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HomeMy WebLinkAbout07-5205STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW JANET STAUB, NO. Q, .~ , ~~~ ~ Defendant IN DIVORCE NOTICE TO DEFEND 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT. FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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. Cumberiand County Bar Association 32 South Bedford Street Cariisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, F7JI~WJE1i ~St I~VDSAY z6 w~ x;~ s~ Carlisle, PA Carol J. Lindsay, E~ Attorney Id. 4469,,3' 26 West High S Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff STEVEN STAUB, Plaintiff v. JANET STAUB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. d 7 , sj~r}0 ~ ~~ ~. I IN DIVORCE COMP~NT IN DIVORCE UNDER SECTION 3301(cl or (dl OF THE DIVORCE CODE 1. The Plaintiff is Steven Staub, an adult individual, residing at 3489 Green Street, Harrisburg, Dauphin County, Pennsylvania. 2. The Defendant is Janet Staub, an adult individual, residing at 2908 Westbury Court, Apt. 806, Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 2, 1979 in Queens, New York. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has FLOIWFR~~S~ LINDSAY 26 West High Stmt Carlisle, PA the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE. Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Carol J. LitS y, s Attorney Id 446 26 West H~ trees Carlisle, PA 17013 (717) 243-6222 Dated: ~ _~ I _ ©~ Counsel for Plaintiff FI~WEaEt ~~ LIIVDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsifications to authorities. Steven Staub date: Pry 2~ 12.01 FI ~RIS~~ IIlVDSAY a~ west ~ s~r«r Carlisle, PA C~, N ~W ~,,. „~ i _ E ~ ~,':r SV _.. G'a f71~=" t~ ~ ~ ~ "r"7 f7'; ~• ` \ r ~ C .' T 0~ ~' ` ~J' \. ,__ f _ ~ ~ l ~ ~~ ~ - G1 C ~ Q A N ~ T ~,. STEVEN STAUB, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07-5205 CIVIL TERM JANET STAUB, :CIVIL ACTION -LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Mark T. Silliker, Esquire, attorney for Defendant Janet Staub, hereby affirm acceptance of a Complaint in Divorce in the above-captioned matter on or about September 4, 2007, by first-class mail, postage prepaid. I further certified that I am authorized to accept service of the Divorce Complaint on behalf of Defendant Janet Staub. I hereby certify that the aforegoing is 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. §4904 relating to unsworn falsification to authorities. Date: ~ 7 Mark T. Si111cer, Esquire ~ ~ n --- ~ r- ~ ~ ~ . _~-,;'_: Y "+ ~ ~ _3 i ~ ,_ , ~ ~ , ; ~a -~ ~ ~ STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07-5205 CIVIL TERM JANET STAUB, :CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Mark T. Silliker, Esquire, attorney for Defendant Janet Staub, hereby affirm acceptance of a Complaint in Divorce in the above-captioned matter on or about September 4, 2007, by first-class mail, postage prepaid. I further certified that I am authorized to accept service of the Divorce Complaint on behalf of Defendant Janet Staub. I hereby certify that the aforegoing is 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. §4904 relating to unsworn falsification to authorities. -~ ~_ Date: ~ 7 _ /-~~ Mark T. Silliker, Esquire C`~ ~ ~ -<.> i ~~~ r`". . ~,,~ ~ ., ~ ~, ,~ :,.; C~:? -- ~, ` P .4 -'~ .'~ -' ~: STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-5205 JANET STAUB, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed August 31, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 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. 4904 relating to unsworn falsification to authorities. Date: 11 Z4 ?~7 S even Staub PLAINTIFF'S 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 of Divorce without notice. SAIDIS, FIAWER ~ LINDSAY 26 West High Street Carlisle, PA 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 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. 4904 relating to unsworn falsification to authorities. Date: ~ ( Zg Ldd 7 St en Staub ^~ <r_ O ~~ ~ ~ _~, ~~,.i . f..y 1. ~ ~ .. 'ey ~ ~ f~j r:--: is .1 .. ~ -~ ~- ~ ' ._~~l.Lg ,~ -', ,° t w ~ "i s y _- ; 1y STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 07-5205 CIVIL TERM JANET STAUB, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 3 l , 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since 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. § 4904, relating to unsworn falsifications to authorities. Date: --Y'.1 ~ ~ v ~ ~ _ ~,:. Staub __::a ~:: ~ -; ~ , -a ; ~ .~,~ ~ - ~ ,',: ,,-:. ;. ,~, ~~a ~ , .,_._ '~~ ~w: STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07-5205 CIVIL TERM JANET STAUB, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOR~'E DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I . 