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Home My WebLink About04-0785 THADDEUS B. GREGG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA ~ : NO. 04 _ 7<l6 IN DIVORCE c.:~'tl, ~ MARIA S. GREGG, Defendant 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 Prothonotary's Office, Cumberland County Courthouse, Cumberland, 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 2 Liberty Avenue Carlisle, P A 17013 (800) 990-9108 ~ ~ ~\\ ~ - S:, 4 C) t . ;-t V\ :::, v \ 0 ...... -( '.J ...l.\ r-' c:-:- <'- ~> J'""" ~, \~-) f,,1 c.,) ~ '"';. (-) "-'1 ..,~\ '."-"'1 ,0 , \-~~ p.-t' ~ (~.~ 0"" -",:.:l , .J THADDEUS B. GREGG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. MARIA S. GREGG, Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, THADDEUS B. GREGG, by and through his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, MARIA S. GREGG, upon the grounds hereinafter set forth: I. Plaintiff is THADDEUS B. GREGG, an adult individual, residing at 1428 Apple Drive, # 197, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is MARIA S. GREGG, an adult individual, residing at 304 II th Street, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 23, 1990 in Perkasie, Bucks County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised ofthe availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, THADDEUS B. GREGG, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. Respectfully submitted, DATED: :;--20-0'1- Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor P.O. 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff . VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. DATED: February 20. 2004 Th&M?!2g?{5y Plaintiff ~ ~ ~(\ ~ - ~ L.lC) t . ;-{ \}\ ~ v \ U ....... -( --.J (') r-' f:;~; ~ ~, :::-~ , , ~n . . \_J ;'-', , r<) c.} ~ ~..., c.) , .J r""; en ",:j "-'- THADDEUS B. GREGG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, SANDRA 1. MEILTON, Esquire on behalf of my client, MARlA S. GREGG, accept service of the Complaint in Divorce, filed to the above number and term in Cumberland County, Pennsylvania on February 23, 2004. 3/3/0,/ . Ddted IILv/~/~l!f ~ - S'mdra 1. Meilton, Es uire TUCKER ARENSBERG & SWARTZ III North Front Street Harrisburg, PA 17101 (717) 234-4121 Attorney for Defendant ....., C;J ;;:::::;. J..- ~" :p; :"'0 1:.1 Cv -< ", (.,) o "T1 :;;:1 nl:n r- ITl ;j C") -) I ~'lC) 5j~ IT, THADDEUS B. GREGG, p'LAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARlA S. GREGG, DEFENDANT CIVIL ACTION - DIVORCE CF.RTTFTCATF, OF SFRVTCll!: I, Ann V. Levin, Esquire, attorney for Plaintiff in the above-captioned matter, do hereby certify that I served a true and correct copy of Praecipe to Withdraw and Enter Appearance on counsel for Defendant by depositing same in the U.S. Mail, first class, postage prepaid, on the & day of April, 2004, addressed as follows: Sandra L. Meilton, Esquire Tucker Arensburg, P.C. III North Front Street Harrisburg, PA 17108-0889 DERSON & SACKS U,~~ By: Ann V. Levin, Esquire I.D. #: 70259 James R. Demmel, Esquire I.D. #: 90918 4431 North Front Street Harrisburg, pA 17110 (717) 234-2401 Attorneys for Plaintiff () "-> c <= ~ = s:: ...- -0(-( ::;. :r'Tj n'l.'--" -;;--1.'; -0 "'7;-:'--' ;;:0 n1- t6\..~ N ~hi _r; r"::::' .. \D r~~~:' ~6 " =H *0 :x 25 -(= N om Z :;! .. ?5 w -< THADDEUS B. GREGG, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA MARIA S. GREGG, Defendant : NO. 04-785 Civil Term : IN DIVORCE TO: Prothonotary PRAECIPE TO WlTHDRA W APPEARANCE - - PI""'"ff. THADDEUS B. GREGG, ;n """"""0' w;ili ili, 'bo~ ..~'" m_, PI""" w;thdrnw"" ""-" of ROBERT B. LIEBERMAN, &qwre, ~ ,"omny.n Dated: _'T. :1..1 ' <J'f' Respe,ctfully SUbmitted, ~0(). RObert B. Lieberman, Esquire 500 North 3rd Street, P.O. Box 1004 HarriSburg, P A 17108-1004 (717) 236-1485 PRAECIPE TO ENTER APPEABANq; TO: Prothonotary Gregg in the above captioned divorce matter. PI_ '''''" "" -"" of JAMEs R DEMMa, &q,;re, ~ ""'orey f" PI",,"ff, Thaddeus B. DATED:_ C;.,( 7- O~ _ . Respectfully submitted, j' J//. ~) ~une1, Esquire 4431 North Front Street, 3rd Floor HarriSburg, P A 1711 0 (717) 234-2401 Ann V. LeVin, Esquire 4431 North Front Street !Iarrisburg" PA 1711 Q AttorneyS .cor L\efE!ll:1ant ",](":0 rrir~"\ ~5~:~ ~fS ~}~ L~ )......c: -.. ~ Q c ~ ...., = = .J:' :l>" -0 :::0 N <.D ~ =rim i~._ ~~ 0('5 2m o -~ ~ --0 - ..,.;.:.. ~ w - THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant : IN DIVORCE PETITION FOR IMMEDIATE RELIEF AND NOW comes Marie S. Gregg, Defendant, through her attorney, Sandra L. Meilton, Esquire, of Tucker Arensberg, P.C., and hereby petitions this Honorable Court as follows: 1. The parties are husband and wife and currently <engaged in the divorce action docketed to the above term and number. 2. After the parties' separation, real estate was purchased at 109 Drexel Hills Park Road, New Cumberland, Cumberland County, Pennsylvania, and said real estate was titled in both Defendant's name and Plaintiff's name. 3. Said real estate has been rented up until this point in time with the current tenants scheduled to vacate the property at the end of April, 2004. 4. The monthly mortgage payment to Wells Fargo for said real estate is $2,037.33. 5. Neither party desires to retain the real estate. 6. Defendant desires to immediately list the real esllate for sale. 7. The real estate is a historic property, i.e, the Willliam Slack Homestead, a Revolutionary War-era home listed on the National Register of Historic Places, and Defendant has carefully researched the real estate market to select a realtor who handles properties of this nature. 8. Defendant has selected Hooke, Hooke and Eckman, LLC, Realtors, 320 S. Hanover Street, Carlisle, Pennsylvania to sell the said real estate. 9. Prior to selecting Hooke, Hooke and Eckman, L1_C, Defendant carefully researched the real estate market enlisting the aid of a qualified individual to help her select a realtor (See attached letter from Richard L. Polan, Jr. emailed to Defendant's counsel and thus not signed which is marked as Exhibit "A".) (Note that Mr. Polan is soon to hold the position of Chief Financial Officer of Maple Press.) 10. Defendant believes and therefore avers that said realtor she selected is the most qualified in the area to handle the sale of this property. (See attached Exhibit "S".) 11. Defendant provided Plaintiff with a listing agreement and infol11lation regarding the realtor she selected. This information was provided to Plaintiff's counsel on March 30, 2004 (See attached documentation marked as Exhibit "C".) 12. Plaintiff has refused to sign same. 13. Defendant has been solely responsible for the management of the property since it was acquired. (See attached letter dated April 29, 2004 from John F. Malady marked as Exhibit "D".) 14. If the property is not listed and sold within the near future, it is Defendant's concern that she will not be able to make the mortgage payments thus having the property fall into foreclosure. 15. Defendant desires that the Court direct Plaintiff to execute all necessary documents in connection with the listing and sale of the property. WHEREFORE, Defendant requests this Honorable Court to: (a) Order Plaintiff to execute all of the documents prepared by Hooke, Hooke and Eckman, LLC, in connection with the listing and sale of real estate located at 109 Drexel Hills Park Road, New Cumberland, Cumberland County, Pennsylvania; (b) Order Plaintiff to cooperate fully with the sale of said real estate; (c) Direct that, unless otherwise agreed by the parties, the proceeds from the sale of the said real estate shall be deposited into an interest bearing escrow account to be established by Defendant's counsel; (d) Award Defendant counsel fees in the amount of $1 ,000 in connection with the preparation, filing and hearing of the within Petition; and (e) Any further relief which the Court deems appropriate. Respectfully submitted, ~~f/~' andra L. Mellton, I D. #32551 TUCKER ARENSBERG, P.C. 111 N. Front Street, P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 ATTORNEYS FOR DEFENDANT VERIFICATION I, Maria S. Gregg, acknowledge that tile facts stated in the within document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~ Maria S. Gregg ~, ~11- DATED: '7/;;J.9Io~ Richard 1. Polan, Jr. 1622 Lowell Lane New Cumberland, Pa 17070 April 28, 2004 Dear Ms. Meilton: I am writing in reference to Maria Gregg's efforts in attempting to sell her property in the Drexel Hills development in New Cumberland. Maria had asked me to help her evaluate a real estate agent she was hoping to hire to sell the property. The agent was David Hooke with the firm Hooke, Hooke and Eckman. Maria was inexperienced with real estate transactions and was looking for support and feedback with making her decision. While not an expert, I have had experience with real estate transactions, having recently sold an existing property and built a new home, and had been a licensed real estate agent in Pennsylvania in my career. In addition, I have highly refined business acumen based on my experience as Vice President, Finance and CFO at multi-million dollar organizations. Maria was looking for me, with my background and experience, to give her a "read" based on our meeting with David Hooke. I felt David Hooke was a very organized and highly motivated real estate agent. He came prepared to demonstrate how his firm would market an ultimately sell the property for Maria. This is a unique property at the high end of the market in New Cumberland, thus not an easy sale. I was impressed that David and his firm had many examples of similarly unique properties in Central Pennsylvania that they had successfully sold. In my opinion, Maria needs an aggressivt:, highly motivated agent with experience selling unique properties to sell her property at its' true value. I think David Hooke would do an excellent job selling Maria's property. Sincerely, Richard 1. Polan, Jr. Exhibit "A" Mar 27 04 II:S4a Hooke Hooke and Eckman 717 248 1822 p.2 Hooke, rn "'oM"H< Hooke & Eckman LLC Rez~Jto~"'s It 320 S. llano\.'er Strt't.'t Carlisic. PA 17(113 PhOH(': 717..249..1844 ~". ,..,,- ra:\;: i! HC.2 March 27, 2004 To whom it may concern: The purpose of the following information is to provide you with a background of Hooke, Hooke, & Eckman LLC Realtors. Hooke, Hooke, & Eckman LLC Realtors is a limited liability corporation registered in the Commonwealth of Pennsylvania with the Department of State and the Bureau of Professional and Occupational Affairs to practice real estate in the State of Pennsylvania. The Bureau of Professional and Occupational Affairs: PO Box 2649 Harrisburg, PA 17105-2649 License Number: RB065323 Hooke, Hooke, & Eckman LLC Realtors is a member in good standing of the National Association of Realtors. William H Hooke is the Broker of Record of Hooke, Hooke, & Eckman LLC Realtors. License Number: RM4l9229 William H. Hooke has been practicing Real Estate in Pennsylvania for 42 years. The Hooke family bas owned and operated Real Estate Brokerages in South Central Pennsylvania for 3 generations sparming over 60 years and beginning in the year 1943. For the purpose of Marketing with the intent to sell the real property described as 109 Drexel Hills Park Road in New Cumberland, P A., Hooke, Hooke, & Eckman LLC. Realtors is a capable entity backed with experience in marketing other unique and similar properties in South Central Pennsylvania. For this service Hooke, Hooke, & Eckman LLC Realtors will charge a fee of 6% of the fmal sale price of the propcrty. If there are any questions, please feel free to call the office. I"'.........", Sincerely, /!! \ ,. ."," (j '. \ ".; , , . , 1- '.. r , . \J )-.,;;di'~,,/'l",-__ !; 1 ;1 , ~6 If "---David Hooke~iUi.kl\r: HOOWo~ Exhibit "B" Mar 27 04 11:55a Hooke Hooke and Eckman .717 249 1822 .... p.3 ~J?f""" ..~. '?C~,,"'.""~ "'-"'~A...a""'.:'UI"'''~''''''.!'JllV~f~~:::~~::::::~::~::~:::~~J:;)~::;~;;;:~::~~1 r ~~~ II t 'J: :-1' ~: ~: pi Ii 11 i: ~I " q! ~~! JI aJe(l asua,,!'1 je!J!UI 11 14: ":'1,:,.,'. .... .. ..' snJ.....s :>>SU;l:>rl ,r: l\r:-'-:-' J.~_. ... '~::-;::-:-:-- _,,"'>' _ :: ',:'--' . " .,'''' ,::,,_ ,::' ., Ji' iJ'6f'?Z"SQILrV d ~~.J,1qsWBH:6~.ixOR6d 11 . '. , . 's:'!&JjV:I~uO!l&dn;);)o PUg I&UO~SS3jO;ld J-Oo D&;UDa> " 1i "" " .'" ",""." '" ;',' J " ',', 31&lS}0 JU~Wf;l&d"<I '. " ,', . . ",'.". "". ":'L" ~ OSWDt:3:"~%QB ..-'" i<,"'\i~8AIASlIu".ijl?(,qlf&\)Ao\UOUlWO:)' ,;:''-'''''.' 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" . .... . . .. llureauofProf$sionaland Occ~pational'A;ff~h-s PO Box 2649 Harrisburg P A 171105"2649 License Type Broker MulticLicensee Broker of Record License Status Active Initial License Date WILLIAM H HOOKE HOOKE HOOKE & ECKMAN LLC 320 SOUTH HANOVER STREET CARLISLE PA 17013 License Number 07/09/2003 RM419229 Expiration Date 05/31/2004 ~~~~~~"h'~ , Signnlute Mar 27 04 11:55a Hooke Hooke and Eckman 717 249 1822 "" 3 " " ~- nc"E.~fno;:g;.~ f: l:O'~ ~c:g E..' e;; 3 g:::':~'<::r'n .Ec ""1;_. '"" l;<>'" ,"::r ~" o . ",,0 " 0 -"" co"'" ~ " ,,- 3" " '" CO" QJ"'~ ::r e::-:3 g~d'~ "D' (l " ~::(;;' 8. " " o . ~- c;J ,. - ~'~c: i. ;; 0.. ..... 0"= ....:::p...... oS-.r",oo 7 () ~ C) 3"9 ~ ~- - .-'{~W a~;;; 3~tO:ao~::s 3-:>>:;1 0.... O'\::r ~ e c.. ..,=: -::roo..o... AI 7" ~ 2.~SI'.l ~...I;IJ 7"S' C ::;'''" .g G;l 000, c <;:: ...... o (ll_C:> 0."'":'<7' ;;;. , ~ ~ ~ ~ :r~ ~ :;c =€ g- ~."d;' g ~ ~ ~ f:!? e ~ Er. g- o =. ~ g :::: 0 0 ('1l :> 0.. :] _ :::r- t'11::1 r=. .. ~ t::d. 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MEETINGHOUSE HEiGHTS .lQffIl.~~i(. / /- e?,t -<1~Q~ ~ , _/. 1..'- 1....1t{plc-/IVr}. ~...Q~~ /......; ..~, Oak two. o 0... M(ltl!:low ',flow Hooke halJdiwol'k / //~ With'hisJather,and variO!-lS :other part- 'r'-ers;'_:'v\Iilliam:'~Bill" Hooke. has. sold' or aevelop~$75mUlion 10$100 million lnreatestate,:in-the' ,last 40 years. TheircreditsJncfude -parts. of13 hOUSA ingdevelopmefitsoin'the, Carlisle' area. ThiS map shoWS.Some of lhose devel- opments in Carlisle and North Middle- ton Townshlp-Th..lypein redsl10ws tI1en~ighborhOl>ds thel-foo~es had a hand in developing. . They alsohaa aroli...indeveloping .. f'enrose.plaza, Ironstone. Ridge;F!eis Acres,seVer~1 mobile home parks, apartments and duplexes. The latesl project isa .68-unit duplex development nE>arthe propOsed Home Depotin southern Carlisle. " (;" ~:>'; ii0;it.:- 1.. \ la'-.......;:, \J;~~g../ \ 'tiiY ~ ~"'Sl.>1"", , Je o ~ :f! 0; $ l? ..2 )? m Trindle ---;..-.......-.-.------.---.-..;. .. E. W'~lo.w Ajiis. (".!-We. Hl! ! . . 11> l.E'l'OI:;rr~ Mar 27 04 12:03p Hooke Hooke and Eckman 717 249 1822 Home Sales Team Real Est;lte Listings William H. Hooke Boker/Partner My father began his real estate can:ler in Carlisle in 1943. I joined him in 1962 and t0gether we built one of the best kown and largest successful real estate agencies in the Carlisle area. Now with my son representing the third generation we are beginning toward that goal again. """,.",~~"""""",-=""",,,,,,,,~,"'''~''''''''~'''''''''''''~--''''''''''''''''''''''''''''''~"''''''"'''''''"~'~'-''''''''''''''''':<<=-''''_'''''''''_''';"'"","",=''.,"",:,~,W~\_''__""""""~~"""," David Hooke Realtor/Partner Born and raised in Carlisle, I am honored and excited to serve the Real Estate needs of the comffil:.mity in my father's and grandfather's footsteps. I'm in this for the long-term and I hope to build long-tenn relationships with my clients by being honest, reliable and utilizing a strong work .,thic. '-''''''''''''"'"''~''':'~_'-'''''''''''''''''~''''''''''~''''''''''''"'''''''''''''''''''''''''''''''''''"..''