HomeMy WebLinkAbout08-4289Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 6 ?- - y 1- ?- y c », J fc?M
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so the
case may proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgment may also be entered against you for any other claim or relief requested
in these papers by the Plaintiff. You may lose money or property or other rights important to
you, including custody and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
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, PA 17013
(717) 249-3166
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. d ?! c .??? a f c r,..
MATTHEW A. STETTER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Christina A. Stetter, an adult individual residing at 341 E. Crestwood
Drive, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant is Matthew A. Stetter, an adult individual residing at 1029 Kathryn
Avenue, Dauphin, Dauphin County, Pennsylvania 17018.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on November 7, 1998 in Devenshire
Memorial Church, Harrisburg, Dauphin County, Pennsylvania.
5. There are two (2) children born of this marriage being Ava L. Stetter (Born: July 20,
2002) and Grace L. Stetter (Born: August 30, 2004).
6. The parties separated on August 1, 2007.
7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs 1 through 9 of Plaintiffs Complaint are incorporated
herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
§3301 of the Pennsylvania Divorce Code.
COUNT II
EQUITABLE DISTRIBUTION
12. The averments in paragraphs 1 through 11 of Plaintiffs Complaint are incorporated
herein by reference thereto.
13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance
with Section 401(d) of the Pennsylvania Divorce Code.
WHEREFORE, Plaintiff, Christina A. Stetter, prays this Honorable Court to enter judgment:
A. Awarding Plaintiff a decree in divorce;
B. Equitably distributing the marital property; and
C. Awarding other relief as the Court deems just and
Dated: July 16, 2008 \Zzz:s ?V --
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
MATTHEW A. STETTER,
Defendant
. NO.
: CIVIL ACTION -LAW
: IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
Dated: 2008
CHRISTINA A. S R
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
MATTHEW A. STETTER,
Defendant
: NO.
CIVIL ACTION -LAW
IN DIVORCE
VERIFICATION
I, Christina A. Stetter, hereby certify that the facts set forth in the foregoing Pleading are
true and correct to the best of my knowledge, information and belief. I understand that any false
statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn
falsification to authorities.
Dated: , 2008
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C STINA A. STETTER
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 4289
CIVIL ACTION -LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Marianne E. Rudebusch, Esquire, hereby accepts service and acknowledges receipt of the
above-captioned Complaint in Divorce on behalf of my client, Matthew A. Stetter, having received
said Complaint on the 1( day of 2008. I hereby indicate I am authorized by my client
l
to accept service on his behalf
/4?cm
Marianne E. Rudebusch, Esquire
Attorney for Defendant
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Supreme Court I.D.:
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE/CUSTODY
DEFENDANT. MATTHEW A. STETTER'S ANSWERS TO
PLAINTIFF'S INTERROGATORIES
TO: Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
Attorney for Plaintiff
Attached hereto, please find Defendant, Matthew A. Stetter's Answers to Plaintiff's
Interrogatories.
Respectfully Submitted,
Dated:
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
(717) 657-0632
Id. No. 63522
1. Are you employed? If so, for each employment which you hold, state:
a. Name and address of employer;
Northwestern Human Services
4391 Sturbridge Drive
Harrisburg, PA 17110
Country Club of Harrisburg
401 Fishing Creek Valley Road
Harrisburg, PA 17112
b. Date of commencement of employment;
April 1995
April 2007
C. Name, title and address of your immediate supervisor;
Adam Rossi, Chief of Staff
4391 Sturbridge Drive
Harrisburg, PA 17110
James Castle
401 Fishing Creek Valley Road
Harrisburg, PA 17112
d. Your job title and description of duties;
Director of Contracts and Communications
Duties include all coordination and management of a professional office
environment; direct support of the Executive Management team, as well
as Regional and site managers, initiation and execution of all professional
service contracts on behalf of our region, as well as independent
contractual agreements for professional and paraprofessional contractors
for the regions programs (see Resume attached to Answer to Production
of Documents).
Chef
2
e. Your hours and rate of pay on earnings, specifying gross average weekly
salary, wages, commission, overtime pay, bonuses.
Monday - Friday; 9:00 a.m. to 5:00 p.m.; $63,000.00 per year
Varied schedule by event or by need; $12.00 per hour
1) Identify the formula used by the employer to determine your specific
bonuses or commissions.
f. Expense and drawing accounts and allowances for transportation and other
accommodation and expenses; and
$45/month cell phone allowance
None
g. Your salary for the last five years.
Current - $63,000.00
7/1/06 - $56,710.61
9/15/06 - $60,000.00
$12.00 per hour
3
2. Please list all employment held by you since November 7, 1998, the date of marriage.
For each employment please identify the following:
a. The dates you were employed;
Employed with Northwestern April 2005 to present. Employed with
Country Club of Harrisburg part-time from April 2007 to present.
b. The reason for leaving; and
N/A
C. The compensation received
See above, as well as income information attached to Answer to
Production of Document.
4
3. For each employment which you hold or held during the marriage, state whether you
participate, or have a right to participate, or have in the past participated in any of the
following employment related benefits:
a. Defined benefit retirement plan;
b. Defined contribution retirement plan;
C. Deferred compensation;
d. Money purchase pension plan;
e. Any other type of employee pension plan;
f. Savings or thrift plan;
g. Cash or deferred plan (401 K);
h. Profit sharing plan;
1. Employee stock ownership (including tax credit or payroll tax credit employee
stock ownership plan;
j. Stock bonus plan;
k. Tax deferred, 403, (b) annuities;
1. Non-qualified, deferred compensation plans, including excess benefit plans,
whether or not refunded;
in. Executive stock option plan, including incentive stock option plans;
n. Welfare or insurance plans including group term life insurance and medical
insurance;
o. Voluntary employees' beneficiary association (VEBA); and
p. Any other employment related benefit not disclosed in your Answers to these
Interrogatories.
ANSWER: See Benefits Statement, 401(k) Statement and 403(B) statement attached
to Answer to Production of Documents.
5
4. For each benefit identified in Interrogatory No. 3 above in which you participate,
identify:
a. Your date of hire for the employment through which the plan is offered.
April 2005
b. The nature and amount of any contributions that you have made in such plans
as of (1) the date of marriage, (2) August 1,2007 and your date of separation,
if different, and (3) currently;
1. Unknown.
2. 10% of annual salary
3. -0-
c. The nature and amount of any contributions to the plan made by your employer
as of (1) the date of marriage, (2) August 1,2007 and your date of separation,
if different, and (3) currently;
1. Unknown.
2. Up to 5% employer match
3. -0-
d. The date you began to participate in the plan;
Unknown; will inquire with Benefits Manager.
e. The date upon which your benefits in the plan are vested;
Unknown; will inquire with Benefits Manager.
f. The amount of vested benefits in the plan as of August 1, 2007 and your stated
date of separation, if different, and currently;
Unknown; will inquire with Benefits Manager.
6
g. The amount of non-vested benefits in the plan as of August 1, 2007 and your
stated date of separation, if different, and currently;
Unknown; will inquire with Benefits Manager.
h. The name(s) of the person(s) other than yourself who has information relative
to the details and amounts of your pension plan benefits;
Barbara Beihl, Benefits Manager, Northwestern Human Services
The presently named beneficiary of such benefits; and
Christina A. Stetter, Beneficiary
Please provide all documents to support your responses to this Interrogatory
in accordance with the request for production of documents served
simultaneously herewith.
See rollover information attached to Answer to Production of Documents.
7
5. State the date of your separation from the Plaintiff and why you believe this date
constituted final separation, if different from August 1, 2007.
ANSWER: August 1, 2007 is the date of physical separation.
6. Identify any and all real estate which you have any interest in, whether it be for
personal use or business use. For each piece of real estate, please identify:
1029 Kathryn Avenue, Dauphin, PA 17018
a. How the interest was acquired and the cost of same;
Purchased 12/16/99; $110,000.00
b. The identity of any lien holder on said real estate and the present amount of
said lien;
Wells Fargo Home Mortgage; $104,381.52
C. Who has paid the lien since August 1, 2007 and your stated date of separation,
if different, to the present; and
Defendant has paid mortgage from August 2007 to present
d. Your present estimate of value of said property.
Present estimated market value is estimated to be $171,000.00 See
appraisal completed and submitted previously by Mark Heckman already
in Plaintiffs possession.
8
7. Please identify each vehicle owned by you. This should include, but not be limited to,
the 2002 Ford Explorer and 2003 Honda Odyssey. For each vehicle, please provide:
a. The year, make and model;
2003 Ford Explorer Sport Trac.
2003 Honda Odyssey
b. Your estimate of value as ofAugust 1, 2007 and your stated date of separation,
if different; and
Unknown how to accomplish a retro valuation bac k to 8/1/07
Current estimated Kelley Blue Book value for 2003 Ford Explorer
$8,000.00
C. Any liens encumbering each vehicle and the value of the lien as of August 1,
2007, your stated date of separation, if different, and currently.
Balance on 8/1/07 for 2003 Ford Explorer was $12,702.26
Balance on 8/1/07 for 2003 Honda Odyssey was $17,605.55
Current PSECU loan balance for Ford Explorer is $6,359.24
Current PSECU loan balance for 2003 Honda Odyssey is $9,525.89
9
8. Please identify by account number and bank name or financial institution, each and
every bank or financial account, whether savings, share or checking, that you have or had an
interest in during the marriage, including but not limited to your PSECU accounts. For each,
please provide:
a. The name and address of the institution;
PSECU
P.O. Box 67013
Harrisburg, PA 17106-7013
b. The account number;
202507533
C. The balance as of August 1, 2007 and your stated date of separation, if
different; and
8/1/07 checking acct. balance - $336.21; savings acct. balance - $5.05
d. The names, addresses and relationship of all owners or authorized users of
each account.
Matthew Stetter
1029 Kathryn Avenue
Dauphin, PA 17018
10
9. List all cash you had in safekeeping as of August 1, 2007, your stated date of
separation, if different, and presently.
ANSWER: -0-
10. As of August 1, 2007, your stated date of separation, if different, and presently, list
the value of any and all Certificates of Deposit and/or IRA. accounts in your name, held for
your benefit, or over which you have ownership or signature power over.