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 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: ~~~ ~ ~ ~ ~1 ane Staub -':``"'' _a ! ) ...s . _ ~..,,.i ""'~ ;..~., ^_ t.. 1 ...'.. r. / ~,.t ', i1 "'°' ~~, -~: LC1...- 1 L-NJ f 1'JL = L4 YI'I S 1 LI_. 1 KtK PR PERTY SETTLEMENT ANp SEPARATION A REEMEN7 Y _ b 1 1 THIS AGREEMENT made this ~- ~ day of ~ ~~~~_, 2007, between ~i STEVEN D. STAUB, also known as SHALOM STAUB, of 34$9 Graen Street, Harrisburg, Dauphin County, Pennsylvania, hereinafter referred to as Husband, and JANET STAUB, of 2908 Westbury Court, Apt. 806, Camp Hill, Cumberland County, r ennsylvania, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been }Dined in marriage on i September 2, 1979 in Queens, New York; and R.2: The parties hereto desire tq settle fully and finally their respective financial and property rights and obligations Including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for ,pousai support, alimony, alimony pertdenfe lice, counsel fees and costs, and the settiina ot` any and ail claims and possible claims against:the other or against their respective estates. ~~` NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as Weil as fog athar good and valuable con5lderatlon and intending to be legally bound, it is agreed as follows: (1) SEPARATION: it shall be lawful for each pasty at ail times hereafter to live separate and apart from the other party at such place qr places as he or she from time to time may choose or deem fit, free from any control, restraint ar interference from the other. Neither party wtil molest the other ar ®ndsavor to compel the other tc: cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the ether as if he or she was single and unmarried axceFt as maybe necessary to carry out the terms of this agreement_ ~~ Ltl.:-1L-b( l7L_15 YI"I S1LL1Kt_h' {2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken. Husband has flied a Complaint in Divorce and Wife has accepted service of the Complaint. Within ninety (90) days of her acceptance of service of the Complaint, the parties will execute Affidavits of Consent and Waivers of Notice and Husband wit! promptly go forward to transmit the F' _ {~ record and secure the Divorce Decree. ~j {3j REAL PROPERTY: The parties were the :owners of two tracts of real estate with` improvements thereon erected. Husband presently resides in tl•ie marital home at $4$9 Green Street, Harrisburg, Dauphin County, Pennsylvania. The parties agree that Husband will continue residing in the Green Street house and that he wit! pay all of the expenses associated therewith Including the taxes and homeowner's insurance, utilities and maintenance costs. In the Spring of 200$, the parties will Ilst the marital home for sale with a realtor agreeable to the two of them. In the event that the realtor or the parties themselves deter-nine that certain repairs or Incidental improvements will increase the likelihood of sale or the pU:'`~``ast? pric®, the parties will have ih6 repairs or Improvements done and equally share the cost thereof. Upon safe of the house, the parties will equally divide the proceeds after payment of the usual costs of sale. By their agreement, the parties can equalize the distribution anticipated in paragraph 7 below from the share each will receive from the proceeds of sale of the rrEarital home. The parties were also owners of a property located at 54t West Lake Drive, Jim Thorpe, Carbon County, Pennsylvania, sold on Juiy 3, 2007. The ~artie~ equally divided the net proceeds from th® sale 4f the West Lake Drive property. The Pottle acl':nowledge that the West Lake Drive property was a recreation or investment property:.=~nc 4i~ai, therefore, there will likely be capital gains taxes to be paid upon its sale. The parties agree to report on their 2007 Federal income tax return one-half of the gain from the sale of the West ± eke Drive property and to pay the taxES thereon. Husband and Wife also own a weak timeshare it iron i3lvsam Lodge, Snowbird, Utah, I ~, U~[r-11-(D ( l71 :1~ Yf"1 S 1 LL 1 KLFi r r~o ,, originally given to Husband by his parents. Wife agrees to relinquish interest in this timeshare, and it will be solely owned by Hustaand. (4) DEBT: A, Marital Debt: The parties know of no marital debt or obligation which the other might be fiabie incurred prior to the signing of this Agreement. Should the parties become aware of any such joint debt, it will be paid by the party who incurred it. The parties agree to cooperate to close any joirtit credit card or other such account. In the course of their marriage, the parties have made jCint financial pledges to nonprofit organizations, including, but not