Loading...
HomeMy WebLinkAbout08-2209f JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff LORI E. LONG, Plaintiff V. TIMOTHY G. LONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. b8- 02,269 0-iVi? -?_- rP , CIVIL ACTION -LAW 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 at the Cumberland Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff LORI E. LONG, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OP- ?-20'7 0170,'/ Te rex TIMOTHY G. LONG, CIVIL ACTION -LAW Defendant DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE Plaintiff, Lori E. Long, by and through her attorney, Jeanne B. Costopoulos, Esquire, avers the following: 1. Plaintiff, Lori E. Long, is an adult individual who is currently residing at 7 Victoria Way, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant, Timothy G. Long, is an adult individual who is believed to be residing in Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 29, 1997, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or 2 its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. There are no children of the marriage between Plaintiff and Defendant. 10. This action is not collusive. COUNT I -DIVORCE 11. The Plaintiff avers that the grounds on which the action is based are as follows: a. That the marriage is irretrievably broken. COUNT II - EQUITABLE DISTRIBUTION 12. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant. To the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Plaintiff desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. 3 13. Plaintiff and Defendant are the owners of various items of real and personal property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution by this court. 14. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, and insurance policies acquired during their marriage, which are subject to equitable distribution by this court. C'OTINT iTi _ ALIMOW pr'ivn??vm? ; MIL ATTORNEY'S FFFC AND C'OSTI 15. By reason of this action, Wife will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 16. Wife is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 17. Wife's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and costs of this litigation. 18. Husband has adequate earnings to provide for Wife's support and to pay her counsel fees, costs and expenses. 19. Wife lacks sufficient property to provide'for her reasonable needs. 20. Wife is unable to sufficiently support herself through appropriate employment. 21. Husband has sufficient income and assets to provide continuing support for the Wife after the entry of a Decree in Divorce. 4 WHEREFORE, Plaintiff requests this Honorable Court: 1) Enter a Decree in Divorce; 2) Equitably distribute all property, both personal and real, owned by the parties; 3) Compel Husband to pay alimony pendente lite to Wife; 4) Compel Husband to pay post-divorce alimony to Wife; 5) Grant Wife's attorney's fees and costs; 6) Grant such further relief as the Court may deem equitable and just. Respectfully Submitted: By: E B. COSTOPOULOS, IRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: Attorney for Plaintiff 5 V VERIFICATION I, Lori E. Long, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: 0I Lori E. Long m C c? ? ? r .4 te- -3 IN -w JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff LORI E. LONG, Plaintiff V. TIMOTHY G. LONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-2209 Civil Term CIVIL ACTION -LAW DIVORCE AFFIDAVIT OF SERVICE I, Jeanne B. Costopoulos, Esquire, verify that the Complaint in Divorce filed April 7, 2008, was served upon the Defendant indicated above on April 24, 2008, by first class, Certified Mail No. 7000 1530 0001 6001 9340, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements of Pa.R.C.P. § 1930.4. I verify that the statements made herein are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. By: JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff Date: ? Q 4 1 ¦ Complete item 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this cad to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: A. Received by F lism P_" Cis@* B. C. \N?,1 . ? Agent D. Is d&Wsi`?-address ciftea. Yes If YES, enter delivery i? Q Ann 24 ts' none :'? l-7G ^4rl { 3. sWvice Type Lc/ ',w ,? jt ?0 cercreed mail O Express QC k h 1 c5 b K j / Dd ' 7 O fY 13 Insured ma 13 CRetum Receipt for Merchandise (" • 4. Restricted Delivery? (Extra Fee) / 2. Article Number ^DOQ 1 0 0" (www an servks Aw (?J PS Forrtx 11, k0d12001 D FOO111 is Ream %.Hpt toesessn ratisz? s? V.; `,; ca M E4 cn .0- LORI E. LONG, V. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 08-2209 CIVIL TERM IN CUSTODY TIMOTHY G. LONG, Defendant PRAECIPE TO ENTER APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Timothy G. Long, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT Douglas . Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Date: July 14, 2008 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Jeanne B. Costopoulos, Esquire 5000 Ritter road Suite 202 Mechanicsburg, PA 17055 Date: July 14, 2008 IRWIN & McKNIGHT D glas . Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 c ctz$ r t LORI E. LONG, Plaintiff V. TIMOTHY G. LONG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 08-2209 CIVIL ACTION - LAW DIVORCE PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Lori E. Long, the Plaintiff in the above-captioned matter. Date: BY: B. COSTOPOULOS, QUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Lori E. Long, Plaintiff, in the above-captioned matter. Date: B ? / y ANDREW C HEELY, ESQUIRE Attorney I.D. No. ( 2-k L F P.O. Box 95 Mechanicsburg, PA 17055 Telephone No. (717) 697-7065 M CERTIFICATE OF SERVICE I, ANDREW C. SHEELY, hereby certify that I served a true and correct copy of a Praecipe for Withdrawal/Entry of Appearance upon counsel of record on the below listed date by first class mail, postage prepaid to the last known address of the person named below: Douglas G. Miller, Esquire IRWIN & MCKNIGHT 60 West Pomfret Street Carlisle, PA 17013 November 2008 Andrew C. Sheel ttorney ?. ?? ?. ,1.,? ? '' r=?= ` .., ? c: ?; -? Todd C Hough, Esquire Lavery, Faherty, Young & Patterson, P. C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 717,233.6633 Attorneys for Defendant LORI E. LONG, Plaintiff V. TIMOTHY G. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-2209 CIVIL ACTION -LAW DIVORCE PRAECIPE FOR WITHDRAWAL / ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdrawal my appearance on behalf of Timothy G. Long, Defendant in the above-captioned matter. Date: /'510T A By: Dougla . Miller, Esquire Atty No. 83776 Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Kindly enter my appearance on behalf of Timothy G. Long, Defendant in the above-captioned matter. Date: _3/1-r zo By: /// d C. Hough, Esquire Atty No. 91060 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 717-233-6633 .? __? . ?' ^°? _ ,n ' ?? r, ; 'J -?7 ` Andrew C. Sheely, Esquire Attorney for Plaintiff/Petitioner 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) andrewc.sheely@verizon.net LORI E. LONG, Plaintiff/Petitioner, VS. TIMOTHY G. LONG, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - Law • of 2209 CIVIL TERM CERTIFICATE OF CONCURRENCE OR NON-CONCURRENCE I, Andrew C. Sheely, Esquire, hereby certify that I served a copy of the attached Petition for Special Relief upon Todd C. Hough, Esquire, by fax transmission on August 18, 2009. I further state that I was advised by Todd M. Hough, Esquire, before and after the fax that he did/ rid not concur with the attached Petition prior to its filing on the date set forth below. Date: August /f, 2009 Andrew C. Sheel , Esquire Attorney for Plaintiff/Petitioner 127 South Market Street P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 Andrew C. Sheely, Esquire Attorney for Plaintiff/Petitioner 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) andrewc.sheely@verizon.net LORI E. LONG, Plaintiff/Petitioner, VS. TIMOTHY G. LONG, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - Law . efi : -*T'- 2209 CIVIL TERM PETITION FOR SPECIAL RELIEF IN RE: PRESERVATION/PROTECTION OF MINOR'S ACCOUNTS Lori E. Long, Plaintiff/Petitioner, by and through counsel of Andrew C. Sheely, hereby files this Petition for Special Relief pursuant to Pa.R.C.P. No. 1920.43, 23 Pa.C.S.A. S 3323(f) and 23 Pa.C.S.A. S 3505, and respectfully states as follows: 1. Petitioner, Lori E. Long, (hereinafter referred to as "Petitioner") is an adult individual who resides at 7 Victoria Way, Camp Hill, Cumberland County, Pennsylvania. 2. Respondent, Timothy G. Long, (hereinafter referred to as "Respondent"), is the defendant in the above captioned matter and lives in Carlisle, Pennsylvania. 3. Petitioner and Respondent were married on November 29, 1997 and separated on July 9, 2006. 4. This is a second marriage for Petitioner and Respondent. 5. Petitioner is the natural mother of Benjamin D. Steele, a minor child of her first marriage. 6. Benjamin D. Steele, a 16 year old minor child, receives a $1,016.00 (approximately) monthly death benefit from Social Security as a result of the death of his natural father, Randy Steele, who died on July 16, 1994. 7. Respondent is employed as a financial planner and is an owner of a business known as Keystone Financial Associates, LLC. 8. During the course of the marriage of Petitioner and Respondent, the monthly death benefit received by Benjamin D. Steele as a result of the death of his natural father, Randy Steele, from Social Security was placed in various funds and investments, including a 529 Savings Plan(s), for the benefit of Benjamin D. Steele upon his emancipation from high school and anticipated attendance at college. 9. An amount of $26,369.89 was invested in a TAP 529 Plan, UGMA/UTMA Core Equity I account #884/30000101799 with Delaware Investments as of July 7, 2006. A copy of the account confirmation is attached hereto as Exhibit "A". 