Loading...
HomeMy WebLinkAbout08-2114FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- of iN 0,414 Ie1M CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 PROVIDE 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 1-800-990-9108 717-249-3166 Respectfully submitted, FRIEDMAN & KING, P.C. By: + iaua?, aia u11C 380 Market Stree Camp Hill, PA 17011 (717) 236-8000 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 61--211Y AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) ,OR SECTION 3301(d) OF THE D ORCE CODE 1. Plaintiff is Andres Galeano, who currently resides at 325 Liberty Court, Mechanicsburg, Cumberland County, PA 17050. 2. Defendant is Azure D. Galeano, who currently resides at 576 Sweet Bay Way, Hershey, Dauphin County, PA 17033. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on November 9, 1997, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The parties separated on July 25, 2007. 8. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. COUNTI REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER _ 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences. 11. While no settlement has been reached as of the date of the filing of this Complaint, the Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant. 12. To the extent that a written settlement agreement might be entered into between the parties prior to the time of hearing on this Complaint, Plaintiff desires that such written agreement be approved by the Court and incorporated in any Divorce Decree which may be entered dissolving the marriage between the parties. WHEREFORE, if a written settlement agreement is reached between the parties prior to the time of hearing on this Complaint, Plaintiff respectfully requests that, pursuant to §§ 3104(a)(1) and (3) and 3323(b) of the Divorce Code, the Court approve and incorporate such agreement in the final Divorce Decree. Respectfully submitted, Date: (A-6 g 382fi Market Street C p Hill, PA 17011 17) 236-8000 JFK/bp VERIFICATION I, Andres Galeano, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Andres Galeano Dated: Xfr/?? I / P pul ?D Vl - 1 D' -:i C: 7 ?y "awl tD -i7 C IV -ft ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY Please enter my appearance on behalf of the Defendant, Azure Galeano, in the above- captioned matter. Date. Mark F. Bayley, Esqu' e Bayley & Mangan 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Defendant ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the within Praecipe upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John F. King, Esquire FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 ??ro Dated: L)_?f Mark F. Bayley, Es uire Attorney for Defendant N O -low rr-r -? t0 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Azure D. Galeano, hereby acknowledge that I received a certified copy of the Divorce Complaint on April ? 2008. OF THE Ir"P' 2009 AUG -4 N : 2"4 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or before July 25, 2007 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made on this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.P. Section 4904 relating to unsworn falsification to authorities. Andres G,fleano, Plaintiff DATED: asy, woe 2009 SEE --1 Pit! 1: 18 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. No. 08 - 2114 CIVIL TERM AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 PROVIDE YOU WITH INFORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA No. 08 - 2114 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S ANSWER NEW MATTER, AND COUNTERCLAIMS AND NOW, comes the Defendant, Azure D. Galeano, by and through her attorney, Mark F. Bayley, and submits the following answer and counterclaims on behalf of Defendant: 1. Admitted as of April 2, 2008. 2. Admitted as of April 2, 2008. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. By way of further answer, Defendant believes the separation took place either on July 25, 2007 or the day before, July 24, 2007. 8. Admitted. NEW MATTER COUNTERCLAIMS COUNT 1- REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO SECTIONS 3104 AND 3502 OF THE DIVORCE CODE 9. Previous paragraphs are incorporated herein. 10. The parties acquired property and assets during their marriage from the date of said marriage until the date of separation. 11. The parties have been unable to agree as to an equitable distribution of said property and assets. 12. The Defendant requests the Court to equitably distribute the property and assets. WHEREFORE, Defendant respectfully requests an Order to be entered distributing the marital estate as the Court deems equitable and just plus attorney fees and costs. COUNT 2 -ALIMONY & ALIMONY PENDENTE LITE 13. Previous paragraphs are herein incorporated. 14. The parties separated on July 24 or 25, 2007. 15. Defendant lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living the parties established during the marriage. 16. Defendant is unable to support herself in accordance with the standard of living of the parties. 17. Defendant has insufficient assets and income to pay for her counsel fees and costs regarding litigation in relation to the within matter. 18. Plaintiff enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of Defendant as well as alimony in accordance with the Divorce Code. WHEREFORE, Defendant requests an Order to be entered awarding Defendant alimony pendente lite and permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant with regard to litigation expenses and so that she may remain in the station of life to which she has become accustomed during the marriage. i Date: I 'L/? /01? Respectfully submitted, BAYLEY & MANGAN Qark F. Bayl y, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Defendant ANDRES GALEANO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. No. 08 - 2114 CIVIL TERM AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: C? , I <C - Dl) L Mark F. Bayley, Esquire ANDRES GALEANO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. No. 08 - 2114 CIVIL TERM AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John F. King, Esquire 19 South Hanover Street Suite 103 Carlisle, PA 17013 A N JAI__? Cl/ 0 ? Mark F. Bayley, Esq ire ?/ Attorney for Defendant 2009 SEP I €3 JIM 2: ti U ,Tv ,z6?, 3a 77 ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA No. 08 - 2114 CIVIL TERM CIVIL ACTION -LAW : IN DIVORCE COUNTER-AFFIDAVIT UNDER 43301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree X _(b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): X (i) The parties to this action have lived separate and apart of a period of at least two years, but the disposition of the marital property is not complete. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. X (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. °V- lB-off LML Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.#87663 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. No. 08 - 2114 CIVIL TERM AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John F. King, Esquire 19 South Hanover Street Suite 103 Carlisle, PA 17013 ut/6T7) -? l Mark F. Bayley, Esquire Attorney for Defendant RL r" i J- "L' OF THE F ; iARY 2099 SEP 18 PH 2- v 0 4, t ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant IN DIVORCE MOTION TO WITHDRAW AND NOW, comes undersigned counsel and in support of the within motion avers as follows: 1. Undersigned counsel entered his appearance in the above captioned matter on behalf of Azure Galeano in May of 2008. 2. In consideration of receiving legal services from the undersigned Ms. Galeano agreed to commence a bi-weekly payment plan with bi-weekly payments set at a nominal amount. 3. Ms. Galeano made three payments and discontinued payments thereafter. 4. Undersigned counsel requested Ms. Galeano to recommence a similar payment plan in August of 2009. 5. Ms. Galeano made a couple of nominal payments and discontinued payments thereafter. 6. Ms. Galeano already carries a substantial unpaid balance with undersigned counsel and obviously is making little to no effort to pay for legal services. 