limited to, Yeshiva Academy ano united Jewish r~ederatlon. The parties agree that they will equally share the cost cif fulfilling those fir~encial pledges. B: Post 5eparatlon Debt: In the evEnt that either party contracted or incurred any debt since the date of separation on November 1, 2008, the party who incurred said dEbt shall be responsible for the payment thereof regardless of the r;ame in which the debt may have been incurred. C: future Debt: From the date of this agreement neither parry shalt contract or incur any debt or liability for which the other party or his or her property er estate might be responsible and shall indemnity and save the other party harmless fror-n any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (3} MOTOR VEHICLES: Each party relinquishes any right, title and interest he ar she may have to any and aII motor vehicles currently in possession cf the other party. Within ten days {~0} of the date of this agreement each party shall exe~:utL a~,,, documents necessary to have said vehicles properly registered in the Other par'ty's name with he Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and lncerrnify the other party from any loss thereon. Wife will retain the Honda C3dyssey or any vehicle purchased with its equity after 3 i lJt=l.:- 11-FO f d1 : 16 F'f"1 51 L_L 1 ht_K r _ nv separation. Husband wilt retain the Volvo XC. The parties agree that the Volvo S40 will be transferred to their daughter, Rena Staub, and that they will continue to equally share the cost of insurance and maintenance for the Volvo until such tirno as one ~r the other of them believes that Rena Is able to pay those expenses herself (6) TANGIBLE PERSONAL PROPERTY: With the axc©ption of those items set ot~t on Exhibits A and B, which shall be the sole and separate property of Husband and Wife, respectively, the parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from: and after the date hereof be the sole and separate owner of all such property presently in his or her possession wheiher said property was heretofore owned Jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from earl, ;arty tc the other for such pro~~pers may be In the Individual possession of each of the parties i-~eretc_ j~~ ~~~.~ (7) INTANGIBLE PERSONAL PROPERTY: each party hereby relinquishes any right, tiffs or interest he or she m2y have In or to any intangible personal property currently titled in the name of or In the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment bene#Ets including retirement accounts, savings plans, pension plans, stock rl~~;G. ,wC,<i~ plans and the 11ke. Nevertheless, the parties hereto t,ave engaged SJ :estate planning pursuant to which they have separated their financial assets into individual nan,as, -'~;,ey agree to value the following assets as of December 31, 2006 and then to equally divide the, ; :: 7. Clelan & CampanylARlS personal account 6~3-83608$ (Husband); 2. Clelan & Company/ARTS large cap accni3r~r 6~3-836096 (Husbandl, 3. Clelan & Company/ARTS TASA account 47g-7422!1 (Husband); 4. Clelan & CompanylARlS personal account ~1;~-F360~0 (Wife); ~~ LtL.- 1 L-1'J f b1 C Lb YPl Lr 1 LL 1 KtK 5, Clelan 8 Company/ARiS large cap account 613-636061 {Wife); i 6. Clelan ~ CompanyJAR15 TASA account 4?9742-18fJ {Wife); 7. Clelan 81 Company/ARiS gifting account 3?9-836A5~ (joint} {already equally divided); S. Clelan ~ CompanylARIS IRA (Vllife); g. Clelan ~ Company/ARIS iRA (Husband}; 10. Prudential Retirement Account (Wife); 11. T. Rowe Price Retirement Account (Wife); 12. Lincoln Retirement Account (Wife); 13. TIAA-CREPE Retirement Account (Husband); 14. New England Securities Retirement Accoun~ Husband}; 15. ING USA Annuity and Lifie Insurance contract (Husband); 16. SERB Pension (Husband); and r _ r~~r 17. 1sr861i bonds with a face value of $1,000. ~0 due on November 1, 2007, $6,000.00 due an March 14, 2008, $6,000.00 bond due on December 1 :, 200$ and $1,000.00 bond due on December 1, 2008. With respect to the lsraeli bonds: the parrs will divide the proceeds from the bonds as they come due. The parties anticipate that when, they equally divide tha f©regoing assets, Wlfe will have more of said assets in her name and therefore will transfer assets 1r4m one of her accounts to Husband's account. With regard to all such accounts of intangible personal property set out above, the parties agree to equally divide any capital gains occasioned by thr liquidation of any account in order to divide lt. To the extent possible, the parties will equally divide the above stated assets in a ~ manner so as to avoid a sale which would yield capital gains. 