10. An amount of $7,685.24 was invested in a TAP 529 Plan, UGMA/UTMA Core Bond I account #784/30000101799 as of July 24, 2006. A copy of the account confirmation is attached hereto as Exhibit "B". 2 11. Respondent, Timothy G. Long, has refused to release control and ownership of the TAP 529, UGMA/UTMA accounts identified in paragraphs 9 and 10 to Petitioner, the natural mother of the minor child. 12. Respondent, Timothy G. Long, after repeated demands, has refused to provide current information on the value of the TAP 529, UGMA/UTMA accounts identified in paragraphs 9 and 10, to Petitioner, the natural mother of the minor child. 13. Respondent, Timothy G. Long, through counsel, has advised Petitioner that Respondent believes all funds held in the TAP 529, UGMA/UTMA accounts for the benefit of the minor child are marital property, and not the minor child's property or assets. 14. Petitioner, Lori E. Long, believes that all funds held in the TAP 529, UGMA/UTMA accounts are the property of the minor child, Benjamin D. Steele, and not marital property. 15. Petitioner has been unable to determine whether or not the TAP 529, UGMA/UTMA accounts continue to exist, to determine the value of said accounts and to protect the accounts for the benefit of the minor child, Benjamin D. Steele. 16. Protection and preservation of the TAP 529, UGMA/UTMA accounts is necessary for the benefit of the minor child, Benjamin D. Steele. 3 17. Petitioner previously served discovery requests upon Respondent and Respondent is under a continuing obligation to provide current information of property which he believes constitutes marital assets. 18. This case has not previously been reviewed by or assigned to any Judge in the Court of Common Pleas of Cumberland County. WHEREFORE, Lori E. Long, Plaintiff/Petitioner, hereby respectfully requests that this Honorable Court enter an Order of Court directing the following: A. Enjoin Defendant/Respondent from transferring, investing, reinvesting, distributing or removing any funds from the TAP 529, UGMA/UTMA accounts pending further order of Court; and B. Direct that Defendant/Respondent immediately provide Plaintiff/Petitioner with current account information regarding the TAP 529, UGMA/UTMA accounts together with monthly statements from July 2006 to the present; and C. Direct that Defendant/Respondent fully cooperate with transferring control and ownership of the TAP 529, UGMA/UTMA accounts held for the benefit of the minor child, Benjamin D. Steele, to Petitioner; and D. Direct any other relief deemed appropriate to protect and preserve the TAP 529, UGMA/UTMA accounts held for the 4 benefit of the minor child, Benjamin D. Steele. 19. A copy of this petition for special relief was faxed to counsel for Respondent prior to filing and counsel for Respondent has previously advised counsel for Petitioner that Respondent will not agree to the requests herein. Date: August N , 2009 Respectfully submitted, eag An rew C. Sheely, Esquire Attorney for Petitioner PA ID 62469 127 South Market Street P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 717-697-7065 (fax) andrewc.sheely@verizon.net 5 VERIFICATION I verify that the statements made in this Petition for Special Relief are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: August Iy 2009 - Lori E. Long F FILED-- it 1'qt r E HP C.) 1 ? _3 + 2009 AUG 19 PM, 12: 40 Exhibit "A" TAP 9M PENRAWANIA TUITION 1000011 P1111aPAa 529 PLAN TRANSFER UGMA/UTMA - PA TIMOTHY G LONG FBO BENJAMIN O STEELE 7 VICTORIA WAY 000007 CAMP HILL PA 17021-1726 1111 111 111 111 It 111111111111111111 Is I I 1111111111111111111111111 July 7, 2006 Your Financial Advisor Page 1 o14 HOUSE ACCOUNT DELAWARE DISTRIBUTORS L. P. 2005 MARKET ST FL 4 PHILADELPHIA PA 19103-7042 Branch Office Code 0000500 WOB 0001 nt Services roprotectthesecurrryofourcbents'informsbon,Deiswmreasenor acceptsccormtre/etedmoumesor Wanascnonsby E-mail at this time. Please do not mcrudo snypnn7aped uriormatron such es eccounrorsocwrsecurdynumbers. tNe will respond vie f-mart melt n pm buamess days. Account Service 800 440.4000 8a m. - 7p.m. tT Man -Fri. Automated Phone 886 244.9877 24twurs, ?days a week See ro versa toe inerrucnons E-mail service0tap529.com Web site www.TAP529.com New Account Confirmation Regular Mail TAP 529 Plan c/o Delaware Investments Document Management Center P.O. Box 42529 Philadelphia, PA 19101.9932 This statement confirms the recemtrade to the Pennsylvania TAP 529 Investment Plan. In addition this confirmation statement provides information about any feea that were applied to your purchase. All trades are executed on the someday received If in good order, if received before the close of regular daytime trading on the Now York Stock Exchange. For more com plats Worm atton ragerding axecu4on of your trades, please see your TAP 529 Plan Disclosure Statement You may request a