.n,..........~"'''''''_''"''''''''',."'',._.^."'..,.,'.,,.''''".,,'''',~,,,..,'''''''-''''''.^''!...,>''',"=~"'~'m'''...,-",..",-...,,,,.,,,..,,,..",,,,,,,,,,,~.,,,~ Dennis Eckman Realtor/Partner It's an honor and privilege to serve each of my clients. Growing up in the Carlisle area, I had great parents who taught me valuable concepts like "The Golden Rule.. I live by it in my personal and professional life and I am ready to serve you as a seller or buyer of real estate. " ~'-'>"""'.'-""-"'>'^"~'~"'"""'''-'''''''~--''"''"~~''..".,.".""..... .p,'".,-'.'.-.....,...,."","'..,~'".~<.,,_, ',."'.'~.,'.~"..w.,,"',.',,.'.....,. ..,,~~.,,_.,,""'_~."'" "~"q'_'",,, Matthew D. Madden, Realtor As a proud new member of the Hooke, Hooke & Eckman team, I am young, hard-wroking and energetic. I will go the extra mile to help you sell your home or find th" one of your dreams .""''''',.,..,.,....".,',.,....'..T'''.,..^'.....''''"'.,,,.,...'''~.,.~''","''',.____~"."..'....''.''n''w'''''~'..'..._~.",'''''"'"''"'\...".,..~...".,..'.."...,.-.,""',~..'.,""y,..-.,.""''''>,'',,.,."....''''''''~P''',..''u~""'~""""'-"',,",'''''''',,,_, Vallery Clouse, Realtor Vallery Clouse comes to Hooke, Hooke & Eckman with over 5 years of expertise, and a closing volume of $14 million. Valley was born and raised in Carlisle, making her extremely knowledgable with the Carfisle area. Her goal in the industry is for complete customer satisfaction, in every transaction. Vallery looks forward to helping you with ail your real estate needs whether you are in the market to sell or buy. p.8 Online N0wslcttcr Mar 27 04 12:04p Hooke Hooke and Eckman p.8 717 248 1822 """,,,~~,,,,,<"""',,,<...,",..,,.;~,,\.,,.,,,.,~,,,,,..-,,...,,.,,,,,,.",,,,,,....""'^'''''~''''''''''''~''''''''~'<'''''''''''''''''W''''''''~''.'''''''~''''''''.''''''''_".""'''''''''''''n'^,''''''''.<"""",,,,,,w,,,,-,,,,,,,,,,,,,-,,,,,,,,,,,,,''''''"~.''"'''''''''\''''''~.~'',".",,,.;,, Dawn Shughart, Realtor Dawn Shughart is a 5 year veteratn of the Real Estate industry in the Carlisle area. Working dilig,ently and being totally available to her buyers and sellers, Dawn has dosed over $25 million of Real Estate. Dawn is excited to be part of a growing and ambitious real estate company. John McAdoo, Realtor John and his wife Cathy are both natives of Carlisle. John background is multi faceted with ~: years in the military, master degree in education, retirement as a teacher and several years of experience in the housing industry including construction and sales. Heather Hurley, Realtor As a young and local native to the Carfisle area, Heather is eager to succeed in dedicating quality service to homeowners and seekers in the market of real estate. I'm motivated and enthusiastic about making a fresh start into a new career that takes customer service and sales 1to a level of increased challenge and reward. Home.. Sales Team. Real Estate Listings. Online Newsletter" Contact ,~.,""","""'" '" .'., ,~, ,. " .. " ....~, ,,',"p,~ .''''. _;~..,", I,.'"'"",",' . ."_ Mar 27 04 12:04p Hooke Hooke and Eckman ~1".,~"." ':;:"":; ~~:~,.~'.':I.~...'~..:~: "~',:,:~:;....,.~- ._ .."~'~'';<":~.:.~~_'_..~.:'' ..,.... ""t,;, ... "',:e .,'~: n<t:. ~ '-";,,:.::~~/ ,~:'~" '.. l:: '. 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O::r::t:.Qtj [3 100 l.2 "''''1-1 rlill~l~ft~~: ~~ency. tbe employing broker may. wIth your consent. designate one or more licensees from the real estate d?Ili--iny_-to represent VOLl. -Other licensees in the company may represent another party and shall not be provIded wIth any confi- _JFJar- i:nformation; The designated agent(s) shall have the duties as Listed above under s~ller agency and buyer agency. _ ;;j~li/designated agency, the employing broker will ~e a d~al.a~ent a~d ha~e the addition~ duties of: .:-!_~:_'~:, . Takincr reasonable care to protect any conftdentlal-iniormatlOn dIsclosed to the licensee. >i:.,"'- Takin~ n:sponsibility to dir~ct and supervise. the business activities of th,~ licensees who represent $e seller and buyer while takingno action that IS adverse or detnmental to either party's interest in the transaction. '~'The desicrnation may take place at the time that the parties enter into a written agreement, but may OCCUf at a later time. .. - '-Regardle~s of when the designation takes place, the employing broker is responsible for ensuring that confidentiarinformation . is not disclosed. }~- :~J?;.;J-~.;,j.r!.-: . ~,LTranSaction~Licensee: , ~'5":';::':'f}:\t:'?~..transaction.lic~nsee i.s a bra.ker or .salesperson who pr?vides communication or docu~ent preparation services or performs i;>~c:(ii'!::iciotfier acts for which a !lcense IS reqUlred WITHOUT beIng the agent or advocate.for eIther the sellerllandlord or the buyer! i~-";;..:..k.",.". .:.~ !fr.-~~..tenant.' Upon signing a writ~en ~g~e eme~t,or dIsclosure 'st.atement, a trans.a ctiOD licensee has the additional duty of limited confi- '~~c'.:, dentiality in that the followmg mfonnatlOn may not be dIsclosed: . ~-~-"-"" ,.. The sellerllandlord will accept a price less than th.e askingllisting price, . I to:,': The buyer/tenant <will pay a price greater than the price submitted in a written offer. f'; The seller/landlord or buyer/tenant will agree to financing terms other than those offered. Other information deemed confidential by the consumer shall not be provided to I:he transaction Iicensee. OTHER INFORL\1ATION ABOUT REAL ESTATE TRANSACTIONS The following are negotiable and shall be addressed in an agreement/disclosure statement with the licensee: . The duration of the employment, listing agreement or contract. The fees or commissions. The scope of the activities or practices. The broker's cooperation with other brokers. including the sharing of fees. ,Any sales agreement.must contain the zoning classification of a property except in cases where the property i~ zoned_solely or primarily to permit single family dwellings. A Real Estate Recovery Fund exists to reimburse any person who has obtained a [mal civil judgment against a Pennsylvania real estate licensee owing to fraud, misrepresentation, or deceit in a real estate transaction and who has been unable tocoUect the judgment ~er exhausting all legal and equitable remedies. For complete details about the Fund, call (717) 783-3658. ~ ACKNOWLEDGMENT Date: I acknowledge that I have received this disclosure. Mq,,,c, S' Gre~~ Print (Consumer ~.J,A Signed (Consum~d-- 'I 3 .,.., . Ot.-j J( S~. Ne.vJ c....J.. fA Address (optional) /1/0'") <:) x . Print (Consumer) Signed (Consumer) Address (optional) ('7) 'lJ '1"1'-( - 18' f.p~ Phone Number (optional) Phone Number (optional) I certify that I have provided this document to the above consumer. Date: :>j <..L /;;>1 , \A<", ,-J I-bokL ~~':nsee) Signed (Licensee) .,_,','...'l i~,dl:; i,; .. ",.;..~ld:. I Adopted by the State Real Estate Commission at 49 Pa. Code !/35.336. Exhibit "C" ;..!.:,:i;:i-11;(~~~f: ,,_/;1; on gnh!!C '~. 'i!J~i ' ,?:,,::;-',; :;.1;: lo1\<r::5~}"_." . ; ..'-~~i1.,:;i;n;")t- ci -i.'J OIV<J t3- . . . i. . . . . . . . . . . . . BUSINESS SERVICES FOR REAL ESTATE (800) 555.3390 - CONSUMER NOTICE THIS IS NOT A CONTRACT CN '~. Pennsylvania Law requires real estate brokers and salespersons (licensees) to advise consumers who are seeking'to sell or purchase resi- dential or commercial real estate or tenants who are seeking to lease residential or commercial real estate where the licensee is work- ing on behalf of the tenant of the business relationships permitted by the Real Estate Licensingand Registration Act. This notke must be provided to the consumer at the first contact where a substantive discussion about real estate occurs unless an oial disclosure has been previously provided. If the oral disclosure was provided, this notice must be provided at the fITst meeting or the fust time a property is shown to the consumer by the broker or salesperson. Before you disclose any' information to a licensee, be advised that unless you select an agency relationship the licensee is NOT REPRESENTING YOU. A business rela.tionship of any kind will NOT be presumed but must be established between the consumer and the licensee. Any licensee who provides you with real estate services owes you the following duties: Exercise reasonable professional skill and care which meets the practice standards required by the Act. Deal honestly and in good faith. Present, in a reasonably practicable period of time, all orfers, counteroffers, notices, and ,communications to and from the parties in writing. The duty to present written offers and counteroffers may be waived if the waiver is in writing. Comply with Real Estate Seller Disclosure Act. Account for escrow and deposit funds. Disclose all conflicts of interest in a reasonably practicable period of time. Provide assistance with document preparation and advise the consumer regarding, compliance with laws pertaining to real estate transactions. ' Advise the consumer to seek expert,a~vice.on matters about the transaction that are beyond the licensee's expertise. . Keep the consumer informed about the transaction and the tasks to be completed. Disclose financial interest in a service, such as financial; title transfer 'and preparation services, insurance, construction, repair or inspection, at the time service is recommended or the.first time the licensee learns that the service will be used. . .' A licensee may have the following business relationships with the consumer: Seller Agency: Seller agency is a relationship where the licensee, upon entering into a written agreement, works only for a sellerllandlord. Seller's agents owe the additional duties of: Loyalty to the seller/landlord by acting in the seller's/landlord's best interest. Confidentiality, except that a licensee has a duty to reveal known material defects about the property. Making a continuous and good faith effort to find a buyer for the property, except while the property is subject to an exist- ing agreement. Disclosure to other parties. in the transaction that the licensee has been engaged as a seller's agent. A seller's agent may compensate other brokers as subagents if the sellerllandlord agrees in writing. Subagents have the same duties and obligations as the seller's agent. Seller's agents may also compensate buyer's agents and transaction licensees who do not have the same duties aod obligations as seller's agents. If you enter Into a written agreement, the licensees in the real estate company owe you ,the additional duties identified above under seller agency. The exception is designated agency. See the designated agency section in this notice ,for more information. Buyer Agency: . Buyer agency is a relationship where the licensee, upon entering into a written agreement, works only for ,the buyer/tenant. Buyer's agents owe the additional duties Qf: Loyalty to the buyer/tenant by acting in the buyer's/tenant's best interest. Confidentiality, except that a licensee is required to disclose known material defects about the property. Making a continuous and good faith effort to find a property for the buyer/tenant, except while the buyer is subject to an existing contract. Diselosure to other parties in the transaction that the licensee has been engaged as a buyer's agent. A buyer's agent may be paid fees, which may include a percentage of the purchase price, and, even if paid by the sellerllandlord, will represent the interests of the buyer/tenant. If you enter into a written agreement, the licensees in the real estate company owe you the additional duties identitied ab?ve under buyer agency. The exception is designated agency. See the designated agency seli:tion in this notice for more information. Dual Agency:. . Dual agency is a relationship where the hcens.ee acts as the agent for both the seller/landlord and the buyer/tenant In the same transaction with: the written consent of all parties. Dual agents owe the additional duties of: Taking no action that is adverse or detrimental to either party's interest in the transaction. Unless otherwise agreed to in writinll. making a continllOll.c.: ::'Inn Or'\("I'; f~it"h ",f-fro.-I" I"ro f;",rl co ......",,"'.. -f....... t....'" ......"'.........-nt I"lnrl ~ I... {}'- i.~... "''' HOOKE, HOOKE & ECK1\1AN LLC. REALTORS 320 S. Hanover Street Carlisle, P A 17013 249-1844 "This analysis has not been performed in accordance with the uniform standards of professional appraisal practice which require val,uers to act as unbiased, disinterested third parties with impartiality, objectivity and independence and without accommodation of personal interest. It is not to - be construed as an appraisal and may not be used as such for any purpose." ~AA.. Seller . ~ 3J~(, lo'-/ Date Xeller ~ A t x ( Date >lzc loL; ate 4 &; ';\0 1. Broker's Fee 2. Preparation of Deed 3. Transfer Tax 4. Seller's Assist to Buyer Home Warranty Municipal Certification Settlement Fee Notary Fees Survey Tax Certifications OvernighUExpress Mail Charges Domestic Lien Search Other Other J 40 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 21 Purchase Price $ 28 29 Total Costs! Adjustments $ 30 31 Estimated Proceeds $ 5. 6. 7. 8. 9.' 10. , 11. 12. 13. 14. Estimated Costs Adjustments (+1-) (e.g., real estate taxes, refund of escrow) t t!1-r~ TOTAL ESTIMATED COSTS/ADJUSTMENTS $ 32 33 Seller's Estimate of Mortgages, Equity, and Other Loan balances, liens, assessments, etc. $ 34 38 ESTIMATED NET PROCEEDS TO SELLER $ 36 '.' ".'~ \. ",,' .,~', , Charges $ $ $ $ $ $ $ $ $ $ $ $ $ $ .2~b1Gf.PO ~ _ Q<l fOqq~OO ,;;:?S_ 00 2..5".00 ~.~~o $ $ q(J'(, ?cD~ O-J DO 21/ Ol(~~ ' 3 'gO, g~ 7, cJC) ;;;. 7ioQ:)o ~Q fO},58"1- . 37 The estimated pro~eeds do not take into account any other mortgages, liens, assessments or other obligations which may be 38 against the Property or the Seller. 39 "" The ahove figures are approximated closing costs and will be adjusted as of d"te of final settlement, if necessary. 41 " IIWe underst"nd and have received a copy of these estimated closing costs hef,Jre signing the Agreement of Sale. 43 44 48 '" 47 ... " 50 51 " 5.1 54 SELLER ~ 1:J. --d4-1- SELLE~ SELLE ' BROKER (Companv Name) .~ I~(Q d ACCEPTEDBY~r~ cc.h---.-.....- I h", g<7'~ DATE V.:J.6/cY-/ 55 58 57 " DA;rE DAM DnE 3LuJo'-t 7 1. 10 11 12 13 14 2. 15 16 17 18 19 LISTlNG CONTR.\CT EXCLUSIVE RIGHT TO SELL REAL ESTATE This form recommend d and approv d for, but not restricted to use by, the members of the Pennsylvania Association of REALTORS~ (PAR). LL ~ f~ . XLS rJ I:C/rl Yh...~ 1 BROKER (Compan ) 2 LICENSEE{S) 3 SELLER ,... Gn 4 Does SeUer have a Listing Contract with another Br 5 If yes, explain: , ? D. Yes ~. PROPERTY . Address j!JCj lJ'f~"-' jh:/1f1 Mtmicipality (city, borough, township) County Zoning Identification (Tax ID #; 9'~ ~fOOQ = LISTED PRICE $ _e:: ~"rY'"<!I' l5~r4J':1L School D1Stri tv e-<,J-S. ~ f ,Co >!jresent Use ook, Page, Recording Date) STARTING & ENDING DATES OF LISTING CONTRACT (ALSO CALLED "TERM") A. No Association ofREALTORS@ has set or recommended the term of this contract. By law, the length or term of a listing con- tract may not exceed one year. Broker and SeUer have discussed and agn:ed upon the length or term of this Contract. B. Starting Date: This Contract starts when, igned by Broker and Sel er, unless otherwise stated here: C. Ending Date: This Contract ends on 20 3. DUAL AGENCY Seller agrees that Bro er m y also represent the buyer(s) of the Property. The Broker is a DUAL AGENT when 21 representing both Seller and the buyer in the sale of a property. ~ 22 4. bESI9NATED AGENCY . . ~23 bJ.