7. Undersigned counsel recently filed economic claims on Ms. Galeano's behalf as well as a counter affidavit under Section 3301(d) of the Divorce Code which preserved said claims for the time being. 8. Undersigned counsel previously forwarded standard interrogatories/document requests to Plaintiffs counsel which have not yet been answered. 9. The matter is now in the discovery phase and stable; should the Court permit undersigned counsel to withdraw, Ms. Galeano will have plenty of time to retain other counsel without injury to her claims. WHEREFORE, undersigned counsel respectfully requests his appearance in relation to the above captioned matter to be vacated. Respectfully submitted, BAYLEY & MANGAN Date: o-zz?Mark F. Bayley, Es ire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. ? L) -- ark F. Bayley, quire ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the within Praecipe upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John F. King, Esquire 19 South Hanover St. Suite 103 Carlisle, PA 17013 Azure Galeano 576 Sweet Bay Hershey, PA 17033 ? D_ zo, C5--) Mark F. Bayley, E uire R 'r_) s s . 20691 OCT 21 fi'r' i I : 5 ? 2 2 2009 ANDRES GALEANO, : IN THE COURT OF COMMON PLEA'S OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA. V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this230( day of Q , 2009 a Rule is hereby issued on the Defendant, Azure Galeano, to show cause why her counsel's appearance should not be vacated. Said rule shall be returnable within twenty (20) days. Should Defendant fail to respond to the within Rule Defendant's counsel shall be permitted to withdraw upon motion to make Rule absolute. J. Distribution: /Mark F. Bayley, Esquire ,John F. King, Esquire ,,"Azure Galeano Cof DES macs, of T 4 V4)4fo' ,wv 20OCT F3 M 12 5 p ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, - Defendant IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Mark F. Bayley, Esquire, and in support of the within motion avers as follows: 1. Undersigned counsel filed a motion to withdraw on October 21, 2009. 2. The Honorable Edward E. Guido issued a Rule to Show Cause on October 23, 2009 made returnable within 20 days of said date. 3. Defendant has not responded to said rule to date. WHEREFORE, Undersigned counsel respectfully requests the Rule issued October 23, 2009 to be made absolute and for the underlying motion to withdraw to be granted. z ? vc? Date: )M/, aTvYark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: I Z /1q 1 Mark F. Bayley, Esquire Attorney for Defendant ANDRES GALEANO, Plaintiff V. AZURE GALEANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 08-2114 IN DIVORCE CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the within document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: John F. King, Esquire 19 South Hanover Street, Suite 103 Carlisle, PA 17013 Azure Galeano 576 Sweet Bay Hershey, PA 17033 I Z Mark F. Bayley, squire l 0 7 THE ? ; .A!! ,r•p; J??tF?? 2009 DEC 17 AN S: Og CUP -- -?? P N, SYLVIA?:? JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717) 258-4343, FAX (717) 422-5526 j ohnfkinglawg2mail.com ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE INVENTORY OF ANDRES GALEANO, PLAINTIFF Plaintiff, Andres Galeano, files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff, Andres Galeano, verifies that the statements made in this inventory are true and correct. Plaintiff, Andres Galeano, understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Andres Galeano, Plaintiff ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) I. Real Property (x) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( x ) 5. Checking accounts, cash ( x ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date) (X)19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits (x) 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: No. Description of Property Names of All Owners 1. Husband's 401(k) H 2. Household furnishings and personal property H and W 3. 1995 Saturn SL1 H and W 4. 1990 Buick Skylark H and W 5. Wachovia Bank checking and savings H 6. PNC Bank checking H 7. Commerce Bank checking H 8. PSECU savings H NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: No. Description of Property ( Reason for Exclusion PROPERTY TRANSFERRED No. Description of Property Date of Consideration Person to Whom Transfer Transferred LIABILITIES Item Description Names of Names of Number of Liability All Creditors All Debtors No. Description of Liability Names of All Creditors Names of all Debtors 1. 401(k) loan LeTort Trust H 2. VISA Embrace H 3. PSL I' National Bank of Liverpool H and W 4. VISA (4876) Aspire H 5. VISA (7036) Aspire w 6. Furnishing loan Jack's H and W 7. PSL Providian H and W ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Sharry Semans, hereby certify that on e. ?2l f x.009, I served a copy of the Plaintiff's Inventory by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Mark F. Bayley, Esq. Bayley & Mangan 17 W. South Street Carlisle, PA 17013 Sharry Semans FILEDh 2 i04 DLL, 22 Ail 8: 4 9 JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717) 258-4343, FAX (717) 422-5526 johnfkin lg aw(c 2mail.com ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINTIFF, ANDRES GALEANO I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ??)- ,L( /C ? ?k1 ,LZm Andres Galeano, Plaintiff INCOME: Employer: Address: Type of Work: Payroll Number: Pay Period (weekly, biweekly, etc.) Gross pay per pay period: Federal filing status: Itemized Payroll Deductions: Federal Withholding: Social Security: Local Wage Tax: State Income Tax: Retirement: Savings Bonds: Credit Union Life Insurance: Health Insurance: Other Net pay per pay period: Versatile Systems, Inc. 100 Sterling Parkway, Suite 307, Harrisburg, PA Computer Programmer/Consultant Bi-weekly $2,384.62 Head of Household $ 30.32 $ 137.64 $ 37.30 $ 71.57 $ 47.69 $ 1.01 $ 53.46 $ 312.06** $1,693.57 * * Medicare tax - $32.19; PA SUI/SDI Tax - $1.43; Spousal support - $112.62; DepCareFSA - $111.12; Lts - $2.00; 401k Loan - $52.70 Actual documentation of withholdings will be made available at trial, if necessary. OTHER INCOME: MONTHLY None. TOTAL INCOME $3,669.40 Net/Month EXPENSES MONTHLY Home: Mortgage/Rent $1,180.00 Maintenance $ Electric $ 100.00 Gas $ Oil $ Telephone $ 20.00 Water $ 50.00 Sewer $ Trash $ Employment: Public transportation $ Lunch $ 60.00 Uniforms $ Taxes: Real Estate $ Personal Property $ Other $ Insurance: Homeowners $ 22.00 Automobile $ 70.00 Life $ Accident $ Health $ Other $ Automobile: Payments $ Fuel $ 30.00 Repairs $ 30.00 Medical: Doctor $ 40.00 Dentist $ 5.00 Orthodontist $ Hospital $ 20.00 Medicine $ Glasses $ Unreimbursed medicals $ Education: Private school $ Parochial school $ College $ Religious $ Personal: Clothing $ 10.00 Food $ 380.00 Barber/hairdresser $ 35.00 Credit payments $ 75.00 Charge accounts $ Memberships $ Loans: $ 75.00 Miscellaneous: Household help $ Child care $ 353.00 Papers/books/magazines $ Entertainment $ 40.00 Pay TV $ Vacation $ Gifts $ Legal fees $ 180.00 Charitable contributions $ 10.00 Child support $ Spousal support $(pd out of paycheck) Other - children's allowances $ 30.00 TOTAL EXPENSES $ 2,815.99 CERTIFICATE OF SERVICE I, Sharry Semans, hereby certify that on ?? ?4 2009, I served a copy of ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE the Plaintiff's Income and Expense Statement by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Mark F. Bayley, Esq. Bayley & Mangan 17 W. South Street Carlisle, PA 17013 Sharry Semans ALEL? f.: 2009 0E-C 22 A i C; 4 J CL?U _ s t r-; , DEC 1 8 20090 6 J ANDRES GALEANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-2114 AZURE GALEANO, Defendant : IN DIVORCE ORDER OF COURT AND NOW, this a 14day of , 2009, upon Defendant's failure to respond to the Rule to Show Cause issued October 23, 2009, said rule is hereby made absolute. The motion to withdraw by Mark F. Bayley, Esquire, is granted and his appearance on behalf of the defendant in relation to the above captioned matter is hereby vacated. Judge Edward E. Guido Di-ibution: ,/ k Bayley, Esquire Jo King, Esquire Azure Galeano en.at rFILED- IF THE r; r!'