TAP 829 Plan Disclosure Statement by rontacting your financial advisor or Delaware Investments at80D440.4000. ransactions-By Investment Option Portfolios Commonwealth of Ponnsylvenis Tuition Account Investment Program Fund Shores Valued by: T A P.Seciaily Reap. Cabe Equity 1 879 PLAN 110001.10 Account owner 529 PLAN TRANSFER UGMAlUTMA - PA TIMOTHY G LONG F90 BENJAMIN 0 STEELE TradaXoti cant shear This Dab Trenaactloa Descrydon Dollar Amount sham Price Trimness" Total thsas 07/07/20M 2006 Contribution $26,359.89 $10.59 2,489.1300 2,489.13M For this transaction your linen cIsI advisor has acted as agent and 0aIaware Distributors, L.P. has acted as the distributor, The Commonwealth of Pennsylvanis Tuition Account Investment Program fund is the issuer of securities. For charges and other fees, sea the TAP 529 Plan Disclosure Statement for details. tures and Options Selected ReRistt7ttion Your account has been registered with TAP 529, Pennsylvania's Tuition Atcount Plan as: 529 PLAN TRANSFER UGMA/UTMA - PA TIMOTHY G LONG FBO BENJAMIN D STEELE 7 VICTORIA WAY CAMP HILL PA 17021-1726 Exhibit "B" %.14, TAP ON PINNIMANIA Te1TtIN ACCNNNT MIMIAN 529 PLAN TRANSFER UGMA/UTMA - PA TIMOTHY 6 LONG FBO BENJAMIN D STEELE 7 VICTORIA WAY CAMP HILL PA 17021.1726 I,IIIII,,IIIIII,,.IIIIIIIIIdIiIllr1lI1111#IId1111III1111111111 Confirmation Statement JuIV 24.2006 Page 2 of 2 Your financial Advisor HOUSEACCOUNT DELAWARE DISTRIBUTORS L. P 2005 MARKET ST FL 4 PHILADELPHIA PA 19103-7042 Branch Office Code 0000500 Wog 0001 This stamment cmtfirms the recent trade to the Pennsylvania TAP 529 Investment Plan. In addition this confirmation fors that were applied to your purchase statement provides information aboutany . All tredeetrdt executed on the some day received if in good order, 0 received before the close of regular deydma trading on the New York Stock Exchange. For more complete infarman9on regarding exec ufon of your trades, please see your TAP 09 Plan Disclosure Statement You may requesta TAP 529 Plan Disclosure Statement by can" yourfinenciel advisor or Delaware Invastments at 900440.4000. Transactions-By Investment Option Portfolios Commanweghh of Pennsylvania Tuition Account Investment Program Fund Shares Valued by: T A P Socially Aesp. Core Bond I SM PLAN PORTFOUD Tra"OllomeNt Date Transaction Daacrr oe Shares This Pd Doper Amaest Share Price Transaction Total SMsIa 07124!2009 Opening Balance $7,495.24 07/2W= 2006 ContriboWn - Nov 717.6640 $200.00 510.43 19.1150 736.8380 For this trensactlon your financial advisor has acted as agent and Delaware Distributors, LP. has acted as the distributor. The Commonweahh of Pennsylvania Tuition Account Investment Program fund is the issuer of securities. For charges and other fees, see the TAP 529 Plan Disclosure Staternentfor details. F' CERTIFICATE OF SERVICE I, ANDREW C. SHEELY, hereby certify that I served a true and correct copy of Petition for Special Relief upon counsel of record on the below listed date by first class mail, postage prepaid, as follows: Todd C. Hough, Esquire LFY&P, P.C. 225 Market Street P.O. Box 1245 Harrisburg, PA 17108 August 2009 Andrew C. Sheely ttorney cr .," F G Rl T?Frt '7 • I ?U9 Al.. 1 1 i, 1'• " LORI E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - Law TIMOTHY G. LONG, Qg-- 2209 CIVIL TERM Defendant/Respondent ORDER OF COURT AND NOW, this day of ag , 2009, upon consideration of the attached Petition for Special Relief, a hearing thereon is scheduled for the !/- day of 2009, at in court Room No. on the Fourth Floor of the Cumberland County Courthouse, Carlisle, Pennsylvania. Pending further order of Court, Respondent/Defendant is enjoined from transferring, disposing, reinvesting, distributing or removing any funds from the TAP 529, UGMA/UTMA accounts referenced in the attached petition. BY THE COURT, J. Andrew C. Sheely, Esquire Attorney for Plaintiff/Petitioner ,"Todd C. Hough, Esquire Attorney for Defendant/Respondent P OF Trig"' lot, hus o l LORI E. LONG, Plaintiff/Petitioner V. TIMOTHY G. LONG, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2209 CIVIL TERM IN DIVORCE IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 11th day of September, 2009, upon agreement of the parties, as announced in open court, and in their presence, it is ordered and directed that: (1) The defendant, Timothy G. Long, shall provide plaintiff, Lori E. Long, with an accounting on the source of the Pennsylvania College Savings Plans, specifically, Account No. 5781884401 and Account No. 5781884402, to plaintiff, Lori E. Long, within sixty days. (2) The defendant, Timothy G. Long, shall provide plaintiff, Lori E. Long, with monthly account statements as to the preceding identified account numbers through email monthly. (3) Neither the plaintiff nor the defendant shall transfer, dispose, distribute, or remove any funds from the above-referenced college savings plans without further order of court. (4) The