--1'!~pplicable )""' {, ip/" Applicable. Broker may designate licensees to represent the separate interests of Seller and the buyer. Licensee (identifiecl ''I '. '. above) is the Designated Agent, who will act exclusively as the Seller Ag<:nt. If Property is introduced to the buyer by a licensee 26 in the Company who is not representing the buyer, then that licensee is aulhorized to work on behalf of Seller. If Licensee is also 27 theBriyer's Agent, then Licensee is a DUAL AGENT. "5. BROKER'S FEE No Association of REALTORS@ has set or recommended the Broker's Fee. Broker and Seller have negotiated 29 the fee that SeHer will pay Broker. Broker's Fee is ~% of the sales price AND $::J '1 61 ~/.= , paid by Seller. 30 6. COOPERATION WITH OTHER BROKERS .; 31 Licensee has explained Broker's company policies about cooperating with other brokers. Broker and Seller agree that Broker will pay 32 from Bro!s>r's Fee a fee to another broker whn procures the buyer, is a member OM Multiple Listing Service (MLS), and who: 33 A. ~represents Seller (SUBAGENT). Broker will pay. ::3 6 oflfrom the sale price. 34 B. ~presents the buyer (BUYER'S AGENT). Broker will pay -:3c{o of/from the, sale price. 35 A Buyer's Agent, even if compensated by Broker for Seller, will n:present the interests of the buyer. " C. 0 does not represent either Seller or a buyer (TRANSACTION LICENSEE). 37 Broker will pay oflfrom the sale price. 38 7. PAYMENT OF BROKER'S FEE 39 A. Seller will pay Broker's Fee if Property, or any ownership interest in it, is sold or exchanged during the term of this 40 Contract by Broker, Broker's salespersons, Seller, or by any other person or broker, at the listed price or any price accept- 41 able to Seller. 42 B. Seller will pay Broker's Fee if a ready, willing, and able buyer is found by Broker or by anyone, induding Seller. A willing buyer 4J is one who will pay the listed price or more for the Property, or one who has submitted an offer accepted by Seller. 44 C. Seller will pay Broker's Fee if negotiations that are pending at the Ending Date of this Contract result in a sale. 45 D. Seller will pay Broker's Fee for a sale that Occurs after the Ending Date of this Contract IF: 46 (I) The sale occurs within ~ D of the Ending Date, AND 47 (2) The buyer was shown or negotiated to buy the Property during the tenn of this contract, AND '" (3) The Property is not listed under an "exclusive right to sell contract" with another broker at the time of the sale. 49 E. If a buyer signs an agreement of sale then refuses to buy the Property, or if a buyer is unable to buy the Property because of fail- so ing to do al~e things required of the buyer in the agreement of sale (buyer default), Seller will pay Broker 51 , <)0 oflfrom buyer's deposit monies, OR the Broker's Fee in Paragraph 5, whichever is less. 52 F. If the Property or any part of it is taken by any government for public use (Eminent Domain), Seller will pay Broker's Fee from 53 any money paid by the government. 54 G, If a sale occurs. Broker's Fee will be paid upon delivery of the deed or other evidence of transfer of title or interest. If the Property 55 is transferred by an installment contract, Broker's Fee will be paid upon the execution of the installment contract. XLS Page 1 of 4 m REALfOR'" Pennsylvania Association of REALTORS'" COPYRIGHT PENNSYLVA.l,(IAASSOCL~TION OF REALTORSI3 2003 Il/03 Th.Vok:e""R...lEal:Jlh.ln~~""" ANY CHANGES TO THIS PAGE MUST BE MADE AND INITIALED ON EACH COpy 56 8. DUTIES OF BROKER AND SELLER 57 sa 59 50 61 62 53 64 65 66 ., 58 9. 69 70 71 72 73 A. Broker is acting as a Seller's Agent, as described in the Consumer Notice, to market the Property and to negotiate with poten- tial buyers, Broker will use reasonable efforts to find a buyer for the Property. B. Seller will cooperate with Broker and assist in the sale of the Property as asked by Broker. C. All showings, negotiations and discussions about the sale of the Property will be done by Broker on Seller's behalf. All writ- ten or oral inquiries that Seller receives or learns about regarding the Property, regardless of the source, will be referred to Broker. D. If the Property, or any part of it, is rented, Seller will give any leases to Broker before signing this Contract. If any leases are oral, Seller will provide a written summary of the terms, including amount of rent, ending date, mid Tenant's respon- sibilities. E. Seller will not enter into or renew any leases during the term of this Contract without first giving notice to Broker, :T I I i I I' t BROKER'S SERVICE TO BUYER Broker may provide services to a buyer for which Broker may aocept a fee. Such services may include, but are not limited to: deed/document preparation; ordering certifications required for closing; financial services; title transfer and preparation servic- es; ordering insurance, construction, repair, or inspection services. Broker will disclose to Seller if any fees are to be paid by Buyer. ' '1 74 10. BROKER NOT RESPONSIBLE FOR DAMAGES 75 Seller agrees that Broker and Broker's salespersons are not responsible for any damage to the Property or any loss or theft of per- 76 sonal goods from the Property unless such damage, loss or theft is directly caused by Broker or Broker's salespersons. 77 78 11. DEPOSIT MONEY , ' , .~ 79 A. Broker, or any person Seller and the buyer name in the agreement of sale, will keep all, deposit monies paid by, or for the ..kif : buyer in an esCrow account until the sale is completed or the agreement of sale is tenninated. If held by Broker, this escrow' "'<.. acoount will be held as required by real estate-licensing laws and regulations. Seller agrees that thepersoIl keeping the deposit monies may wait to deposit any uncashed check that is received as deposit money until Seller has accepted an offer. B. If Seller joins Broker or Licensee in a lawsuit for the return of deposit monies, Seller will pay Broker's and Licensee's attor- neys' fees and costs. "\ . 80 81 '2 53 8' as 86 12. OTHER PROPERTIES Seller agrees that Broker may list other properties for sale and that Bioker may show other properties to prospective buyers. 87 86 89 13. CONFLICT OF INTEREST ' '" A conflict of interest is when Broker or Licensee has a financial or personal interest where Broker or Licensee cannot put Seller's interests before any other. If Broker, Lioensee, or any of Broker's salespeople has a confliot of interest, Broker will notify Seller in a timely manner. 91 15. SELLER WILL REVEAL DEFECTS & ENVIRONMENTAL HAZARDS A. Seller (including Sellers exempt from the Real Estate Seller Disclosure Law) will disclose all known material defects andlor environmental hazards on a separate disclosure statement. A material defect is a problem or condition that: (I) is a possible danger to those living on the Property, or (2) has a significant, adverse effect on the value of the Property. The fact that a structural element, system or subsystem is near, at or beyond the end of the normal useful life of such a struc- tural element, system or subsystem is not by itself a material defect. ' B. If Seller fails to disclose known material defects andlor environmental hazards: (I) Seller will not hold Broker or Licensee responsible in any way; (2) Seller will protect Broker and Licensee from any claims, lawsuits, and actions that result; (3) Seller will pay all of Broker's and Licensee's costs that result. This includes attorneys' fees and court-ordered payments or settlements (money Broker or Licensee pays to end a lawsuit or claim). 'j ~ "~ , .'~ .~ - ,:; ",;,.j% 92 93 94 14. PUBLICATION OF SALE PRICE 95 Seller is aware that tbe Multiple Listing Service (MLS), newspapers, and other media may publish 'the final sale price 'of the 98 Property after settlement. .97 98 99 100 101 102 103 10' 105 106 107 lOB 109 '<j" .,.,t- .... :;..,)!;' "" XLS Page 2 of 4 ;:;~, ;l,i\ij ':{~ "l~~;):': ,'i" ~",~~. , -'.- ,:; '_C~ ~--; , Al'lY CHANGES TO THIS PAGE MUST BE lYlADE AND lJ.'IITIALED ON EACH COPY j I. 110 16. IF PROPERTY WAS BUILT BEFORE 1978 . . .'.l:-' -_ .0' 111 The Residential Lead-Based Paint Hazard ReductlOn Act says that any seller of property. built;before 1978. must g,Lve:the buyer 111 an EPApamphlet titled Protect Your Family From Lead in Your Home. The seller alsq II!us~t,ll.thebuyer.ani:Lthe.!brokeTiwhat 113 the seller knows about lead-based paint and lead-based paint hazards that are in or on thqlr,operty)'e~g.;old. sdier must t~ll the 114 buyer how the seller knows that lead-based paint and lead-based paint hazards are on th, .property, where the lead-based paint 115 and lead-based paint hazards are, the condition of the painted surfaces, and any other information se\lerknows about lead-based 116 paint and lead-based paint hazards on the property. Any seller of a pre-1978 structure musi also give.the)'~yer any records and 117 reports that the seller has or can get about lead-based paint or lead-based paint hazards in or around the .property being sold, the 118 common areas, or other dwellings in multi-family housing. According to th" Act, a seller must give a buyer 10 days (unless sell- 119 er and the buyer agree to a different period of time) from the time an agreement of sale is signed to have a "risk assessment" or 120 inspection for possible lead-based paint hazards done on the property. Buyers may choose not to have the risk assessment ~r 121 inspection for lead paint hazards done. If the buyer chooses not to have the assessment or inspection, the buyer must inform the 122 .seller in writing of the choice. The Act does not require the seller to inspect for lead paint hazards or to correct lead paint haz- 123 ards on the property. The Act does not apply to housing built in 1978 or later. '" 125 17. RECOVERY FUND 125 Pennsylvania has a Real Estate Recovery Fund (the Fund) to repay any pe~lon who has re,eived a final court ruling (civil judg- 127 ment) against a Pennsylvania real estate licensee because of fraud, misrepr'~sentation. Of deceit in a real estate transaction. The 128 Fund repays persons who have not been able to collect the judgment after trying all lawful ways to do so. For complete details 129 about the Fund, call (717) 783-3658, or (800) 822-2113 (within Pennsylvania) and (717) 783-4854 (outside Pennsylvania). 130 131 18. NOTICE TO PERSONS OFFERING TO SELL OR RENT HOUSING lJ.'I PENNSYLVANIA 132 Federal and state laws make it illegal for a seller, a broker, or anyone to use RACE, COLOR, RELIGION or RELIGIOUS 133 CREED, SEX, DISABILITY (physical or mental), FAMILIAL STATUS (Ghildren under 18 years of age), AGE (40 or older), 134 NATlONAL ORlGIN, USE OR HANDLING/TRAINING OF SUPPORT OR GUIDE ANIMALS, or the FACT OF RELA- 135 TIONSHIP OR ASSOCIATION TO AN INDIVIDUAL KNOWN TO HAVE A DISABILITY as reasons for refusing to sell, 136 show, or rent properties. loan money. or set deposit amounts, or as reasons for any decision relating to the sale of property. ;1'37 .' 138 19. ADDITIONAL OFFERS 139 If asked by a buyer or cooperating broker, Broker will reveal the existence of offers on the Property, unless prohibited by Seller. .1'"' ONCE SELLER ENTERS INTO AN AGREEMENT OF SALE, BROKER IS NOT REQUIRED TO PRESENT OTHER 141 OFFERS. 142 143 20, TRANSFER OF THIS CONTRACT A. Broker will notify Seller immediately in writing if Broker transfers thi:! Contract to another broker when: (1) Broker stops doing business, OR (2) Broker forms a new real estate business, OR (3) Broker joins his business with another. Seller agrees that Broker may transfer this Contract to another broker. Broker will notify Seller immediately in writing when a transfer occurs or Broker will lose the right to transfer this Contract. Seller will follow all requirements of this Contract with the new broker. B. Should Seller give or transfer the Property, or an ownership interest in it, to anyone during the term of this Contract, all own- ers will follow the requirements of this Contract. 144 145 145 147 148 149 150 151 152 153 154 21. NO OTHER CONTRACTS Seller will not enter into another listing contract with another broker that b"gins before the Ending Date of this Contract. 189 160 161 23. CHANGES TO THIS CONTRACT All changes to this Contract must be in writing and signed by Broker and Seller. 185 156 157 22. 158 1&2 1&3 1&4 24. 1&5 1&& 1'67 ENTIRE CONTRACT This Contract is the entire agreement between Broker and Seller. not a part of this Contract. " Any verbal or written agreements thatV;7n,.!"ade before are ~'.J';';';"~' SPECIAL lJ.'ISTRUCTlONS The Office of the Attorney General has not pre-approved any special conditions or additional-teiriiS':ilii:led' by imy parties. Any special conditions or additional terms in this Contract must comply with the Pennsylvania Pl<1\l>:b~1llJl'~;.,99ns,umer Contract . '.' - ~""",..,{.~, Act. 'r "'" - '~-'. ,,1~:':\': - (~ ~, --'''--'._~~'.'t:;":-. . XLS Page 3 of 4 '~~~'~,";'~',:, " 16' 25. MARKETING OF PROPERTY /!aI, '/ Z zoY/ A. Whe? permitted, Bwker, at Broker's option, may use: o--Csale sign c;a...&l5fci ~ign' n Key in office ~k box ILYPrint lelectr'?!!i.c advertising, including photographs ~rty oddress in prinUelettrohIc advertising. B. Broker lld---"'WiIl/O wiIl not use a Multiple Listing Service (MLS) to advertise the Property to other real estate brokers and salespersons. 173 SeIler agrees that Broker, Licensee, and the MLS are not responsible for mistakes in the MLS and/or advertising of the Property. 174 26. ITEMS INCLUDEDINOT INCLUDED IN THE PRICE OF THE PROPERTY A. Included in the sale and purchase price are all existing items permanently instaIled in the Property, free of liens, including plumb- ing; heating; lighting fixtures (including chandeliers and ceiling fans); water treatment systems; pool and spa equipment; garage door openers and transmitters; television antennas; shrubbery, plantings, and unpotted trees; any remaining heating and cooking fuels stored on the Property at the time of settlement; waIl to waIl carpeting; window covering hardware, shades, and blinds; built- in air conditioners; built-in appliances, and the range/oven, unless otherwise stated. Also included: 169 170 171 172 178 176 177 178 t79 180 181 B. The foIlowing items are NOT included in the purchase and price of the Property: H//htknJ h,,,,~ 182 183 C. Items leased by the SeIler: 184 185 185 187 18' 18' 190 191 192 193 194 195 196 197 '98 199 200 201 202 203 204 20S 208 207 208 20' 210 ADDITIONAL INFORMATION (OPTIONAL) TITLE & POSSESSION A. SeIler wiIl give possession of Property to a buyer at settlement, or on -'# ,d-r- B. At settlement, SeIler wiIl give fuIl rights of ownership (fee simple) to a buyer except as fdIlows: (I) Mineral Rights Agreements: (2) Other: ~eIler has: :J tst ceo Mortgage with: ~ ~'1. Amount of balance $ rrd~t?t'; fi1/fPhone: ifpfj 'It/1- 7.57,-/ Acct. #: ' Address: 5:>':<."' "k, , 11'7 o EqUIty Loan WIth: "'7"'J Amount of balance $ ~: Phone: Acct. #: eIler authorizes Broker to receive mortgage payoff and/or equity loan payoff information. from lender(s). D. SeIler has: 0 Judgments o Municipal Assessment o Past Due ,Taxes o Other: $ $ $ . $ E. If Seller, at any time on or since January I, 1998, has been obligated to pay support under an order on record in any Pennsylvania county, list the county and the Domestic Relations Number or Docket Number: 00 ~4n 3;)0;:)21 . TAXES, UTILITIES, & ASSOCIATION FEES A. At settlement, SeIler wiIl pay one-half of the total Rea] Estate Transfer,Taxes, unless otherwise stated here: B. Real Estate Property Tax Assessment $ ~27;.C></O -><.