-'rW -0TARY ?H9 DEC 22 A 11: 5 9 ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE ?i Z a MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a master with respect to the following claims: o fo (x) Divorce (x) Distribution of Property O Annulment O Support (x) Alimony () Counsel Fees (x ) Alimony Pendente Lite () Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant has appeared in the action personally (her atty Mark Bayley was granted leave to withdraw) (3) The Statutory ground(s) for divorce (is)(are)3 3 01 (c)(d) (4) Delete the inapplicable paragraph(s): The action is not contested. b. An agreement has been reached with respect to the following claims* C. The action is contested with respect to the following claims: equitable distribution and alimony (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take _4_ hours. (7) Additional information, if any, relevant to the motion: Defendant has not yet filed her Inventory or Income and Expense Statement. Date: January 4, 2010 L2.L? 6 F. King, Esq. #61919 Attorney for Plaintiff ORDER APPOINTING MASTER AND NOW, January , 2010,. , Esq. is appointed master with respect to the following claims: By the Court: ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this 5`h day of January, 2010, serving the foregoing motion for appointment of master upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail addressed as follows: Azure D. Galeano 63 Roosevelt Drive Bethpage, NY 11714 harry Semans Cam' ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term a? AZURE D. GALEANO, CIVIL ACTION -LAW i, Defendant IN DIVORCE - MOTION FOR APPOINTMENT OF MASTER ?s Plaintiff moves the court to appoint a master with respect to the following claims: o N (x) Divorce (x) Distribution of Property O Annulment O Support (x) Alimony O Counsel Fees (x) Alimony Pendente Lite () Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant has appeared in the action personally (her atty Mark Bayley was granted leave to withdraw) (3) The Statutory ground(s) for divorce (is)(are)3301(c)(d) (4) Delete the inapplicable paragraph(s): a. The action is not eoirtested. agreemen! has been reached with respect to the following c! C. The action is contested with respect to the following claims: equitable distribution and alimony (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take _4_ hours. (7) Additional information, if any, relevant to the motion: Defendant has not yet filed her Inventory or Income and Expense Statement. 34N 0 7 2010 u f?; Date: January 4, 2010 4LG? F. King, Esq. #61919 Attorney for Plaintiff ORDER APPOIN ING MASTER AND NOW, January -j-4 , 2010, , Esq. is apl8inted master with respect to the following claims: By the Cou OD N 01 {J m ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this 5`h day of January, 2010, serving the foregoing motion for appointment of master upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail addressed as follows: Azure D. Galeano 63 Roosevelt Drive Bethpage, NY 11714 `harry Semans JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 FAX (717) 695-2207 johnfkin lg aw& mail.com Attorney for Plaintiff Fll_?? U fu .: E 7 i i 3: 16 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT Date of marriage: November 9, 1997 Date of separation: July 25, 2007 Three children: Kerry, DOB: 08/14/1997; Abigail, DOB: 10/17/2000; Zachary, 08/30/05 Plaintiff/Father has primary physical custody of the children I. Assets Marital Assets Item Value Notes Husband's 401(k) As of 9/30/07 $28,822 1995 Saturn SLI $1,000 H possession; joint title 1990 Buick Skylark $1,000 W possession; joint title Personalty Unknown Already divided II. Expert Witnesses None III. Witnesses (Other than the Parties) None, at this time. Plaintiff reserves the right to supplement. IV. Exhibits 1. Plaintiffs Income and Expense statement 2. Plaintiff s Inventory 3. Copy of Plaintiff s 2008 tax return 4. Copy of Retirement Plan Account Statement from 7/01/07 to 09/30/07 5. List of household furnishings in Plaintiff s possession V. Income Husband's gross monthly income is approximately $4,000.00 VI. Expenses (monthly) $2,815.99 (see Expense Statement, Exhibit 1) VII. Pension/Retirement Benefits See Exhibit 4 VIII. Tangible Property See attached list of personal property in Plaintiffs possession, Exhibit 5 IX. Marital Debts Item Amt Owed as of 07/25/07 (DOS) Notes 401(k) loan $4,720.93 Husband is paying Embrace Visa $2,365.62 Husband is paying 1" National Bank of Liverpool $2,113.95 Husband is paying Aspire Visa (ending 4876) $ 696.79 Husband is paying Aspire Visa (ending 7036) $ 536.44 Husband is paying Jacks Home Furnishing $ 550.00 Husband is paying Providian Bank $2,803.30 Husband is paying TOTAL $13,787.03 X. Proposed Resolution 1. Each party to keep assets and personal property now in their possession or control 2. Husband to be responsible for all marital debts 3. Husband's 401(k) to Husband 4. Each party to pay their own counsel fees and costs 5. Spousal support to terminate upon entry of the Divorce 6. The parties shall be divorced from the bonds of matrimony pursuant to 3301(d) XI. Miscellaneous Defendant has not filed either her Income and Expense Statement or Inventory. It should also be noted that Defendant has been aware of the Master's hearing since January 7, 2010, when she called Plaintiff's counsel office seeking legal advice regarding the hearing. The Defendant has been informed that she must contact her own attorney. It should also be noted that on or about March 3, 2010, Defendant contacted Plaintiff and stated that she would be moving to California soon. Plaintiff asked Defendant what she would be doing about the upcoming Master's hearing and her response was that she didn't really know and maybe she would get an attorney. This cavalier attitude should be noted by the Master in considering any continuances. Dated: March 2010 Respectfully submitted, JO G ? .,-P.C. By: ohn F. King, Es D# 61919 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 Attorney for Plaintiff EXHIBIT #I JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717) 258-4343, FAX (717) 422-5526 iohnfkin 71 - ,gmail.com ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant p o IN THE COURT OF CONEVON PLEAS - CUMBERLAND : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINTIFF, ANDRES GALEANO I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: C 7 Andres Galeano, Plaintiff INCOME: Employer: Address: Type of Work: Payroll Number: Pay Period (weekly, biweekly, etc.) Gross pay per pay period: Federal filing status: Itemized Payroll Deductions: Federal Withholding: Social Security: Local Wage Tax: State Income Tax: Retirement: Savings Bonds: Credit Union Life Insurance: Health Insurance: Other Net pay per pay period: Versatile Systems, Inc. 100 Sterling Parkway, Suite 307, Harrisburg, PA Computer Programmer/Consultant Bi-weekly $2,384.62 Head of Household $ 30.32 $ 137.64 $ 37.30 $ 71.57 $ 47.69 $ 1.01 $ 53.46 $ 312.06** $1,693.57 * * Medicare tax - $32.19; PA SUI/SDI Tax - $1.43; Spousal support - $112.62; DepCareFSA - $111.12; Lts - $2.00; 401k Loan - $52.70 Actual documentation of withholdings will be made available at trial, if necessary. OTHER INCOME: MONTHLY None. TOTAL INCOME $3,669.40 Net/Month EXPENSES Home: Mortgage/Rent Maintenance Electric Gas Oil Telephone Water Sewer Trash Employment: Public transportation Lunch Uniforms Taxes: Real Estate Personal Property Other Insurance: Homeowners Automobile Life Accident Health Other Automobile: Payments Fuel Repairs Medical: Doctor Dentist Orthodontist Hospital Medicine Glasses Unreimbursed medicals MONTHLY $1,180.00 $ 100.00 $ $ 20.00 50.00 $ 60.00 $ 22.00 $ 70.00 $ 30.00 $ 30.00 $ 40.00 $ 5.00 $ 20.00 Education: Private school $ Parochial school $ College $ Religious $ Personal: Clothing $ 10.00 Food $ 380.00 Barber/hairdresser $ 35.00 Credit payments $ 75.00 Charge accounts $ Memberships $ Loans: $ 75.00 Miscellaneous: Household help $ Child care $ 353.00 