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Home My WebLink About07-5199 w Divorce Complaint Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 ~ Fax: 717-975-0697 ~ Email: dianeradcliff C~comcast.net Attorney for Dianne R. Woods IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, v. Plaintiff N0. 0 '7 ' sr 4 4' c? r`r~ CIVIL ACTION -LAW JACK L. WOODS, JR., DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED tN 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 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT !S 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. iF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. ~ 7 - 5 19 ~j V, CIVIL ACTION- LAW JACK L. WOODS, JR., DIVORCE Defendant DIVORCE COMPLAINT Plaintiff, DIANNE R. WOODS by attorney, Diane G. Radcliff, Esquire, and files this Divorce Complaint, of which the following is a statement: 1. The Plaintiff is Dianne R. Woods, an adult individual who currently resides 1247 Rebert Drive, Mechanicsburg, Cumberland County, PA 17055 since 1968. 2. The Defendant is Jack L. Woods, Jr., an adult individual residing at 1247 Rebert Drive, Mechanicsburg, Cumberland County, PA 17055 since 1968. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 14, 1968 at Churchtown, Cumberland County, PA. 5. Plaintiff avers that there are no children under the age of eighteen (18) years born of the marriage. 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. -1- . . 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. ly submitted, Dl ~ G. RkDCLI ,ESQUIRE (Attorne s ration No 32112) 3448 Trindle Road Camp Hill, PA 17011 Email: dianeradcliffC~comcast.net Phone: (717) 737-0100 Fax: (717) 975-0697 Counsel for Dianne R. Woods -2- .. VERIFICATION DIANNE R. WOODS verifies that the statements made in this Complaint are true and correct. DIANNE R. WOODS understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DIANNE R. WO D Date: ~ ~ 9 D -3- c? ~' o r- ~~ -:, ~ ~ ~ ~ ~ ~ _ -- - ~= ~ `N ~ -~ c,n c- ca w ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff v. JACK L. WOODS, JR., Defendant N0. 07- x/99 CIVIL ACTION -LAW DIVORCE MARITAL AGREEMENT BETWEEN JACK L. WOODS, JR. AND DIANNE R. WOODS TABLE OF CONTENTS RECITALS ......................................................................... 1 SECTION I General Provisions ............................................................. 1 SECTION II I! Distribution of Property and Debts ........................................... 06 SECTION III Counsel Fees, Support, Alimony, etc ....................................... 13 SECTION IV Closing Provisions and Execution ............................................ 14 NOTARY .......................................................................... 15 EXHIBIT "A" Personal Property Division List ................................................ 16 MARITAL AGREEMENT THIS AGREEMENT made this 30`h say of August, 2007, by and between DIANNE R. WOODS, ("Wife") of 1247 Rebert Drive, Mechanicsburg, PA 17055, and JACK L. WOODS, JR., ("Husband") of 1247 Rebert Drive, Mechanicsburg, PA 17055. PREAMBLE AND RECITALS R-1. WHEREAS, the parties hereto are husband and wife, having been married on July 14, 1968 in Cumberland County, Pennsylvania, and were separated on July 9, 2007 (in house separation). R-2. WHEREAS, The parties are the parents of two (2) children: Jack L. Woods, III, born July 14, 1972, and Cory M. Woods, born May 16, 1978, both of whom are emancipated, (the "Children"). R.3 WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of alt matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: SECTION I GENERAL PROVISIONS 1.01. INCORPORATION OF PREAMBLE. The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. -1- 1.02. DIVORCE DECREE. The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent no-fault Divorce Decree in Wife's above captioned divorce action. Upon the execution of this Agreement, or as soon as possible under the terms of said Divorce Code if said documents can not be signed upon the execution of this Agreement, the parties shall execute and deliver to Wife's attorney their respective Affidavits of Consent and Waivers of Notice. After receipt of those signed Affidavits and Waivers Wife's attorney will then file all the remaining documents necessary to secure the entry of the Divorce Decree. If either party has filed a counterclaim, counter-affidavit, or any claim for economic relief, he or she agrees that any such claims have been fully resolved by virtue of this Agreement, and he or she shall withdraw any such claims and, if necessary, shall take such further steps as may be necessary to allow for a prompt finalization of any divorce action between the parties. 1.03. EFFECT OF DIVORCE DECREE, INCORPORATION AND MERGER. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. This Agreement shalt not, however, merge with the Divorce Decree, but rather, it shall continue to have independent contractual significance and each party shalt maintain their contractual remedies as well as Court remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. This Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 1.04. DATES. The "date of execution", "execution date" or "date of this Agreement" shall be defined as the date of execution by the party last executing this Agreement. The transfer of property, funds and/or documents provided for herein shall take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 1.05. VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT . Each party acknowledges that this Agreement has been entered into of his or her own volition, with full knowledge of the facts and full disclosure of their separate and joint estates, and that each believes this Agreement to be reasonable under the circumstances. Further, Husband acknowledges that he has been advised of his right to be advised by an attorney of his own choosing prior to entering into this Agreement and that he voluntarily has decided not to retain such counsel, and further acknowledges that he is aware of his legal rights and obligations governed by this Agreement. Husband acknowledges that he accepts this Agreement and represents that said acceptance is not based on any advice or representation made by Wife's legal counsel, Diane G. Radcliff, Esquire, nor has any such advice and/or representation been given to Husband by said counsel. -2- 1.06. FINANCIAL DISCLOSURE. The parties acknowledges that each has had the opportunity to conduct discovery and investigation as to the incomes of the parties, the parties' marital assets and debts and their respective separate assets, debts and monthly expenses. The parties further acknowledge that there has been a full and fair disclosure of the identity and value of the parties' marital assets and debt, their separate estates and their respective incomes. The parties hereby waive any further discovery and/or disclosure of the parties' marital assets and debt, their respective separate estates and incomes and expenses, except for such disclosure that may be necessary as a result of a breach of this Marital Agreement. 1.07. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS . Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 1.08. BANKRUPTCY. The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to Court determination the same as if this Agreement had never been executed by the parties. 1.09. MUTUAL RELEASES. Except as other wise expressly provided in this Agreement, ~I Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from the following: A. Claims Against Property or Estate: Any and all right, title, interest and/or claims in or against the other party, the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other party, the estate of such -3- other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. B. Life Time Conve av Hess: 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 (I) the Commonwealth of Pennsylvania, (ii) State, Commonwealth or Territory of the United States, or (iii) any other country; C. Marital Rights: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente fits, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise. D. Breach Exceution: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 1.10. EFFECT OF RECONCILIATION. This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as Husband and Wife or otherwise, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shalt be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. 1.11. BREACH. If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies: A. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 PA. C.S.A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. -4- B. Damages: The right to damages arising out of breach of the terms of this Agreement, C. Attornevs Fees and Costs: The right to reimbursement of all reasonable attorney's fees and costs incurred as the result of the breach and in enforcing rights and obligations under this agreement. D. Other Remedies: Any other remedies provided for in law or in equity. E. Considerations for Reasonable Attorneys Fees: Any award of "reasonable attorneys fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered. Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching party. 1.12. INCOME TAX MATTERS. With respect to income tax matters regarding the parties the following shall apply: A. Prior Returns: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failure to disclose the nature and extent of his or her separate income on the aforesaid joint returns. B. Current Returns: The parties shall file individual tax returns for the current tax year and for every tax year hereafter absent future mutual agreement to the contrary. C. Preservation of Records: Each party will keep and preserve for a period of three (3) years from the date of their divorce all financial records relating to the marital estate, and each party will allow the other party access to those records as may be reasonably necessary from time to time. D. No Tax on Property Division: Except as specifically set forth in this Agreement, the division of marital property herein provided is not intended to constitute in any way a sale or exchange of assets. It is understood that the -5- property transfers described herein fall within the provisions of Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer to the transferee. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the terms of this Paragraph on his or her applicable federal or state income tax returns. 1.13. WAIVER OR MODIFICATION. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 1.14. MUTUAL COOPERATION. Each party shall, at any time, and from time to time hereafter, and within five (5) business days of request , take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 1.15. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 1.16. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them including, but not limited to, the Marital Agreement executed on August 29, 2007, which agreement is now deemed to be null and void. There are no representations or warranties other than those expressly set forth herein. SECTION II DISTRIBUTION OF PROPERTY AND DEBTS 2.01. FINAL EQUITABLE DISTRIBUTION OF PROPERTY. The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. -6- 2.02. AFTER-ACQUIRED PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, since the date of the parties' marital separation, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried and each party hereby waives, releases, renounces and forever abandons any right, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this Paragraph. 2.03. INHERITANCE. Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest and claim, if any, either party may have in and to any inheritance of any kind or nature whatsoever previously, or in the future, received by the other party. 2.04 DISTRIBUTION OF MARITAL PROPERTY AND DEBTS. The parties' marital assets and debts shall be divided and distributed as follows: A. Real Estate- Rebert Drive: The jointly owned real estate known and numbered as 1247 Rebert Drive, Mechanicsburg, PA 17055, ("the Real Estate"), having an estimated value of $240,000 +/-and encumbered with a mortgage owed to PHH Mortgage, ("the Mortgage"), having an approximate balancing owing of $190,000 +/-, shall be divided and distributed in accordance with the following: 1. Conveyance: Husband shall prepare and Wife shall execute and deliver all documents in the usual form conveying, transferring and granting to Husband all of Wife's right, title and interest in and to the Real Estate. The deed of conveyance therefor shalt be executed by Wife upon Wife's signing of this Agreement and held in escrow by Wife's attorney pending the refinance/assumption of the Mortgage at which time the deed shall be delivered to Husband to record. 2. Liens and Encumbrances: The said conveyance shall be subject to all liens and encumbrances covenants and restrictions of record including, but not limited to, the lien of the Mortgage, real estate taxes and any other municipal liens. 3. Household Expenses: Until Wife vacates the Real Estate, the parties shall share in the household expenses by continuing to deposit their entire respective pay checks/retirement checks into the joint AmeriChoice Bank Accounts from which all household bills shall be paid. Each party shall receive $200 per pay from that AmeriChoice account as spending money. Any funds remaining in that account when Wife -7- vacates the Real Estate shall be equally divided between the parties. Once Wife vacates the Real Estate Husband shall thereafter be solely responsible for the payment of the Mortgage, real estate taxes, other municipal liens and any and all other expenses associated with the Real Estate, and shall indemnify, protect and save Wife harmless therefrom. The foregoing notwithstanding, any household bills (utilities and the like) that cover a period prior to the date Wife vacates the Marital Home, but are billed after that date, shalt be prorated as of the date Wife vacates the Marital Home, and Wife shall contribute and pay 50% of that prorated amount, with Husband paying the remainder of said bills. 4. Occupancy: Wife shall be entitled to occupy the Real Estate until the date the Divorce Decree is entered between the parties, by which date Wife shall vacate the Real Estate and thereafter Husband shall be entitled to exclusively occupy the same. Wife may, but shall not be required to, vacate the Real Estate any time prior to the date the divorce decree is entered. 5. Refinance: Husband shall apply for refinancing/assumption of the Mortgage within fourteen (14) days of the date of this Agreement and shall complete that refinance/assumption within sixty (60) days of the date of this Agreement so as to release Wife from further liability thereunder. 