plaintiff believes that the Pennsylvania College Savings Plans accounts are non-marital assets held by the defendant for the benefit of Benjamin D. Steele's college education. The defendant believes that the funds are marital assets held by the defendant for the benefit of Benjamin D. Steele's college education. The issue of whether the funds are a marital or a non-marital asset is 08-2209 CIVIL TERM reserved for resolution by the Cumberland County Divorce Master or as the parties may agree. (5) To the extent that the economic claims raised in the pending divorce action are not resolved prior to Benjamin D. Steele's entry into college, the plaintiff and defendant agree that these funds shall be made available for his education, provided that the equitable claims as to the issue of whether or not those college funds are marital or non-marital shall be preserved until further order of court. By the Court, ? Andrew C. Sheely, Esquire For Plaintiff/Petitioner ? Todd C. Hough, Esquire For Defendant/Respondent :bg iF-s m??I T 9//s lo? ri Kevin A. Hess, J. FILFLD-C:- - r F OF WE FFr'!Ti .; OTARY 2009 SEP 15 AN i I.4 7 LORI E. LONG, : IN THE COURT OF COMMON PLEAS?)OF ? _ Plaintiff : CUMBERLAND COUNTY, PENNSYLV IAc -- c._ -4 71: -n =r = VS. CIVIL ACTION - Law F Off' rv 1 TIMOTHY G. LONG, W - 2209 CIVIL TERM - -1 D -?7 Defendant MOTION FOR APPOINTMENT OF MASTER 1-0 Lori E. Long, Plaintiff, moves the Court to appoint a Master with respect to the following claims: (X) Divorce (X) Distribution of Property (X) Alimony (X) A.P.L, Attorney fees and costs 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 by his attorney, Todd Hough, Esquire. (3) The Statutory basis for divorce is 23 Pa C.S.A. S 3301(c). (4) Delete the inapplicable paragraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: None c. The action is contested with respect to the following claims: Equitable Distribution, Alimonv. Attornev fees. Costs (5) The action does not involve complex issues of law/fact. (6) The hearing is expected to take 1 day (7) Additional information r evant to h wt' None Date : Jc. 1r r 20 to XrArew C. Sheely, Esq Attorney for Plaintiff ORDER APPOINTING MASTER AND NOW, , 2010, E. Robert Elicker, Esquire, is appointed Master with respect to the following claims: Divorce and all claims raised in the action. By the Court: J. JAN ? 6 2010 LORI E. LONG, : IN THE COURT OF COMMON PLEASC-)OF o Plaintiff : CUMBERLAND COUNTY, PENNSYLV IAG 7a t?- c_ VS. CIVIL ACTION - Law f N N) Y TIMOTHY G. LONG, W - 2209 CIVIL TERM Defendant ': v m r MOTION FOR APPOINTMENT OF MASTER 6. Lori E. Long, Plaintiff, moves the Court to appoint a Master ^ with respect to the following claims: (X) Divorce (X) Alimony (X) Distribution of Property (X) A.P.L, Attorney fees and costs 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 by his attorney, Todd Hough, Esquire. (3) The Statutory basis for divorce is 23 Pa C.S.A. S 3301(c). (4) Delete the inapplicable paragraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: None C. The action is contested with respect to the following claims: Equitable Distribution, Alimony, Attorney fees, Costs . (5) The action does not involve complex issues of law/fact. (6) The hearing is expected to take 1 day (7) Additional information r evant to h t' : 5 None ? Date: q J l /? 20 /U A E h l A rew C. S ee y, s r Attorney for Plaintiff ORDER APPOINTING MASTER a ? AND NOW, caw 2010, E. Robert Elier ,?^ Esquire, is ap inted Master with respect to the following:==-O=aims Divorce and all claims raised in the action. By the Court: A44,( P. s(Y )91? % NOC44 J. e? aaI ro FILED-OFFICE CF THE Pr 0T'10IN0 TA Y Todd C. Hough, Esquire Lavery, Faherty, Young & Patterson, P. C. 225 Market Street Suite 304 P. O. Box 1245 Harrisburg PA 17108-1245 717.233.6633 Attorneys for Defendant LORI E. LONG, Plaintiff V. TIMOTHY G. LONG, Defendant 2010 SEP 29 P 1--52 `"UMBERLAQ COUNT'l° PENNSYLVAN1.IA : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2209 CIVIL ACTION - LAW DIVORCE PRAECIPE FOR WITHDRAWAL / ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Timothy G Defendant in the above-captioned matter. Date: f Zy /,'a By: tld C. Hough, Esquire Attorney No. 91060 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, Pennsylvania 17108-1245 Tel: 717-233-6633 Kindly enter my appearance on behalf of Timothy G Lone, Defendant-in the above-captioned matter. Date: 1 ) z 7 I t a By: Paul He 1166 Harrisburg, PA 17108-1166 Tel: 717-237-5343 Attorney No 48 urick McNees allac LLC 100 Pine reet P. O. Box Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LORI E. LONG, Plaintiff VS. TIMOTHY G. LONG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY 08 - 2209 CIVIL TERM ORDER OF COURT r- - o IN RE : ALIMONY CO AND NOW, this ! day of 7WAA cA , 2011, it is" _}. hereby ordered and Decreed that Defendant, Timothy G. Long, shall pay Plaintiff, Lori E. Long, alimony in the amount of fifteen hundred dollars ($1,500.00) per month, in accordance with the terms of paragraph 7 of their Agreement dated March 15, 2011. BY THE COURT, A 4 J. Andrew C. Sheely, Esquire Attorney for Plaintiff, Lori E. Long (gyPie* I J. Paul Helvy, Esquire sl i%s Attorney for Defendant, Timothy G. Long LORI E. LONG, Plaintiff VS. TIMOTHY G. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2209 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2011, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on March 15, 2011, 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 to transmit the record with the affidavits of consent and waivers of the parties so that a final decree in divorce can be entered. BY THE COURT, 14, . KeviX'A. Hess, P.J. cc: Andrew C. Sheely Attorney for Plaintiff J. Paul Helvy Attorney for Defendant J LORI E. LONG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 08 - 2209 CIVIL TIMOTHY G. LONG, Defendant IN DIVORCE 1. Husband and Wife are owners of improved real estate located at 7 Victoria Way, Camp Hill, East Pennsboro Township, Cumberland County, Pennsylvania. Husband and Wife agree that Husband shall transfer all of his legal and equitable ownership in the real estate to Wife on or before April 15, 2011. Wife's counsel shall prepare a deed necessary to effectuate this transfer and shall delivery it to counsel for Husband. Husband shall promptly sign said deed and return it to wife. Subject to the provisions contained herein, Husband relinquishes all of his right, title and interest in the martial real estate to Wife. 2. Husband and Wife agree that Wife shall list the marital real estate at 7 Victoria Way, Camp Hill, East Pennsboro Township, Cumberland County, Pennsylvania with a reputable real estate company on or before May 15, 2011, and shall continue listing the property for sale until the real estate is sold or the mortgage and line of credit are refinanced such that husband has no further obligation for said debts. In the event that Wife does not refinance the property, and the property has not been sold by August 31, 2011, the sales price for said property shall be reduced by $5,000.00 per month until said property is sold. Wife shall be entitled to all net proceeds from the sale of the marital real estate after payment of real estate commissions, transfer taxes and payoff of the existing first mortgage and line of credit held by Metro Bank. Nothing herein shall prohibit Wife, if possible, from refinancing the first mortgage and line of credit held by Metro Bank while the real estate is listed for sale. 3. Pending the sale of the marital residence, Husband and Wife agree that Husband shall pay a monthly amount of one hundred twenty dollars ($120.00) and Wife shall pay an amount of eighty dollars ($80.00) each month to maintain the line of credit account current. Payments made hereunder shall commence during the month of April 2011 and shall continue until the real estate is sold or the mortgage and line of credit are refinanced by Wife. Husband and Wife shall provide proof of such payments upon request of the either party. 4. Husband and Wife agree that Wife shall maintain the first mortgage, taxes and insurance current until the sale of the marital residence. In the event of casualty, fire or other loss destroying the marital residence, Husband and Wife agree that any and all insurance proceeds shall be paid to satisfy the existing encumbrances as set forth above, and that Wife shall be entitled to any remaining proceeds from said policies of insurance. 5. Husband and Wife agree that Husband shall transfer a cash amount of twenty-five thousand dollars ($25,000.00) to Wife on or before April 15, 2011. 6. Husband and Wife agree that Husband shall cause or permit a rollover or transfer of his entire value of an IRA managed by AIM investments, account 4032135370, on or before April 15, 2011. Husband and Wife agree that they both shall cooperate to accomplish this rollover through execution of a qualified domestic relations order or other document required by the plan provider. Husband hereby relinquishes and waives any and all rights in the IRA managed by AIM investments. Wife's counsel shall prepare any qualified domestic relation orders or other documents necessary to effectuate this transfer. 