Papers/books/magazines $ Entertainment $ 40.00 Pay TV $ Vacation $ Gifts $ Legal fees $ 180.00 Charitable contributions $ 10.00 Child support $ Spousal support $(pd out of paycheck) Other - children's allowances $ 30.00 TOTAL EXPENSES $ 2,815.99 ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Sharry Semans, hereby certify that on Lr 2009, I served a copy of the Plaintiff's Income and Expense Statement by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Mark F. Bayley, Esq. Bayley & Mangan 17 W. South Street Carlisle, PA 17013 •t Sharry Semans EXHIBIT #2 } JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717) 258-4343, FAX (717) 422-5526 johntkin lawggniail.com ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant t-7 ED -d ..D -• IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE INVENTORY OF ANDRES GALEANO, PLAINTIFF Plaintiff, Andres Galeano, files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff, Andres Galeano, verifies that the statements made in this inventory are true and correct. Plaintiff, Andres Galeano, understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Andres Galeano, Plaintiff ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) I. Real Property ( x) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( x) 5. Checking accounts, cash ( x) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date) ( x )19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( x ) 24. Debts due, including loans, mortgages held ( x ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: No. Description of Property Names of All Owners 1. Husband's 401(k) H 2. Household furnishings and personal property H and W 3. 1995 Saturn SLI H and W 4. 1990 Buick Skylark H and W 5. Wachovia Bank checking and savings H 6. PNC Bank checking H 7. Commerce Bank checking H 8. PSECU savings H NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: No. Description of Property I Reason for Exclusion PROPERTY TRANSFERRED No. Description of Property Date of Consideration Person to Whom Transfer Transferred LIABILITIES Item Description Names of Names of Number of Liability All Creditors All Debtors No. Description of Liability Names of All Creditors Names of all Debtors 1. 401(k) loan LeTort Trust H 2. VISA Embrace H 3. PSL 1' National Bank of Liverpool H and W 4. VISA (4876) Aspire H 5. VISA (7036) Aspire w 6. Furnishing loan Jack's H and W 7. PSL Providian H and W ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Sharry Semans, hereby certify that on C'„ 2009, I served a copy of the Plaintiff's Inventory by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Mark F. Bayley, Esq. Bayley & Mangan 17 W. South Street Carlisle, PA 17013 mil/' Sharry Semans EXHIBIT #3 Form Department of the Treasury-Internal Revenue Service 1040A U.S. Individual Income Tax Return pq) 2008 IRS Use Only--Do not write or staple In this space Label Your Brat name and Mlal Last name OMB No. 1545-0074 (See page 17.) L Your social security number A B Andres Galeano ism 8348 E If a joint return, spouse's first nerve and kWA Last name Spouse's social security msnber Use the L IRS label. p E H Home address (number and street). H you have a P.O. box, am page 17. 2 APt ?• You must artier . . please rint please print E 3 5 Liberty Ct your SSN(s) above. or type- town or poet once, state, and DP code. M you have a toreiggn address, Bee pays 17. r Prentia Mhanicsburg PA 17050 Checking a box below will not change your tax or refund. Election Campaign Check here if you, or your spouse if filing jointly, want $3 to go to this fund (see page 17) ? ? You ? Spouse Filing 1 ? Single 4 Q Head of household (with qualifying person). (See page 18.) Status 2 ? Married filing jointly (even if onl?xone had income) If the qualifying person is a child but not your dependent, Check only 3 ? Married filing separately. Enter spouse's SSN above and enter this child's name here. ? one box. full name here. ? 5 ? Qualifying widow(er) with dependent child (see page 19) Q Exemptions If more than six dependents, see page 20. 6a Yourself. If someone can claim you as a dependent, do not check box 6a. b ? Spouse c Dependents: {1) First name Last name (2) Dependent's social security number (A Dependent's relat tp to YOU (4) tf qualifyin child for child tax credit (see pa 20) ,Kerry Grace Galeano ? 8168 Daughter Abigail Leigh Galeano 40 :40 8377 Daughter Zachary Reed Galeano r ' 4933 Son Q Boxes checked on 1 So and ab No. of children on Sc who: Lived with 3 YOU e did not We with you doe to divorce or (see page 21 g on ec not 0 entered above _ Add m.r"re d Total number of exemptions claimed. N 4 Income Attach 7 Wages, salaries tips. etc. Attach Forms W-2. 7 54058 92 Form(s) W-2 here. Also Sa Taxable interest. Attach Schedule 1 if required. 8a 0 00 attach b Tax-exempt interest. Do not include on line 8a. 8b Form(s) 9a Ordinary dividends. Attach Schedule.1 H required. 9a 0 00 1099-R N tax b Qualified dividends (see page 24). 9b was withheld. 10 Capital gain distributions (see page 24) . 10 0 00 If you did not yet a W-2 see 11 a IRA 11 b Taxable amount , page 23 23. . distributions. 11a 0 00 (see page 24). 11 b 0 00 Enclose but do 12a Pensions and 12b Taxable amount , not attach, any annuities. 12a 0 00 (see page 25). 12b 0 00 payment 13 Unemployment compensation and Alaska Permanent Fund dividends . 13 0 00 14a Social security 14b Taxable amount benefits. 14a 0 00 see page 27). 14b 0 00 15 Add lines 7 through 14b (far right column). This is your total income ? 15 0 Adjusted . 00 gross 16 Educator expenses (see page 29). 16 0 00 income 17 IRA deduction (see page 29). 17 0 00 18 Student loan interest deduction (see page 31). 18 0 00 19 Tuition and fees deduction. Attach Form 8917. 19 0 00 20 Add lines 16 through 19. These are our total adjustments. 20 0 00 21 Subtract line 20 from line 15. This is your adjusted ross incom ? 21 g e. 54058 92 For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 78. Cat. No. 11327A Form 1040A (2008) Form 1040A (2008) Tax, credits, and payments standard Deduction for- 0 People who checked any box on line 23a, 23b, or 23c or who can be claimed as a dependent, see page 32. • All others: Single or Married filing separately, $5,450 Marred filing jointly or Qualifying widow(erj, $10,900 Head of household, $8,000 If you have a qualifying child, attach Schedule b Nontaxable combat a election. 40b EIC. 41 Additional child tax credit. Attach Form 8812. 41 42 Recovery rebate credit (see worksheet on pages 53 and 54). 42 _ 43 Add lines 38, 39, 40a, 41, and 42. These are our total pal Refund Direct 44 45a If line 43 is more than line 37, subtract line 37 from line 43. This is the amount you overpaid. Amount of line 44 you want refunded to you If Form 8888 is attache deposit? , Seepage 55 0, b Routing and fill in number Do- C Type: ® Checking El Savings 45b, 45c, 00- d Account and 45d or number Form 8888. 46 Amount of line 44 you want applied to your 2009 estimated tax. 46 0 00 0 00 00- 43 44 1110- n 45a 0 00 44 883 46 883146 Amount 47 Amount you owe. Subtract line 43 from line 37. For details on how you owe to a see page 56. 00- 47 0 00 48 Estimated tax penalty see page 57). 48 Third party Do you want to allow another person to discuss this return with the IRS (see page 57)? ?Yes. Complete the following. ?No designee Designee's Phone Personal identification name 110- no. 01. ( ) number (PIN) ? Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of rrry knowledge and belief, they are true, correct, and accurately list all amounts and sources of income I received during the tax year. Declaration here of preparer (other than the taxpayer) is based on all information of which the preparer has any knowledge. Joint return? Your signature Date Your occupation Daytime phone number See page 17. Computer Programmer (717) 790-9039 Keep a copy for your Spouse's signature. If a joint return, bath must sgn. Date Spouse's occupation records. Paid Preparers, Date Preparer's SSN or PrIN signature Check i ? preparer's Firm's name (or ff-Mbyed use only yours if self-employed), EIN address, and ZIP code Phone no. ( ) 22 Enter the amount from line 21 (adiusted gross income). 