6. Sale: In the event Husband has not completed the Mortgage refinancing/assumption within the sixty (60) day time period as aforesaid, then the parties shall list the real estate for sale with a qualified real estate broker and shall market and sell the Real Estate, the parties further agreeing to follow all reasonable advice as to listing and sales offered by their broker. Upon said sale all proceeds will be paid to Husband as Husband's sole and separate property. B. Real Estate Deaosit -Charter Homes: The parties previously received a refund of a $17,288 deposit from Charter Homes ("Charter Homes Refund") which was deposited into their joint Americhoice Account. Wife has received her share of that refund by way of a check from that account in the amount of $8,000. Husband's share of that refund has been used to reduce the amount of wife's share of his TSP plan. The parties reaffirm this distribution and waive any further distribution of the Charter Homes Refund. C. Bethany Beach Mobile Home: The jointly owned trailer located in Bethany beach, all contents of that trailer and the right to rent the lot on which that -8- trailer is located and alt other rights associated with the trailer shall be distributed to wife as her sole and separate property. D. Vehicle(~and Vehicle Loan(s): The parties' vehicles, boats, snowmobiles, motorcycles, trailers, campers and the like owned by one or both of the parties, or the trade in value thereof if the Vehicles have been sold or traded in prior to the date of this Agreement ("Vehicles"), and loans associated therewith, shall be divided and distributed as follows: 1. To Wife: The 2004 Lexus and the purchase price loan/debt for that vehicle owed to MftT Bank. Until Wife vacates the Real Estate, the regular payments due for the vehicle loan shall be paid out of the joint AmeriChoice account. Once Wife vacates the Real Estate, Wife shall be solely responsible for the payment of the vehicle loan which is in her sole name. 2. To Husband: The 2001 Chrysler Sebring, the title to which is unencumbered. E. Investments: The parties shares of stock, brokerage accounts and other investments (the "Investments") shall be divided and distributed as follows: 1. To Wife: Wife has no marital investments that are subject to equitable distribution between the parties. 2. To Husband: Husband has no marital investments that are subject to equitable distribution between the parties. F. Accoun s: The parties' bank accounts, certificates of deposit, and other monetary deposits, ("the Accounts") shall be divided and distributed as follows: 1. To Wife: Wife's Commerce Checking and Savings Account. 2. To Husband: Husband has no marital bank accounts that are subject to equitable distribution between the parties. 3. Joint Account: The joint AmeriChoice F.C.U. account shall be divided and distributed as provided in paragraph 2.04.A.2. above. G. Life Insurance: The parties' life insurance policy and the cash value thereof shall be divided and distributed as follows: -9- 1. To Wife: Wife has no marital life insurance polices or any cash value in any such policies that are subject to equitable distribution between the parties. 2. To Husband: Husband has no marital life insurance polices or any cash value in any such policies that are subject to equitable distribution between the parties.. H. Retirement Plans: The parties' Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any employee benefit plan and/or any other retirement type plans (the "Retirement Plans") shall be divided and distributed as follows: 1. To Wife: Wife's TSP account; Wife's CSRS retirement plan; and $89,000 from Husband's TSP account as provided in subparagraph 3 below. 2. To Husband: Husband's FERS retirement plan, Husband's Bethlehem Steel pension plan and Husband's TSP account less the $89,000 to be paid to wife as provided in subparagraph 3 below. 3. Husband's TSP: Wife shall receive $89,000 from Husband's TSP account. The distribution to be made to Wife shall be made to her by way of tax free roll over of retirement benefits pursuant to a Qualified Domestic Relations Order ("QDRO") to be prepared by Wife's attorney and approved by the parties. To the extent permitted under the Plan, Wife payment shall be rolled over into Wife's TSP account, or if not possible then into an IRA account to be established by Wife. The distribution of the said amount shall be made as soon as possible after approval of the order by the Court and the Plan Administrator. The remaining value of the Plan shall be Husband's sole and separate property. Husband shall not be permitted to withdraw any sums from his TSP or to take out any loans from his TSP account prior to the roll over of Wife's share thereof into her TSP or into her IRA account. 