ANSWER: -0-
11
11. Please advise if you are or were you the owner or beneficiary of any policies of life
insurance as of August 1,2007 and your stated date of separation, if different. For each such
policy, state:
a. The name of each owner of such policy;
Northwestern Human Services
b. The name of the beneficiary of each such policy;
Christina A. Stetter
C. The face amount of each such policy;
Unknown.
d. The accrued cash value of each such policy presently, as of August 1, 2007 and
your stated date of separation, if different;
Does not believe there is a cash value.
e. The date each policy was purchased;
Unknown.
f. Whether the policy was whole life or term life; and
Unknown.
g. The nature and amount of any loan against any policy and the date any loan
was incurred.
None.
ANSWER: Life Insurance is offered through employer. The amount of coverage is
2x the employee's annual salary. Defendant does not have the requested information
in his possession and will supply the information at a later date.
12
12. Are you the grantor, beneficiary or holder of a power of appointment for any trust
created by you, any member of your family or by any corporation? If so, for each such trust,
state:
a. The date of the trust instrument;
b. The name of the settlor of each trust;
C. The name of the beneficiary of such trust;
d. The amount of each trust corpus;
e. Any restrictions on alienation to which such corpus is subject; and
f. The terms of each trust instrument.
ANSWER: N/A
13
13. Have you received any inheritance prior to marriage, during marriage or after
separation? If so, please identify the following:
a. Description of inheritance received;
b. Date of receipt;
C. Disposition of inheritance as of the date of receipt;
d. Disposition of inheritance as of August 1, 2007 and your stated date of
separation, if different;
C. Disposition of inheritance currently; and
f. Name of decedent, date of death and county which the estate was probated.
ANSWER: N/A
14
14. Do you own stocks, bonds, mutual funds or fund shares? If so, for each please state:
a. The name of the corporation or the issuer;
ING Direct/Sharebuilder
b. The number of shares and the base amount of such security;
8 shares of Krispy Kreme Doughnuts, Inc., with a base share value of
$2.95 per share, current value of all shares held is $23.60
8.04 shares of Oracle Corporation, with a base share value of $21.71 per
share. Current value of all shares held is $174.55
1.26 shares of Soapstone Networks, Inc., with a base share value of .46 per
share, current value of all shares held is .58
Money Market Cash Balance of $4.74.
C. The date(s) such securities were purchased;
Securities were purchased initially through "Buy and Hold" then were
transferred to Sharebuilder/ING as of 2/26/03.
d. The maturity date(s) of such securities, if applicable;
N/A
e. The market value of such securities as of August 1, 2007 and your stated date
of separation, if different;
Unknown.
f. The current market value of such securities; and
Total ING Direct/Sharebuilder Account Value is currently $203.47
15
g. The dividends paid by each such securities for each year for the last five (5)
years.
None. Securities have been losing value since inception.
16
15. List all personal credit cards, debts, liabilities or claims against you individually or
jointly with another person as of August 1,2007 and your stated date of separation, if
different. For each such debt, state:
a. The name of the creditor of such obligation
PSECU
b. The amount of credit line for each obligator;
$8,000.00 - line of credit
$2,000.00
$3,500.00
C. Any current balance owed upon each such obligation; and
d. The balance as of August 1,2007 and your stated date of separation, if
different, and whether you believe said obligation is marital debt.
$4,862.23 (See 8/2007 PSECU Statement) - Loan for roof replacement and
other work on marital home
Used to repair vehicles following accident caused by Plaintiff, as well as
for brakes and tires on 2003 Ford Explorer.
Incurred for home repair (kitchen sink) balance as of 8/1/07 - $904.24
17
16. Identify any safety deposit box or similar depository which you have or are utilizing.
For each, please include:
a. The location;
b. The owners, custodians or registered owners and renters;
C. The number or designation;
d. The contents thereof including date, acquisition and value; and
e. The identity of all persons with access thereto.
ANSWER: N/A
17. Identify any and all personal property which you have an interest in and which you
believe has a value in excess of $250.00. For each, please provide:
a. A description;
b. The location of same as of August 1, 2007, your stated date of separation, if
different, and presently;
C. The date of purchase and purchase price; and
d. Your estimated current value.
ANSWER: N/A
18
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08-4289
MATTHEW A. STETTER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this day of , 2009, I, Katherine A. Frey,
Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Defendant, hereby certify that
a copy of the within document has been served, by depositing a copy of the same in the
United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the
following addressee:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
By:
Katherine A. Frey
or Th f', ;10TARY 1 7.1-1 nr, js,' i "", 2• ?
Uv? NvJ ! C• $
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CHRISTINA A. L-,M ER,
Vs.
MATTHEW A. STEITER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 08 - 4289
Defendant
MOTION FOR APPOINTMENT OF MASTER
Christina A. Stetter (Plaintiff) (Defendant), moves the court to appoint a master with
respect to the following claims:
(50 Divorce ( Distribution of Property
() Annulment () Support
O Alimony O Counsel Fees
() Alimony Pendente Lite () Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant (has) \0hea-set) appeared in the action (psmeaa1l) (by his attorney,
Marianne E. Rudebusch , Esquire).
(3) The Staturory ground (s) for divorce ( (are)
3301(c) and 3301(d)
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
b. An agreement has been reached with respect to the following claims:
c. The action is contested with respect to the following claims:
Distribution of property
(5) The action (iiweWes) (does not involve) complex issues of law or fact
(6) The hearing is expected to take One (1) (heum) (days).
(7) Additional information, if y, relevapt to, the motion:
Date: August 4 ? 1, 2009
Attorney for (Plaintiff) (Be€en )
Print Attorney Name ......... Barbara Sumple-Sullivan, Esquire
ORDER APPOINTING MASTER
AND NOW, , 20 O9 , Esquire
is appointed master with respect to the following claims:
By the Court:
J.
FILE - ""',i-F-k E
OF THE p--^: 3 ?-,' `) fOTARY
2009 AUG 28 PH 2: 10
SEP 012009a 4;?
CHRISTINA A. STEITER,
Plaintiff
Vs.
MATTHEW A. STEiTER,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 08 - 4289
Defendant
MOTION FOR APPOINTMENT OF MASTER
Christina A. Stetter (Plaintiff) (Defendant), moves the court to appoint a master with
respect to the following claims:
(} Divorce W Distribution of Property
() Annulment ( ) Support
O Alimony O Counsel Fees
() Alimony Pendente Lite () Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant (has) (has -ae) appeared in the action ?psneiW13+? (by his attorney,
Marianne E. Rudebusch , Esquire).
(3) The Staturory ground (s) for divorce ( (are)
3301(c) and 3301(d)
(4) Delete the inapplicable paragraph(s):
a. The action is not contested.
b. An agreement has been reached with respect to the following claims:
c. The action is contested with respect to the following claims:
Distribution of property
(5) The action (iiwelves) (does not involve) complex issues of law or fact
(6) The hearing is expected to take one (1) _ (days).
(7) Additional information, if y, reieyapt to, the motion:
Date: August C? 1, 2009
dtttomey for (Plaintiff) Pefmd&PA)
Print Attorney Name ......... Barbara Sumple-Sullivan, Esquire
WX%"MIt 1Mr X- Wll\ 1 i 'I %N iVj_'%0 X L` A
AND NOW, , 20M___, Esquire
is appointed maste with respect to the following claims: Q 4 A*6 Zzd1 '0-4-7_
FILED-- CHRiCiE
OF 1K PR, ,-!l Fig
2609 SEP -I FM 3: 48
2009 AUG 28 PM 2: 10
CUB r_,+ i ?F Y
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16
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08-4289
MATTHEW A. STETTER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
1. a. PLAINTIFF'S BACKGROUND
Christina Stetter
341 E. Crestwood Drive
Camp Hill, PA 17011
DOB: 6/10/74
Age: 35
Education: High School Graduate
Occupation: Tech Business Analyst
Highmark Blue Shield
b. DEFENDANT'S BACKGROUND
Matthew Stetter
1029 Kathryn Avenue
Dauphin, PA 17018
D
DOB: 10/4/71
Age: 38
Education: California University of Pennsylvania
Harrisburg Area Community College/Shippensburg
University
Business Administration (no degree obtained)
Occupation: Director of Contracts and Communication
Northwestern Human Services
C. Date of marriage: 11/7/98
d. Place of marriage: Harrisburg, PA
e. Date of separation: 8/1/07
L Children: Ava L. Stetter (born 7/20/02)
Grace L. Stetter (born 8/30/04)
Both children reside with Plaintiff/Mother
g. Grounds for Divorce: 3301(c)/3301(d)
h. Issues for determination: Equitable Distribution
II. PERTINENT PROCEDURAL HISTORY
Complaint in Divorce filed: 7/17/08
Acceptance of Service dated: 7/21/08; filed 7/24/08
Motion for Appointment of Master: 8/28/09
Appointment of Master: 9/1/09
Plaintiff's Affidavit of Consent/Waiver of Notice: N/A
Defendant's Affidavit of Consent/Waiver of Notice: N/A
III. INVENTORY APPRAISAL
To be supplied.
2
IV. WITNESSES
a. Lay:
Defendant
Plaintiff, on cross
b. Expert:
Mark Heckman, Real Estate Appraiser, if necessary.
Defendant reserves the right to identify additional witnesses.
V. EXHIBITS
a. Appraisal of Marital home.
b. Wells Fargo Statements dated 9/20/07 and 4/7/09
C. NADA value of 2003 Honda Odyssey
d. PSECU Statement dated 8/31/07
e. NADA value of 2003 Ford Explorer
f. ING Statement dated 8/14/09
g. Historical Price statement for Krispy Kreme Doughnuts dated 8/1/07
h. Historical Price statement for Oracle Corp. Dated 8/1/07
i. Historical Price statement for Soapstone Networks, Inc. Dated 9/1/07
j. Member's I" statement for Wife dated 7/24/07
k. Wife's Retirement Savings Statement w/ Highmark dated 9/30/07
1. Wife's Retirement Savings Statement w/ Highmark dated 3/31/09
M. Husband's Retirement Portfolio Statement w/ Northwestern dated 6/30/09
n. World Points Visa statement dated 8/1/07
o. Member's First Visa Statement dated 8/24/07
P. Loan statement for roof dated 2/7/08
q. Husband's Income & Expense Statement (to be supplied)
r. Husband's Inventory Statement (to be supplied)
S. Support Order dated 2/12/08
t. Husband's 2008 W2
Defendant reserves the right to identify additional exhibits.