23a Check ? You were bom before January 2, 1944, ? Blind Total boxes 0 if t Spouse was bom before January 2, 1944, ? Blind } checked ? 23a b If you are married filing separately and your spouse itemizes deductions, see page 32 and check here No- 23b ? c Check if standard deduction includes real estate taxes (see Dane 321 No- 23c Page 2 5405s792 24 Enter our standard deduction see left margin). 24 8000 00 25 Subtract line 24 from line 22. If line 24 is more than line 22, enter -0-. 25 46058 92 26 If line 22 is over $119,975, or you provided housing to a Midwestern displaced individual, see page 32. Otherwise, multiply $3,500 by the total number of exemptions claimed on line 6d. 26 14000 00 27 Subtract line 26 from line 25. If line 26 is more than line 25, enter -0-. This is our taxable income. ON- 27 32058 92 28 Tax including an alternative minimum tax see page 33). 28 4239 00 29 Credit for child and dependent care expenses. Attach Schedule 2. 29 600 02 30 Credit for the elderly or the disabled. Attach Schedule 3. 30 0 00 31 Education credits. Attach Form 8863. 31 0 00 32 Retirement savings contributions credit. Attach Form 8880. 32 0 00 33 Child tax credit (see page 37). Attach Form 8901 if required. 33 3000 00 34 Add lines 29 through 33. These are our total credits. 34 3600 02 35 Subtract line 34 from line 28. If line 34 is more than line 28, enter -0-. 35 638 98 36 Advance earned income credit payments from Form(s) W-2, box 9. 36 0 00 37 Add lines 35 and 36. This is your total tax. 10- 37 638 98 38 Federal income tax withheld from Forms W-2 and 1099. 38 1522 44 39 2008 estimated tax payments and amount applied from 2007 return. 39 0 00 40a Earned income credit EIC . 40a 0 00 Form 1040A (2008) Schedule 2 Department of the Treasury-Internal Revenue Service (Form 1o4oA) Child and Dependent Care Expenses for Form 1040A Filers (99) 2008 OMB No. 1545-0074 Name(s) shown on Fonn 1o4oA Your social sec uty number Part I (a) Care provider's (b) Address (number, street, apt. no., (c) Identifying (d) Amount paid 1 name city, state, and ZIP code) number (SSN or EIN) (see instructions) Persons or 718 Hogestovn_v__Road _ organizations pie Dumpling Gan Mechanicsbu PA 1-7-0-5 83-0394214 4138 50 who provided 410 Fallowfield Road the care West Shore YMCA Cam Hill PA 17011 23-1665437 2462 00 You must (If you have more than two care providers, see the instructions.) complete this No = 1- Complete only Part II below. part. Did you receive dependent care benefits?Yes ----0, Complete Part III on the back next. Caution. If the care was provided in your home, you may owe employment taxes. If you do, you must use Form 1040. See Schedule H and its instructions for details. Part II 2 Information about your qualifying person(s). If you have more than two qualifying persons, see the instructions. Credit for child and dependent care expenses For Paperwork Reduction Act Notice, see Form 1040A instructions. (a) Qualifying person's name (b) Qualifying person's social (c) Qualified expenses you incurred and paid First Last security number in 2008 for the person listed in column a Zachary Reed Galeano S 4933 1138 62 Abigail Leigh Galeano 8377 1231 00 3 Add the amounts in column (c) of line 2. Do not enter more than $3,000 for one qualifying person or $6,000 for two or more persons. If you completed Part III, enter the amount from line 27. 3 3000 12 4 Enter our earned income. See the instructions. 4 54058 92 5 If married filing jointly, enter your spouse's earned income (if your spouse was a student or was disabled, see the instructions); all others, enter the amount from line 4. 5 54058 92 6 Enter the smallest of line 3, 4, or 5. 6 3000 12 t anuer the amount rrom r-orm 1 u4uA, line zz. f 540581 92 8 Enter on line 8 the decimal amount shown below that applies to the amount on line 7. If line 7 is: H line 7 is: But not Decimal But not Decimal Over over amount is Over over amount is $0-15,000 .35 $29,000-31,000 .27 15,000-17,000 .34 31,000-33,000 .26 17,000-19,000 .33 33,000-35,000 .25 19,000-21,000 .32 35,000-37,000 .24 21,000-23,000 .31 37,000-39,000 .23 23,000-25,000 .30 39,000-41,000 .22 25,000-27,000 .29 41,000-43,000 .21 27,000-29,000 .28 43,000-No limit .20 8 X , 20 9 Multiply line 6 by the decimal amount on line 8. If you paid 2007 expenses in 2008, see the instructions. 9 600 02 10 Enter the amount from Form 1040A, line 28. 10 4239 00 11 Credit for child and dependent care expenses. Enter the smaller of line 9 or line 10 here and on Form 1040A, line 29. 11 son Cat. No. 107491 schedule 2 (Form 1040A) 2008 Schedule 2 (Form 1040/) 2006 Part 111 12 Enter the total amount of dependent care benefits you received for 2008. This amount should be shown in box 10 of your Form(s) Dependent W-2. Do not include amounts that were reported to you as wages care benefits in box 1 of Form(s) W-2 Page 2 12 29991 88 13 Enter the amount, if any, you carried over from 2007 and used in 2008 during the grace period. See the instructions. 13 0 00 14 Enter the amount, if any, you forfeited or carried forward to 2009. See the instructions. 14 ( 0 00) 15 Combine lines 12 through 14. See the instructions. 15 29991 88 16 Enter the total amount of qualified expenses incurred in 2008 for the care of the qualifying person(s). 16 6600 50 17 Enter the smaller of line 15 or 16. 17 2999 18 Enter your earned income. See the instructions. 18 540581 92 19 Enter the amount shown below that applies to you. • If married filing jointly, enter your spouse's earned income (if your spouse was a student or was disabled, see the instructions for line 5). • If married filing separately, see the instructions for the amount to enter. • All others, enter the amount from line 18. 19 54058 I 92 20 Enter the smallest of line 17, 18, or 19. 20 29991 88 21 Excluded benefits. Enter here the smaller of the following: • The amount from line 20, or • $5,000 ($2,500 if married filing separately and you were required to enter your spouse's earned income on line 19). 21 88 22 Taxable benefits. Subtract line 21 from line 15. Also, include this amount on Form 1040A, line 7. In the space to the left of line 7, enter "DCB." 22 0 00 To claim the child and dependent care credit, complete lines 23 through 27 below. 23 Enter $3,000 ($6,000 if two or more qualifying persons). 23 6000 00 24 Enter the amount from line 21. 24 2999 88 25 Subtract line 24 from line 23. If zero or less, stop. You cannot take the credit. Exception. If you paid 2007 expenses in 2008, see the instructions for line 9. 25 3000 12 26 Complete line 2 on the front of this schedule. Do not include in column (c) any benefits shown on line 21 above. Then, add the amounts in column (c) and enter the total here. 26 3600 62 27 Enter the smaller of line 25 or 26. Also, enter this amount on line 3 on the front of this schedule and complete lines 4 through 11. 27 3000 12 Schedule 2 (Form 1040A) 2008 Andres Galeano 169 64 8348 Addendum for Form 1040A Schedule 2 2008 "Child and Dependent Care Expenses form Form 1040A Filers" Part II 2) (a) Qualifying person's name (b) Qualifying person's (c) Qualified expenses First Last SSN Kerry Grace Galeano 40954OW 8168 1231.00 ?f EXHIBIT #4 Versatile Systems, Inc. 401(k) Plan Andres Ga.leano 401 Independence Ct Mechanicsburg PA 17050 Retirement Plan Account Statement From 7/01/07 to 9/30/07 Date Of Birth 2/24/1977 Date Of Hire 1012412001 Date Of Termination Rehired This statement has not been audited. Please review your account and report any errors to the Plan Administrator within 30 days. For account or investment information, please contact: Beginning Balance 27,141.59 LeTort Management & Trust at 717-761-7626.--' Change This Period 1,680.91 Ending Balance 28,822.50 Vested Balance 28,822.50 Beginning Contributions & Payments & Ending Vested Investment Balance Forfeitures Withdrawals Transfers Gain or Loss Balance Percent Managed Investment Portfolio 22 789.14 1,292.28 0.00 316.20 317.51 24,715.13 Participant Loan 4352.45 0.00 0.00 -316.20 71.12 4,107.37 Total Balance 27.141.59 1,292.28 0.00 0.00 388.63 28,822.50 Total Balance 27,141.59 1,292.28 0.00 0.00 388.63 28,822.50 S13r1RI PRICES L- IN\ LST11l_?