , CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the Inventory and Appraisement upon the attorney for Justin A. Keshish, Defendant, by First Class United States mail addressed as follows: Frank C. Sluzis, Esquire 2000 Linglestown Rd. Suite 106 Harrisburg, PA 17110 Date: January 20, 2009 `~~"" Mary A. tter Dissinger ~ .~ ..,..; ; c._ ~.~ -•r ; T ~ J - ~ [~ , _.t .- ~ ' ~ ~' `' i ~r ~ ~ '~ , N '°C Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. . CIVIL ACTION - LAW Justin A. Keshish , N0. 07-4979 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on and served on August 21, 2007 . '2. The marriage of Plaintiff and Defendant is irretrievably '.broken and ninety (90) days have elapsed from the date of filing '.and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Q_ ~ ~~~~ ethann E. Keshish ~1~L - ,~.~;: vs 3 i~_ k w_ ~~[. Bethann E. Keshish, Plaintiff vs. Justin A. Keshish, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW N0. 07-4979 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lice, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date • QF( ~ C~ ~.,.~- Bethann E. Keshish ^ '~'y~ ~r i t~ ~~ 2~Q9 5~.' ~ ~ ~'~` ~:`~ ~:, , F .~~~u: BETHANN E. KESHISH, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :DOCKET N0.07-4979 CIVIL JUSTIN A. KESHISH, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 21, 2007. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Justin . Keshish fi~l._ j..., f t~1r_ 4F T~-i~ °~a' ~ ; ~:~?T~1fav 249 ~~~ 29 C~~ i'_~ ~'; ~,.-;, :,'~, ,,. ~~CEIVED ~P Q ~ 2~9 tt~~INGER ~& ~~~~i~NGER BETHANN E. KESHISH, Plaintiff v. JUSTIN A. KESHISH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET N0.07-4979 CIVIL CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: J in A. Keshish ~s~~i ~ ~~ ' ~;~~' ,'~,. ~:,r'°~~ ~~ ~~ ~~- ~~~ MARITAL SETTLEMENT AGREEMENT This .Agreement made this ~~ day of c ,rYer^, 2009, by and between Justin A. Keshish, hereinafter referred to as "Husband", and Bethann E. Keshish, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 2, 2004, in York County, Pennsylvania; WHEREAS, a Complaint in Divorce has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania on August 21, 2007, and docketed to term and number 07-4979, Civil Term; WHEREAS, differences have arisen between Husband and Wife in consequence of which they have determined to live separate and apart from each other, and that they be divorced from the bonds of matrimony; WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including but not limited to the ownership and equitable distribution of real and personal property; past, present and future, support, alimony and/or maintenance; and any and all claims which either party has, or may have against the other or the other's estate. In consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree to the terms set forth in this Agreement. 1. Separation ~, ~ .,N n '~ SEP o 12Ud9 ._.> ~r:. t~iSSII~G~~ ~ ~~~~t;~~R Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority and control. Neither party shall harass the other or attempt to harass the other, nor compel the parties' cohabitation. 2. Waiver of Rights and Mutual Releases Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property and estates from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. This release shall be effective regardless of whether such claims arise out of former or future acts, contracts, engagements or liabilities of the parties or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or other country. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including but not limited to alimony, alimony pendent elite, equitable distribution or marital property, counsel fees or expenses. 3. Effect of Divorce Decree on Agreement Either party may enforce this Agreement as provided in section 3105(a) of the 2 ~:. ,., .. ~$~~Ol fi~SS1NGEE ~ ~.µ.,.; ~~aER Divorce Code. As provided in section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendent elite, counsel fees or expenses shall not be subject to modification by the court. 4. Date of Execution The "date of execution" or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. Otherwise, the "date of execution" or "execution date" shall be the date on which the last party signed this Agreement. 5. Headings Not Part of Agreement The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. 6. Severability and Independent and Separate Covenants Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If a court declares any term, condition, clause or provision of this Agreement void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken. In all other respects this Agreement shall be valid and continue in full force, effect and operation. 7. Additional Instruments Each party shall execute, acknowledge and deliver to the other any and all instruments, assignments, releases, satisfactions, deeds, notes or other writings that may be necessary to give full force and effect to this Agreement. 8. Agreement Binding on Heirs This Agreement shall be binding on and shall enure to the benefit of the parties 3 F :- _,, M. ~~~~ ~-•,r ~ ~ i ~ooq ~1SSIC~C ~ u4~ ~ ~ ;. and their respective heirs, executors, administrators, successors and assigns. 