'fha transfer of the assets set out above from one party to the ether shall be a tax-free exchange otherwise. If capital gains are ~ 5 O~ IJtC-1L-b( bLCLb rl•, a•L_i ,hr_r< • x~ enjoyed, the parties will divide the iax liability for those gains. The parties acknowledge that Husband i5 the recipien# of an SERS pension which is in pay status. By Domestic Relations Order prepared by counsel for iNife, Husband will tran$°Fer to Wi#e one-half of his interest in the SERS plan. The Domestic Relations Order will call for Wife to waive any claim to a survivor annuity and the parties anticipate an increase, thereby tq the ~~ monthly SERS payment. (8) SHArftEti EXPENSES: The parties acknowledge that their children Have reached majority, but that their daughter, Rena Staub, still relies upon her patents for certain expenses. The parties agree that they wilt continue to split equally the expenses for Reno's support until cne or the other of them believes that she is self-supporting. The parties also agree to equally Share the expenses for the family dog, Champ, including cares by ti~e veterinarian and other routine maintenance expenses, inctuding dog sitting when neither party can care for Champ. Champ wi!! /~' remain residing at 3489 Green Str$et. ,~x ~ (9) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he nr she may have one against the other far alimony, spt~usal support or alimony and alimony pendente iit8. (1Q) ADVICE OF COUNSEL: The parties hereto acknr~w(edge that each has been notlfled of his or her right t0 consult with counsel of his cr her :hoicE, and have been provided a copy of this agreement with which to consult with caunspl, Husband is represented try Carol J. Lindsay, Esquire and Wife is represented by Mark SlEliker, esquire. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the exec:::Eior, ~f this agreement is not the resufi of any duress or undue influence, and that it is not the resuEt cif any- improper or if(ega( agreement ~ ! . i r r DEC-12-07 @2c27 F'M SILLIKER ! . _ ~, , t a CeQments. The parties will equally share the cost of preparation and filing of the Complaint or g in Divorce and the preparation of the Marital Settlement Agreement. Husband's counsel will I ' reimburse Husband for one-half of their cost upon prepare those documents and Wife wail prasentatian to her of a statement for those services. hall from time to time, at the ~~ ADD1T10NAl_ tNgTRUMENTS: Each of the part~e~ s /~ ~ request of the ether, execute, acknowledge and deliver to the nther party any and all further instruments that may be reasonably required to give full farce and effect to the provisions of this Agreement. ./ ~ I t~2) INCOME TAX: The parties have heretaforn fled Joint Federal and State Tax returns. Both parties agree that in the event any deficiency in >=ederal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and i hold harmless the oilier from and against any loss or liability for any such tax deficiency or j I assessment and any interest, penalty and expense Incurred ir: connection therewith. Such t8x, ! interest, penalty ar expense shalt be equally paid by the rarties or, in the event of a refund, f equally divided between the parties. ~j ' (13] BANKRUPTCY: The parties hereby agree that thA provisians of this Agreement shelf not be dlschargeabie in Banknlptcy and expressly agree to reaffirm any. and ail obligations f contained herein. in the event a party flies such banl~rt~ptcy and pursuant thereto obtains a 1 discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be nuN and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by thiG Agreement including aNmony j shalt be subject to court determination the same as if this Agreement had never been entered ,. Into. (~4) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, aclcnow(edge and agree that each is fully and completely +nformed of, and is familiar with, the 7 k i S,. ~ DEC-12-07 02 .2 r F'M tiI Ll I FCEFt ~ ' wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate ~~¢ the other and received any such information requested. Egch has made a full and complete di5::i~sur6 tc the other of his and her entire assets, liabilities, Income and expenses and any furt'~er enumeration ar statement t fin this Agreement is specifically waived. ./ (15) RIGHTS ANQ RESPONSIBILITIES: Husband and 'v'Vife acknowledge that each of r _ e rs them has read and understand his and her rights and responsibilities under this Agreement and ~ that they have executed this Agreement under no compulsion tca do so but as a voluntary act. (16) [~ULL SETTLEMENT: Except as herein othen~vise provided, each party hereby releases the other from any and ail claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in foil settlernpr.