3
VI. INCOME INFORMATION
See Defendant's Income & Expense Statement (to be supplied)
See Support Order dated 2/12/08.
VII. EXPENSE INFORMATION
See Defendant's Income & Expense Statement (to be supplied).
VII. PROPOSED ECONOMIC RESOLUTION:
Defendant proposes a 50150 division of the marital estate between the parties.
Defendant shall retain the marital home and refinance the joint mortgage in his name
alone within 12 months from the date of the issuance of a Decree in divorce.
Respectfully Submitted,
i uuwtknn +,? e. ZU4 OL,
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Dated:
4
EXHIBIT A
- I Mark Heckman Real Estate Appraisers
Property Description UNIFOF RESIDENTIAL APPRAISAL REP' 'T File No. 1029Kathrvn
Property Address 1U29 Kathryn Avenue - City Dauphin -- State PA Code 17018
Legal Description Deed Book: 3576 Pa e: 531 County Dauphin
Assessors Parcel No. 430160430000000 Tax Year 08/09 R.E. Taxes $ 2,192.00 S ecial Assessments $ None Kwn
Borrower N/A Current owner Christina A & Matthew A Stetter occupant X owner Tenant Vacant
„ Property a raised X Fee Simple Leasehold Project Type F] PUD Condorninium UDNA only) HOA$ N/A /Mo.
-
Neighborhood or Project Name Middle Paxton Township Ma Reference See Assessors Parcel Census Tres 247
Sale Price $ WA Date of Sale N/A Description and $ amount of ban cha siconcessions to be paid by seler N/A
Lender/client Barbara Sum le Sullivan, Es q. Address 549 Bridge Street, New Cumberland, PA 17070
Appraiser Mark W. Heckman Address 1309 Bri a Street New Cumberland PA 17070
Location Urban Suburban X Rural Predominant Single family housing Present land use % Land use change
Bull[ up ? Over 75% X 25 75% CD Under 25% occupancy $ PRICE E One family 45% ? Not likely ? Likely
Growth rate ? Rapid X Stable ? Slow X? Owner 70 Low New 24 family 3% X In process
Property values ? Increasing X? Stable ? Declining ? Tenant 860 High 75 Multi4m* 2% To: Residential from
Demandlsupply Shortage X? In balance ? Ova
Oversupply X Vacant (
? 65°,6) ''"' '
-,: ' '" ;: Predominant itn?9
Commercial
vacant.
Marketin time Linder 3 mos. X 3.6 mos. Over 6 mos. v.m.r (a. % 160 35 Vacant i 50%
Note: Race and the racial composition of the neighborhood are not appraisal factors.
Neighborhood boundaries and characteristics: The subject property is located in Middle Paxton Township. Insufficient sales in close proximity to
the subject property require the appraiser to extend search parameters.
• Factors that affect the marketability of the properties in the neighborhood (proximity to employment and amenities, employment stability, appeal to market, etc.):
j
The sub
ect property is in a rural portion of this r ion. A substantial portion of the surrounding land in the area is agricultural and
- woodlands. Market activity indicates average or better acceptance in the market lace. No unfavorable factors were observed which
would adverse) affect marketability.
Market conditions in the subject neighborhood (including support for the above conclusions related to the trend of property values, demand/supply, and marketing time
-- such as data on competitive properties for sale in the neighborhood, description of the prevalence of sales and financing concessions, etc.):
See Attached Addendum.
Project Information for PUDs (If applicable) -- Is the developer/builder in control of the Home Owners' Association (HOA)? YES NO
Approximate total number of units in the subject project Approximate total number of units for sale in the subject project
Describe common elements and recreational facilities:
Dimensions See Legal Description Topography Basically Level
Site area 3.20 Acres Comer Lot Yes X No Size Typical for area
Specific zoning classification and description Agricultural-Rural Residential Shape Rectangular
Zoning compliance Q Legal ? Legal norxoftmwg (Grandfathereftse) Illegal No zoning Drainage Appears adequate
Highest & best use as ' roved: X Present use Other use (explain)
View Average
Utilities Public Other Off-site Improvements Type Public Private Landscaping Typical
Electricity X? 200 AMPS Street Asphalt X? ? Driveway Surface Asphalt
Gas ? Curb/gutter Asphalt X? ? Apparent easements None a arent
Water ? Well Sidewalk None ? ? FEMA Special Flood Hazard Area Yes X No
Sanitary sewer ? Septic Street lights None ? ? FEMA Zone C Map Date 08/15/1979
Storm sewer Alle None FEMA Ma No. 4203870015B
Comments (apparent adverse easements, encroachments, special assessments, slide areas, illegal or legal no nconforming zoning, use, etc.): See Attached
Addendum.
GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION BASEMENT INSULATION
No. of Units 1 Foundation Concrete Blk Stab 40 Area Sq.Ft. 719 Roof ?
No. of Stories 1 Exterior Walls Vinyl Craef Space 10 % Finished 0 Ceiling ?
Type (Det./Att.) Detached Roof Surface As h. Sh. Basement 50 Ceiling Unfinished Walls ?
Design (Style) Ranch Gutters & Dwnspts. Aluminium Sump Pump None Wails Conc. Block Floor ?
Existing/Proposed Existin Window Type Dbl Insul. Dampness None noted Floor Concrete None ?
Age (Yrs.) 59 Storm/Screens No/Yes Settlement None noted outside Entry Yes Uri- X?
Effective Acie (Yrs.) 18 Manufactured House No Infestation None noted
ROOMS Foyer Living Dinin Kitchen Den Fermi Rrn. Rec. Rm. Bedrooms # Baths t
' Basement
Level1
1
Area
1
1
3
1 M 1,4
7
3
• Leve12
0
Finished area above oracle contains: 6 Rooms; 3 Bedroom si; 1 Baths ; 1.437 S w are Feet of Gross Livin Area
INTERIOR Materials/Condition HEATING KITCHEN EQUIP. ATTIC AMENITIES CAR STORAGE:
Floors Vi, HW, CT C UAv Type FA Refrigerator ? None ? Fireplace(s) X? N
?
Walls Plstr DW/Avers a Fuel Oil Range/Oven X? Stairs ? Patio Rear X? one
G
s
Trtm/Finish Wood/Average
Condi6DnAV
Disposal ?
Drop Stair ?
D-ck ? arage
#ofcars
Attach
d 1
Bath Floor Vinyl/Average COOLING Dishwasher ? Scuttle X? Porch ? e
Detached
Bath Wainscot Ceramic Tile/Ay Central Yes Fan/Hood ? Floor ? Fence ? Built-In
Doors HOllowcore/Av Other None Microwave ? Heated Pool ? Carport
CorditionAv . Washer/Dryer Finished Driveway 2
Additional features (special energy efficient items, etc.): New ro of and soffits; sta ined wood work; a portion of the second gar age has been d to a
added to the family room.
Condition of the improvements, depreciation (physical, functional, and external), repairs needed, quality of construction remodeling/additions
etc.: These
,
improvements are of average quality frame design and reflect average maintenance. ProRerty reflects normal physical depreciation and
no deficiencies are noted. No unusual functional obsolescence or external inadequacies were observed.
Adverse environmental conditions (such as, but not limited to, hazardous wastes, toxic substances, etc.) present in the improvements
on the site
or in the
,
,
immediate vicinity of the subject property: No adverse environmental conditions were observed in the improvements, on the site, on in the
immediate vicinity of the subject ro erty.
Rye Uac Fa 70 653 PAGE 1 OF 2 F- V- Form Tau G93
PIOEUZG,a^q.1 so .. awD ,Sm ww.aoreemn
Mark Heckman Real Estate Appraisers
Valuation Section. UNIFOF RESIDENTIAL APPRAISAL REP' T Fir. hu„ 1n9gKnfh-
ESTIMATED SITE VALUE, , ,,,,, , ,, , , , , , , , , , , , ,,-: $
ESTIMATED REPRODUCTION COST-NEW OF IMPROVEMENTS:
Dwelling Sq. Ft. @ $ _ $ 0
Sq. Ft. @ $ = 0 Comments on Cost Apprbach (such as, source of cost estimate,
site value, square foot calculation and for HUD, VA and FmHA, the
estimated remaining economic life of the property):
In view of the age of these improvements, the Cost Approach
F/P, Patio = cannot be considered an accurate indicator of value.
Garage/Carport Sq. Ft. @ $ = 0
Total Estimated Cost New , , _ , , , , • , , • , • . • . = $ 0
Less Physical
I Functional External Est. Remaining Econ. Life: 32
Depredation = $ 0
Depredated Value of Improvements , , , , , . , ... , • , • , , , . • = $ 0
"As-is" Value of Site Improvements • , , , , , , . , , • , . , .. , .. = $
INDICATED VALUE BY COST APPROAC H . . .... • = s 0
ITEM SUBJECT COMPARABLE NO. 1 COMPARABLE NO.2 COMPARABLE NO. 3
1029 Kathryn Avenue
Address Dauphin 3511 Fishing Creek Valley Rd
Harrisburg 1287 Adams Lane
Dau hin 1863 Valley Road
Ma sville
Proximity to Subject
Sales Price
$ N/A 8.5 Miles
IN w . ' E 159,900 .75 Miles
A_..