> yearly Taxes $ '1; 7 sS"'_ ~ . Wagellncome Tax $ . p~aPita Tax $ C. Estimated Utilities (trash, water, sewer, electric, gas, oil, etc.): /70 ,jz, jdarl-,,'c). D. Association Fees $ Include: B~INANCING SeIler~t the foIlowing arrangements for buyer to pay for the Property: . Cash onventional mortgage 0 FHA mortgage 0 V A mortgage o SeIler's help to buyer (ifany): 211 . Seller has read the Consumer Notice as adopted by the State Real Estate Commission at 49 Pa. Code ~35.336. 212 Seller gives permission for Broker to send information about this transaction to the fax number(s) and/or e-mail address(es) listed below. 213 Seller has read the entire Contraot before signing. All Sellers must sign this Contraot. 2'4 Return by facsimile (FAX) constitutes acceptance of this Contract. 215 NOTICE BEFORE SIGNING: IF SELLER HAS LEGAL QUESTIONS, SELLER IS AD 216 SELLER'S MAILING ADDRESS: 0 :/1. SED TO CONSULT AN ATTORNEY. /: . / 707.:> 217 21' PHONE: 77L-f - Igf: ~ FA,'{: 'JY1.e~ ~. A"7V DATE 'xATE E-MAIL: ::5 b (. )O~ 219 SELLER ,,}(ELLER 223 BROKER (Company Name) I~.~. rl-E(> ~ /:-L ~ . )(~ . 224 ACCEPTEDBY ~~ .A-......A...::.. DATE "3 (2{,/2Jl! I XLS Page 4 of 4 ~ 8 8 ~5 . . . .. . . . . tt . -- . . . . . BUSINESS SERVICES FOR REAL ESTATE (800) 555.3:390 1 Property Address 10 '1 2 3 Seller r'\ C\ r', G\ r \ h... cl J ~ '"' <. C; ,e.:J.:J 4 A seller must disclose to a buyer all known material defects about property being sold that are not readily observable, This disclosure 5 statement is designed to assist Seller in complying with disclosure requirements and to assist Buyer in evaluating the property being 6 considered. 7 This Statement discloses Seller's knowledge of the condition of the property as of tbe date signed by Seller and is not a substitute for 3 any inspeotions or warranties that Buyer may wish to obtain. This Statement is not a warranty of any kind by Seller or a warranty or 8 9 representation by any listing real estate broker, any selling real estate broker, or their licensees. Buyer is encouraged to address concerns 9 10 about the conditions of the property that may not be included in this Statement. This Statement does not relieve Seller of the obligation 10 11 to disclose a material defect that may not be addressed on this form. 11 12 A material defect is a probiem with the property or any portion of it that would have a significant adverse impact on the value of the 12 13 residential real property or that involves an unreasonable risk to people on the land. 14 SELLER'S PROPERTY DISCLOSURE STATEMENT nr<:_'f..e.J f.\.,,\\S Pc,,\( j:(,J. N~~ C""",b, fA },)o'70 SPD 2 4 , 7 13 14 16 " dYes o No " 19 19 20 20 2t 21 22 33 22 23 3. ROOF b-.+ 010>"\0;:: c"rf.'''"o''- .30 ':'on , 23 24 (a) Date roof installed: Documented? 0 Yes 0 No ~Jn.known q 5Q ~\..,<." h.~",,< r.~"\"'- ~J 24 (b) Has the roof been replaced or repaired during your ownership? ~ Yes [] No 25 (c) If "yes," were the existing shingles removed? E" Yes 0 No 0 Unknown 26 (d) Has the roof ever leaked during your ownership? );;rYes 0 No V (e) Do you know of any problems with the roof, gutters or downspouts? 0 Yes ~No 28 Explain any "yes" answers that you give in this ~ction: c..o-Pfe <' va... \"':J <,. . ....<-[" '. ". J 29 30 "'0"'" ,"of Cl.-, ~,<...\-'~<' 199-::. ';":l.OO~.fe.r'oJ.'" '-"f\~~' <~\- 30 31 4. BASEMENTS AND CRAWl: SPACES (Complete only if applicable) 31 (a) Does the property have a sump pump? 0 Yes "5 No 0 Un.known (b) Are you aware of any water leakage, accumulation, or dampness within the basement or crawl space? .L:::i Yes If''yes:' describe in detail: 0'"'\::, :";~e.. --.1_\...,;..-., \:'~"~,.....,e.-,\ ;~ :J~\-"'<..r ,,--\~ ~~..J n_ "",.-'1\-.. ,,;J~ of "''''.....,,~ (c) Do you know of any repairs or other attempts to control any water or dampness problem in the basement or crawl space? o Yes ~No If "yes:' describe the location, extent, date, and name of the person who did the repair or control effort: 25 26 27 28 29 ~=} s\...\ ...'5, 32 32 34 o No 3J 3S 34 36 35 37 36 37 38 41 o No ;!9""Yes 38 39 40 41 o No 42 39 .. 49 40 5. TERMITES/WOOD-DESTROYING Il'ISECTS, DRYROT, PESTS (a) Are you aware of any termites/wood-destroying insects, dryrot. or pests affecting the property? KYes (b) Are you aware of any damage to the property caused by termites/wood-destroying insects, dryrot. or pests? (c) Is your property currently under contract by a licensed pest control company? ::>KfYes 0 No 43 (d) Are you aware of any termitelpest control reports or treatments for the property in the last five years? 1& Yes 0 No 44 Explain any "yes" answers that you give in this section, including the name of any servicy/treatment provider, if applicable:_ 45 46 r-.,:l Oc.\-\....e. ',,....)e...~~ -\ -~f"'e._\~J, ~~r ,J '....\t.r ......\-';:> rr""\~"-c:. ~l;c. c::r-<=.","~c-\::J -vc:.("'"'\ ""d c.(...;.:...~t~ 46 47 6. STRUCTURAL ITEMS ;~ "'H~~~ "" \<r--:~.) '-' "... \.<<CL 47 (a) Are you aware of any past or present water leakage in the house or other structures? ~Yes 0 No .. (b) Are you aware of any past or present movement, shifting, deterioration, or other problems with walls, foundations, or other struc- 49 tural components? 0 Yes &No 50 (c) Are you aware of any past or present problems with driveways, walkways, patios, or retaining walls on the property? DYes .l8:"No (d) Is your property constructed with an Exterior Insulating Finishing System (EIFS). such as drivit or synthetic stucco? DYes )2!::"No 0 Unknown If "yes," describe any known problems: 45 42 43 '44 50 51 52 51 52 53 53 54 55 54 " 55 57 56 " SPD Page 1 of 4 ~eller Initials: ~ 57 " Explain any "yes" answers that you "give in this.section. "Wben:"e:'{plaining reports to control or repair, please describe the loca- 62 tioo and extent of the problem, aod the date and person by whom'the work ,"'as done. if known: P r l~ r -1-0 -h"....., <.. r 53 64 O..-l.......,~rS' f-".....\...,<>"..)<. ,f\f'(.)> b""'r..:>\-.......... b......\~) -0::......\\ \~.;:..:r.s d~""e c..~ I c:.~.......o\',~......... of: s.....lc... j"ll~ " 7. ADDlTIONSIREMODELS Have you made any additions, structural changes, or other alterations to the property? r3-'Ye~ 0 No 65 If "yes:' describe: ~ ,-' <:. e ~ e. J o~ '" ~ \..., s~'. \ \- ; " I "1 "J ...,- 66 I 59 60 " 62 6J 66 67 (e) ;;r'~y~~::.e e:;r..:fec :.s ffi- flO(;rmg~-mcluillilg'St,w;s?ryr:0':~e~'?~~OZ0C::lJrikTIown 59 60 " 67 68 8. WATER AND SEWAGE (a) "What is the source of your drinking water? B"Public Water o Conununity Water 0 None 0 Other (explain) (b) If your drinking water source is not public: When was your water last tested? Is the pumping system in working order? If "no," explaln: (c) Do you have a softener, filter, or other purification system? If "yes," is the system 0 Leased 0 Owned (d) What is the type of sewage system" 0 Public Sewer ~Individual On--lot Sewage Disposal System o Individual On-lot Sewage Disposal System in Proximity to Well 0 Community Sewage Disposal System o Ten-acre Permit Exemption 0 Holding Tank 0 None 0 None AvailablelPermit Limitations in Effect If Individual On-lot, what type? 0 Cesspool I9'1Srainfield 0 Unknown 0 Other (specify): Is there a septic tank on the Property? g--yes 0 No 0 Unknown If "yes," what is the type of tank? 0 MetaVsteel 19'Cementlconcrete o Other (specify): Other type of sewage system (explain): (e) When was the on-site sewage disposal system last serviced? (I) IS there a sewage pump? 0 Yes 1iYN0 If "yes," is it in working order? 0 Yes 0 No (g) Is either the water or sewage system shared? 0 Yes If "yes," explain: (h) Are you aware of any leaks, backups, or other problems relating to any of the plumbing, water, and sewage"related items? o Yes ~No If "yes," explain: 94 9. PLUMBING SYSTEM (a) Type of plumbing: o Other (explain): (b) Are you aware of any problems with any of your plumbing fixtures (e.g., including but not limited to: kitchen, laundry, or bath- 97 room fixtures; wet bars; hot water heater; etc.)? 0 Yes g-No If "yes," explain: 100 10. HEATING AND AIR CONDITIO\liING 101 (a) Type of air conditioning: g' Central Electric 0 Central Gas Number of window units included in sale Location (b) List any areas of the house that are not air conditioned: S ..... r""""\..........c. r \1:::.:, '1-.... \.... e _ ,}-. ro~ ~ -1..,;;:1- e.. 59 70 71 72 7J 74 75 75 77 78 78 80 81 " " " 85 86 '7 " " 9<l 91 92 93 95 " 97 98 ,. 102 103 104 105 106 107 10' 109 110 111 112 ,113 11. 115 118 117 '18 119 ", sa 69 70 71 72 73 74 7' 76 77 78 78 80 81 " " 84 85 o On-Site Water (Well on Property) \-Vhat was the result of the test? DYes 0 No o Yes B"l'{o o Fiberglass o Unknown J J- J 9 - 0 ;) " '7 ~o " 89 90 91 92 93 B"topper o Unknown 94 95 o Galvanized o Lead o pvc 96 98 99 o Wall 100 101 o None 102 103 104 (c) Type of heating: 0"Electnc ~Fuel Oil 0 Natural Gas 0 Propane (On-site) Are there wood or coal burning stoves? 0 Yes i9"No If "yes," how many? _ Are they working? Are there any fireplaces? B'Yes 0 No If "y~s," how many? l Are they working? lB""Yes Other types of heating systems (explain): o Yes o No 10' o No 106 107 108 109 110 111 112 113 114 "' 118 117 118 119 "0 (d) Are there any chimneys? g"Yes 0 No When were they last cleaned? "- \,,~...... Cl (e) List any areas of the house that are not heated: g/Yes If "xes:' how many? 11103 nQ~-e... Are they working? o No (I) Type of water heating: 0 Electric 0 Gas 0 Solar (g) Are you aware of any underground fuel tanks on the property? If "yes," describe: 0" \ \- "'~ K If tanks are not owned. explain: (h) Are you aware of any problems with any item in this section? If "yes," explain: 0\ \ [] No if Other: Q'Yes o Yes ~ , G'No SPD Page 2 of 4 ~lIer Initials: ~ ,~,;2';> ,,~--.,.,...,,-_..~.. ..-.--......--. , DYes !3l-11"0 121 122 140 , "'J:EN'l'JAND.:~l:ppiiA.NCES INCLUDED IN SALE (Complete Ofl1y if applicable) 123 .~:,:i;nw~~it~plia~t-es-u'ltimatelY included in the sale will be deterrnln~d by negotiation and according to the terms of the 124 ~~fn'drit-bf Sale'. 125 '.0 Electrl.c'Garage Door Opener N~). of Transmitters 125 ~Srnoke Detecwrs How many? ~ 3 Location \........, ev'~l':' (""Q:)~ 127 o Security Alann System ;s10wned 0 Leased 0 Lease Informati'JIl 128 o Lawn Sprinkler No. 0 Automatic Timer 129 o Swinuning Pool D Pool Heater 0 SpaIHot Tub 130 PooVSpa Equipment (list): 131 (f) ~ Refrigerator ff Range i>:K Microwave Oven 1Si Dishwasher 0 Trash Compactor 0 Garbage Disposal 132 (g) 0 Washer 0 Dryer 133 (h) 0 Intercom 134 (i) ;B Ceiling fans No. ~ Location f~(""- 'r 135 UJ 0 Other: 136 Are any items in this section in need of repair or replacement? 0 Yes ~No 0 Unknown 137 If "yes," explain: 133 139 13. LAND (SOILS, DRAINAGE, AND BOUNDARIES) 139 (a) Are you aware of any Ell or expansive soil on the property? 0 Yes 'tB No 140 (b) Are you aware of any sliding, settling, earth movement, upheaval, subsidence:,.or earth stability problel!JS that have occurred on 141 or affect the property? 0 Yes 0 No 142 Note to Buyer: The property may be subject to mine subsidence damage. lY1aps of the counties and mines where mine subsidence 143 damage may occur and mine subsidence insurance are available through: Department of Envuonmental Protection, Mine Subsi- 144 dence Insurance Fund, 3913 Washington Road. McMurray, PA 15317,(800) 922-1678 (within Pennsylvania) or (724) 941-7100 14S (outside Pennsylvania). 146 (c) Are you aware of any existing or proposed mining, strip-mining, or any other excavations that might affect this property? 147 DYes "::8l'No 146 (d) To your knowledge. is this property, or part of it, located in a flood zone or wetlands area? 0 Yes B"No 149 (e) Do you know of any past or present drainage or flooding problems affecting the property? 0 Yes C!f-1\ro 150 (f) Do you know of any encroachments, boundary line disputes, or easements? 0 Yes lQ--'No 151 Note to Buyer: Most properties have easements running aCross them for utmty services and other reasons. In many cases, the 152 easements do not restrict the ordinary use of the property, and Seller may not be readily aware of them. Buyers may wish to 153 determine the existence of easements and restrictions by examining the property and ordering an Abstract of Title or searching 154 the records in the Office of the Recorder of Deeds for the county before entering into an Agreement of Sale. 155 (g) AI;; you aware of any shared or common areas (e.g.,~vewa~bridges, docks, walls, etc.) or maintenance agreements? 156 ~~ O~ . m Explain any "yes" answers that you give in this section: $ ho" oj J.,J,~<: '-' "J 158 1'59 160 161 128 129 130 131 132 133 134 135 136 1:17 138 i41 142 143 144 145 146 147 146 149 150 151 152 153 154 155 156 157 158 1S9 160 14. 161 HAZARDOUS SUBSTANCES (a) Are you aware of any underground tanks (other than fuel tanks) or hazardous substances present on the property (structure or soil) such as, but not limited to, asbestos. Polychlorinated biphenyls (PCBs), Ureaformaldebyde Foam Insulation (UFFI), etc.? 162 DYes i:SJo1.Io (b) To your knowledge, has the property been tested for any hazardous substanCes? 0 Yes (c) Do you know of any other environmental concerns that migbt impact upon the property? Explain any "yes" answers that you give in this section: ~No DYes 163 162 163 164 155 166 167 166 169 170 171 172 173 174 175 175 177 178 179 180 181 B""No 164 165 166 (d) Do you know of any tests for radon gas that have been performed in any buildings on the property? If "yes." list date, type, and results of all tests below: DATE TYPE OF TEST RESULTS (picocurieslliter or working levels) 1"'=-~4v-.. r-(..r"\..J~....... -\..: "'...... .J-o-.,-(. ~...... j 't,~ - ...,-\<~>,...\ ;" :.20'-'> - f'..,~~oJ ~Yes o No 167 168 169 170 171 172 173 174 175 176 177 178 179 180 191 NAME OF TESTING SERVICE (e) Are you aware of any radon removal system on the property? g'Yes 0 No If "yes," list date installed and type of system, and whether it is in working order below: DATE INSTALLED TYPE OF SYSTEM PROVIDER \"")"1)' ""'-l.c,~~ Sj"!,<'''''''' c'"''''\,~ 't<..s.-t WORKING ORDER if Yes 0 No DYes 0 No DYes 0 No 192 SPD Page 3 of 4 Xller Initials: tr'I..)d 182 183 184 las 156 157 188 189 190 (f) If property was constructed"or if construction began, before 1978, you must disclose any knowledge of lead-based paint on the 18J property. Are you aware of any lead-based paint or lead-based paint hazards on the property? 0 Yes [J;I--!<[o 184 If "yes," explain how you know of it, where it is, and the condition of those lead-based paint surfaces: 185 186 (g) If property was constructed, or if construction began, before 1978, you must disclose any reports or records of lead-based paint 187 or lead-based paint hazards on the property. Are you aware of any reports or records regarding lead-based paint or lead-based 188 paint hazards on the property? 