4. Waiver: Any interest that either party may have, or may heretofore have had in or as the result of the Retirement Plans of the other party, including rights or contingent rights in and to unvested retirement benefits and/or by virtue of being a spouse, beneficiary, contingent beneficiary or otherwise is hereby extinguished, except as specifically herein provided, and the parties shall hold his or her Retirement Plans free and clear from any right or interest which the other party now has -10 or may heretofore have had therein or thereto. I. Personal Property: The parties' tangible personal property including, but without limitation with specific reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property ("the Personal Property") shall be divided and distributed as follows: 1. To Wife: All items of personal property in the possession of Wife, not otherwise distributed to Husband herein, and the items of personal property under the set forth on the list attached hereto as Exhibit "A", and made a part hereof. 2. To Husband: All items of personal property in the possession of Husband, not otherwise distributed to Wife herein, and the items of personal property set forth on the list attached hereto as Exhibit "A", and made a part hereof. J. Debts: The parties' marital debts, loans, credit cards and other obligations, not otherwise divided and distributed herein, shall be divided and distributed as follows: 1. To Wife: Wife shall be solely liable for and shall timely pay any credit cards, loans, debts and liabilities incurred in Wife's individual name. 2. To Husband: Husband shall be solely liable for and shall timely pay any credit cards, loans, debts and liabilities incurred in Husband's individual name. 3. Wife's Capital One Credit Card Account: The foregoing notwithstanding the parties shall pay all charges made and balances owed on Wife's Capital One credit card account #1474 incurred up to the date Wife vacates the Real Estate, to be paid out of and from the parties' joint AmeriChoice account. Once Wife vacates the Real Estate, Wife shall be solely responsible for all charges made and balances owed on that account which are incurred after the date she vacates the Real Estate. 2.05. MISCELLANEOUS DISTRIBUTION PROVISIONS: The following miscellaneous provision shall apply to the distribution of the parties' marital assets and debts: A. As Is Condition: Except as otherwise specifically herein provided, and with respect to the transfer of any tangible assets provided for in this Marital -11- Agreement, the parties acknowledge that he or she have had the opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate property and he or she is fully aware of the condition of such tangible asset and is receiving those assets in "as is" physical condition, without warranty or representation by or from the other party. B. Title Transfer: If appropriate, for effectuating the transfers as herein provided, those titles shall be executed and delivered to the appropriate party on the date of this Agreement, unless another date is provided herein. For purposes of this Paragraph the term "title" shall be deemed to include a "power of attorney" if the title is unavailable due to financing arrangements or otherwise. C. Personalty Transfer: if either party is entitled to any items of personal property in the possession of the other party as of the date of this Agreement, the parties shall promptly make arrangements so as to permit that .party to remove the items of property from the other party's possession no later than thirty (30) days from the date of this Agreement. D. Waiver. Each of the parties specifically waives, releases, renounces and forever abandons whatever right, title and interest they may have in any property that is to become the sole and separate property of the other party pursuant to the terms of this Agreement. E. Liens: In the event any asset is subject to a lien or encumbrance, the party receiving the asset as his or her separate property shall take it subject to said lien and/or encumbrance and shalt be solely responsible and liable therefor, unless otherwise specifically herein provided. F. Debt Balances and Prior Payments: Any debt herein described shall be deemed to include the current balance owed on the debt. Unless otherwise herein specifically provided, there shall be no adjustment in the distribution provisions for the payment of any portion of the marital debts prior to the execution of this Marital Agreement, whether or not that debt or the prior payment thereof is specifically referenced in this Paragraph, said payment having been taken into consideration in determining the distribution of marital assets and debts herein provided. G. Indemnification: Any party assuming an obligation pursuant to the terms of this Agreement shall indemnify, protect and hold the other party harmless from and against all any and all liability thereunder, including, but not limited to, any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this -12- indemnification. H. After Acquired Debts: Each of the parties represents and warrants to the other that since the parties' marital separation he or he has not contracted nor incurred any debtor liability for which the other or his or her estate might be responsible. From the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is individually and solely liable. I. Cancellation of Joint Debts: Any joint debt shall be canceled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. Further, the parties shall cooperate in closing any remaining accounts which provide for joint liability. J. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. K. Refinance: In the event a party is assuming a liability for which the parties are jointly liable, that party shall refinance the same within sixty (60) days of the date of this Agreement so as to release the other party from any and all liability thereunder. SECTfON III COUNSEL FEES. SPOUSAL SUPPORT, APL. ALIMONY AND HEALTH INSURANCE 3.01. WAIVER OF COUNSEL FEES. The parties hereto agree and do hereby waive any right and/or claim each may have, both now and in the future, against the other for counsel fees, costs and expenses. The foregoing notwithstanding, the parties agree that any attorneys fees and costs incurred in Wife's divorce action and in the preparation of this Marital Agreement and any documents to effectuate the terms hereof shall be considered to be a marital debt and shall be paid equally by the parties 3.02. ALIMONY. APL, AND SUPPORT. The parties hereto agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support and maintenance. -13- 3.05. HEALTH INSURANCE. The following shall apply regarding health insurance: A. Health Insurance for Spouse: Any party who currently carries health/dental/vision insurance coverage on the other party shall continue to provide that insurance coverage on that other party until the date of the entry of the Divorce Decree. Both parties shall be entitled to elect Cobra coverage under each other's employment policy if available and to the extent permitted under federal rules and regulations provided that he or she shall be solely responsible for the payment of the costs and premiums therefor. B. Health Insurance Documentation: Any party having the insurance coverage on the other party pursuant to the terms of this Paragraph shall be required to provide the other party with all documentation pertaining to the insurance including, but not limited to, medical insurance cards, benefit booklets, claim submission forms and all statements pertaining to the determination of insurance coverage as to each claim made thereunder. SECTION IV CLOSING PROVISIONS AND EXECUTION 4.01. COUNTERPARTS.. This Agreement may be executed in counterparts, each of which shall be deemed to be an original, but alt of which shall constitute one and the same agreement. 4.02. BINDING EFFECT. By signing this agreement, each party acknowledges having read and understood the entire agreement, and each party acknowledges that the provisions of this agreement shall be as binding upon the parties as if they were ordered by the Court after a full hearing. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have signed sealed and acknowledged this Agreement the day and year above written. WITNESS: n / (SEAL) ACK L. WOODS, JR. 0 (SEAL) DIANNE R. ODS -14- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this 30T" day of August, 2007, before me the undersigned officer, personally appeared, JACK L. WOODS, JR., known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal. ~ARY PUBLIC ~ mission Ex ires• COMMONWEALTH OF PENNSYLVANIA Notarial Seal plane G. Radc~f, Notary Pt~lic Camp t1iN Bono, Cuntberiand County My Corrtmission Expires Jan.11,2008 Member. Pennsylvania Association Of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. On this 30`h day of August, before me the undersigned officer, personally appeared, DIANNE R. WOODS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I~ereunto set my hand and notarial seal. PUBLIC ssion Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Diane G. Raddilf, Notary Public Camp Hill l3oro, Cumberland County My Commission Expires Jan. 11, 2008 :;iember, Pennsylvania Association Of Notaries -15- EXHIBIT "A -PERSONAL PROPERTY DIVISION ROOM DESCRIPTION PARTY TO RECEIVE Kitchen Refrigerator Jack Dining Room Table and Hutch Dianne China in Hutch Dianne Wine Rack Dianne Living Room Brown Rocking Chair Dianne End Stand Jack Floor Lamp Dianne Ceramic Lamp Dianne Foyer Sweeper Jack Jam Closet Jack Coat Shelf Dianne Umbrella Stand Dianne Family Room Couch Dianne Entertainment Center Dianne Yellow Rocker Dianne 2 Dr. End Stand Dianne Light Pole Jack Brown Light Jack TVNCR Jack Sun Room Love Seat and Rocker Jack Oak Rocker Dianne Magazine/End Stand Jack Metal Truck Dianne Cheny Flat Trunk Dianne Storage Cabinet Dianne Receiver/CD Player Jack Book Shelf Dianne Child's Trunk Dianne -16- EXHIBIT "A • PERSONAL PROPERTY DIVISION ROOM Sun Room Cont. Bedroom #1 Bedroom #2 Decorator Bench 1 Tall file Cabinet 1 Tall File Cabinet Tread Machine Queen Bed Tall Dresser Short Dresser Flat Top Trunk Suitcase Stand Hanging Light Sweeper Single Bed Oak Dresser Other Dresser