=t$ 150,000 3.2 Miles
: t $ 180,000
PricelCross Liv. Area
Data and/or
Verification Sources $ 0.00 0
Inspection
AssesRec & MLS $ 154.34 In R= V0
Assessment Records & MLS
Assessment Records & MLS 4 s 116.55 m t -' I; I
Assessment Records & MLS
Assessment Records & MLS ; s 156.79 0 f
Assessment Records & MLS
Assessment Records & MLS
VALUEAMJSTMEim DESCRIPTION DESCRIPTION Adp-ht DESCRIPTION t->s DESCRIPTION (_)snaNSn?a
Sales or Financing
Concessions 151
Conventional
None Known
Cash
None Known
Conventional
None Known
Date of sale rime s a:. N.. -. ' 10/26/2007 9/24/2007 ; 3/11/2008
;
Location RuraUAvera a Rural/Good -5,000 Rural/Averse Rural/Avers e
IoldlFee Fee Simple Fee Simple Fee Simple Fee Simple
Site 3.20 Acres 2.10 Acres +5,000 1 Acre +11,000 2.45 Acres +4,000
View Averse Averse Averse Avers e
Design and Appeal Ranch/Average Ranch/Average Ranch/Average Ranch/Average
ofCosarstion Averse Averse Averse Avers e
e 59 Years 69 Years 56 Years 49 Years
Condition Averse Averse Averse Average
Above Grade Tad ; Beano ' aft Tsai ; Bdam awry
' Tww ; edam ' eaft
a
raw ' edn u ' awns
Room Count 2 6 3 1.00 7 3
1.00 6; 1; 1.00 ' 5; 3 1
00 ;
Gross Living Area 1,437 S .Ft. 1,036 S .Ft. +10,000 1,287 S .Ft. 1 +3,800 .
1.148 5 .Ft. +7,200
Basement &Fihished
Rooms Below Grade Partial Basement
Unfinished Full Basement
Unfinished Full Basement
Unfinished Full Basement
Rec, BR, F-8th, Off15 000
Functional Utili Typical for Age T ical for A e T ical for A e Typical for Age
Heating/Cooling Oil FA, CAir Oil FA, EBB, No CA +3,000 Oil HW CAir Oil HW CAir
Energy EfficientItens Re I. Windows None +3,000 Re I. Windows Re I. Windows
Garage/Carport 1 Aft. Garage 2 Car Det. Gar -3,000 None +4,000 1 Car Det Geri An croon -2,000
Porch, Patio, Deck,
Fre laces , etc. Patio
1 Fireplace Deck, End. Par. -4,000
None +2,000 None +2,000
1 Fireplace Similar
None +2,000
Fence, Pool, etc. None Ina. Pool -3,000 None In g. Pool -3,000
Other None None None None
i
Net Ad'. total ". f
Adjusted Sales Price
Of Comparable wit:, x X + - E 8,000
fiirss s?+' °ev
t y? c? E 167 900 X + ; s 20,800,
;
„- -9 t $ 170.800 + X
; E 6,800
tom"" 8°jo
A m.8rz E 173,200
Comments on Sales Comparison (including the subject property's compatibility to the neighborhood, etc. ): See Attached Addendum.
ITEM SUBJECT COMPARABLE NO. 1 COMPARABLE NO.2 COMPARABLE NO. 3
Date, Price and Data None within the None within the prior year of None within the prior year of None within the prior year of
Source for prior sales past 3 years. above sale date. above sale date. above sale date.
within year ofappraisal Coun Records County Records County Records Coun Records
Analysis of any current agreement of sale, option, or listing of the subject property and analysis of any prior sales of subject and mmparables withcl one year of the date of appraisal:
According to the records provided b the county assessment office the subject roe HAS NOT transferred in the past three ears.
According to the information in the r ional MLS, the subject property HAS NOT transferred in the past three ears.
INDICATED VALUE BY SALES COMPARISON APPROACH , , , , , , , ..... , ..... • , $ 171,000
INDICATED VALUE BY INCOME APPROACH ff le Estimated Market Rent s N/A /Mo. x Gross Rent Mu W ' N/A = $ N/A
This appraisal is made X "as Is" subject to the repairs, alterations, inspections or conditions listed below subject to completion per plans and specifications.
ConditronsofAppratsal: See Attached Addendum.
Final Reconciliation: See Attached Addendum.
The purpose of this appraisal is to estimate the market value of the real property that is the subject of this report, based on the above conditions and the cartiBcetion, contingent
and limiting conditions, and market value definition that are stated in the attached Freddie Mac Form 439/Fannie Mae Form 1004B(Revised ),
1(WE) ESTIMATE THE MARKET VALUE, AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OFTHIS REPORT, As OF Februa 5, 2009
(WHICH IS THE DATE OF INSPECTION AND THE EFFECTIVE DATE OF THIS REPORT) TO BE $ 171,000
APPRAIS R: SUPERVtS IS R (O 1 );
SS nature ? Signature , [JDid Not
Name Raetta Souders, Asst. to Certified Appraiser Name M k W. Heckman, General Appraiser Inspect Property
Date Report Signed 02/27/2009 Date Report Signed 02127/2009
State e Certification # Assistant to the certified appraiser. State State Certification # GA000666L St
t
PA
a
e
Or State License # State Or State License #
Freddie Mac Fain 70 sin PAGE 2 OF 2 Fame Mae F.-1001 6-M
P?,eox .soozw.erzlw.weaaaaae,
Mark Heckman Real Estate Appraisers
EXHIBIT B
Return Mail O,
PO Box 14411
Des Moines, lA 503063411
050992 1 AT 0.334 2992/050992MD2992 165 01 ACMDBO 665
MATTHEW A STETTER
CHRISTINA A STETTER
341 E CRESTWOOD DR
CAMP HILL PA 17011-1211
nunnunun?nnunnunnuuunnu?nnuunnn
Summary
Payment (Principal and/or Interest, Escrow) $1,042.23
Optional Product(s) $0.00
Current Monthly Payment $1,042.23
Overdue Payments $1,042.23
Unpaid Late Charge(s) $37.78
Other Charges $0.00
Ll?bb ?a i a[a?
P?
vl?
ement
Monthly Mortg?9/20/07
Statement Date LLoan Number 2751637
Customer Se
0 Online
wellsfargo.com
g Telephone TTY Deaf/Hard of He
(800) 262-5294 (800) 934-9998
O- Fax
(866) 278-1179
n Payments Correspondence
PO Box 6427 PO Box 10335
Carol Stream IL 60197 Des Moines IA 50306
Important Messages
Our records indicate your monthly payment is
delinquent and a late charge has been
assessed. In the future, please make your
payment on or before the due date to avoid la
charges and adverse credit bureau reporting.
If your payment has been sent, please
disregard this notice.
Property Addre&z
1029 KATHRYN AVENUE
DAUPHIN PA 17018
Unpaid Principal Balance $107,858.60
(Contact Customer Service for your payoff balance)
Interest Rate 6.750%
Interest Paid Year-to-Date $5,497.29 i
Taxes Paid Year-to-Date $2,158.99 j
TOTAL PAYMENT DUE 10/01/07 $2,122.24 crow Balance $190.58
Activity Since Your Last Statement
Late
Date Description Total Principal Interest Escrow Charge Other
09/17 LATE FEE $37.78-
09/10 SCHOOL TAX PMT $1,396.64- $1,396.64- CENTRAL DAUPHIN SD (2)
09/10 MTG INS PMT $70.87- $70.87- RADIAN GUARANTY INC
Late charges are assessed after the close of business on the assessment date and only after all pavments
received have been applied.
Please detach and return with your payment
Loan Number 2751637
Current Monthly Payment Due $1,042.23
Total Payment Due 10101107 $2,122.24
After 10116107 Add Late Fee $37.78
Total Amount Due After 10116107 $2,160.02
Automatic Mortgage
Payment: To enroll,
Check & sign here Signature MATTHEW A STETTER
CHRISTINA A STETTER
2 9 92/05 0992A02992 165 01 ACM060 665
WELLS FARGO HOME MORTGAGE
PO BOX 6427
CAROL STREAM IL 60197-6427
Yt
In[u11uu1nurnloll nnnrnIgill uIunruunnuu
p,ni srn"
101
Please spenlry ? aSt°v4Ral
additional funds.
Any additional
funds not
secified %%1!1 be
:applied first to AddiY?or I D
ar; outsandino
O her
a
o 4\ = a
e
e
E
Return Mail Operations
• PO sox 14411
?. • ' + Des Moines, lA 50306-3411
Monthly Mortgage Statement
Statement Date 04!07/09
Loan Number 2751637
Customer Service
000 01 AM27 6+S
MATTHEW A STETTER
CHRISTINA A STETTER
1029 KATHRYN AVENUE
DAUPHIN PA 17018-9748
IIIIi[Jill i11111111u111ofgill i111111111FIr?111i1?i1i111111
X Online
welisfargo.com
-aclr
Fax
(866) 278-1179
Correspondence
PO Box 10335
Des Moines IA 50306
Q Payments
PO Box 6427
Carol.Stream IL 60197
+ wr Telephone
(800) 262-5294
Hours of Operation
Mon - Fri, 6 AM -10 PM
Sat, 8 AM - 2 PM
TTY Deaf/Hard of Hearin
(800) 934-9998
Important Messages
Summary
Payment (Principal and/or Interest, Escrow)
Optional Product(s)
Current Monthly Payment 05/01/09
Overdue Payments 04/01109
Unpaid Late Charge(s)
Other Charges
Property Address
$1,024.18 1029 KATHRYN AVENUE
$0.00 DAUPHIN PA 17018
$11024.18 Unpaid Principal Balance $104,881.30
(C011rad CustomerSen*9 foryDwpayaRbatanw)
$1,024.18
$37'78 Irderest Rate 6.750%
$0'00 Irrtarest Paid Year-to-Date $1,775.41
Taxes Paid Year-to-Date $747.10
TOTAL PAYMENT DUE 05101/09 $21086.14 Escrow Balance $627.07
Activity Since Your Last Statement
Date Description Total Principal Interest Escrow Late
Charbe Other
04/07 PAYMENT $1,061.96 $164.74 $5900.88 $268.56 Unappled $37.78
03117 MTG INS PMT $70.87- $70.87- RADIAN GUARANTY INC
Please detach and rrdum wfth your psymant
1=11111111111111M EI111111111 Loan Number
CurrenE Monthly Payment Due
Total Payment Due 05101109
After 05116109 Add Late Fee
Total Amount Due After 05116109
Cheolr hereand see
reverse for address MATTHEW A STETTER
correetlom CHRISTINA A STETTER
33=00000100= 00001 ANr27 885
2751637
$1,024.18
$2,086.14
$37.78
$2,123.92
WELLS FARGO HOME MORTGAGE
PO BOX 6427
CAROL STREAM IL 601917-6427 !! tt
'1"11"111!1/"II111'IIII1 ?1111'II?11'1"111(I1'f I?111!'1'It'
•?+j^tn
flnritdliy f'axlne n1 ?;
X ptl.i ant,
Prin1:1p al
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:rL r•,Jta,....R.•rr [=l!;tn3r
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0000WAKI a AUM SU2
- - - - - - - - - - - - - - - - --
a
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.