0 Yes ~No 189 If "yes," list all available reports and records: 190 205 206 191 191 192 15. CONDOiYllN1UMS AND OTHER HOMEOWNER ASSOCIATIONS (Complete only if applicable) 192 Type: 0 Condominium 0 Cooperative 0 Homeowner Association or Planned Community 193 Other 194 Notice regarding Condominiums, Cooperatives, and Planned Communities: According to Section 3407 of the Umform Condo- 195 minium Act (68 Pa. C.S. ii3407 (relating to resale of units) and 68 Pa. C.S. ii4409 (relating to resale of cooperative interests)] and 196 Section 5407 of the Uniform Planned Community Act (68 Pa. C.S. ii5407 (relating to resale of units)], a buyer of a resale unit in a 197 condominium, cooperative, or planned community must receive a copy of the declaration (other than the plats and plans), the by- 198 laws, the rules or regulatioris, and a certificate of resale issued by the association in the condominium, cooperative, or planned com- 199 munity. The buyer will have the option of canceling the agreement with the return of all deposit monies until the certificate has been 200 provided to the buyer and/or five days thereafter or until conveyance, whichever occurs first. 201 202 16. MISCELLANEOUS 202 (a) Are you aw~ of any historic preservation restriction or ordinance or archeological designation associated with the property? 203 DYes C;;YNo 204 (b) Are you aware of any existing or threatened legal action affecting the property? 0 Yes ~o 205 (c) Do you know of any violations of federal, state. or local laws or regulations relating to this property? 0 Yes ~o 206 (d) Are you aware of any public improvement,' condominium or homeowner association assessments against the property that remain 207 unpaid or of any violations of zoning, housing, building, safety or flie ordinances that remain uncorrected? 0. Yes ~ 208 (e) Are you aware of any judgment, encumbrance, lien (for e:<ample, co-maker or equity loan), overdue payment on a support obli- 20' gation, or other debt against this property that cannot be satisfied by the proceeds of this sale? 0 Yes g/No' 210 (f) Are you aware of any re~o~ including a defect in title, that would prevent you from giving a warranty deed or conveying title to the 211 property? 0 Yes l1VNo 212 (g) Are you aware of any material defects to the property, dwelling, or fi:<tures which are not disclosed elsewhere on this form? 213 o Yes ~o 214 A material defect is a problem with the property or any portion of it that would have a significant adverse impact on the value of 215 the residential real property or that involves an unreasonable risk to people on the land. 216 Explain any "yes" answers that you give in this section: . 217 193 '" 195 196 197 198 199 200 201 203 204 207 20' 209 210 211 212 213 214 215 216 217 218 218 ~9 ~9 220 The undersigned SeHer represents that the information set forth in this disclosure statement is accurate and oomplete to the hest 220 221 of SeHer's knowledge. SeHer hereby authorizes the Listing Broker to provide this information to prospeotive buyers of the prop- 221 222 erty and to other real estate licensees. SELLER ALONE IS RESPONSIBLE FOR THE ACCURACY OF THE INFORMATION 222 223 CONTAINED IN THIS STATEMENT. SeUer shall cause Buyer to be notified in writing of any information supplled on this form 223 224 which is rendered inaccurate by a change in the condition of the property following completion of this form. 22"- ~5 ~ 226 WITNESS LLER ~ -J. ...{)""11 227 WITNESS ELLER 22' WITNESS # SELLER ~ATE 3J ~b )0'1 )tfATE DATE 225 226 227 228 229 230 231 23,2 233 234 2JS 236 RECEIPT AND ACKNOWLEDGEMENT BY BUYER 237 The undersigned Buyer acknowledges receipt of this Disclosure Statement. Buyer acknowledges I:hat this Statement is not a warranty and that, unless 238 stated otherwise in the sales contract, Buyer is purchasing this property in its present condition. It is Buyer's responsibility to satisfy himself or herself as 239 to the condition of the property. Buyer may request that the property he inspected, at Buyer's expense and by quaJitied professionals, to determine the con- 240 dition of the structure or its components. 241 WITNESS 24' I WITNESS 243 WITNESS BUYER BUYER BUYER DATE DATE DATE 229 230 231 232 233 234 236 236 237 236 239 240 241 242 243 EXECUTOR, ADMINISTRATOR, TRUSTEE SIGNATURE BLOCK According to the provisions of the "Real Estate Seller Disclosure Act," the undersigned executor, administrator or trustee is not required to fill out a Seller's Property Disclosure Statement. The executor, administrator or trustee. must, however. disclose any known material defect(s) of the property. DATE 244 SPD Page 4 of 4 244 n~ MORTGAGEIEQUITYLOAN PAYOFF ATTENTION PAYOFF DEPARTMENT l~~\\'>~O!~\~g3 3S D~., f\o\,,",~ '> r A S.o 30 b - o::LsS- LENDER PHONE ~b"";;( 3 '-1_ !? ~'I \ MORTGAGE ACCOUNT NUMBER 0) :\ Y '3:;:{ (,5 11 PROPERTY OWNER Me."" "-. ~ 1h"".-\c-1 <.~~ (, n'::, 5 SOCIAL SECURlTYNUMBER(S) U?;;:1. - '-ic1- g'j\::?;, ).:JI - (,'-1-'74 &'.:< PROPERTY ADDRESS Ii)~ rJr"-fe.\ p,:,\\> Pc.c-'--<. y<.J. Ne---.J C~--J,. ,,-\\c~,J f'A (iO'l1..::> LENDER NAME LENDER ADDRESS We have contracted to sell the above mentioned property. Please c()nsider this letter our notice of intent to payoff our mortgage. This letter is our authorization to release a payoff statement and all information which may be requested concerning the balance due on the above referenced loan account to Hook, Hooke & Eckman LLC WE understand that there may be a charge to fax the payoff. It is necessary to get the payoff as soon as possible after the last payment is recorded so settlement can proceed on time. X~k..A~ I Seller Signature 3):<(.,)0'--1 Witness Xeller Signature Witness MALADY & WOOTEN PUBLIC AFFAIRS 604 North Third Sireet Harrisbu.rg, PA 17101 717 236.9600 717 2369696 FAX April 29, 2004 Sandra Meilton, Esquire Tucker Arensberg PC III North Front Street Harrisburg, PA 17108-0889 Dear Attorney Meilton: I would like to follow-up with you on a recent conversation I had with Maria Gregg on the status of maintenance and the sale of property at 109 Drexel Hills Park Road, New Cumberland. Since the actual settlement date for the sale of our home to the Gregg's in mid-January, we have had no interaction with Mr. Gregg. Maria Gregg has been the only contact person for issues relating to the care and maintenance of their home, for rental payments and for their attempts to re-sell the home. On approximately six occasions over the last two months, Mrs. Gregg has been the only individual involved with showing the home to prospective buyers. On one separate occasion, she spent the better part of a Sunday afternoon with an interview of a prospective real estate agent and followed that up with an evening meeting at our residence later that week. Mrs. Gregg has shown a great deal of sensitivity to our situation of being a renter at their property. When she had taken the initiative to attempt to sell the home on her own, she placed a sign at the top of the driveway for the property that said "for sale by owner." After we had indicated to her that we had received several inquiries and interruptions Exhibit "D" April 29,2004 Page 2 at their property throughout all times of the day, Mrs. Gregg (without our asking) removed the sign to avoid any further inconvenience to my wife and family. I hope this letter provides clarification to you, and I remain available should you have any additional questions. Sincerely, JFM/sap (....{L~R. t!lF.MaladY ~ CERTIFICATE OF SERVICE "7 -14. AND NOW, this day of May, 2004, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby certify that I have this day served a copy of the within document, by first class mail, postage prepaid, addressed as follows: Ann V. Levin, Esquire 4431 N. Front Street Harrisburg, PA 17110 ~ fJ:~\ ~~ 68251.1 ""c f~' - , (") ~; r-> g .r- ::r: -;-",. -. ~. o --n r:~? :-J . ~ =r.'iJ rn r:: r-t1 ""n -''JT ~:)C) ~-~~ ~t~, -,;rn ~,-~ ?I;~ C) C:' \7 THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant : IN DIVORCE RULE AND NOW, this --rz.- day of ~ ' 2004, in consideration of '- the Petition for Immediate Relief filed by Defendant, a Rule is issued on Plaintiff as to why Defendant's Petition should not be granted. RULE returnable -J 6' days after service on Plaintiff and/or his counsel. /1 J. oj-13 -()4 ,".i'''' ''0 t\-~\ l (\\.....!hP~~ \,i"'\~;\ .,t',,::;\~: ;::'::'.1,1<""\ , ",\"r;-, . ,:'.' .1'\', :J l~lI" :'.) . ~G :~ \{d ~ \ ~\:\\ ,,~~? .'. l"'" .",).' :10 \"",/1""':\.5' \\.y"G =-" r,':;"-l .l,;,-:~~,.' \. .....C\-i\\-\ -J,-l\:'\:'o- '. :J'~' THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 04-785 CIVil TERM MARIA S. GREGG, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF DAUPHIN ) Sl- AND NOW, this ~ I day of , 2004, personally appeared before me, a Notary Public in and for the afo said Commonwealth and County, Gloria M. Rine, paralegal to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on May 14, 2004, she mailed a certified copy of a Rule in connection with the Petition for Immediate Relief to Ann V. Levin, Esquire, by certified mail no. 7099 3400001636236023, return receipt requested, and the same was received on May 17, 2004, as indicated by the return receipt card which is attached hereto. #r- /fl~ Sworn to and subscri~d befo me this "",,' / day of , 2004. (SEAL) NoIariaI SeoI Pld1e PaltI Thomas, NoIBry NIle CllyOl Hantsburg, ~ ClMIy My Coo,. ,...... ElcpiI8I MlIr.14, iIlC11 MemIler. Pennsylvanl. AnodIlIlln OfNlllllIWiS U.S. Postal ServIce CERTIFIED MAIL RECEIPT (Own" fll M,IIIOnly Nil f,hUfdll( I' CovPfdye Plovn}edj rn ru Cl ...D l I Postage $ Certified Fee Postmark Return Receipt Fee Here (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ 5/I4/04 rn ru ...D rn ...D ,..,. Cl Cl Cl Cl ~ lT1 RecJif!mt's Name (Please Print Clearly) (to be completed by mailer) ------AtM-y.---I.EVIN~uESQiJlEE___uu___ a- St-41rlto'N.PO~ ST a- Cl -Ciiy.-~flURGupAu17Uo----u----------uu---- f'- 1. :lVN.er ~. HtiliWl~ ,PA 171.10, ';'''::;;--'::~f!~~,~;''9~'''~'-~~:~~# ~~. ';"'j' .,',~, ..., 0 " = = ,I .r- -< - ~g -..... ::;:jtP. ):::>" rn _, -~ '""C'm ''? ~~ N :u &" C),(J ;.::0 -0 ~~; ~~ =t: <::,iTI (:-? '.. z ... :<! ~...... 7640-1-4lMay 26, 2004 3:39 PM THADDEUS B. GREGG, PLAINTIFFIRESPONDENT IN THE COURT OF COMMONS PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-785 CNIL TERM MARlA S. GREGG, DEFENDANT~ETITIONER CNIL ACTION - DIVORCE ANSWER TO PETITION FOR IMMEDIATE RELIEF AND NEW MATTER AND NOW, comes Plaintiffl'Respondent Thaddeus B. Gregg, by and through his counsel Smigel, Anderson & Sacks, LLP, and files this Answer to Petition for Immediate Relief and avers as follows: 1. Admitted. 2. Admitted. By way of further answer, the parties' actual date of separation may be an Issue. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted in part and denied in part. It is admittl~d that the real estate is a historic property listed on the national register. It is denied that Defendant has carefully researched the real estate market to select a realtor who handles properties ofthis nature. By way of further answer, Defendant informed Plaintiff that these realtors actually left a message on her answering machine and they "sounded nice." 8. Admitted. 9. Denied. It is denied that the Defendant carefully researched the real estate market or that she enlisted the aid of a "qualified individual." By way of further answer, Mr. Polon is a personal friend of Defendant and has no clear real estate expertisl~. 10. Denied. It is denied that the realtors selected by Defendant were the most qualified in the area to handle the sale of the property at issue. By way of further answer, Plaintiff is unaware of any comparative research with other realtors that Defendant did. II. Admitted in part and denied in part. It is admitted that Plaintiff was provided with some information regarding the realtors selected by Defendant, but it is denied that Plaintiff was provided with a listing agreement. 12. Admitted. By way of further answer, Plaintiff believes that there are other qualified realtors who will charge the parties a lower fee than that sought by Hook, Hook & Eckman. 13. Admitted. By way of further answer, Defendant has refused to allow Plaintiff access to the home and refused Plaintiffs offers to help, manage, or care for the property. Plaintiff believes that there is very minimal management required. 14. No response required. To the extent a response is required, Defendant recently inherited approximately $300,000.00 and will be more than able to make the monthly mortgage payment. 15. No response required. NEW MATTER 16. Defendant/Respondent, Thaddeus B. Gregg, repeats and realleges the averments in paragraphs I through 15, which are incorporated by reference herein. 17. Plaintiff has been in contact with a realtor from Howard Hanna since March 2003 who will list the property and take a five percent commission instead of six percent. 18. There is a pre-payment penalty for the mortgage associated with the property. Plaintiff estimates this will cost the parties $12,000.00 when the property is sold. 19. Plaintiff believes that Howard Hanna has a broader marketing ability, i.e. website, special and listing showcasing in advertising. (See Exhibit A). 20. Plaintiff believes that the realtor he has selected will be able to sell the property more quickly than the realtors selected by Defendant. 21. Defendant has refused to even consider Plaintiff s proposed realtor. 22. Plaintiff has made a good faith comparison of the services and fees of each realtor and feels that it is in both parties' best interests to list the propeny with Howard Hanna. WHEREFORE, it is respectfully requested that the Court dismiss Defendant's Petition for Immediate Relief. Respectfully submitted, SMIGEL, ANDERSON & SACKS Date: ') - ~ b - 0 f By: J, ~ u LL___) &Levin, Esquire J.D. #: 70259 James R. Demmel, Esquire J.D. #: 90918 4431 North Front Street Harrisburg, P A 1711 0 (717) 234-2401 Attorneys for Plaintiff/Respondent VERIFICATION I, Thaddeus B. Gregg, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. (' )Z.,JOV( Date: award anna. DETWEILER REALTY@ THESE TWENTY lWO POSITIVE ACTIONS ARE OUR PLEDGE TO YOU TO SELL YOUR HOME QUICKLY AND AT THE HIGHEST POSSIBLE PRICE. ; G---~J~/ PERFORMANCE PLEDGE '-'-'-'-~~" 1. 100% MONEY BACK GUARANTEE. We pledge to offer this to prospective buyers if your home qualifies. Z. MARKET EVALUATION. Our knowledge of the market enables us to determine a realistic opinion of the market value of your home. We pledge to use this knowledge in helping you competitively price your home by providing you with a Master Market AnalysissM. 3. NATIONWIDE EXPOSURE. As a member of the Cendant Real Estate Network in the Harrisburg Area, we pledge that reIocatingfamilies moving to this area will have an opportunity to see your home. 4. PROGRESS REPORTS. We know that you want to be kept informed of our sales efforts, so we pledge you a minimum of two progress reports a month. 5. QUALIFIED BlNERS. Our experience enables us to separate lookers from buyers, and we pledge to vigorously pursue qualified buyers for your home. 6. FOR SALE SIGN. The Howard Hanna Detweiler Realty "For Sale" post sign is widely recognized and respected throughout this area and has proved to be an effective source of buyers. We will place one in your yard, with your permission. 7. INfERNET. We pledge to market your home on the internet everyday until it sells. 8. PRINT ADVERTISING. We pledge to promote the sale of your home with print advertising. 