Silver Light Tiffany Light Flat Top Trunk Safe Stage Coach Trunk Bed Stand TV Garage 2 Tall Rubbermaid Storage Cabinets 1 Wooden Storage Cabinet 1 Entertainment Cabinet 1 Small Storage Cabinet Outside MetaUWood Bench Glider Metal Fold up Table Set Grill PARTY TO RECEIVE Dianne Dianne Jack Jack Dianne Dianne Dianne Dianne Jack Dianne Dianne Dianne Jack Jack Jack Jack Jack Jack Dianne Jack Jack Dianne Jack Jack Dianne Dianne Dianne Dianne Jack -17- EXHIBIT "A -PERSONAL PROPERTY DIVISION ROOM DESCRIPTION PARTY TO RECEIVE Outside Cont. White Lounge Chair Dianne Green Lounge Chair Jack Antique Plow Dianne Wooden Bench Dianne Snow Blower Jack Painted Fence Dianne Laundry Room Washer Jack Dryer Jack Bedroom Down White Rocker Dianne 2 Dr File Cabinet Jack Wood TV Trays Dianne Desk and Chair Jack Futon Jack TV Dianne End Stand Computer Jack Printer/fax Jack Flat Fax Jack Salesman Trunk Jack Doll Truck Jack White Pole Lamp Dianne Quilt Stand Dianne Computer Stand Jack VHS to DVD Conv. Jack Upstairs Hall Stand Jack Shelving Closet Dianne Trailer Small Refrigerator Jack Room Air Conditioner Jack -18 C`r h., r--a ~ ~~ ~.. ~ - -.., -n x=° ~ ^-.a ~~ T ~~~ i = ~ C'7 . i i~ = f..r1 t :~ C::: "~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. 07-5199 v. CIVIL ACTION -LAW JACK L. WOODS, JR., DIVORCE Defendant ACCEPTANCE OF SERVICE I, Jack L. Woods, Jr., the Defendant in the above captioned action, hereby accept service of the Complaint duly endorsed with a Notice to Plead, which Endorsed Complaint was filed in the above captioned matter on August 31, 2007. Date: ~ - ~~ ~ 7 T ack L. Woods, Jr. 1247 Rebert Drive Mechanicsburg, PA 17055 ` u'': ~ Ct~:~` if ....,. .,~ ~~"C, ~ tM' ~ - i - W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff V. JACK L. WOODS, Defendant N0. 07-5199 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 31, 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 in 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. Dated: ~ ~ -`7 d ~ . ~ ACK L. WOODS S S ~ a * .~ . ~ ~ ~,_ ~ ~(~ L .4.. ~ ..t. 1y ~,. ., L I.,... ~".~ . «~^ ~ ~ ~ ~~~ . , ¢¢¢ Vii. E .~~ ~ y "~ ~ r..i.. ~~ ~ V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. 07-5199 CIVIL TERM V. CIVIL ACTION -LAW JACK L. WOODS, IN DIVORCE Defendant 1. I consent to the entry of a final decree in 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 Waiver 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. Dated: ~ 2 `" ~ ~ 4 ~ %l/ ACK L. WOODS ~. °~ ' ~~ ~_ +;F~. =;~.. F n Ci": ~„„ -`"~} IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. 07-5199 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE V. JACK L. WOODS, Sr Defendant 1. I consent to the entry of a final decree in 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 Waiver 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. _. ~ ~ Dated: lag /D 0~~ ~ DI NNE R. WOOD ~~ ~ c ~ x~ .~ ~' ~ - -+q ~ "~j" -'s .~' r*? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. 07-5199 CIVIL TERM V. CIVIL ACTION -LAW JACK L. WOODS, ~i~, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 31, 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 in 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. Dated: /o OJ DIA NE R. WO DS ~-, ,.,. ~~' .»-~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff N0. 07-5199 CIVIL ACTION -LAW DIVORCE v. JACK L. WOODS, JR., Defendant TO THE PROTHONOTARY: PRAECIPE OF TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: 8/31 /2007 b. Manner of Service of Complaint: Defendant's Acceptance of Service c. Date of Service of Complaint: 9/5/2007 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: 12/10/2007 b. Defendant: 12/7/2007 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Marital Agreement dated 8/30/2007, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: 12/14/2007 b. Defendant's Waiver: 12/11/2007 DIANE RADCL F, ESQUIRE 3 Trindle d " A 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 fl ~;, -- _.,s ~~: ~ ~ ~, .~' l N THE CC7U RT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~. =~> - ._ NO. 07-5199 CIVIL TERM VERSUS JACK L. WOODS, JR. Defendant DECREE IN DIVORCE AND NOW, ~~-=.L•.. /gam _ ,=~8~ lT IS ORDERED AND DECREED THAT -nT21TiI~TTa' R jg1C~CLnS. PLAINTIFF, AND ~7ACK L WOODS, JR,, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA5 NOT YET BEEN ENTERED; No issues are outstanding. All issues have been resolved and settled by the Parties' Marital Agreement dated August 30, 2007, filed of record and incorporated into but not merged with, this Decree. BY THE COURT: ATTE J- PROTHONOTARY ~~' ~~~ ~ ~~~ ~ ~~ ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff v. JACK L. WOODS, JR., Defendant No. d 7 - 519 9 caw: I ~-~-~• CIVIL ACTION -LAW DIVORCE STIPULATION FOR ENTRY OF ORDER TO DIVIDE THRIFT SAVINGS PLAN. APPROVED DOMESTIC RELATIONS ORDER AND NOW, thisday of , 20(1, come the parties, Dianne R. Woods, Plaintiff and Jack L. Woods, Jr., Defendant, who stipulate and agree that the foregoing Order to Divide Thrift Savings Plan, Retirement Benefits Order, shall be entered by the Court and specifically consent to and authorize the entry of said Order. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year above written. WITNESS: `~ _f (SEAL) DIANNE R. WOODS DATE: g~o7ln/I ~ 7 L. WOODS, JR. '~ (SEAL) DATE: g " Z ~ - ~/ -4- C~ ^' Y ^ ~ ._ - ~..~ ~ ~ ` , ~, ~ ..~I • A ,RyL ~ ~ ` Q f.'~ ~ ( ' _~~, ,1. _ii 1 _» s '-"y 1~. l~ ~l V r~ 1~ ~~ j R l~11111 a00~,~,, `~ ~,,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANNE R. WOODS, Plaintiff v. JACK L. WOODS, JR., Defendant N0. 07-5199 CIVIL ACTION -LAW DIVORCE ORDER TO DIVIDE THRIFT SAVINGS PLAN RETIREMENT BENEFITS COURT ORDER AND NOW, this «~ day of , 2008, upon consideration of the within Stipulation of the parties and their Marital Agreement dated August 29, 2007, it is hereby ORDERED AND DECREED as follows regarding the Defendant/Participant's, Jack L. Woods, Jr.'s, Thrift Savings Plan (TSP): 1. Marital Relationship: Jack L. Woods Jr. ("Husband" and "Participant")and Dianne R. Woods ("Wife" and "Payee") were formerly husband and wife. They were married on July 14, 1968, and divorced on December 19, 2007. 2. Marital Agreement: As part of that divorce, the parties entered into a marital agreement dated August 29, 2007 ("the Agreement"), which provides for a division of their marital estate and all other property, real and personal, tangible and intangible, including their respective rights and interests in their various retirement plans and benefits including, but not limited to, Defendant's, Jack L. Woods, Jr.'s, Thrift Savings Plan ("TSP"). 3. Participant: Participant is Jack L. Woods, Jr. The following is the required information regarding Participant: A. Address: 1247 Rebert Drive, Mechanicsburg, PA 17055; B. Date of Birth: 6122/1949; C. Social Security Number: 191-40-9900. 4. Pavee: Payee is Dianne R. Woods. The following is the required information -1- ~~~ r ~t~~ ~- , ~ ;wa ~ S .,, E~~S ~. i P~'I~ ~.i~~ -SofB,~~ ~ ,.: ..;. ~t~ Jr1 regarding Payee: a. Address: 1247 Rebert Drive, Mechanicsburg, PA 17055; b. Date of Birth: 12/16/1949; c. Social Security Number: 197-40-5496. 5. Applicable Plan: The Name of Plan/Retirement Benefits to which this Order applies is: Thrift Savings Plan (TSP) of Jack L. Woods, Jr. 6. Plan Administrator: The name, address, fax and phone numbers of the Plan Administrator is: Regular Mail Address: TSP Legal Processing Unit CODIS - P.O. Box 4390 Fairfax, VA 22038-9998 Overnight Mail Address: SI International Fair Oaks Facility ATTN: CODIS -TSP Legal Processing Unit Suite 700 11781 Lee Jackson Memorial Highway Fairfax, VA 22033 Fax No. 1-703-592-0151 Phone: 1-877-968-3778 7. Payee's Distributive Share: Payee is awarded a portion of the Plan Participant's Thrift Savings Plan (TSP), in the amount of $89,000 as of August 29, 2007. 8. Earnin s: Earnings will be paid on the amount awarded to the Payee under this Order until payment is made to Payee. 9. Payment: Payment of the awarded amount is to be made to the Payee to an IRA or other eligible employer plan. Payee will submit the required forms to the Plan Administrator for that purpose. 10. Time of Payment: Payee's benefit payments described above shall be paid as soon as administratively feasible after the Plan administrator's approval of this -2- Retirement Benefits Order. 11. Death: If the Payee dies after the issuance of this Order, but before the distribution herein provided occurs, any sums due the Payee hereunder shall be paid instead to her estate. In addition such assigned benefits shall not be affected by the death of Participant. 12. Notification of Change in Address: Participant and Payee shall promptly notify the Plan Administrator of any change in their address from that set forth in this Order. 13. Property Distribution: This is a property distribution order made in and under the Divorce and Equitable Distribution Statutes of the Commonwealth of Pennsylvania, and in accordance with the provisions of such statute, the portion being distributed to the Payee has been determined to be her property. 14. Conformity with ReQUlations: This Order is written and shall considered to be written in conformity with the regulations governing the Thrift Savings Plan. 15. Service: A certified copy of this order shall be served upon the Plan Administrator and shat[ take effect immediately and shall remain in effect until further Order of Court. 16. Effective Date: A certified copy of this Order shall be served upon the Plan Administrator and shall take effect immediately and shall remain in effect until further Order of Court. 17. Retention of Jurisdiction: This Court shall retain jurisdiction over the issues so as to carry forth the intent of this Order by the Court. BY THE COURT: J. DISTRIBUTION TO: Diane G. Radcliff, Esquire JaR'k L. Woods, Jr. 3448 Trindle Road 1247 Rebert Drive Camp Hill, PA 17011 Mechanicsburg, PA 17055 Attorney for Dianne R. Woods, Plaintiff Pro Se -3-