685 0002751637 1 07000102418010619602086140204836 000000002933263523 3
EXHIBIT C
Summary Used
http://www.nada,o ides.com/print.aspx?LI=1-21-1-5014-710-1254-6
NADA;
ro,.! T.u Il? !' JA€7Aqui,des.com 10/21/2009
Vans
2003 Honda Odyssey-V6 Wagon 5D EX
PRICING
Rough Average Clean Clean
Trade-In Trade-In Trade-In Retail
Base Price
$5,525 $6,550 $7,400 $9,925
Options
Aluminum/Alloy Wheels N/A N/A N/A N/A
TOTAL PRICE $5,525 $6,550 $7,400 $9,925*
Rough Trade-In
The Rough Trade-in values on nadaguides.com are meant to reflect a vehicle in rough
condition. A vehicle with significant mechanical defects requiring repairs in order to
restore reasonable running condition; Paint, body and wheel surfaces have considerable
damage to their finish, which may include dull or faded (oxidized) paint, small to
medium size dents, frame damage, rust, or obvious signs of previous repairs; Interior
reflects above average wear, with inoperable equipment, damaged or missing trim, and
heavily soiled /permanent imperfections on the headliner, carpet, and upholstery; May
have a branded title and un-true mileage; Vehicle will need substantial reconditioning
and repair to be made ready for resale; Some existing issues may be difficult to
restore. Because individual vehicle condition varies greatly, users of nadaguides.com
may need to make independent adjustments for actual vehicle condition.
Average Trade-In
The Average Trade-In values on nadaguides.com are meant to reflect a vehicle in
average condition. A vehicle that is mechanically sound but may require some
repairs/servicing to pass all necessary inspections; Paint, body and wheel surfaces have
moderate imperfections and an average finish and shine which can be improved with
restorative repair; Interior reflects some soiling and wear in relation to vehicle age,
with all equipment operable or requiring minimal effort to make operable; Clean title
history; Vehicle will need a fair degree of reconditioning to be made ready for resale.
Because individual vehicle condition varies greatly, users of nadaguides.com may need
to make independent adjustments for actual vehicle condition.
Clean Trade-In
The Clean Trade-In values on nadaguides.com are meant to reflect a vehicle in clean
condition. A vehicle with no mechanical defects and passes all necessary inspections
with ease; Paint, body and wheels have minor surface scratching with a high gloss
finish and shine; Interior reflects minimal soiling and wear, with all equipment in
complete working order; Vehicle has a clean title history; Vehicle will need minimal
reconditioning to be made ready for resale. Because individual vehicle condition varies
greatly, users of nadaguides.com may need to make independent adjustments for
actual vehicle condition.
Clean Retail
The Clean Retail values on nadaguides.com are meant to reflect a vehicle in clean
condition. A vehicle with no mechanical defects and passes all necessary inspections
with ease; Paint, body and wheels have minor surface scratching with a high gloss
? _r?
Vehicle Evaluation
http://nada'3.nada.com/UCGWeb/VehicleEvaluation.aspx?fn=2&uid
Used Cars/Trucks
Period: X2007 August
Region: Eastern
VIN: Decode]
Reference
Year: 2003
Make: HONDA
Series: Odyssey-V6
Body: Wagon 5D EX
Mileage: ]62,500 Adjustment: $0
MSRP: $26,900 Weight: 4,365
{'+CLYd1u05 P,7nt pel-tS Get fa .ru Ch.?cl Y9rHCJn History Lie?ort
New! New!
Rough Average Clean Clean Clean
Trade-In Trade-In Trade-In Loan Retail
Base: $0 $0 $12,725 $11,475 $15,275
Mileage $0 $0 $0 $0 $0
Adjustment:
Options $0 $0 $0 $0 $0
Adjustment:
ue:
a
usted
V
alue:
V
0 $0 $12,725
11,475 $15,275
At NADA valves are reMited wth permssion of
NADA Used Car Gude, NADASC.
Trade-In Loan Retail
Aluminum/Alloy Wheels 0 0 0
?- Luggage Rack 50 5o 75
F Theft Recovery Sys 75 75 100
Towing/Camper Pkg 125 125 150
EXHIBIT D
P0. Box 67013 (717) 234-8484 (Harrisburg)
Harrisburg, PA 17106-7013 (800) 237-7328 (Nationwide)
website - http://www.psecu.com 6
MATTHEW A STETTER
CHRISTINA A STETTER
1029 KATHRYN AVE
DAUPHIN PA 17018-9748
JOINT OWNER
MEMBER NUMBER ! STATEMENT DATE
i
0202XXXXXX 08/31/07
08/31 Payment: Dividend 0.250% 0.09 173.34
Annual Percentage Yield Earned 0.260% from 08/01/07 through 08/31/07
Based on Average Daily Balance of 412.11
08/31 Ending Balance
Dividend YTD: Year to Date 173.34
0.92
Number
002674 Amount Number Amount
58
57 002683 23
08 Number Amount Number Amount
002679* .
.
30.00 002684 83.36 002687
002688 20.00 002691
35
96 002693* 40.00
002680
100.00 002685 40.00
002689 .
20
00 20.00
002682*
* 495.00 002686 20.21 002690 .
61
70
Asterisk next to number indicates skip .
in number sequence
*** ANNUAL PERCENTAGE RATE 9.900%
Post Eff Description *** Periodic Rate (Daily) 027123%
08/01
ID 21 SIGNATURE LOAN Beginning Balance Principal FIN CHG Fees Balanc e
ff
08/31 Ending Balance 4862.23
A Payment of 200.00 is due on 08/30/07 4862.23 $
-- YTD Finance Charge: Year to Date 340
79
-----
* ------
** ANNUAL PERCENTAGE RATE 5
740% .
***
Post .
Eff Description Periodic Rate (Daily) _015726%
08/01
ID 22 2003 FORD EXPLORER Beginning Balance Principal FIN CHG Fees Balance
08/11 Payments via Home Banking Transfer From Share 04 12816.75
08/31 Ending Balance 114.49- 30.23 12702.26
A Payment of 144.72 is due on 08/17/07 12702.26
YTD Finance Charge: Year to Date 481.68
*** ANNUAL PERCENTAGE RATE 5.740%
Post Eff Description *** Periodic Rate (Daily) 015726%
08/01
ID 24 2003 HONDA ODYSSEY Beginning
Balance Principal FIN CHG Fees Balance
08/10 Payments Transfer From Share 04 17605.55
08/24 Payments Transfer From Share 04 147.65- 38.76 17457.90
--- Continued on following page --- 147.97- 38.44 17309.93
EXHIBIT E
J Summary Used
http://www.nadaguides.com/print.aspx?LI=1-21-1-5014-710-1254-
r?.o. ;sas _ NADAgvides. co 10/21/2009
suvs
2003 Ford Explorer Sport Trac-1/2 Tan-V6 Utility 4D XLT (4WD)
PRICING
Rough Average Clean Clean
Trade-In Trade-In Trade-In Retail
Base Price
$6,750 $7,825 $8,700 $11,875
Options
TOTAL PRICE $6,750 $7,825 $8,700 $11,875-
Rough Trade-In
The Rough Trade-in values on nadaguides.com are meant to reflect a vehicle in rough
condition. A vehicle with significant mechanical defects requiring repairs in order to
restore reasonable running condition; Paint, body and wheel surfaces have considerable
damage to their finish, which may include dull or faded (oxidized) paint, small to
medium size dents, frame damage, rust, or obvious signs of previous repairs; Interior
reflects above average wear, with inoperable equipment, damaged or missing trim, and
heavily soiled /permanent imperfections on the headliner, carpet, and upholstery; May
have a branded title and un-true mileage; Vehicle will need substantial reconditioning
and repair to be made ready for resale; Some existing issues may be difficult to
restore. Because individual vehicle condition varies greatly, users of nadaguides.com
may need to make independent adjustments for actual vehicle condition.
Average Trade-In
The Average Trade-In values on nadaguides.com are meant to reflect a vehicle in
average condition. A vehicle that is mechanically sound but may require some
repairs/servicing to pass all necessary inspections; Paint, body and wheel surfaces have
moderate imperfections and an average finish and shine which can be improved with
restorative repair; Interior reflects some soiling and wear in relation to vehicle age,
with all equipment operable or requiring minimal effort to make operable; Clean title
history; Vehicle will need a fair degree of reconditioning to be made ready for resale.
Because individual vehicle condition varies greatly, users of nadaguides.com may need
to make independent adjustments for actual vehicle condition.
Clean Trade-In
The Clean Trade-In values on nadaguides.com are meant to reflect a vehicle in clean
condition. A vehicle with no mechanical defects and passes all necessary inspections
with ease; Paint, body and wheels have minor surface scratching with a high gloss
finish and shine; Interior reflects minimal soiling and wear, with all equipment in
complete working order; Vehicle has a clean title history; Vehicle will need minimal
reconditioning to be made ready for resale. Because individual vehicle condition varies
greatly, users of nadaguides.com may need to make independent adjustments for
actual vehicle condition.
Clean Retail
The Clean Retail values on nadaguides.com are meant to reflect a vehicle in clean
condition, A vehicle with no mechanical defects and passes all necessary inspections
with ease; Paint, body and wheels have minor surface scratching with a high gloss
finish and shine; Interior reflects minimal soiling and wear, with all equipment in
complete working order; Vehicle has a clean title history. Because individual vehicle
if 2
Vehicle Evaluation
http://nada3.nada.corri/UCG Web/VehicleEvaluation.aspx?fn=2&uic
Used Cars/Trucks
Period: 2007 Au
ust
g
......... ..........
Region: Eastern
r3rd Row Seat Trade-In Loan Retail
...........
VIN:
F Bed Liner 125 SZS
150
?
Reference
r Bed Liner-Spray On 75
75 75 100
Leather Seats 75 100
Year.