9. PROPERTY PREVIEW. Howard Hanna Detweiler Sales Associates primarily responsible for selling your home will preview your home as soon as practicable, so that they may better know your homes features and benefits. 10.MULTIPLE LISTING SERVICE. We pledge to place your home in Central Penn Multi-List, Inc., thus enlisting the sales assistance of as many as 1 ZOO sales people in our market area. 11. HOWARD HANNA DETWEILER REALTY TRADE PROGRAM. Our h'ade program enables a prospect to buy your home before selling his present home. We pledge to offer this Plan to qualified buyers when circumstances warrant. IZ.ADVANCED EQUITY LOAN. Our advanced equity loan program solves the dilemma of buying before you sell. We pledge to offer this plan to qualified buyers when circumstances warrant. 13.APARTMENT DWELLERS TRADE-IN PROGRAM. This program enables renters to purchase your home without the worry of both a mortgage payment and rental payment. 14. SELLING PREPARATION. You can help us speed the sale of your home at a better price. We pledge to give you a list of significant ways you can help. 15.HOME WARRANfY. If your home qualifies, we pledge to offer a Home Warranty to you, a plan designed to give your home a "competitive edge". 16. PREARRANGED SHOWINGS. We pledge to arranze showings as far ahead of time as possible to allow you to prepare for the showing. 17. A V AlLABILfIY. Our full time sales staff is available seven days a week to show your home. We pledge that your home will never be off the market as long as we are responsible for its sale. 18. FINANCING. As financing is often the key to making the sale possible, we pledge to you the up-to-date financing knowledge necessary to assist the buyer in purchasing; your home. 19.IN.HOUSE MORTGAGE SERVICES. As a mortgage correspondent, we offer the buyer the convenience of one-stop shopping and the ease of coordination with one of our lenders. 20. NEGOTIATIONS. We pledge to use our "professional" influence to negotiate the highest price possible for your home, 21. BINDING CONTRACT. As the sale of real estate in our state must be in writing, a binding legal contract will be written for your protection. Z2.SETILEMENT DEPARTMENT. We pledge you the skilled services of our Settlement Department, staffed with personnel whose sole task is to handle the myriad of details that go into a smooth settlement. "PENNSYLVANIA, OHIO AND WEST VlRGINIA'S LARGEST FAMILY OWNED FULL SERVICE REAL ESTATE COMPANY" When you need it SOLD! Victor Plitt sold 100% of his listed homes in 2002, earning him aJales achievement award. Helps people own Real Estate. Compare him to other REALTORS'. Give Victor Plitt a ca . and give him a five minute Interview over the phone. oward anna. DETWEILER REAL TY@ 3310 Market Street Camp Hill, PA 17011 717-761-19'10 www.howardhanna.com Direct: 717-421-6341 E-mail: vlctorplitt@comcast.net A1EMBEa OF . National of REAl. Associat" TORS- IOn . PennsYI of REA Vania Ass . LTORS_ oClation . C?reater Ha . Clation f Tnsburg A o REALTO sso_ . Mill' RS- IonD I o lar Club Member CLtsSE,s lIV . REAL. ESTATE r . . REAL. ....,w ESTATE . FAIR I-l APPRAISAL . OUSING ACT Up to d ate On LE GAL ISSUES Victor P'li D' tt U"ect (717) . Born in 1%3 . 421-6341 Ma . , VICtor h rned "'ith th as Ihed . fro ree h I In Man'l m CUmbe I C I dren h -, and, No h rand V I ,e no",. It Cat I" a ley in ] 98 reSIdes in C 0 Ina and C Dedicated 10 2 and earned h' amp I-lm. Vict entral PA. An eXPetie Goon S"n'h IS real estate I' Or graduated . nced ..... ,C:ll Icells . In sales. C . agent "'ith . e In I 990 SER onslde h . oVer . . VICE PRO'n rs 1mself a a mmion doll , vlD ars . Offering Exclusive Value- Aa~ded Programs! 100% Money Back Guarantee * If for any reason the buyer of a home listed by Howard Hanna is not satisfied, Howard Hanna will buy back the home for 100% of its purchase price, Benefits Home Sellers . Sets the home apart from others in the market. . Buyers are comfortable with a guarantee of knowing that Howard Hanna believes in the value of the home. . Results in homes selling faster than competing properties. . Results in homes selling for the highest fair market value. Benefits Home Buyers . Gives buyers confidence in the value of the home they are purchasing. . Overcomes many objections to buying. . Reassures out-of-state buyers who are unsure of neighborhoods or the local market. . Gives confidence to increase the offer to meet the seller's price, . Shows that, unlike any other ,,:a! estate company, Howard Hanna stands behind the property for 100% of the ,.Iue. . Pie.., ",U H_nl H.n.. Re4lhte Sm>Ues for i/et4ih on how yon m.y qn.lify for this exelnsi.. 0.1.. ....4 prolJ"'m. Advanced Equity Program Offered by Howard Hanna Financial Services, our exclusive program makes it possible for a buyer to purchase your home before selling their present home. Apartment Dwellers Trade- In-Program This enables renters to purchase your home without the worry of having both a mortgage and rental payment. We will assume the renter's lease so that they are free to close on the sale of your home. Powerhouse Mortgage A mortgage program that allows the buyer to purchase your home with no down payment on a thirty-year fixed rate loan. Home Warranty Available from Home Security of America, Inc., the buyer is relieved of concerns about the condition of your home and its mechanical systems, resulting in a faster sale. ~ Market Your Home...Like No Other! ;.; H ,\ }~ ;'~ ,iI, ., n Howard Hanna Real Estate Services uses a wide variety of advertising vehicles to market your home like no other real estate company can, With our intense and targeted programs, Howard Hanna delivers, Television - Showcase of Homes One of our most successful marketing programs airs Sunday mornings. Television is the strongest advertising vehicle because it reaches morc viewers and households in the shortest amount of time. This benefits you because the more people that see your home, the more likely we are to facilitate a sale with the most favorable conditions to you. The featured homes appear on our award-winning websitc, www.howardhanna.com. Pre-Marketing We will work with you to determine the general and specific buyer markets that are best suited to buy your home. This targets Qur marketing effort so that we can sell your home morc quickly. Open Houses We have found that many sales arc "impulsive" and open hOllses enable us to generate more buyers from those who are not really seriously looking for a home. Open houses also expose your home to buyers. The weekly list of open houses is advertised in newspapers and on our wehsite. Multi-List Service We will market your home through the appropriate multi-list service. This exposes your home to experienced real estate agents that are working with the most qualified buyers in the marketplace. Present Sheets/Brochures Promotional materials are created for home buyers and distributed through open house tours and special mailings. These are designed to help prospective buyers remember your home more than any other after viewing. ~s Great Estates 1< ~dA;~Xl~~j Howard Hanna's exclusive affiliation with Christie's Great Estates, the world's largest network of independent real estate brokers specializing in the marketing of exclusive properties, increases the exposure of your real estate to affluent buyers and sellers both locally and internationally. The affiliate network of Christie's Great Estates includes 120 market share leading real estate firms with 400 offices and 12,000 real estate agents. Newspaper We offer the greatest newspaper exposure of any real estate company in Pennsylvania, Ohio, West Virginia and New York with advertising in more than 43 publications. Target Marketing;Direct Mail We have customized mailers and postcards to market your home to the right buyer using the most sophisticated database programs available. Our direct mail is followed up with phone calls so that we secure potential buyers for you. We are proactive and do not wait for buyers to call us - we go after them for you. \ ,; i' d ,., '" '.1 j' i Homes Guide I Every issue of every market area we serve includes our listings of homes. I This provides daily photo advertising that will generate interest from 1 serious buyers. , ! Appointment Center Through the use of on-line technology, the home selling process is streamlined, making marketing transactions faster and easier than ever before. Buyers can easily search for properties, make an appointment, make an offer and contact your listing associate, all through the website. i I \ I I ! Signage j Our distinctive grem and , gold sign serves as " 24-hour ! salesperson. Buyers drive through areas to determine where they would like to live. The name of the # I real estate company on the sign will prompt serious. buyers to call about your home and enable us to generate more activity. 1 I i I I \ i \ Up-to-the-minute Internet Site... 1)500,UOO Page Views Per Month... www.howardhanna.com More buyers are "wching the web because they can view the entire home inventory* 1 and now they can do that right at howardhanna.com. We have harnassed the global and technical power of the Internet so that you can view every available home at your conveniencf:, seven days a week, 24 hours a day! Wiil, the web-based technology used to create the Hanna HomeFinder, ~...___~.__..._..._m..__W'______ '...__....___._...__.____ Hma HomeFinder is a new and innmrile way ~f!ales ~~iR.~~~or!~se!rwi~_~E~Ild_~k!l: clients are automatically updated about new on the market properties that meet their requirements via email. Howard Hanna Real Estate Services was the first in the area to have all of their home listings placed on the internet. This user friendly site provides immediate and detailed description of all of our listings with interior and exterior photos. . Homes cltrrently listed ",ith /troken Jmrtieipating in Internet DAta Imlmnge GoHanna.com Howard Hanna Real Estate Services was the first in the area to offer to its associates an intranet system that allows access to information company-wide on each new listing within 24 hours. , i ....,.._~_.....J , ....~ ..___.._. ~_.""_.._..,.~._._"_ '"_.'. __._..._.",._.....__",o<...,.._,."..-_m_'_ What are the benefits of using Howard Hanna Detweiler Realty as your listing broker? 1. We Provide an extensive buyer base bringing in more prospective buyers who have entered into buyer agent relationships, thus maximizing the exposure of the property. 2. We Qualify the buyer, which avoids the waste of time and effort in preparing and showing the property to unqualified lookers, as well as minimizing security risks in showing the property to strangers. 3. We are available for appointments at the buyers convenience, thus increasing the exposure and enabling the seller to continue life as usual with minimal interruption. 4. We know the marketplace, lmabling us to give knowledgeable, professional advice on pricing and market conditions that affect value. 5. We have access to relocation companies and transferees which broadens the buyer base eVlm further to motivated buyers who must buy soon. 6. We provide all documents and disclosures required by law to legally sell your home, thus avoiding legal entanglements. 7. We review and assure that all documentation required for closing is received by the loan ofl1cer, thus avoiding any surprises at closing. 8. We partner with a reputable mortgage company who doesn't charge excessive fees and shares our mission to help get the buyer and seller to settlement. In fact, we have in-house mortgage originators to pre-qualify on short notice. 9. We negotiate the highest price and best possible terms for the seller in an objective, knowledgeable manner. 10. We promote the property in a variety of media using internet, print, direct mail and custom marketing pieces maximizing exposure to the highest number of prospective buyers. 11. We provide secondary marketing available only to real es- tate professionals who have a buyer base through multiple list- ing services, internet, fax and tours. 12. We have access to vendor lists who may be called upon in preparing the home for rharketing, home inspection and appraisal. We have access to professional illppraisal services to establish or resolve value issues. 13. 14. Our expert trouble shooting and problem solving skills mini- mize obstacles and conflicts which could jeopardize a transac- tion such as conflicts in negotiations, mortgage approval, inspections, appraisal, title and closing issues. 15. We facilitate the process to get from listing to fmal settlement allowing the seller to concentrate on other important matters. 16. We provide exclusive Howard Hanna programs affording the seller an edge over the competition. Programs include the Money Back Guarantee, Home Warranty, Apartment Dwellers Trade-in Program, E-home Sales & Equity Advance Program. 17. We adhere to a strict National Codle of Ethics assuring our agents will act in a fiduciary, confidential manner in all aspects of the transaction. 18. We otTer a selling bonus to all How:llrd Hanna agents at no additional cost to seller mobilizing the entire Howard Hanna network to focus on our listings before any others. 19. We otTer experienced management support which provides additional assurance of client satisfaction. 20. We are on the cutting edge of technology with our award winning internet website, the SOurCI~ of choice for today's buyer, which includes the e-homesales appointment center, on-line open house advertising and our gohanna intranet site. 21. All inquiry calls are handled by listing agent who has the most knowledge and motivation to se:ll your property, thereby providing a much higher level of service and commitment. 22. We exercise skill, competence and care in all aspects of the transaction pledging to fulfill our primary goal of serving the needs of our client with the strictest attention to each and every detail of the real estate transaction. 23. We comply with the NEW home inspection law to insure state requirements are met for buyers and sellers. THADDEUS B. GREGG, PLAINTIFFIRESPONDENT IN THE COURT OF COMMONS PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANTIPETITIONER CIVIL ACTION - DIVORCE CERTIFICATE OF SERV][CE I, Ann V. Levin, Esquire, attorney for Defendant in the above referenced matter, do hereby certify that I have served a true and correct copy of our Answer to Petition for Immediate Relief and New Matter upon counsel for Plaintiff by depositing same in the U.S. Mail, first class, postage pre-paid on the :lit, ~ day of May, 2004 addressed as follows: Sandra L. Meilton, Esquire Tucker Arensburg, P.C. III North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 SMIGEL, ANDERSON & SACKS By:-A' / J L') Ann V. Levin, Esquire I.D. # 70259 James R. Demmel, Esquire I.D. #: 90918 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiff/Respondent '" 0 l~ "-""" -1'1 ~- -r_' ::.-: -l U. :';)~ I ., -< rn p.:::. < ,., rn /'..' :.~CJ CU ~3(S -0::: ~-Sl~ -. cn (,) ~--j -( r-"'I ~:o (fj -< THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 04-785 CIVIL TER:M MARIA S. GREGG, Defendant : IN DIVORCE Answer to New Matter, AND NOW comes the Defendant, Maria S. Gregg, by hl3r attorney, Sandra L. Meilton, Esquire and respectfully states as follows in response to said New Matter: 16. No responsive pleading required. 