+ and satisfaction of any and atl of said party's rights against the other for past, present and future :iaims on account of support, maintenance, alimony, alimony pendente lite, counsel Leo;.; ~^sts and expenses, equitable distribution of marital property and any other claims of ~~ ;ar;, i~ ~ciuc~ing a!1 claims which have '~ action for divorce. ~~ r' been raised or may be raised m an ('17') RELEASE GF ALL CLAIMS: Except as sway be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their i-~eirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respE~.; ~o the ~Ilowing: A. All liability, claims, causes of aGti'~~ dar-ages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All tights, title, interest or claims iI~`: ~r t~ wny property of the other, whether real, personal or mixed and whether ~~ow owned or herea`ter ;~c~ _~ired; C. All rights of co~:rtesy and dower end ail r_Iaims or rights in the nature Of 6 I - - DEC-12-07 02_28 PM ~iILL1Kt.K ~ ~ ~4 courtesy and dower; p. Ali widow or widower's rights; E, A!I right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: {1 } to take against the other's will; {2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority tc~ participate or intervene in a deceased spouse's estate In any way, whether arising under the laws cf ~enrssyivania or any other country, territory, state or political sUbdlvision. 1=. All rights or claims to any accounting; G. A11 rights, claims, demands, Iiat~iGties and obligations arising out of or in ther real, ersonal ronnectlon with the marital relationship or the joint ownership ^'' property, whe p ar mixed; H. All rights, claims, demands, liabilities anti obligations arising under the + t provisions of the Pennsylvania Divorce Code, as the same rr~ay e arnended from time to time, and under the provisions of any similar statute enacte~~ ~y any ::,iher country, stake, territory or I polltic~al subdlvisiart; I. All rights, claims, demands, liabilities any' ~I~iigations each party now has, or i may hereafter have, against or with respect to the otheF (18) GOVERNING LAW: This Agreement Sx~all ve ~t;rzstrued under the law of the j Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, al! other provisions shall continue in full force anc~ effect. (19} INCORPORATION INTO DECREE: In tine s~er<t ;i~at either of the parties shall i 9 i i T .~ DEC-12-07 02:28 PM ~~>1LL_lhth .~ ~ • recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall ndt be merged into such judgment or decree ar~:4 t"~is Agreement shall survive any such final judgment or decree of absolute divorce and shalS be entirely cCependent thereof. {2L1) BREACH: (n the event that either party breaches any provision of this Agreement, he or she shall be r$sponsible for any and all costs Incurre:~ tc enforce the Agreement, including, but not limited to, court cost and counsel fees of the other parry..n the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available. !~ ',im. or her, However, before either party seeks recourse from the Court, he or She wi11 ente ~ ~~t~~ g,~ ^~ `aith negotiations with the other to resolve the issues which arise from the alleged breach eit~ier trough a mediation or throe the collabvratlve law process. _ 4 (21) RELIGIOUS DIVaRC~ PRDCEEDSNQ: ~usbar~d agrees to provide Wife with a gef to complete the religious divorce proceeding acct~rcing to ,;ewish religious law. }~ ` " {ZZ) ENTIRE UNDERSTANDING: This AgrPer-gent cor~stltutes the entire understanding between the parties and there are r~o covenants, conditic.~~~ , r~;oresentations, ar agreements, oral ar written, of any nature whatsoever, other than those her eir ~:~;>ntained. {Z3} AGREEMENT BINDING ON PARI"iES .4NC~ '-iEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and ~a51yr?°.- iN WITNESS WHEREOF, the parties hereto ;r~°ending to be legally bound have her n ' set their hands and seals the day and year first written atrove. WITNESS: ~~-- _-- C? (Shalom) Staub Ja Staub ' Za i i r STEVEN STAUB, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5205 CIVIL TERM JANET STAUB, :CIVIL ACTION -LAW Defendant : IN DOVORCE ADDENDUM TC~ PROPERTY SETTLEMENT AGREEMENT The undersigned, Steven Staub, a/k/a Shalom Staub, hereafter referred to as Husband, and Janet Staub, hereafter referred to as Wife, hereby agree to the following: It is acknowledged, and otherwise agreed between the parties that Wife has not yet had the opportunity to remove articles of personal property from the marital residence which she wishes to retain.. Therefore, it is agreed that Wife shall-have an additional 60 days from the date of this agreement, in order to obtain said articles of personal property. It is further agreed that in the event the parties cannot agree on which additional articles of personal property shall be removed. by Wife, then this shall be referred to a mediator to be agreed upon between them, whose recommendation shall be binding upon them. Date: ~ ~~ "~ (C ~ Janet ub Date: t f lZ3 !?.