Luggage Rack 300
50 300
350
Make: FORD TRUCK
NBX Pkg.
r' Pioneer/Audiophile Stereo
550 50
550 75
600
Sergi: Explorer Sport Trac
f-' Power Seat
- 175 175 200
Body: Utility
4D XLT 4WD
F Power Sunroof 150 150 vs
,
Mileage: +62 500
Adjustment: $0
r Rear Air Conditioning 375
100 375
100 425
....._. ............:
MSRP: $26,885
Weight: 4,342
F Rear Entertainment System
F Running Boards
400
400 125
450
GeLYalues pri
:
F Snow Plow Pkg./plow 75
900 75
9 100
nt Re3soris.
??i ,/..,:rocn? ver,rd« nic7ory Report
(-. Theft Recovery Sys 00 1,000
F Towing/Camper Pkg 75
75
100
New! New!
V8 Gas Engine 125 125
150
Rough Average Clean
Clean Clean
F W/out Auto
Trans 350 350
400
Trade-In Trade-In Trade-In Loan Retail .
.
F W/out Cruise Control -525 -525 -525
Base: $0 $D $13,350
$12,025 $15,925
F Winch -125
250 -125
250
125
300
Mileage $0 $0 $0
Adjustment: $0 $0
Options $0 $0 $0
Adjustment
$D $0
Adjusted ------------
Value: $0 $0 $13,350 ------....--
$12,025 $15,925
AI NADA valres are reprmed wth per sson of
NADA Used Car Guide, NADASr-
of 1
EXHIBIT F
QperLlrn Account I? Out dg)g ] .. Search I
Trade sharepulLper
Overview Portfolio Transaction History Transfer Money Records & Statements Forms & Applications I
Portfolio
Positions gains & Losses Balances Dividend Reinvestment
Positions
Stott & ETF Positions
Symbol Name Quote' Change Quantity Market Value
KKD KRISPY KREME DOUGHNUTS INC $2.95 40.06 8.0000 $23.60 Buy ? Sell
ORCL ORACLE CORP $21.71 -$0.28 8.0400 $174.55 Buy Sell
SOAP SOAPSTONE NETWORKS INC COM $0.46 $0.02 1.2649
-- $0.58 Buy Sell
Stock and ETF Market Value $198.73
_-?- ~
Money Market Cash Balance $4.74 Deposit Money
Total Account Value $203.47
Switch Account
2077-00004B039b-01 - indlvtdual ice.
About Us Contact Us Site Map i Privacy & Securely Agreements Pricing & Rates Careers Cafds ( The Shop Mobile I ingdvect.com
' Market value is calculated based on delayed quote data. Tell a
All quotes are delayed: NYSE and Amex - at least 20 minutes, NASDAQ -15 minutes. Research Disclosure Friend
Research Disclaimer: Some research material provided by MarketWatch. 0 MaricetWatch, Inc_ 2008. All rights reserved. Subject to SW
the Terms of Use. Designed and powered by Dow Jones Client Solutions. MarketWatch. the MarketWatch logo, BigCharts and the
BigCharts logo are registered trademarks of MarketWatch, Inc. Dow Jones is the registered trademark of Dow Jones & Company, inc.
Intraday data provided by Interactive Date Real Time Services and subject to the Terms of Use. Intraday data is at least 20-minutes
delayed. All tunes are ET. Historical and current end-of-day data provided by Interactive Data Pricing and Reference Data. The Dow
Jones Indexess" are proprietary to and distributed by Dow Jones & Company, Inc., and have been licensed for use.
Securities products are offered by ShareBulkter Securities Corporation, a registered broker-dealer and Member FINRA/SIPC.
ShareBuilder Securities Corporation is a subsidiary of ING Bank, fsb. Brokerage Financial Statement
Securities products are: Not FDIC Insured • Not Bank guaranteed • May lose value
https://www.sharebuilder.com/shuebuilder/Account/Portfolio/Positions.aspx R/1 A/7nnn
EXHIBIT G
+ KKD: Historical Prices for KRISPY KREME DOUGHNT - Yahoo!
Krispy Kreme Doughnuts Inc. (KKD)
Trade Now
Historical Prices
http://finance.yahoo. c.om/q/hp?s=KKD&a=07&b= I &c=2007&d=0
?Ayt?,2:32PM Ef: 3.02 t 0.06 (2.03%)
RpfRAGet Historical Prices for: ?- j
SET DATE RANGE
Start Date: F7 I: Daily
F7 ? I Eg. Jan 1, 2003 (`, Weekly
End Date: f- F F777 (; Monthly
C Dividends Only
First I Prev Next I Last
PRICES
Date Open High Low Close Volume Add
Close'
1-Aug-07 7.27 7.33 6.65 6.94 794,400 6.94
" Close price adjusted for dividends and splits.
First I Prev Next Last
1t
Download To Spreadsheet
?1,q4 x g = #tss 5a
of I
EXHIBIT H
' ORCL: Historical Prices for Oracle Corporation - Yahoo! Finance
Oracle Corp. (ORCL)
http: //finance.yahoo. rom/q/hp?s=ORCL& a=07&b= ] &c=2007&d
At 2:33PM ET: 22,23 0.00 (0.00%)
It j Trade IVow
Historical Prices Get Histo
SET DATE RANGE
(?--- !:. Daily
Start Date: Eg. Jan 1, 2003 y
L C Weekly
End Date: F Monthly
..........
( Dividends Only
PRICES
First Prev Next Last
Date Open High Low Close Volume Adj
Close"
1-Aug-07 18.93 19.82 18.83 19.79 54,798,800 19.69
Close price adjusted for dividends and splits.
First Prev Next I Last
_Downioad To Spreadsheet
I* I CI `7 x
rical Prices for: ?-
,a 15TI1
I 1 of 1
EXHIBIT I
SOAP.PK: Historical Prices for SOAPSTONE NETWORKS - Yahoo... http://finance.yahoo.cn iVq/hp?s=SOAP.PK&a=07&b=1&c=2007&
Soapstone Networks Inc. (SOAP.PK)
d.. ,.. ..,, At 2:14PM ET: 0.46* 0.01 (2.17%)
,iv++Nan'In
Trade IVow
Historical Prices Get Historical Prices for: ?'-
i
SET DATE RANGE
Start Date: F7 F- r- i> Daily
Eg. Jan 1, 2003 (7 Weekly
End Date: ?- ( Monthly
t Dividends Only
PRICES
First Prev Next I Last
Date Open High Low Close Volume Add
Close"
1-Aug-07 10.15 10.33 9.90 10.16 380,500 10.16
' Close price adjusted for dividends and splits.
First I Prev Next I Last
Download To Spreadsheet
19- T, Ili
X (?Uy q = ?Id ES
l of I
EXHIBIT J
V
St
MEMBERS 1St
FEDERAL CREDIT UNION
CHRISTINA A STETTER
1029 KATHRYN AVE
DAUPHIN PA 17018-9748
Send Inquires to:
5000 Louise Drive
PO Box 40
Mechanicsburg, PA 17055
www.memberslst.org
Main Switchboard: (717) 697-1161 or (800) 283-2328
EZ Call: (717) 697 4372 or (800) 283.4372
TDD: (717) 697-5312 or (800) 283-2328 ext. 5312
TeleBranch: (717) 795-6049 or (800) 237-7288
Statement of Accounts
Jun 25, 2007 thru Jul 24, 2007
Account Number: 150825
Account Balances at a Glance:
Checking:
Savings:
Certificates:
Loans:
Money Management:
Your current Member Loyalty Reward level is Silver. Page:
409.29
46.72
0.00
0.00
0.00
1 of 3
Tell anyone you know who isn't a m ember of Members 1st that it only takes a $5 minimum deposit in a
regular savings account to become a member. Use our Cash4U referral program and when your referral
opens an account you'll receive $51
CHECKING ACCOUNTS
11 -CHECKING
Date Transaction Description
Jun 25
Balance Forward Additions Subtractions Balance
Jun 25 Withdrawal Debit Card Debit Card 623.52
06/24/07 2389 JCPENNEY STORE 2389 YORK PA 24.83- 598.69
Jun 25 Withdrawal Debit Card Debit Card
06/24/07 011000060010204 TOM S 20 60010204 ENOLA P 46.89- 551.80
Jun 25 A
Check 000598 Tracer 0025785727
Processed Check - VERIZON ARC TYPE: CHECK PYMT ID
2 54,49- 497.31
Jun 26 :
005022221
Withdrawal POS #799282
POS TOYS R US 3500 CAPITAL CTY M CAMP HILL PA 33.29- 464.02
Jun 26 Check 000600 Tracer 0027897941
Processed Check - WFNNB CREDITCARD TYPE` CHECK PYMT ID 50.00- 414.02
Jun 27 : 9311
Check 000597 Tracer 0627001474 429215
Jun 27 Check 000601 Tracer 0627011076 48.60- 365.42
Jun 27 Check 000599 Tracer 0627015878 100.00- 265.42
Jun 28 Deposit Transfer From Share 00 121.01- 144.41
Jun 28 Check 000602 Tracer 0628011107 50.00 194.41
Jun 30 Withdrawal Debit Card Debit Card 54.75- 139.66
06/29/07 0006384270 ORIENTAL TRADING CO 800
22 54'80- 84.86
Jun 30 -
80475
Deposit Swipe 5 Rebate
Jul 02 Check 000603 Tracer 0702017366 0'20 85.06
Jul 05 Check 000604 Tracer 0705004966 30.48- 54.58
Jul 06 Deposit Transfer From Share 00 41.41- 13.17
Jul 06 Withdrawal POS #293023 830.77 843.94
POS GROVERS RIVERV 4401 N. FRONT STRE HARRISBUR 22'23 821.71
Jul 06 G PA
Withdrawal at ATM #000023
ATM MEMBERS 1ST FCU 3512 MARKET ST CAMP HILL PA 120.00- 701.71
Jul 06 Withdrawal EZ Call Transfer To Share 00