7. Husband and Wife agree that Husband's spousal support obligation shall terminate March 31, 2011. Husband shall pay Wife alimony payments in the amount of fifteen hundred dollars ($1,500.00) per month, for a period of twenty-four (24) consecutive months, commencing in April of 2011, unless terminated earlier in accordance with the provisions contained herein. All payments shall be made to Wife directly from Husband through electronic transfer from Husband to Wife prior to the 15th day of each month. Payments from Husband to Wife shall be included in Wife's income for tax purposes and shall be deductible from Husband's income for tax purposes. Husband and Wife agree that the terms of this paragraph shall be reduced to a court order executed simultaneously with the entry of a Decree in Divorce. Husband's obligation to make the aforesaid alimony payments to wife shall terminate upon the first of the following to occur: Wife's death, Husband's death, Wife's remarriage or Wife's cohabitation with a person of the opposite sex. The payments herein shall be non-modifiable with respect to term and amount except that the payments shall be modifiable in the event that husband becomes permanently disabled such that he is unable to engage in gainful employment. Wife's counsel shall prepare an alimony order in accordance with this paragraph. 8. Husband and Wife agree that Husband and Wife shall cause Wife to be named as the custodian for all TAP 529 plan accounts currently held by Husband for the benefit of Benjamin D. Steele. Husband and Wife agree to complete the necessary forms to transfer custodial control of the TAP 529 Plans from Husband to Wife on or before April 15, 2011. Husband shall prepare the necessary documents to effectuate this transfer. 9. Husband and Wife agree that Husband shall transfer ownership of a life insurance policy, including all surrender values thereon, owned by Husband insuring the life of Sarah Steele to Sarah Steele on or before April 15, 2011. Husband and Wife agree to cooperate to complete the necessary forms to transfer ownership of this life insurance policy to Sarah Steele. Husband shall prepare the necessary documents to effectuate this transfer. 10. Husband and Wife agree that Husband shall Transfer ownership of a Lincoln Benefit life insurance policy, including all surrender values thereon, owned by Husband insuring the life of Benjamin D. Steele to Benjmanin D. Steele on or before April 30, 2011. Husband and Wife agree to cooperate to complete the necessary forms to transfer ownership of this life insurance policy to Benjamin D. Steele. Husband shall prepare the necessary documents to effectuate this transfer. 11. Husband and Wife hereby agree that Husband shall remove a baby grand piano, a freezer, a flat screen TV in the basement and various Christmas ornaments from the marital residence prior to April 15, 2011, unless the parties agree to an extension of time for husband to remove the aforesaid property. Husband shall provide wife with 48 hours of advanced notice via email prior to coming to the marital residence to pick up the aforesaid property. 12. Upon Husband's compliance with the above-stated terms and conditions, Wife hereby agrees that Wife shall herein and forever release Husband from any claim, interest or demand she may have against Husband arising out of their marriage including but not limited to any further claims for support, APL, alimony, counsel fees, costs, and expenses, and equitable distribution. Wife acknowledges that husband shall receive assets which include Keystone Financial Associates, LLC, Husband's Proequities Brokerage account, Husband's MMA Deferred Compensation Plan, Husband Proequities Deferred compensation and Husband's Nationwide insurance policy owned by Husband and insuring Husband and Husband's Nationwide insurance policy owned by Husband and insuring Meredith V. Long. 13. Husband and Wife agree that each party has fully and fairly disclosed all martial assets, incomes and other property owned by the other during the course of a pending divorce settlement docketed to No. 08-2209 in the Court of Common Pleas of Cumberland County, Pennsylvania. 14. The parties agree to cooperate with one another in permanently closing the $5,000.00 line of credit held in joint names with Metro Bank. 15. The parties agree that if there is any outstanding joint debt not specifically discussed herein that the individual incurred said debt shall promptly satisfy said debt or take the necessary steps to refinance said debt such that the other party has no obligation for said debt. 16. Husband and Wife shall maintain the motor vehicles in his or her possession and shall transfer any motor vehicle titles prior to April 15, 2011 in the event such is necessary to comply with the terms of this paragraph. 17. The parties agree to the entry of a divorce decree. The parties have signed affidavits of consent and waivers of notice and have delivered them to the Divorce Master's Office this date. Said documents shall be filed by the Divorce Master's office with the Prothontary's office in order to obtain a divorce decree. 18. 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. 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: DATE: ?d t4-t/ dgAs? Andrew C. Sheely Lori E. Long Attorney for Plaintiff Paul H lvy Timothy G. Long Attorney for efendant Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LORI E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - Law TIMOTHY G. LONG, 08 - 2209 CIVIL TERM J Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the: Divorce Code was filed on April 7, 2008. 