\ T .Af.I J)C170V17 FAD 01= 111 R1OI? Price Per Allocation Investment Shares Share Percentage Managed Investment Portfolio 24,715130 1.00 1000/0 'articinant Loan 4.107.370 1.00 00/0 LeTort Management & Trust Company www.letorttwt.com EXHIBIT #5 Response to Interrogatories/Document Request #7 Vehicles: 1995 Saturn SLi Value about $1,000.00 Purchased around 2003 or so. Jointly owned In Andres Galeano's possession. 1990 Buick Skylark Value about: $1,000.00 Purchased around 2005 or so. Jointly owned. In Azure Galeano's possession. Living Room: Sofa and Love Seat Value about: $200.00 Purchased around 2003 or so. Jointly owned In Andres Galeano's possession. Television 1 Value about: $50.00 Purchased around 2003 or so. Jointly owned. In Andres Galeano's possession (Untill tube burnt out). Television 2 Value about: $50.00 Purchased around 2003 or so. Jointly owned. In Azure Galeano's possession. Television Furniture Value about: $50.00 Purchased around 2001 or so. Jointly owned In Andres Galeano's possession. Stand-up Piano Value about: $200.00 Purchased around 1996 or so. (Prior to marriage.) Jointly owned. In Andres Galeano's possession. Dinning Room: Table and Chair set Value about: $200.00 Purchased around 2003 or so. Jointly owned In Andres Galeano's possession. Kitchen: Silverware, Pots, Pans, small appliances(blender, mixer, toaster, coffepot) Value about: $50.00 Purchased around 1998 or so. Jointly owned. In Andres Galeano's possession. Microwave Value about: $30.00 Purchased around 2001 or so. Jointly owned In Azure Galeano's possession. Slow Cooker Value about: $50.00 Purchased around 2001 or so. Jointly owned. In Azure Galeano's possession. Kerry & Abby's Bedroom: Bunks Beds Value about: $50.00 Purchased around 2002 or so. Jointly owned. In Andres Galeano's possession. Zachary's Bedroom: Baby Crib Value about: $50.00 Purchased around 2001 or so. Jointly owned In Andres Galeano's possession. Rocking Chair with foot stool Value about: $25.00 Purchased around 2001 or so. Jointly owned. In Andres Galeano's possession. Master Bedroom: Two desk computers, plain printer, photo printer, 1 Monitor Value about: $150.00 Purchased around 2002 or so. Jointly owned. In Andres Galeano's possession, (Until one computer died, and one monitor died.) Digital Camera Value about: $100.00 Purchased around 2003 or so. Jointly owned. In Azure Galeano's possession. Digital Camcorder Value about: $150.00 Received around 2005 or so. Jointly owned. In Andres Galeano's possession. Bed Value about: $200.00 Purchased around 2003 or so. Jointly owned. In Andres Galeano's possession. Bedroom Dreser, Breau with Mirror, Nightstand, Headboard Value about: $100.00 Purchased around 2001 or so. Jointly owned. In Andres Galeano's possession. Azure's Jewlery Value about: $200.00 Purchased around 2001 or so. Jointly owned. In Azure Galeano's possession. Azure's Clothes Value about: $100.00 Purchased from 1997-2005 or so. Jointly owned. In Azure Galeano's possession. Andres's Clothes Value about: $50.00 Purchased from 1997-2005 or so. Jointly owned. In Andres Galeano's possession. ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE Q .J CERTIFICATE OF SERVICE _ J 1, Sharry Semans, hereby certify that on September 1, 2009,1 served; a c6 o£4 the Plaintiff's 3301(d) Affidavit by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: Mark F. Bayley, Esq. Bayley & Mangan 17 W. South Street Carlisle, PA 17013 JIM 1;,4- Sharry Se a s ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this 5`' day of January, 2010, serving the foregoing order and notice setting hearing upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail Certified Restricted Delivery #7006-0100-0005-1039-9290 addressed as follows: Azure D. Galeano 43-100 Palm Royal Apt. 621 LaQuinta, CA 92253 A&t?' 4_Aa_,? Sharry Semans C3 Ir ru tr Ir m 0 r-q Ln a 0 C3 0 C3 r9 C3 r0 O C3 N ¦ Complete items 1, 2, and 3. Also complete m 4 if Restricted Deliveryis desired. ¦ f nt your ne d address on the revthat we retum the rd to you. sch this to the back of the maipon the front if space permits. 1. Article Addressed to: 1 P (r 0/0 C? z2-S 3 ? Agent C. D. Is delivery address different from Item litem 1 If YES, enter delivery address below: ? No 3. Service Type HD,CiQMed Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) EL-yes- 2. Article Number (Transfer from service fate 7006 010 0 0005 103,9 9290 PS Form 3811, February 2004 Domestic Return Receipt _ 102585.02-M-1540 C) G CI F- -ter)..'. i. y -+- 7 C _ 0 CX) Andres Galeano : In The Court of Common Pleas of the : 9't' Judicial District of Pennsylvania Plaintiff : Cumberland County Branch V. NO. 08-2114 Azure D. Galeano : Civil Action - Law Defendant : In Divorce Praecipe for Entry of Appearance To the Prothonotary: Kindly enter my appearance on behalf of Defendant Azure D. Galeano. Papers may be served at the address set forth below. Christopher J. Basner, Esquire Attomev for Defendant Azure D. Galeano Zi N 205985 cl) ' Supreme Court Identification Number c: < Christopher J. Basner P. C. c Firm rrv 341 Market Street Street Address Newport, PA 17074 City, State, Zip Code (717) 567-6993 Telephone Number Date: August 25, 2010 Signature CC File John F. King, Esq. ANDRES GALEANO, IN THE COURT OF COMMON PLE NNS*A A Plaintiff : CUMBERLAND COUNTY, PE V. NO. 08-2114 Civil Termw AZURE D. GALEANO, = CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Compl aint in Divorce under Section 3301(c) of the Divorce Code was filed on April 2, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. DATED: S ! .2Q f Andres Galeano ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSY6VANIA v. NO. 08-2114 Civil Term r? CIVIL ACTION -LAW GALEANO D , . AZURE Defendant IN DIVORCE Ch WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A ::? TJ:k DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a Divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 3? ?O 1 L1 'l ?? a... C- Andres Galeano, Plaintiff ANDRES GALEANO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. n NO. 08-2114 Civil Term c ?n m? ? ? AZURE D. GALEANO, CIVIL ACTION - LAW -T4 - Defendant IN DIVORCE C, 3? ?I :-« AFFIDAVIT OF CONSENT c-n 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 2, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. DATED: .l k? A e D. Weano ANDRES GALEANO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-2114 Civil Term c n F AZURE D. GALEANO, CIVIL ACTION -LAW 7 Defendant IN DIVORCE ` (TS +? WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF 4 c-n Q DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a Divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: S" - 31 - I L CA, A4 re D. 0 lean, Defendant ANDRES GALEANO, Plaintiff vs. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 21.14 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of yr?? 2010, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on August 31„ 2010, the date set for a Master's hearing, the agreement and stipulation having been transcribed and signed by the parties, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe ':o transmit the record with the affidavits of consent and waivers of the parties so that a final decree in divorce can be entered. cc: John F. King, Jr. At orney for Plaintiff Christopher J. Basner Attorney for Defendant BY THE COURT, / r Kevin A. Hess, P.J. 't? 1.37 .-?1 1 l . ei -T1' ANDRES GALEANO, Plaintiff VS. AZURE I). GALEANO, Defendant THE MASTER: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2114 CIVIL C7 .1 C x 7'2 Y IN DIVORCE r . ... ...a _ i Today is Tuesday, August'', -33 2010. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Andres Galeano, and his counsel. John F. King, Jr., and the Defendant, Azure D. Galeano. Her counsel, Christopher J. Basner is on the telephone listening to the proceedings and will be hearing the statement of the agreement on the record. This action was commenced by the filing of a complaint in divorce on April 2, 2008. The complaint raised grounds for divorce of irretrievable breakdown of the marriage. Both parties have signed affidavits of consent and waivers of notice of intention to request entry of divorce decree today. The affidavits and waivers will be filed by the Master's office with the Prothonotary's office. The divorce can, therefore, conclude under Section 3301(c) of the Domestic Relations Code. An answer, new matter, and counterclaims were filed by the Defendant on September 18, 2009. The 1 counterclaims raised by the Defendant are alimony and alimony pendente lite. No claim has been raised by either party for counsel fees and costs. The counterclaim does not specifically raise counsel fees and costs; however, a request: for counsel fees and costs is made in the wherefore clause of the claim for equitable distribution, and a request for litigation expenses in the claim for alimony. It is the Master's understanding that the claims for alimony and counsel fees are going to be specifically withdrawn and that withdrawal will be stated in the agreement. An agreement is going to be placed on the record in the presence of the parties and counsel. The agreement as stated on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties leave the hearing room today, they are bound by the terms of the agreement even though they do not subsequently sign the agreement affirming the terms of settlement as stated on the record. However, the Master has discussed with counsel and the parties the method of having a review of the agreement and we have decided that after the agreement is transcribed today, the parties and Mr. King will return to review the agreement for typographical errors, make any corrections as 2 necessary, and the parties will be asked to affix their signatures affirming the terms of settlement. We are going to fax a copy of the transcribed agreement to Mr. Basner for his review prior to his client signing. The parties were married on November 9, 1997, and separated on July 25, 2007. They are the natural parents of three children, all of whom are in the custody of the Plaintiff, father. Mr. King. MR. KING: These are the terms of the marital settlement agreement that have been agreed to by the parties: 1. The parties agree that there is one marital asset of note other than the personalty. That asset is husband's 401(k) account. The parties agree that the value of that 401(k) account at the date of separation was $24,715.00. The parties agree that husband's 401(k) shall be divided, that being the aforementioned value, 50% to each party. The parties agree that wife's share shall be distributed by way of a roll over to a qualified account created and identified by wife. If required by the plan administrator, the QDRO shall be prepared by husband and submitted for review by the plan administrator prior to submittal to the Court for signature. Husband shall prepare the QDRO, if required by the plan administrator, no later than thirty (30) days from today's date, August 31, 2010, and then shall immediately forward that QDRO for approval by the plan administrator. 2. The parties have also reached an agreement regarding the personalty which was acquired during the marriage. The parties have agreed to distribute to wife t=hese particular items that are identified on a six-page document which we will mark and have affixed hereto as Joint Exhibit No. 1. This exhibit lists a number of items, and other than those items that have the word "no" written beside them, they shall be distributed to wife. There are several items that have the word "exists" with question marks and regarding 3 those items there will be a determination whether or not they are actually still present at the marital residence and if they are, wife shall receive them. The parties have also agreed that wife shall remove said personalty within a single one weekend period, that period consisting of a Saturday from 8:00 a.m. until 6:00 p.m. and Sunday, the next day, from 8:00 a.m. until 6:00 p.m. That weekend period shall be identified by wife and wife shall give husband at least a five (5) day notice period prior to the commencement of that weekend period. It is further agreed that the items shall be removed no later than October 31, 2010, which effect_vely gives wife a two month time period in which to schedule the weekend. The parties further agree that should any of the items which were identified on the joint exhibit: not be removed prior to the terminal date identified herein of October 31, 201.0, those items shall then become the sole property of husband. 3. The parties have also agreed that there is a particular set of personalty that is at issue, that being certain pieces of jewelry that have been identified by wife in the joint exhibit. During the weekend period, to be identified by wife, she shall be given access to all of the boxes that are stored in the basement of husband's residence for the purpose of performing a search for said jewelry. The parties agree that any and all pieces of jewelry found by wife as identified on the joint exhibit, shall be taken by wife and shall become wife's sole property. In addition,, during --hat search, if wife should find a certain antique clock which is identified on the joint exhibit, that shall also be taken by wife and become her sole property. 4. Wip=e agrees to withdraw her claim for alimony and alimony pendente lite and in addition has agreed that any claim which may have been raised relating -to counsel fees or cost of litigation shall also be withdrawn. 5. Regarding marital debt, the parties have agreed that any remaining marital debt or any marital debt that was in existence at the time of separation shall be the responsibility of husband. The parties further agree that neither party has any responsibility for debt incurred by the other post-separation. THE MASTER: Mr. Basner, before Mr. King 4 reads this one statement on the record about the waiver of interest in estates, do you have any comments or additions or questions about the agreement as placed on the record? MR. BASHER: My only comment is that intially you had stated that Mr. Galeano has custody of the children. I think just to clarify, although it may not be legally necessary, that this order is not intended to supercede any custody order. THE MASTER: I don't think that is necessary. MR. KING: The parties agree that they shall continue to be bound by the custody order currently in place, having been issued by the Court of Common Pleas of Cumberland County, Pennsylvania. MR. BASNER: I think that -_s fine. MR. KING: 6. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the :request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. THE MASTER: Mrs. Galeano, have you heard the agreement as stated on the record? 5 MRS. GALEANO: Yes. THE MASTER: Do you understand it? MRS. GALEANO: Yes. THE MASTER: And you are in agreement that the statement of the settlement of the claims will conclude all matters relating to this divorce? MRS. GALEANO: Yes. MR. KING: Mr. Galeano, you were present in the room during my recitation of the term; of the agreement, were you not? MR. GALEANO: Yes. MR. KING: And did you understand those terms as stated. MR. GALEANO: I did. MR. KING: Do you understand that upon execution of this agreement any and all claims or rights or obligations that either of you might have arising from your marriage or any claims from the divorce action will be extinguished? MR. THE the agreement in o to rephrase that a both bound by this MS. GALEANO: I do. MASTER: Now, they don'- have to execute rder to be bound by it, so may be you want little bit. You understand that you are agreement even though you don't sign it? GALEANO: Right. 6 THE MASTER: When you leave this room you have extinguished all claims. MR. GALEANO Do you understand that? I understand that I am bound to this agreement as of this moment. THE MASTER: And you understand the same? MRS. GALEANO: Yes. THE MASTER: MR. Basner, are you satisfied that we can close the record? MR. BASNER: Yes. Thank you. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: Cohn F. Kin , J . Attorney fo aintiff ?.rnristopner j. tsasner Attorney for Defendant DATE: 51h; /'ll(7 e ndres Galeano iGaleano 7 AAA _W de-n_ _ _ eY a _ bra G _i ,?a n.? WJ s__ sS_anj ?ar,? mays p n b.>7 SLi _ CL O i l Cbo K odes -__esP mo.rOla a ?- , and 0 ?o3?G? _ L (i n room SDa an lave yea an_ C'n .r t?a-i n mend Ce-cLe-r i i ?' Gln ? v CA ocK w r 1 ? G r, Swi n c?, q ?h D L nc" r r p os ?- On room "Iqgp _ C_?_end _es r.. _.1 _ ce1?_l - lUn box, F .... __a? ivy, I -h wds hog ),cL - wm6s Wash clc e-s baxs_ _ Sapp--- . Nor, , _-_ e t _and__ _Cbrr;tFo??,e _ bi r,_l-Coy E---O?n? wn, Q col i c a??._ -d_ C.0 M6 o1 _S _ _ ! _ _ e (J2Gi al_ - CVir smGtS b1.G n a52.r u n D? I C _ _?C? rUr? ? ? f 1 _ (r esK Qnd cha,r. ECf_c4-ri cbro_o r 'D Ul) can v aLcre-'o bvo m box °- CJs Ctrdle,5s, PhDnL., answe-rin3 ro),chnc, Cwkr).,cl V M _ , _d ar?o n _ ?rnex? e L 3 ? 00 f - e +- d i ?Tn ?i anon . Dnd tm u-all cd- b an ? ? o?m D ,n r+ ? G ANDRES GALEANO, Plaintiff v. AZURE D. GALEANO, Defendant TO: Prothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.08-2114 Civil Term CIVIL ACTION -LAW IN DNORCE Praecipe to Withdraw Counts Kindly withdraw Count 1 and Count 2 of Defendant's Answer, New Matter and Counterclaims filed on September 18, 2009, and so mark the docket. ChristoQher J. Basner, Esquire Attorney for Defendant Azure D. Galeano "~ d cam; `"' ~p ~- 205985 ti ~ ._ ~'= Supreme Court Identification Number ~ ~ ~ ~~ Christopher J. Basner P.C. ~~ ~ <t~ Firm ~ ~~ ~'-~ a m4 341 Market Street v ~ Street Address ,_ Newport. PA 17074 City, State, Zip Code (717) 567-6993 Telephone Number Date: October 20, 2010 Signatur cc: File John F. King, Esq. Azure D. Galeano Andres Galeano ; In The Court of Common Pleas of the 9'~ Judicial District of Pennsylvania Plaintiff ;Cumberland County Branch v. NO.08-2114 Azure D. Galeano :Civil Action -Law Defendant : In Divorce Certificate of Service I am hereby causing to be filed this day a Praecipe to Withdraw Counts via US Mail, postage prepaid, to the Cumberland County Court of Common Pleas. I am hereby this day serving same upon Counsel for the Plaintiff via facsimile at (717) 695-2207, and, via US Mail, postage prepaid. Christoaher J. Basner, Esquire Attorney for Party Named Above 205985 ~.... ~,.;,. Supreme Court Identification Number ~-r ~ r -` Christopher J. Basner P.C. _ ~ ~~ Firm ca ~° ~ [ ~- 341 Market Street `~ ~- }-- ~ a ~ ~ = Street Address c~: ~~ -. © w ~= ~~ ~ Newuort. PA 17074 f ~_. ~ ~ City, State, Zip Code X717) 567-6993 Telephone Number Date: October 20, 2010 Signature cc: Fite John F. King, Esq. Azure D. Galeano 4 JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 FAX (717) 695-2207 johnfkinglaw ,gmail.com ~Fi! ~a-G~FIC~ Attorney ~oQ ~~~r~i~f ~~ ~ ~ ~^. ~~ C~1~9B'ERI.AC~~ CUf.,-,~ i ~ P~N~'SY~.~~'~d~: ANDRES GALEANO, Plaintiff v. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2114 Civil Term CIVIL ACTION -LAW : IN DIVORCE MOTION TO REVOKE APPOINTMENT OF MASTER Plaintiff ,Andres Galeano, moves the court to revoke the appointment of a master with and in support of the motion states: 1. On January 6, 2010, Plaintiff filed a Motion for Appointment of Master. 2. On or about January 8, 2010, E. Robert Elicker, Esq., was appointed Master. 3. On or about August 31, 2010, the parties came to a settlement regarding all claims of the divorce action. 4. Due to the settlement of the divorce action, no Master is required. 5. Defendant concurs with this Motion. WHEREFORE, it is respectfully requested that the appointment of E. Robert Elicker, Esq., as Master be revoked. Dated: October 28, 2010 Respectfully submitted, JOHN F. KING LA%~W, P.C. By: P~ hn F. King, Esq. ID NO. 61919 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 (717) 695-2207 FAX Attorney for Plaintiff ~DRDER AND NOW this /,Q~ day of , 2010, upon consideration of NOV p ~ [u~u `~ ANDRES GALEANO, Plaintiff v. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE the Plaintiff s Motion to Revoke Appointment of Master, it is hereby ORDERED and DECREED that the appointment of E. Robert Flicker, Esq., as Master is hereby revoked, and it is further ORDERED that the Prothonotary shall so m~ Distribution: ohn F. King, Esq. 4076 Market St., Camp Hill, PA 17011 /Christopher Basner, Esq., 341 Market Street, Newport, PA 17074 Ca i£s ~na6~, /~ ~(tU ~~ ~ m ~ ~~ u ,- ~ , ~~ ou , v G Op Q "O ~ ~ =O .... O j's1 y~ ~ ~-~ '~ O :t] ~ ~ ~~IO X049 -~ P 3r l~~~s ANDRES GALEANO, ~ ~~ ~9$E ~ ~ ~ 9 ~1~~~~ QURT OF COMMON PLEAS Plaintiff ~ ~ ~ ~,,t,s S't`~,U~ ~~. , AND COUNTY, PENNSYLVANIA v. N0.08-2114 Civil Term AZURE D. GALEANO, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Cade. 2. Date and manner of service of the complaint: On Apri13, 2008, by Acceptance of Service. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff and Defendant, September 3, 2010. 4. Related claims pending: There are no related claims pending. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date Plaintiffs and Defendant'sWaiver of Notice was filed with the Prothonotary: September 3, 2010 ~~ ~~~. n F. King, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF ANDRES GALEANO CUMBERLAND COUNTY, PENNSYLVANIA V. AZURE D. GALEANO NO 08-2114 Civil Term DIVORCE DECREE AND NOW, ,6/1?e ,-e- / A? 016 , it is ordered and decreed that ANDRES GALEANO plaintiff, and AZURE D. GALEANO defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente bite if any economic claims remain pending The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, Attest: J. i rothonotary 9 rt(;6. rn"66 a i? -" ?'';S 736iPr ANDRES GALEANO, Plaintiff V. AZURE D. GALEANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2114 Civil Term CIVIL ACTION -LAW IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this e?' day of , 2010, it appearing to the Court that: WHEREAS, the parties hereto were husband wife, and a divorce was granted and decree filed on and WHEREAS, Andres Galeano, Social Security Number 169-64-8348, hereinafter referred to as "Member" is a participant in the Versatile Systems, Inc. 401(k) Plan; and, WHEREAS, Azure D. Galeano, Social Security Number 193-58-8986, hereinafter referred to as "Alternate Payee" has raised claims for equitable distribution of marital property pursuant to the Pennsylvania Divorce Code, 23 Pa.C.S.A. 3101 et sec; and, WHEREAS, Member's current and last known mailing address is 325 Liberty Court, Mechanicsburg, PA 17050; and WHEREAS, Alternate Payee's current and last known mailing address is 215 W. Chocolate Avenue, Apt. 8W, Hershey, PA 17033. NOW, THEREFORE, it is ORDERED, ADJUDGED AND DECREED as follows: 1. The lump sum amount of $12,357.50 (hereinafter referred to as "equitable distribution portion") is to be allocated to the Alternate Payee for the purpose of equitable distribution of the marital estate. 2. The equitable distribution portion shall be transferred from Husband/Member's Versatile System's Inc. 401(k) Plan to a certain State Farm Mutual Fund IRA account, for the benefit of Azure Galeano, namely account number 9141868, by way of check mailed to State Farm Mutual Funds, PO Box 219548, Kansas City, MO 64121, within thirty (30) days from the filing of this Order. 3. If the Alternate Payee predeceases the Member, the Alternate Payee's benefit identified herein shall be payable to the estate of the Alternate Payee. 4. Alternate Payee may not exercise any right, privilege or option offered by Versatile Systems, Inc. 401(k) Plan or its administrator, LeTort Trust. Versatile Systems, Inc. 401(k) Plan or its administrator, LeTort Trust, shall issue individual tax forms to Member and .Alternate Payee for amounts paid to each. In no event shall Alternate Payee have greater benefits or rights other than those "Xhich are available to Member. The Alternate Payee is not entitled to any benefit not otherwise provided in this Order. All other rights, privileges sand options not granted to Alternate .Payee are preserved for Member. le? Dated: '2010 IIV)' -urn <> rj C) ca