17. Defendant is without sufficient information to respond to the allegations set forth in paragraph 17 and proof thereof, if relevant, is demanded at trial. 18. Defendant is without sufficient information to respond to the allegations set forth in paragraph 18 and proof thereof, if relevant, is demanded at trial. To the extent that a responsive pleading is required, it is averred that Plaintiff recommended the pre-payment penalty clause to Defendant so that she could get a lower mortgage rate when financing the purchase. 19. Defendant is without sufficient information to rE~spond to the allegations of Plaintiff's beliefs set forth in paragraph 19 and proof thereof, if relevant, is demanded at trial. To the extent that a responsive pleading is required, it is averred that with modern technology and the use of the internet by realtors, the Hook, Hook & Eckman Group selected by Defendant has as broad a market as does Howard Hanna. It is further averred that Defendant does not believe that a broader market is necessarily beneficial for marketing the house in question. The property in question is unique and requires a realtor who deals in similar properties. It is further averred that Defendant originally tried a for sale by owner approach and received many calls from individuals who were curious about the property but not truly interested or who would not financially qualify for financing. 20. Defendant is without sufficient information to respond to the allegations of Plaintiff's beliefs set forth in paragraph 20 and proof thereof, if relevant, is demanded at trial. To the extent that a responsive pleading is required, it is averred that Defendant provided Plaintiff with a Listing Agreement from Hook, Hook & Eckman early in April and, therefore, if Plaintiff was truly concerned about the speed with which the real estate was sold, he could have signed the Listing Agreement and the real estate would have been already on the market for the better part of four to six weeks. 21. Denied. It is denied that Defendant has refused to consider Plaintiff's proposed realtor. To the contrary, it is averred that she spoke with the realtor and reviewed the information which he provided to her. After giving careful consideration to the realtor recommended by Plaintiff, Defendant is not satisfied with the realtor's qualifications since as averred earlier in the pleading, the property in question requin~s realtors with the ability to handle the unique property in question. Further, Defendant is uncomfortable with the Hanna Group because of Plaintiff's personal connections with them. By way of further reply, it is averred that Defendant spoke with many realtors and reviewed the qualifications of each of them in an effort to select the best realtor to handle the property in question. 22. Defendant is without sufficient knowledge to respond to the allegations set forth in paragraph 22 in that she does not know what Plaintiff believes is in the parties' best interest. To the extent that a responsive pleading is required, Plaintiff has advised Defendant that he will not sign the Listing Agreement with Hook, Hook & Eckman until all of the property issues in this case are resolved. Defendant believes and therefore avers that Plaintiffs suggestion that Howard Hanna handle the sale of the property in question is simply a method to delay listing the property and thereby putting pressure on Defendant to provide him with a settlement proposition that he finds acceptable. WHEREFORE, Defendant requests that this Honorable Court grant Defendant's request for relief. Respectfully submitted, TUCKER ARENS BERG, P.C. By:.A~A~~~~~ Sandra L. Meilto ,I.D. 32551 P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 DATED: (; -/foL! Attorneys for Defl3ndant 69022.1 VERIFICATION I, Maria S. Gregg, acknowledge that the facts stated in the within document are true and correct to the best of my knowledge, information and beHef. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. :~\lJ,~~ Maria S. Gregg r;r DATED: c,) ~J O~ CERTIFICATE OF SERVICE AND NOW, this 18th day of June, 2004, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby cElrtify that I have this day served a copy of the within document, by mailing same by fax and first class mail, postage prepaid, addressed as follows: Ann V. Levin, Esquire 4431 N. Front St Harrisburg, PA 17110 ~ 171 ,I. ~ II ( ,-; r 1,7/~ GTaila M. Rine r-~ C.=.l L~:;) -'~ <- ~:__.: ....'.... o -" .--< ::r:~ ril-':...i -o~ ::-.0 c.:J () 1 ~~~~ ~8 '" ~-) (Jill ., ~; -< 1'-' ...,., -.'1"" t;,? J::- THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MARIA S. GREGG, DEFENDANT : 04-785 CIVIL TERM ORDER OF COURT AND NOW, this 7--? ______ day of June, :2004, following a review of the pleadings, and being satisfied that there are no facts aHeged that warrant an order of immediate relief, IT IS ORDERED that the petition of Maria S. Gregg for immediate relief, IS DENIED. r~ Court, Edgar 13. Bayley, J. .1\nn V. Levin, Esquire For Plaintiff / 0& -J.3 -() ~ v'8andra L. Meilton, Esquire For Defendant :sal Vir\ A)J\!n(~( ': ,.,..rl" "d 'J II .O! "p.} " I"J 07 ~!nl~ f/nnz l.,.v 1\; uU ),::,'\IOi\JUi-LLOdd 31-11 :iO :(::~:IO~-03l!~:l II II I! II II II II II II I' II I' II II II Ii II II II I I I II II II II THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMONS PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - DIVORCE CRRTlFTCATF, OF SF,RVTrR I, Ann V. Levin, Esquire, attorney for Plaintiff in the above referenced matter, do hereby certify that I have served a true and correct copy of Plaintiffs First Set of Interrogatories upon counsel for Defendant by depositing same in the U.S. Mail, first class, postage pre-paid on the ,~( day of Du-~, 2004 addressed as follows: I II II Ii I' ,I II II II II II II II II II II II II II I: II I I I II II II II Sandra L. Meilton, Esquir<, Tucker Arensburg, P.C. III North Front Street P.O. Box 889 Harrisburg, PA ]7108-0889 SMIGEL, ANDE:RSON & SACKS, LLP By: .uLJ V. Levin, Esquire I.D. # 70259 James R. Demmel, Esquire LD. #: 909]8 443] North Front Street Harrisburg, PA 17]]0 (717) 234-240] Attorneys for Plaintiff ,"",,-,J c,:.~ C:'-' <';:J, f. ,"-" c..c THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMONS PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - DIVORCE CF,RTTFTrATR OF SRRVWF, I, Ann V. Levin, Esquire, attorney for Plaintiff in the above referenced matter, do hereby certify that I have served a true and correct copy ofP]aintiffs First Request for Production of Documents upon counsel for Defendant by depositing same in the U.S. Mai], first class, postage pre-paid on the J I day of ~ ..<~ 2004 addressed as follows: I I I II II II II I[ I, II II II II II II II I II II I Sandra L. Meilton, Esquirle Tucker Arensburg, P.C. 1]] North Front Street P.O. Box 889 Harrisburg, PA ] 7]08-0889 SMIGEL, ANDERSON & SACKS, LLP ByLJJ L ) Ann V. Levin, Esquire LD. # 70259 James R. Demme], Esquire LD. #: 909]8 4431 North Front Street Harrisburg, P A ] 711 0 (717) 234-240] Attorneys for Plaintiff -- c...~ ~ THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Plaintiff, do hereby certify that I served a true and correct copy ofthe foregoing Plaintiffs Answers to Defendant's Interrogatories was served on counsel for the Defendant by depositing same in the U.S. Mail, first class, postage paid, on the ,/ IL., 0 ;, day of fV rr~ , 2005 and addressed as follows: SANDRA L. MEILTON, ESQUIRE TUCKER ARENSBURG, P.c. P.O. BOX 889 HARRISBURG, PA ]7]08-0889 SMIGEL, ANDERSON & SACKS, LLP ByLu~ Ann V. Levin, Esquire LD. #: 70259 443] North Front Street Harrisburg, PA ] 7110 (717) 234-240] Attorney for Plaintiff C) C ~ ,= c-" :P" --c ::v \ -' -\10- ~ ~..,., \.lC -0 r.n :r:.!y :::~:?! 9~ (~~) (') ,~ 'T\ >')1. :-:::.\ :3~ -~, r:-? en ..0 7640-1-4 THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Plaintiff in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Plaintiffs Answers to Defendant's Request for Production of Documents on counsel for the Defendant by placing same in the U.S. Mail, first class, postage paid on the 5' day of ~~L , 2005 and addressed as follows: SANDRA L. MEILTON, ESQUIRE TUCKER ARENSBURG, P.C. P.O. BOX 889 HARRISBURG, P A 17108-0889 SMIGEL, ANDERSON & SACKS, LLP 1 By: Ann . Levin, Esquire LD. #: 7 259 4431 North Front Street Harrisburg, PA 17110 (717) 234-240] Attorney for Plaintiff \ n .-.' ~~ .~-:;;lo W1 "J :;..:.J "-.--: o -"n -. ...,.. fii --d:f' , ;"AJ: -l -.c "4 "1 ?'~ r;-? ;f;""~ "".c en :-<:. ..0 \\ ~ \ ~ ,I .\ , \ \ 7640- \-4 THADDEUS B. GREGG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARIA S. GREGG, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Plaintiff in the above captioned matter, do hereby certify that I served a true and correct copy of the foregoing Plaintiffs Answers to Defendant's Second Request for Production of Documents on counsel for the Defendant by hand-delivery on the ---L5- day of May, 2005, addressed as follows: SANDRA L. MEIL TON, ESQUIRE TUCKER ARENSBURG, P.C. P.O. BOX 889 HARRISBURG, PA ] 7108-0889 Respectfully Submitted, SMIGEL, ANDERSON & SACKS, LLP By _L/ l/~~ Ann V. Levin, Esquire LD. #: 70259 4431 North Front Street Harrisburg, P A 17110 (717) 234-2401 Attorney for Plaintiff .-.Il c.) - ~ ; '( <..'J \...'~~' . 611120063:44,\9 PMlAVVsmm MARRIAGE SETTLEMENT AGREEMENT AGREEMENT MADE this q <-Hr day of --:::JZi,rz..L , 2006, by and between Maria S. Gregg ("Wife") - AND - Thaddeus B. Gregg ("Husband"), at Harrisburg, Pennsylvania. WHEREAS, the parties hereto are husband and wife having been married on June 23, 1990, Doylestown, Pennsylvania; WHEREAS, three (3) children were born of this marriage; said children being: Samantha Winslow, born March 27,1993; Olivia Burr, born March 5,1996; and Henry Bartholomew, born April 11,2001. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all rnatters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the foregoing premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. Divorce and SeDaration. The parties agree to the entry of a decree in divorce pursuant to Section 3301(c) of the Divorce Code of 1980. Husband and Wife shall at all times hereafter have the right to live separate and apart frorn each other and to reside from time to time at such place or places as they shall respectively deern fit, free from any control, restraint, or interference whatsoever by the other. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. The parties acknowledge that a divorce action has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania at docket number 04-785. The parties agree that they will execute and file Affidavits of Consent and Waivers of Notice of Intention to Request Entry of a Divorce Decree in the aforementioned matter simultaneously with the signing of this Agreement. Thereafter, counsel for Husband shall expeditiously file a Praecipe to Transmit Record and obtain a divorce decree. 2. Division of ProDertv. Husband and Wife agree that the following constitutes an equitable distribution of the marital property. A. Husband's ProDertv. The following property shall become the sole and exclusive property of Husband: I. The 2001 Honda Accord. Wife shall cooperate in transferring title to this vehicle to Husband. 2 - 2. The Vanguard Individual Retirernent account with the last four digit account number 2642. 4. The Fidelity IRA with the last four digit account number 4828. 5. During the marriage, Husband had interest in businesses which operated under the names United Mortgage Network, Inc. and Colonial Settlement Services, Inc. Wife waives all right, title and interest to these business entities. Husband accepts responsibility for any and all liabilities connected with the businesses and will hold Wife harmless in the event she is pursued for any liabilities incident to the operation of the businesses. 6. All household goods and personalty currently in Husband's possession -or control. B. Wife's ProDertv. The following property shall become the sole and exclusive property of Wife: I. The home and lot situate at 304 II th Street, New Cumberland, Pennsylvania (hereinafter "marital home") subject to all existing liens and obligations. Wife shall refinance or otherwise satisfy the rnortgage associated with this home within sixty (60) days of the signing of this agreement. At such tirne as the home is refinanced or the debt is satisfied in full, Husband shall execute a deed transferring all right, title and interest to the property to Wife. Husband agrees that as of the date of execution of this Agreement, any and all title policies and any other policies of insurance with respect to the Marital Home shall be endorsed to reflect Wife as the sole owner thereof and further agrees that Wife shall be entitled to receive any payments now or hereafter due under such insurance policies. Wife shall be solely and exclusively responsible for all costs, expenses and liabilities associated 3 with or attributable to the Marital Home, including, but not limited to, any mortgages, any and all home equity loans or lines of credit, taxes, insurance premiums, utilities, maintenance and repairs. Wife shall keep Husband and his successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, costs or expense, including actual attorneys fees, which may be incurred in connection with such liabilities and expenses or resulting from Wife's ownership interest in the Marital Home. If Wife refuses to indemnify Husband for any such expenses, Husband is entitled to recover from Wife all costs, expenses and legal fees incurred in enforcing Wife's duty to pay the expenses. 2. The 2003 Honda Odyssey. Husband shall cooperate fully in transferring title to this vehicle to Wife. 3. The Legacy Bank escrow account number 8990, with an approximate value of$83,594.36 as of March 20, 2006. 4. The PSECU checking and savings accounts with the last four digit account number 8823. 5. The PSECU Vacation and Christmas accounts. 6. The PSERS Annuity inherited from Wife's mother. 7. The inheritance and any cash received frorn Wife's mother. 8. All household goods and personalty currently in Wife's possession or control. c. LumD Sum Payment. Wife shall pay to Husband $28,000 within ten (10) days of the escrow account being transferred to her name alone. This payment shall satisfy in full all of Husband's ~s to equitable distribution. This payment shall be offset in the amount~tf~,73 Husband's support arrears shall be satisfied in full as of May 1, 2006. Wife shall sign the letter attached hereto as Exhibit A simultaneously with the signing ofthis Agreement. The letter shall then be forwarded to the Domestic 4 Relations Office. Wife shall cooperate in any other manner that may be required by the Domestic Relations Office to rnark the arrears satisfied as of May 1, 2006. D. Children's Prooertv. The custodial accounts for the benefit of the parties' three children will continue to be maintained for the benefit ofthe children. There is currently one 529 College Savings Iowa account for the benefit of each child, which will be used to contribute to the costs of a post-high school education for the children. E. Satisfactory Division of Marital and Non-Marital Property. Husband and Wife hereby acknowledge that they have divided, to their mutual satisfaction, all of their marital and non-marital assets, including but without limitation, business interests, partnerships, inheritances, jewelry, clothing, pensions, brokerage accounts, stocks, bonds, life insurance policies or other securities, individual retirement accounts, 40l(k), employment benefits, checking and savings accounts, mutual funds and other assets, whether real, personal or mixed, tangible or intangible. 