2. The marriage of Plaintiff and Defendant is r _.- co ?..?., way, _ -- irretrievably broken and ninety (90) days have elapsed from the date of filing 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : ?? Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LORI E. LONG, Plaintiff, VS. TIMOTHY G. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - Law 08 - 2209 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. ?) 2. I understand that I may lose rights concerning ?-a alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : Lo i E. Long Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LORI E. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - Law TIMOTHY G. LONG, 08 - 2209 CIVIL TERM Defendant , CC' OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of,t Divorce Code was filed on April 7, 2008. Defendant accepted75 service of the divorce complaint on April 24, 2008. ` 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: l? Timothy Long ri r Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LORI E. LONG, Plaintiff, VS. TIMOTHY G. LONG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - Law ' -3 408 - 2209 CIVIL TERM _ E .? aTEti? WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER rm? 53301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : c___ - 77 Timothy G. Long LORI E. LONG, Plaintiff VS. TIMOTHY G. LONG, Defendant TO THE PROTHONOTARY: Kindly transmit the r information to the Co 1. Ground for di 2. Date and I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 08 - 2209 IN DIVORCE n C -?3 PE TO TRANSMIT RECORD zrn x r- -rC ? 37 c-y d, together with the following ? for entry of a divorce decree: 5'`a -4 e: Irretrievable breakdown: 3301(c) of service of the complaint: Acceptance b Defendant on April 24, 2008. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit required by 3301(c) of t e Divorce Code: by plaintiff 3/15/11; by defendant 03/15/11. N ? s M- -Urn rn °-+c - a r -n -a cu --4m cn > b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code N/A (2) Date of filing and service of the plaintiff's affidavit upon the respondent: N/A 4. Related claims pending: The court maintains jurisdiction over the division of Defendants AIM/INVESCO IRA as set forth in paragraph 6 and alimony a ents as set forth in paragraph 7 of the March 15 2011 Tropert settl --? which is 01 - ated but not mer4 Z ement a ree i in the Divorce Decree. 5. Complete either (a) or (b) a. Date and anner of service of the notice of intention to file praecipe to tr smit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 03/I /11 Date defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 03/R/11 Andr6w C. Sheely, Esquir Attorney for Plaintiff 127 South Market Street Mechanicsburg, PA 17055 (717) 697-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORI E. LONG V. TIMOTHY G. LONG : NO. 08 - 2209 DIVORCE DECREE AND NOW, Mz 9 " . 2011 , it is ordered and decreed that LORI E. LONG , plaintiff, and TIMOTHY G. LONG , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The court maintains jurisdiction over the division of Defendants AIM/INVESCO IRA as set forth in paragraph 6 and alimony payments as set forth in paragraph 7 of the March 15. 2011 property settlement agreement which is incorporated but not merged in this Divorce Decree. By the Attest:/ I A J. Prothonotary Ot"+' ('.spy rno? 4,o a Shealy Nc w ? C *Y rnpu "0 at#t? Ne'V4 LORI E. LONG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. TIMOTHY G. LONG, Defendant NO. 08-2209 CIVIL TERM IN DIVORCE PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of McNees Wallace & Nurick LLC on behalf of Defendant in the above-captioned matter. B Dated: 5h o l PRAECIPE TO EN TO THE PROTHONOTARY: Please enter the appearance of Timothy WALLACE & NURICK LLC Y aul Helvy Attorney I. o. 5314 100 Pine treet P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5343 TER APPEARANCE rnCD zM ?M cn r" ?D by G. Long, pro se. By -? Timothy G. Long 176 Cumberland Parkway Mechanicsburg, PA 17055 an CZ) r°ri Dated: S-// Z/ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORI E. LONG VS. TIMOTHY G. LONG CIVIL ACTION - LAW Plaintiff FILE NO. 2209 Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME 2008 Notice is hereby given that the Plaintiff/*eferxtwTr in the above matter, having been granted a Final Decree in Divorce on the 29th day of March, 2011 hereby elects to resume the prior surname of Lori E. Steele and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: / COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Signature Signs ure of name being resumed SS. On the ` f < t day of 20before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that4oAhe executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. NOTARIAL SEAL BECKY M. KNISELY, Notary Publk Mechanksburg Boro, Cumberland Co. MY Commission Expires Nov. 19, 2014 ,, ? i A GZrk-E ?'??°0 ? Q? (!k.? 3ga8- ?z?atob saw