Jul 07 Withdrawal POS #406088 200.00- 501.71
POS GROVERS RIVERV 4401 N. FRONT SIRE HARRISBURG P 7.59- 494.12
Jul 07 A
Withdrawal at ATM #067275
ATM COMMUNITYBANKS 800 PETERS MOUNTAIN DAUPHIN PA 42'00- 452.12
Jul 09 Withdrawal Debit Card Debit Card
07/08/07 049800000002287 SHEETZ 00002287 HALIF 48'19- 403.93
Jul 09 AX PA
Withdrawal at ATM #008004
ATM RGNUMAC 4401 N FRONT STREE HARRISBURG PA 20.00- 383.93
Jul 09 Check 000605 Tracer 0709008915
123.96- 259.97
-- Continued on following page - I
St Send Inquires to:
5000 Louise Drive Main Switchboard: (717) 697-1161 or (800) 283-2328 Jun 25, 2007 thru Jul 24, 2007
PO Box 40 EZ Call: (717) 697 4372 or (800) 283-4372 Account Number: 150825
MEMBERS P Mechanicsburg, PA 17055 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312
www.memberslst.org TeleBranch: (717) 795-6049 or (800) 237-7288 Page: 2 of3
Date Transaction Description Additions Subtractions Balance
Jul 10 Withdrawal POS #676509 11.65- 248.32
POS RITE AID CORP. 1137 MARKET STREET LEMOYNE PA
Jul 11 Withdrawal POS #077675 29.99- 218.33
POS BON-TON CAMP H 3525 GETTSBURG RD CAMP HILL PA
Jul 11 Deposit by Check 20.00 238.33
Jul 11 Check 000609 Tracer 0711012452 35.00- 203.33
Jul 12 Withdrawal Debit Card Debit Card 12.25- 191.08
07/11/07 094500000011726 ARBY'S #1172 00011726 CAMP
Jul 12 Deposit EZ Call Transfer From Share 00 200.00 391.08
Jul 12 Check 000608 Tracer 0712008742 63.41- 327.67
Jul 12 Check 000607 Tracer 0712006059 100.00- 227.67
Jul 13 Withdrawal at ATM #002454 140.00- 87.67
ATM MEMBERS 1 ST FCU 3512 MARKET ST CAMP HILL PA
Jul 16 Check 000606 Tracer 0716003649 23.08- 64.59
Jul 17 Withdrawal at ATM #057916 22.00- 42.59
ATM COMMUNITYBANKS 800 PETERS MOUNTAIN DAUPHIN PA
Jul 18 Withdrawal Debit Card Debit Card 20.07- 22.52
07/17/07 037800042103325 EXXONMOBIL 42103325 HARRIS
Jul 20 Deposit Transfer From Share 00 830.77 853.29
Jul 20 Wthdrawal at ATM #004937 140.00- 713.29
ATM MEMBERS 1ST FCU 3512 MARKET ST CAMP HILL PA
Jul 20 Withdrawal Debit Card Debit Card 10.03- 703.26
07119/07 079900006954747 AMOCO OIL 06954747 LEMOYNE
Jul 21 Withdrawal POS #315271 56.94- 646.32
POS GROVERS RIVERV 4401 N. FRONT STRE HARRISBURG PA
Jul 23 Check 000613 Tracer 0028211321 49.29- 597.03
Processed Check - VERIZON ARC TYPE: CHECK PYMT ID: 2005022221
Jul 23 Check 000611 Tracer 0497739612 90.00- 507.03
Processed Check - FIA CardServices TYPE: CHECK PYMT ID: 2200000001 DATA: 18004212110
Jul 24 Withdrawal POS #211113 15.26- 491.77
POS ERFORD RD BP RTE 11 & ERFORD RD LEMOYNE PA
Jul 24 Withdrawal Debit Card Debit Card 32.48- 459.29
07/23/07 4445042419176 CVS PHARMACY #1917 003 HARRI
Jul 24 Withdrawal at ATM #009751 40.00- 419.29
ATM RGNL/MAC 4401 N FRONT STREE HARRISBURG PA
Jul 24 Check 000610 Tracer 0027498598 10.00- 409.29
Processed Check - W NNB CREDITCARD TYPE: CHECK PYMT ID: 9311429215
Jul 24 Ending Balance 409.29
Courtesy Pay and NSF Fee Summary
Courtesy Pay Fees Year- to- Date
CHECK SUMMARY
Check # Amount Date
000597 48.60 Jun 27
000598 54.49 Jun 25
000599 121.01 Jun 27
000600 50.00 Jun 26
000601 100.00 Jun 27
000602 54.75 Jun 28
000603 30.48 Jul 02
000604 41.41 Jul 05
Asterisk next to number indicates skip in nu mber sequence.
16 Checks Cleared for $995.48
60.00
Check # Amount Date
000605 123.96 Jul 09
000606 23.08 Jul 16
000607 100.00 Jul 12
000608 63.41 Jul 12
000609 35.00 Jul 11
000610 10.00 Jul 24
000611 90.00 Jul 23
000613' 49.29 Jul 23
WITHDRAWALS AND OTHER CHARGES
Date Amount Description Date Amount Description
Jun 25 24.83 Withdrawal Debit Card Debit Card Jul 11 29.99 Withdrawal POS #077675
Jun 25 46.89 Withdrawal Debit Card Debit Card Jul 12 12.25 Withdrawal Debit Card Debit Card
Jun 26 33.29 Withdrawal POS #799282 Jul 13 140.00 Withdrawal at ATM #002454
-- Continued on following page --
St Send Inquires to: 1. PO 5000
Box 40 Louise Drive Main Switchboard: (717) 697-1161 or (800) 283-2328
M Jun 25, 2007 thru Jul 24, 2007
EZ Call: (717) 697 4372 or (800) 283-4372
EMBERS 11 Mechanicsburg, PA 17055 TDD: (717) 697-5312 or (800) 283-2328 ext. 5312 Account Number: 150825
www.memberslst.org TeleBranch: (717) 795.6049 or (800) 237-7288
Page: 3 of 3
WITHDRAWALS AND OTHER CHARGES
Date Amount Description
Date
Jun 30 54.80 Withdrawal Debit Card Debit Card Jul 17 Amoun t Descri tion
Jul 06
22.23
Withdrawal POS #293023 22.00 Withdrawal at ATM #057916
Jul 06
120.00
Withdrawal at ATM #000023 Jul 18 20.07 Withdrawal Debit Card Debit Card
Jul 06
200.00
Withdrawal EZ Call Transfer T Jul 20
140.00
Withdrawal at ATM #004937
o
Share 00
Jul 20
10.03
Withdrawal Debit Card Debit Card
Jul 07 7.59 Withdrawal POS #406088 Jul 21
Jul 07 42.00 Withdrawal at ATM #067275 56.94 Withdrawal POS #315271
Jul 09
48.19
Withdrawal Debit Card Debit Card Jul 24
Jul 24 15.26 Withdrawal POS #211113
Jul 09 20.00 Withdrawal at ATM #008004 32.48 Withdrawal Debit Card Debit Card
Jul 10
11.65
Withdrawal POS #676509 Jul 24 40.00 Withdrawal at ATM #009751
23 Withdrawals and Other Charges for $1,150.49
DEPOSITS AND OTHER CREDITS
Date Amount Description Date
Jun 28 50.00 Deposit Transfer From Share 00 Jul 11 20.00 Amount Descri by
Jun 30 0.20 Deposit Swipe 5 Rebate Deposit by Check
Jul 12 200.00 Deposit EZ Call Transfer From
Jul 06 830.77 Deposit Transfer From Share 00 Jul 20 Share 00
6 Deposits and Other Credits for $1,931.74 830.77 Deposit Transfer From Share 00
SAVINGS ACCOUNTS
00 - REGULAR SAVINGS
Date Transaction Description
Jun 25 Balance Forward Additions Subtractions Balance
Jun 27 Withdrawal at ATM #009500 436.54
ATM MEMBERS 1 ST FCU 392 E PENN DR ENOLA PA 100.00- 336.54
Jun 28 Withdrawal
Jun 28 Withdrawal Transfer To Share 11 140.00- 196.54
Jun 30 Deposit Dividend 1.000% 50.00- 146.54
Annual Percentage Yield Earned 1.010% from 61112007 through 613012007 0.16 146.72
Jul 02 Deposit Members 1st Online Transfer
From MORRIS,PATRICIA XXXXXXXXXX Share 00 300.00 446 72
Jul 02 Withdrawal Members 1 st Online Transfer
To Loan 4121449991508255 VISA PAYMENT TO 4121449991508255 300.00- 146.72
Jul 03 Withdrawal at ATM #002046
ATM MEMBERS 1 ST FCU 392 E PENN DR ENOtA PA 100.00- 46.72
Jul 06 Deposit ACH HIGHMARK INC
TYPE: DEPOSIT ID: 3000000100 830'77 877.49
Jul 06 Withdrawal Transfer To Share 11
Jul 06 Deposit EZ Call Transfer From Share 11 830.77- 46.72
Jul 12 Withdrawal EZ Call Transfer To Share 11 200.00 246.72
Jul 20 Deposit ACH HIGHMARK INC 200.00- 46.72
TYPE: DEPOSIT ID: 3000000100 CO: HIGHMARK INC 830.77 877.49
Jul 20 Withdrawal Transfer To Share 11
Jul 24 Ending Balance 830.77- 46.72
YTD SUMMARIES 4s.7z
TOTAL DIVIDENDS PAID
00 REGULAR SAVINGS $0.74
11 CHECKING $0.00
Total Year to Date Dividends Paid
NOTE: Total includes closed shares
0.74
EXHIBIT K
'r
YOUR RETIREMENT SAS
?o..^aS STATEMENT
HighMark Investment Plan
i IGHMMK,M
07/01/2007 to 09/30/2007
Page 1 of 5
0002362 11411457
CHRISTINA A STETTER
341 E. CRESTWOOD DRIVE
CAMP HILL PA 17011
ACCOUNT SUMMARY
Your vested balance rs based on your
account balance, which does not include Beginning Balance on 07/01/2007
Contributions
$14,835.18
any loan balance. Your loan balance
equals 77.45% of your account balance Other Additions
Dividends & Interest $637.07
$846.44
on 0-913012007. Unrealized Gain/Loss $0.04
$976
Ending Balance on 09/30/2007 $17,295.65
65
Net Change
Vested Balance $2,460.47
Loan Balance $17,295.65
Balance Including Loans $3,656.93
$20,952.58
Year to Date Contributions $1
863
76
Your Personal Rate of Return ,
.