3. Taxes. In the past, the parties have filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is rnade against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. It is specifically and mutually understood and agreed and recognized by and between the parties 5 hereto that Wife shall claim the U.S. Individual Income Tax and any other federal, state, or local income or other tax exemptions for the parties' oldest two children, Olivia and Samantha. It is specifically and mutually understood and agreed and recognized by and between the parties hereto that Husband shall claim the U.S. Individual Income Tax and any other federal, state, or local income or other tax exemptions for the parties' youngest child, Henry. The parties shall cooperate in signing any appropriate forms to allow the other to claim the exemptions as required herein. 4. Additional Documentation. The parties agree to execute any deeds, assignments, titles or other instruments necessary and appropriate to accomplish the aforesaid division of property. 5. Transfers Subiect to Existinl! Liens. Notwithstanding any other provisions in this document all property transferred hereunder is subject to the existing lien or liens set forth above. The respective transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party rnay suffer or may be required to pay on account of such lien or encumbrance. 6. Representations and Warranties. The parties represent and warrant to each other that the property described in this Agreement represents all of the property in which they have any right, title and interest, and that such property is subject to no rnortgage, pledge, lien, security interest, encurnbrance or charge except those which are disclosed herein. 7. Equitable Division. By this Agreement the parties have intended to effect an equitable division of their jointly owned property. The parties have determined that an equitable division of such property conforms to a just and right standard, with due regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of 6 assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the rnarital estate. It is the intention of the parties to treat all transfers herein as non-taxable. 8. Relinquishment of Ril!hts. Except as expressly provided herein, Husband forever relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now or hereafter have in any tangible or intangible assets now belonging to Husband. 9. After-Acquired ProDertv. Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of properly, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose ofthe same as fully and effectively, in all respects and for all purposes as though he or she were unmarried. 10. Wife's Debts. Wife represents and warrants to Husband that since their separation_ .. ~ " ~, she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands rnade against him by reason of debts or obligations incurred by her. Specifically, Wife agrees to be solely responsible for any debt that her brother rnay claim that one or both of the parties owes to him as of the date of this Agreement. From the date of execution of this Agreement, Wife shall use only those credit cards and accounts for which she is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. 7 II. Husband's Debts. Husband represents and warrants to Wife that since their separation _ , M~ 5, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. Frorn the date of execution of this Agreement, Husband shall use only those credit cards and accounts for which he is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. I2. Liabilities. All debts, contracts, obligations or liabilities incurred at any time in the past or future by either party will be paid prornptly by said party, unless and except as otherwise specifically set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified and save harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, as of the date of this Agreement, contract nor incur any debt or liability for which the other or his or her property may be responsible, and shall indemnify and save harmless the other from any and all claims or demands made against him or her by reason of debts or obligations incurred by him or her and from all expenses, legal costs, and counsel fees unless provided to the contrary herein. 13. Counsel Fees. Costs and Expenses. Each party shall be responsible for his or her own legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their marriage. 8 14. Alimonv. In exchange for and in consideration of the promises and representations made hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the other or the respective separate property of the other under the laws of the Commonwealth of Pennsylvania or any other governing state, country, territory or jurisdiction in the nature of spousal support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative, permanent or lump sum and right to seek equitable or community distribution or division or assignment of property or sirnilar marital rights. 15. Full Disclosure. The respective parties do hereby warrant, represent and declare and do acknowledge and agree that each is and has been fully and completely informed of and is familiar with and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his or her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. 16. Releases. Each party does hereby remise, release, quitclaim and forever discharge the other and the estate of the other from any and every claim that each other may now have, or hereafter have or can have at any time, against the other, or in and to or against the other's estate, or any part thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take against each other's will, or for support or rnaintenance, or of any other nature whatsoever, except any rights accruing under this Agreement. 17. Indemnification. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this Agreernent, on which the 9 other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnifY and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the irnposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 18. General Provisions. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between thern. There are no representations or warranties other than those expressly set forth herein. 19. Fair and Equitable Contents. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations. Each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and 10 that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 20. Breach. It is expressly stipulated that if either party fails in the due performance of any of his or her material obligations under this Agreement, the other party shall have the right, at his or her election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services rendered by the non-defaulting party's attorney in any action or proceeding to cornpel performance hereunder. 21. Execution of Documents. Each party shall on demand execute any other documents that may be necessary or advisable to carry out the provisions of this Agreement. 22. Modification. No modification, rescission or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 23. Severabilitv. If any provision of this Agreement is held by a Court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 24. Applicable Law. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. Al!reement Not to be Merl!ed. This Agreement may be filed with the Court for incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise shall not be merged into said Decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this 11 Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. Witness: Th1!!!!!ffi1 SMIGEL, ANDERSON & SACKS, LLP ByLu :L:) Ann V. Levin, Esquire I.D. #: 70259 4431 North Front Street Harrisburg, P A 17110 (717) 234-2401 Attorney for Plaintiff TUCKER ARENSBURG, P.C. ~~.Jj Maria S. Gregg, Defend:l1- By: s~{~ 11] 1 North Front Street P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 ]2 COMMONWEALTH OF PENNSYL VANIA COUNTY OF DAUPHIN ss. Personally appeared before rne, a Notary Public in and for the aforesaid Commonwealth and County, Thaddeus B. Gregg, who being duly sworn according to law deposes and says that he is a party ofthe foregoing Agreement and he executed ~ for the purposes therein contained. Witness rny hand and seal this I 2 day of ~ ' 2006. My Commission Expires: Not:IDa~~ea\ Public VIcky L. Fltt. tar)' h' County_ SU'6quenanna Twp.. I?auPJ~ 6 '2001 My commission EXplres ., r\9 Membar,pennSylVaniaAsSOCiabOllofNota s 13 COMMONWEALTH OF PENNSYLVANIA : 55. COUNTY OF DAUPHIN Personally appeared before rne, a Notary Public in and for the aforesaid Commonwealth and County, Maria S. Gregg, who being duly sworn according to law deposes and says that she is a party of the foregoing Agreement and she executed ~e for the purposes therein contained. Witness my hand and seal this '1 day of -:::JCi ~ , 2006. ~~L Notary Public My Commission Expires: NOWlW.IEAL GI.CllllA M. AN NoIaIy l'ubIc: CIIV OF IWlIJIIIlK. lWJPl.1 COUNlV My Commlllllll. &pIIW Nov II. 2CI07 ]4 , SMIGEL, ANDERSON & SACKS LLP ANN V. LEVIN, ESQUIRE PHONE: (717) 234-2401 TOLL FREE: 1-800-822-9757 ATrORNEYSATLAW FACSIMILE (717) 234-3611 EMAIL: alevin@sasllp.com www.sasllp.com June 1, 2006 FileNo. 7640-1-4 TRANSMITTED VIA FACSIMILE- 717-240-6248 Ms. Jennifer Gibboney, Conference Officer Cumberland County Domestic Relations 13 North Hanover Street Carlisle, P A 17013 Re: Maria Gregg v. Thaddeus Gregg Docket no. 00190 S 2004 PACSES no. 100106211 Dear Ms. Gibboney: ~ ~ Please mark Mr. Gregg's arrears "satisfied in full" as of May 1,2006. Per an agreement between the parties, Mr. Gregg has satisfied the t1D$. 7~rrears balance outside of the Domestic Relations Office. Ms. Gregg is in agreement with this, as evidenced by her signature and that of her attorney below. Please call my office if you have any questions. I would appreciate it if you could confirm that the arrears have been marked satisfied in full. Thank you for your attention to this matter. Very truly yours, ~ ,,1,J;1 Maria S. Gregg ~ L~~ ~v6 Ann V. Levin AVL:smm cc: Sandra L. Meilton, Esquire Ms. Maria Gregg Mr. Thaddeus Gregg 4431 North Front Street. Harrisbur". Pennsvlvania 17110 A l'ENNSYLV ANIA LIMITED LIABILITY l'AlITNERSHIP -G' r. Q L ~? -- ~o c:..; ex" (Ii -,._- _. ". ~ IAVUsnun//June 13.200610:47 AM THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - LAW 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. Ground for divorce: irretrievable breakdown under S3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: The Complaint was served via first class mail on counsel for the Defendant on March 3, 2004. A copy of the Acceptance of Service is attached hereto. 3. (a). Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff, June ]2, 2006; by Defendant, June 9, 2006. (b)(l). Date of execution of the affidavit required by S3301(d) of the Divorce Code: N/A; (b )(2). Date of filing and service of the Plaintiffs affidavit upon the respondent: N/A. 4. Related claims pending: None. 5. (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. 7640-1-4 (b). Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: A copy is attached hereto and is being filed simultaneously with this Praecipe. Date Defendant's Waiver of Notice in ~330](c) Divorce was filed with the Prothonotary: A copy is attached hereto and is being filed simultaneously with this Praecipe. Date: tr /3. 0 h SMIGEL, ANDERSON & SACKS, LLP B~ J~u~~ A'nilV. evin, Esquire J.D. #: 70 9 4431 North Front Street Harrisburg, P A 17110 (7] 7) 234-240] Attorney for Plaintiff THADDEUS B. GREGG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. ---=",:;;--f'l\: CIVIL ACTION - LAW _' . ~:-:e"ff:t\J1:'3ji NO. 04-785 C~ TERM MARlA S. GREGG,. F--~ 'J, l\JM ., , Defendant ",t>.R 1 _ : \~ DIVORCE \. .-;~:;~ 'V9J;...="'. ACCEPTANCE OF SERVICE I, SANDRA 1. MEIL TON, Esquire on behalf of my client, MARIA S. GREGG, accept service of the Complaint in Divorce, filed to the above number and term in Cumberland County, Pennsylvania on February 23,2004. 5/3 joJ-/ Dited . Luiu~~ > if. r; ,~' . > '-JI'{ .- Sandra 1. Meilton, Esquire TUCKER ARENSBERG & SWARTZ III North Front Street Harrisburg, P A 171 0 1 (7]7) 234-4121 Attorney for Defendant o ,,':xJ5 -:-'.,"' .~' '-,' ,..., ~ a -""" "'n -... s; :;:f =.;::; i'i.::n r- - -Dr'll - :00 01 ::E :;:iQ ~ ,o:b' S? fj.f;? f'l.... :b! '''V :J:J w --<:; '~"-' . ~j,j:;:' ,3;:,!:~~J 1~~ --., --< (") ('.,:' -"-' .-< ..., c~~ C::'"") c;r" r", :::tl ::r!:J] in f=. ~.'~S i c:: c~.._ (.,.r; --n ;( ; ~, - , ,len ~7FI GO ...0 ".:.0 :< . THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301(c) ofthe Divorce Code was filed on February 23,2004. 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]8 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: c.; /1'2/0 <0 TO,ZPfJ&r--- 0 """ 0 = ~;. ':';;:.-, -n r:;:r"' ! ~ '- ::::1 , ~~ .-l,.--n n1""'~- ," '~ 0'1 -,"". ..,1 , -~. \,) ~-?\ \",'\ -7 ',- '. (,) :-11 -<~ -..l --< IAVUsrnrn//June 12.2006 \0:59 AM THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &330I(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the staternents 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: 61lz/ob r;uJJ 8&- Thaddeus B. Gregg, Plaintiff <--, c,.:::' c;:::> cr' ,-- S r'", ',:;-0 -l :;r.:,., n1~" ii-; C (..r, " ~ , ':~ ~~(;~ ;'~':\ ;Jj -< - .. w C1:i . . . ,. THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under 9330l(c) of the Divorce Code was filed on February 23, 2004. 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 ofa 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. 94904 relating to unsworn falsification to authorities. Date: ~ )9)Oc:' ~.;. Jj Maria S. Gregg, Defendant ;f . ... ,., C? c".'? "" c- c:: ~'\'''' - - (j"", r") ';'h ::;J 01:0 <::: "':J",~, ~~"} '-;~ -,~~:'i.':/ .,.....-r: '::':.r{1 "::!, ~ -0 ~ - c;) CD IAVLl,mml/June 8, 2006 5:09 PM ,. THADDEUS B. GREGG, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 04-785 CIVIL TERM MARIA S. GREGG, DEFENDANT CIVIL ACTION - LA W IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of] 8 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ro)Cj )Oc" ~ ~,J;j Maria S. Gregg, Defendant ~ ~ ..., <= f~ (".". ~ ."- o -n -:l ~~\ "'~,'~? "~-.\ 'C",- - if. ..,., :,~::~ n ::::\ 'J:''' ':JJ ~ ::L: (.0) CO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~I:l B. GREG; No. 04 - 785 VERSUS MARIA s. r.m;n: DECREE IN DIVORCE . AND NOW, \\W ~ V' -z-\ ~-b , IT IS ORDERED AND DECREED THAT Thaddeus B. Gregg , PLAINTIFF, . AND Maria S. Greqq , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. It is fllrth",r ()RnF.RF.I1 ,mn n~rm t-""t- t-hp M>lrri,,9'" !,:pt-t-l""""nt- ~W""""""nt- executed by and between the parties, dated June 9, is incorporated by reference into this Decree for the purposes of t but shall NOr be deetped to have been merged. with this Dee " . By THE CRT: . J. ATTES~ ~. (~ ~OTHONOTARY W""" fJ!' 1!. "".- ~ 'lfl. Le .? ~ fr ?-. ~ ~ -pO %,1..<"/ .# . .,"" .. . .' ~., ": . ' 4: \."i . ,