9. Inte rag tion This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants or promises other than those expressly set forth in this Agreement. 10. Modification or Waiver to be in Writing No modification or waiver of any term of this Agreement shall be valid unless in Writing and signed by both parties. 11. No Waiver of Default Either party's failure to insist upon strict performance of any term of this Agreement shall in no way affect the right of that party to enforce the term. 12. Applicable Law This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 13. Attorneys' Fees for Enforcement The breaching parry shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successful in establishing that a breach has occurred. 14. Voluntary Execution Each party understands the terms and conditions of this Agreement and acknowledges that the Agreement is fair and equitable. The parties have reached this Agreement freely and voluntarily without any duress, undue influence, collusion or 4 ~P ~ ~[. ~~:;; improper or illegal agreements. 15. Disclosure of Assets Each party has had an opportunity to discuss with counsel the concept of marital Property under Pennsylvania law and the right to seek discovery under the Divorce Code and the rules of civil procedure; and the right to have the real estate, personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth. Each party confirms that there has been disclosure to the other of such income, assets and liabilities. Each party waives any right to further disclose, valuation, enumeration or statement of income, assets or liabilities. Neither party desires to make or append to this Agreement any additional enumeration or statement. Neither party shall sue the other party or that party's heirs, executors, administrators or assigns, alleging denial of any right to full disclosure, or fraud, duress, undue influence or failure to have available full, proper and independent representation by legal counsel. If either party subsequently discovers any property interest not identified in this Agreement, that property shall be divided equally. If, however, one party knowingly concealed or misrepresented the existence of the property, then that property shall become the sole and separate property of the other. The concealing party shall pay all costs associated with the failure to disclose, including but not limited to transfer costs and counsel fees and expenses. 16. Husband's and Wife's Debts Except as otherwise set forth in this Agreement, the parties represent and warrant ,.._ _. y CEIVED ~. SfP q ~. 2009 0~~4~~~~G ~J~SS-'NGER to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save harmless the other from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. Any and all debt or obligation in the name of the party shall become the sole debt or obligation of that party. 17. Advice of Counsel Both parties have received independent legal advice from counsel. They have been informed fully as to their legal rights and obligations, including all rights available to them under the Divorce Code and other applicable laws. Husband is represented by Frank C. Sluzis, Esquire. Wife is represented by Mary A. Etter Dissinger, Esquire. 18. Equitable Distribution 1. Real Estate The parties agree that they are joint owners of a parcel of real estate with improvements which is located at 1500 Dalkeith Drive, Mechanicsburg, Cumberland County, Pennsylvania. The marital real estate is currently under a contract of sale. The parties agree that any and all proceeds from the sale of the marital real estate shall become the sole property of Husband. Wife agrees to cooperate and execute any and all documents necessary to finalize the sale of the marital real estate. The parties agree that the subject real estate is encumbered by a mortgage and a home equity loan held by Wells Fargo. Said mortgage and home equity loan will be satisfied from the proceeds of the sale of the marital real estate. Husband shall be solely liable for said mortgage and home equity loan and shall indemnify and save harmless 6 Wife from any and all claims or demands made against Wife by reason of this debt or obligation. 2. Investments and Other Accounts Any and all investments, including brokerage accounts, money market accounts, stocks, and bonds shall become the sole property of the party named on the account. Prior to executing this Agreement the parties divided the funds in their bank accounts, and neither party shall assert a claim to the funds retained by the other party. 3. Life Insurance Policies Neither party acquired any life insurance policies with cash or surrender value, and each party is entitled to designate any beneficiary of any term life insurance policies which that party may have acquired during the marriage. 