~7 ---r ~~~ ~~ Steven Staub `~,.~~' ~_; I ~ : s. ~ ~ ~ ~~ ~.~44 ~. ~,ry~ '~. -., STEVEN STAUB, Plaintiff v. JANET STAUB, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on September 4, 2007. An Acceptance of Service was filed with the Court on October 30, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-5205 IN DIVORCE By Plaintiff: November 28, 2007 and filed with the Prothonotary on November 29, 2007. By Defendant: December 7, 2007 and filed with the Prothonotary contemporaneously herewith. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated November 28, 2007 and the Addendum dated December 7, 2007 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: By Plaintiff: November 28, 2007 and filed with the Prothonotary on November 29, 2007. By Defendant: December 7, 2007 and filed with the Prothonotary contemporaneously herewith. ~~ ~S~ er-o~sni~uw 26 Wesc High Street Carlisle, PA SAIDIS, FLOWER ~~ ~ ~, Carol J. Lind y, squire Supreme C rt I No. 44693 26 West Hi treet Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff ``' ~ =^;` ~ = `i- i ~- ~ ~ r--? "` `?- ;'~ , `'~ ~ f r. + S'i ...~" ~ ..~5 ~_ .f. - ~ «.1... 1l , ~ y ~ i"1 ,~ r~„r I N THE COURT OF COiWI ICI ON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STEVEN STAUB y a ~~ ~' 07-5205 No. VERSUS JANET STAUB DECREE IN DIVORCE r AND NOW, _ 7~ lam, ~ 2007 , IT IS ORDERED AND STEVEN STAUB DECREED THAT AND JANET STAUB ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated November 28, 2007 and the Addendum dated December 7, 2007 are incorporated, but Trot merged, into this Decree in Divorce. „a~~,~ BY THE COURT: ATT E J. PROTHONOTARY ~~ ~~~ ~~ ~~~ ~ ~~ ~~' y k L~. ~~ - ~r r• , STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-5205 JANET STAUB, Defendant IN DIVORCE STIPULATION AND AGREEMENT FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this a-(ap( day of , 2008, the parties, Steven Staub, Plaintiff, and Janet Staub, Defendan , having been divorced by Decree dated December 19, 2007 of the Court of Common Pieas of Cumberland County, entered at Docket Number 07-5205, do hereby stipulate and agree as follows: 1. The Plaintiff Steven Staub, (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania State Employees' Retirement System (hereinafter referred to as "SERB"). 2. SERB, as a creature of statute, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §§5101-5955 ("Retirement Code") 3. Member's date of birth is January 28, 1956 and the Member's Social Security SATDIS, F7AWER Sz 26 West High Strect Carlisle, PA number is 079-40-0405. 4. The Defendant is Janet Staub (hereinafter referred to as "Alternate Payee"} is the former spouse of Member. Alternate Payee's date of birth is December 1, 1951 and the Alternate Payee's Social Security number is 080-38-0367. 5. Member's last known mailing address is: 3489 Green Street, Harrisburg, PA 17110-1442. 6. Alternate Payee's current mailing address is: 255 North 17th Street, Camp Hill, PA 17011. It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. Fifty percent (50%) of the Member's retirement benefit is to be allocated to Alternate Payee as the equitable distribution portion of this marital asset. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph Seven (7), shall be paid to Alternate Payee and shall commence as soon as administratively feasible or on or about the date SERS approves a Domestic Relations Order incorporation this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to SAIDIS, PLANNER Sz LINDSAY 26 Wcsr High Srreer Carlisle, PA the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits paid by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or other authorized representative of the Secretary, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Payee and any other alternate payees named under other SERS-approved Domestic Relations Orders ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement I, Board prior to Member's death. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death ~ (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. 10. The terms and amounts of Member's retirement benefit payable to Alternate Payee after SERS approved the Domestic Relations Order incorporating this Stipulation and Agreement depends upon which option Member selects at retirement. Member and Alternate Payee expressly agree that Member shall select the maximum single life annuity with a withdrawal of contributions. Alternate Payee waives the survivor annuity previously elected. 