4. Pension and Retirement Benefits Husband and Wife agree that each does hereby specifically waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be, in any pension plan, retirement plan, IRA account, profit sharing plan, 401(k) plan, 403(b) plan, keogh plan, stock plan, tax deferred savings plan, any employee benefit plan andlor other retirement plan or plans of the other party, acquired in the past or future by the other party, whether acquired through said party's employment or otherwise (hereinafter "Retirement Plans"). Hereafter, the Retirement Plans shall become the sole and separate property of the party in whose name or through whose employment said plan or account is held or carried. 5. Personal Property 7 ~~A p ~: The parties shall retain all personal property in their possession as that party's sole possession. year first above written. 19. ~ousal Support Alimony Alimony Pendente Lite and Maintenance Neither party shall pay spousal support, alimony, alimony pendent elite or maintenance to the other, and both parties waive their right to claim such payments. 20. Counsel Fees Costs and Expenses Each party shall pay his or her own counsel fees, costs and expenses, and both parties waive their right to claim such payments. 21. No-Fault Divorce The parties agree to execute contemporaneously with the execution of this Agreement Affidavits of Consent pursuant to Section 3301 (c) of Divorce Code and Waiver of Notice of Intention to Seek Entry of Divorce Decree. IN WITNESS WHEREOF, the parties have signed this Agreement on the day and ESS: EAL) C stin A. Keshish ,,,~ ~~~ (SEAL) Bethann E. Keshish 8 ~"~' ;;- ''_~ _. , . ~~ ~~ ~, ..4 ~,~~~'fi t :~ ~ a COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~~ ~~ 1 v : SS z ~ Personally appeared before me the undersigned officer, this /I day of 2009, JUSTIN A. KESHISH, known to me, or satisfactorily proven to be, the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. ~_ Nbtarv Public NOTARIAL SEAL IaYlANOA L EMERSON Nogry- P~Ite suSOUEw-NNA TIMP, oAI~IaN CDUNTY My Commhsion ExpUp drn 2.2012 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~~Q j(~Y~ : S S Personally appeared before me the undersigned officer, this (~ day of 2009, BETHANN E. KESHISH, known to me, or satisfactorily proven to be, the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. ~.... NOTARIAL SERI. DANIELLE R VAN HORN N~- P~1Ne Not Public MMYSVII.LE SOROUBH, PERRY COUNTY Mill CoawnNNoa E~pint ~ ai, 2O1! 9 r t{ r „_ 2C~~ c=,~~~ ~ "~ p~1 i%~ ~~r ., CLr ._ '~; i ._ _. ~~~ 1A~E .JA41AA~nt~ NO~A~~ ~ Af3Ni-NlA aiidu4 Y~~ VtMtlO~ MIiHgUAO !' !kilMAFi3lid~i$ SCOS .S reuL sR~igx3 €r~isa~+ra~ ~'~~"~ -, SEP L ~. 2flU~ fl~~s~~~ ~: ~~ 5~i`+~i:~~~ JA31! .~#'~41t NACMM f1AV A ~.1~~NlAtT rysss~ YTMl1[i'! Yii~i~~ H~114;1~ ~JJlYl1'if~IRA L f QS , ~ ~, t~A R R0E#R4u v!N BETHANN E. KESHISH, Plaintiff vs. . JUSTIN A. KESHISH, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 07 - 4979 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this ~_ day of ~~•~~~- , 2009, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated September 18, 2009, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. B COURT, S ,, ~ c~~ ./ cc. Mary A. Etter Dissinger At orney for Plaintiff Frank C. Sluzis Attorney for Defendant nn __ I -. ~-o l ~.S Ma-~C~cl..~ 6 ,n~$~oq Edgar B. Bayley, P.J. ~y _~j'~ ~~~~ {~~~ "~ ~~`~ ~~ J L+L.s"~ ~ ~ ~J ~,~~,J Bethann E. Keshish, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Justin A. Keshish, N0. 07-4979 Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 21, 2007, by United States Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff September 18, 2009; by Defendant August 31, 2009. 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce filed with the Prothonotary: KEYBOARD() Date Defendant's Waiver of Notice in § 3301(c) Divorce filed with the Prothonotary: KEYBOARD() Respectfully submitted, Date : !' f~G ~f1 DISSINGER AND DISSINGER ~ G'~ - _.. Mary A. Etter Dissinger Attorney for Plaintiff Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 717-975-2840 cc: Frank C. S?uz:is, Esq., 2000 Linglestown Rd., Suite 106, Harrisburg, PA 17110 ~~ ~~r_ 2449 ~4V _5 P~3 2~ 5b e i !h'J1V t~1` ~ 1f 1{ 47i'~, IN THE COURT OF COMMON PLEAS O CUMBERLAND COUNTY, PENNSYLVANIA BETHANN E. KESHISH, PLAINTIFF V. JUSTIN A. KESHISH : NO. 07-4979 -CIVIL DIVORCE DECREE AND NOW, Nov~v~nbe.t ~0 ~.~~~ , it is ordered and decreed that Bethann E. Keshish ,plaintiff, and Justin A. Keshish ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: None The Marriage Separation Agreement of the parties dated September 18, 2009, is hereby incorporated but not merged. By the Court,. Attest: J. Protho tary ~, ~yi.GZti~~ ~C . ~ o o~ ~~ ~ ~` Y~'~ ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Bethann E. Keshish Plaintiff VS. Justin A. Keshish Defendant NOTICE TO RESUME PRIOR SURNAME FILE NO. 20? Q IN DIVORCE - 0 w 3 . Vt Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 10th day of November 2009 hereby elects to resume the prior surname of Lau and gives this written notice pursuant to the provisions of 54 P.S. 704. Signature Signature ?ofame being resumed COMMONWEALTH OF PENNSYLVANIA . : SS. COUNTY OF CUMBERLAND On the day of _?_?? 20 before me, a Notary Public, personally appeared the above affiantt known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA otary Public J/. vd jJ? -T- NOTARIAL SEAL Vicky L. Knott, Notary Public Conewago Twp., Adams County My Commission Expires Mar. 13, 2012