11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid tc each. 12. In the event of the death of Alternate Payee prior to receipt of all of payments SAIDIS, FIAWER Sz LINDSAY ,,~,a uw 2G West High Street Carlislc, PA payable from SERS under a Domestic Relations Order incorporating this Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate Payee by SERS shall be paid to Alternate Payee's Estate to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit as set forth in paragraphs 7 and 9. 13. In no event shall Alternate Payee have benefits or rights greater than those that are available to Member. Alternate Payee is not entitled to any benefit not otherwise '. provided by SERS. Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Stipulation and Agreement. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Stipulation and Agreement are preserved for Member. Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. §1311, et seq. 14. It is specifically intended and agreed by the parties hereto that any Domestic Relations Order incorporating this Stipulation and Agreement: (a) Does not require SERS to provide any type of benefit, or any option, not otherwise provided under the Retirement Code; (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living adjustments or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Dauphin County, Pennsylvania, shall retain SAIDIS, ~~OWER ~ LINDSAY 26 Wes[ High Stree[ Carlisle, PA jurisdiction to name any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic ~, Relations Order; provided, however, that such amendment shall not require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that such amendment or right of the Court to so amend will not invalidate the parties' existing Domestic Relations Order. 17. Upon entry of a Domestic Relations Order incorporating this Stipulation and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and --~ , , + ~ , Agreement and any attendant documents shah be served upon SERS immediately. Such Domestic Relations Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until such time as a further Order of Court amends or vacates the Domestic Relations Order. WHEREFORE, the parties intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. ub/MemtSer Carol J. Lind~fa ,wire 26 West H" h Str et Carlisle, A 17 3 Attorn for ember Janet taub/Alternate Eat Mirk T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112-1149 Attorney for Alternate Payee FI~OVVER ~ LINDSAY 26 West High Street Carlisle, PA C~? ^~~ `3 ~~::~ ~~ ~--, ~ _ ~__' f ,~~ ~ j ~.~ , •,~ ~. (.w W • ~ , ", 61M10420oe,v-1 STEVEN STAUB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~• CIVIL ACTION -LAW NO. 07-5205 JANET STAUB, Defendant IN DIVORCE ORDER AND NOW, this 6t`' day of ~vhL , 2008, the attached Agreement dated Z Z~ of the parties in this case is incorporated, but not merged into this Order of Court. BY THE COURT, J. ZOWER 8i j~VDSAY 26 West High Street Cazlisle, PA ,~x .~ , , ~~ w ~ !+-. ~~.~~ •~- .~ ~ 1~ .I'~~~y~7,~~,~j~ :.,~~~ Z~ ,E ~d ~` '' `~#1,~p STEVEN STAUB, Plaintiff v. JANET STAUB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-5205 IN DIVORCE STIPULATION AND AGREEMENT FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this] , 5't' day of ~ a/(Ch , 2009, the parties, Steven Staub, Plaintiff, and Janet Staub, Defendant, having been divorced by Decree dated December 19, 2007 of the Court of Common Pleas of Cumberland County, entered at Docket Number 07-5205, do hereby stipulate and agree as follows: 1. The Plaintiff Steven Staub, (hereinafter referred to as "Member"} is a member of the Commonwealth of Pennsylvania State Employees' Retirement System (hereinafter referred to as "SERB") 2. SERB, as a creature of statute, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §§5101-5956 ("Retirement Code"). 3. Member's date cf birth is Je~ uary 2S, 1956 and the Member's Social Security FLOWERIS SZ LINDSAY u~ 26 West High Street Carlisle, PA number is 079-40-0405. 4. The Defendant is Janet Staub (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is December 1, 1951 and the Alternate Payee's Social Security number is 080-38-0367. 5. Member's last known mailing address is: 3489 Green Street, Harrisburg, PA 17110-1442. 6. Alternate Payee's current mailing address is: 255 North 17th Street, Camp Hill, PA 17011. It is the responsibility of the Alternate Payee to keep a current mailing address on file with SERS at all times. 7. Fifty percent (50%) of the gross annuity payable to Member by SERS shall be allocated to Alternate Payee as her equitable distribution portion of this marital asset. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph Seven (7), shall be paid to Alternate Payee and shall commence as soon as administratively feasible or on or about the date SERS approves a Domestic Relations Order incorporation this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable benei:ICiary to F, IRIS 6i LIlVDSAY 26 West High Street Carlisle, PA the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits paid by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or other authorized representative of the Secretary, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Fayee and any otl~ar alternate payees named under other SERS-approved Domestic Relations Orders ("Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. 10. Member and Alternate Payee agree that within a reasonable period of time SAIDIS, FIAWER ~ LINDSAY 26 West High Street Cazlisle, PA after the issuance of the parties' decree in divorce, Member shall file an application to re- elect his retirement benefits with SERS. Member agrees that he shall select a Maximum Single Life Annuity upon re-electing his retirement benefits. The recomputed Maximum Single Life Annuity shall be paid by SERS to Member and Alternate Payee in accordance with this Stipulation and Agreement. The parties acknowledge that Member shall not be permitted to take a lump sum withdrawa{ of any kind in connection with his application to re- elect his retirement benefit. In the event this Stipulation and Agreement is approved by SERS subsequent to the issuance of the parties' divorce decree but before Member files an application tc, reelect leis retirement benefits, SERS shall divide and pay the annuity otherwise payable to Member in accordance with the terms of this Stipulation and Agreement until such time as Member files for and begins to receive a recomputed Maximum Single Life Annuity. 11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Altemate Payee for amounts paid to each. 12. In the event of the death of Alternate Payee prior to receipt of all of payments payable from SERS under a Domestic Relations Order incorporating this Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate Payee by SERS shall be paid to Altemate Payee's Estate to the extent of Altemate Payee's equitable distribution portion of Member's retirement benefit as set forth in paragraphs 7 and 9. 13. In no event shall Alternate Payee have benefits or rights greater than those that are available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS. Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Stipulation and Agreement. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Stipulation and Agreement are preserved for Member. Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. §1311, et seq. 14. It is specifically intended and agreed by the parties hereto that any Domestic Relations Order incorporating this Stipulation and Agreement: (a) Does not require SERS to provide any type of benefit, or any option, not otherwise provided under the Retirement Code; (b} Does rot require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based ~IS,~ LINDSAY 2G West High Street Carlisle, PA upon cost of living adjustments or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to name any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that such amendment shall not require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that such amendment or right of the Court to so amend will not invalidate the parties' existing Domestic Relations Order. 17. Upon entry of a Domestic Relations Order incorporating this Stipulation and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon SERS immediately. Such Domestic Relations Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until such time as a further Order of Court amends or vacates the Domestic Relations Order. WHEREFORE, the parties intending to be legally bound by the terms of this ~ ~IS,~ LINDSAY 26 West High Street Cazlisle, PA Stipulation and Agreement, do hereunto place their hands and seals. St en Staub/Mer~ibef~ Carol J. Linda ~ 26 West Hi eet Carlisle, PA 013 Attamey fior Merrrber a t Staub/Alternate P~a/yee Mark T. Sil iker, Esquire 5922 Linglestown Road Harrisburg, PA 17112-1149 Attorney for Alternate Payee a~ n~~ ~~Cmrx~r 289 APR -2 PM ~ ~ 17 ~~~~~ A~ 0 3 ~~ STEVEN STAUB, Plaintiff v. JANET STAUB, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-5205 IN DIVORCE ORDER nth day of AQrti, ~~ 2009, the attached Agreement dated N1g,rc~ 31 ~ ~,~~9 of the parties in this case is incorporated, but not merged into this Order of Court. BY THE COURT, J. SAIDIS, FLOWER ~ LINDSAY A'rtORNEYS.ATIAW 26 West High Street Carlisle, PA Distribution: /~arol J. Lindsay, Esquire, 26 West High Street, Carlisle, PA 17013 / Mark T. Silliker, Esquire, 5922 Linglestown Road, Harrisbur PA 1711 g, 2 eoP~~~ ~.~.~ ~~~~09 ~~ 1p"~~t~ '-'i ~ ri "-Jti > w { 1~ ~~ ~yt 0~~ ~_ yt~1n V4VN t3~ ~;_,