6.28%
All the data you need to track your
retirement investment is here. This
statement is designed to keep you up
to date on the status of your account
so you can effectively plan and invest
for your future. Take a minute to
review your statement carefully and
report any incorrect information
immediately.
ACCOUNT GROWTH
21,000
13,500
6,000
03/06 09/06 03/07 09/07
T- Account Balance
Account Internal Rate of Return
from 10/01/2006 to 09/30/2007: 18.02%
03/31/2006 09/30/2006 03/31/2007 09/30/2007
14,958.83 $9,562.72 $13,132.75 $17,295.65
The growth of your account can be influenced by a number of factors, including the specific investment options
selected, the diversification of your investment among asset classes and the contributions to your account. Past
performance does not guarantee future results. If ou would like to make changes to any of these areas, contact a
representative or go online to wm..wachovia.comlmyretireplan.
CONTRIBUTION SUMMARY
By saving through your pion you can add contribution Rate
to the financial nest egg you will need in This Period Year-to Date
the future. All Contribution Sources
EE PreTax
EE PreTax Supplemental
CHRISTINA A STETTER 026709
AMP 11411457 PBS 000019560 200710141449 C
J39526 20071014 NNNNNN DFLT ACTV
$637.07
$1,133.80
$78.12
$651.84
$1,863.76
Total Contributions
4.00% $404.53
4.00% $0.00
n /a c'l7'1 CA
EXHIBIT L
YOUR RETIREMENT SAVINGS STATEMENT
HighMark Investment Plan
11MM 00EIT13K 1141147
6„111 U111111 ,„I I, n i 6, d 1„L 1,,, l f,„i h l x,1,1, I l l b„I
.rte CHRISTINA A STETTER
34 _I= &ES31nrnOD DRIVE
???--CAMP HILL PA 17011
ACCOUNT SUMMARY
Beginning Balance on 01101/2009 $16,678.60
Contributions $987.01
Unrealized Gaintl.ass -$1,400.49
Ending Balance on 03131!2009 $16,265.12
Net Change . -$413.48
Vested Balance $16,265.12
Year to Date ConMbutions $9flZ01
Your Personal Rate of Return
r
&M K-
0110.1120Q9. to.03131/200
Page 1 of
AD the data you need to brack your
retirement investment 1s here. This
*tement is designed to keep you up to
date on the status of your account so you
can effectively plan and invest for your
future. Take a minute to review your
statement carefully and report any incorrect
information immediately.
ACCOUNT GROWTH
2D.= _ w. Your Personal Rate of Return
?-? From 04/4/12008 t0 03131/2009: -36.07-A
15.000 D9N3M7 0313112008 09/3012008 03/314009
$17,295.65 $18,309.86 $19,115.76 $16,265.12
.? 111,000
-
The growth of your acrxlunt taro be influenced by a number of tactars,.;ncrudung the specific
investment options selected
os?ol 03M 09= 0=
r.. ,
the dlversiflcatfon of your hves e-nt among asset classes mud the contributions to your account. Past perfonn awe does
'- • Accoant Bd3m not guanantse futine rr d s. If you world Ike t0 make duwxjes to any ofthese areas, c wdact a representafive or go ar w
- to www.wachowacom/myreflreplan.
=. CONTRIBUTION SUMMARY
-,?• By _saving ffinw h your plan you can
add to the rmanclat crest egg you wNl Contribution
Rate
This Period Year to Date
. need/in the biros. Ali Contribution Sources
_ EE PreTax A*ft $556.15 $556.15
EE PreTax Supplemental 4.00% $111.10 $111.10
Em wer match n/a $319.76 $319.76
Total Contributions $987.01 $987.01
CHRISTINA A 8TETTEP 694777
ODElT13C 058880 10320574401-f NNNNY NNNNN NN NNNNN NNNNN NNN 000001
304,063
EXHIBIT M
ItJMAN SERVICES
PIKE
'A 19444-1810
Your Company Contact:
LBC, Participant Services at
1-800-826-7859
11
on yawShk
MATTHEW STETTER
1029 KATHRYN AVE.
DAUPHIN PA 17018-9748
SSN: XXX-XX-7533
NORTHWESTERN HUMAN SERVICES
430 - 70106
Important note from LBG: Please read your statement, check it for accuracy, and
calf us with any concerns so we can investigate for you. Errors must be reported
in writing within 30 days of your receipt of this statement to be addressed.
YOUR.TOTAL ACCOUNT VALU>r.tS:
$53,262:48 'AS OF 06/30/2009:
0
T
O
«
sip
YOUR RETIREMENT PORTFOLIO FROM 04/01/2009 TO 06/30/2009
Your Recent Retirement Account History*
???1hiM::?"CClli?Ett'?`R?-`''?19a„??;??.•?-:r,.?_..?. _ _ Opening Value on 04f0112009
Contributions
Investment Gain/(Loss)
Total Account Value on 06/3012009
High
Davisny Venture Fd Class A
Drey S&P 500 -index Fund
Jenisn Mdcap Gr A
Putnam Equtpty Income Fd A
Thornburg Irrrtrtlt Value Fd 1
LOW
Blkrck Govt Inc Port Inv A
Total Account Value
$45;2.00
$7,978.87
$53.262.48
94.21%
$4,949.95 1.066511
$9,341.00 0.683319
$7,748.39 1.320029
$10,993.41 1.315182
$17,145.62 2.072289
6.79%
$3,084.11 1.224857
100°l0 $53,262.48
Due to rounding, Total Account Value percentage may not equal 100%. Your actual
balance may be different If you are not yet fully vested with your employer. Please contact
your employer for details.
$62.085
$0
$62,085 $49.646 $45,284 $53262
SeP30, 2008 Dec 31, 2008 Mar 31,200!) Jun 30, 2009
'COrreatlons made after the close of past periods are not reflected in
this representattan.
Low
High
00428213 ?
Page 1 of 8
EXHIBIT N
Summarv of Transactions
Previous Balance ' 1-$6,356.45
Payments and Credits $90.00
Cash Advances +. "
Purchases and Adjustments + $0.00
Periodic Rate Finance' Charges + $25.97
Transaction Fee Finance Charges + $0.00
New Balance Total $6,292.42
August 2007 Statement
Credit Line: $8,000.00
_?.`a ? vailable:
?ling Cycle and Paymi
Pays in Billing Cycle
Closing Date
Payment Due Date
Current Payment Due
Past-Due Amount
Total Minimum
Payment Due
t Information
30
08/01/07
08/27/07
$88.00
$0:00
077 ,
Worl(Woints OE
Forlnformation on YourAccount Visit
www.bankofamerica.com
Mail Payments to-
BANK.OF AMERICA
P.O. BOX 15721
WILMINGTON, DE 19886-5721
Mail BiNing Inquiries to.
BANK OF. AMERICA
P.O. BOX 15026
WILMINGTON, DE 19850-5026
Call toll-free 1-800-789-6685
TDD hearing-impaired 1-800-346-3178
Posting Transaction Reference Account
Payments and Credits Date Date Number Number Category Amount
PAYMENT - THANK YOU 07/21 90.00 C R
3E f ii L g F3Fy 71, 7
x
?LA
_
Corresponding Annual Balance Subject to
Category Periodic Rate Percentage Rate Finance Charge
Cash Advances
A. Balance Transfers, Checks 0.013671 % DLY 4.99% $0.00
B. ATM, Bank 0.013671 % DLY 4.99% $0.00
C. Purchases 0.013671% DLY 4.99% $0.00
4.99%
VIEW UP-TO-THE-MINUTE ACCOUNT ACTIVITY, YOUR STATEMENT ONLINE, AND MORE WITH
OUR FREE ONLINE BANKING SERVICE. VISIT BANKOFAMERICA.COM TODAY TO ENROLLI
EXHIBIT 0
T AUG_22-2008 FRI 09_44 AM MEMRERS IST VISA DEPT
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EXHIBIT Q
EXHIBIT R
EXHIBIT S
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
CHRISTINA A. STETTER ) Order Number 01054 S 2007
Plaintiff )
vs. ) PACSES Case Number 866109706
MATTHEW A. STETTER ) Docket Number 01054 S 2007
Defendant ) Other State ID Number
ORDER OF COURT
® Final Q Interim O Modified
AND NOW, 12TH DAY OF FEBRUARY, 2008 based upon the Court's
determination that the Payee's monthly net income is $ 3,338.40 and the Payor's
monthly net income is $ 3, 884.87 , it is hereby ordered that the Payor pay to the
Pennsylvania State Collection and Disbursement Unit
ONE THOUSAND SEVENTY ONE AND 67/00
Dollars ($1, 071.67 ) a month payable BI-WEEKLY as follows: first payment due
FEBRUARY 2008, AT RATE OF $484.62, FOR CURRENT SUPPORT AND $10. FOR ARREARS
The effective date of the order is o i / o 1 / o s .
Arrears set at $ 213 5. 0 0 as of FEBRUARY 12, 2 o o 8 are due in ful l
IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by
contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license
revocation, and the freeze and seize of financial assets. These enforcement/collection
mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to
make each payment on time and in full will cause all arrears to become subject to immediate
collection by all the means listed above.
For the Support of:
Name Birth Date
AVA L. STETTER 07/20/02
GRACE L. STETTER -08/30/04
Form OE-518 Rev.4
Service Type M Worker ID 21103
STETTER V- STETTER PACSES Case Number: 666109706
The defendant owes a total of $1, 071.67 per month payable BI-WEEKLY ;
$1, 050 . 00 for current support and $ 21.6 7 for arrears. The defendant must
also pay fees/costs as indicated below. This order is allocated and monies are to be applied as
follows:
Frequency Codes: 1 =One Time M =Monthly
Payment Amount/
Frequency
D
bt T
D
i
i
$ 525.00 e
vn
c r
l
on Beneficiary
/M CS ALLOC/MED AVA L. STETTER
$525.00 /M CS ALLOC/MED GRACE L. STETTER
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
$ 0.00 /
Said money to be turned over by the Pa SCDU to:
CHRISTINA A. STETTER . Payments must be made by check or
money order. All checks and money orders must be made payable to Pa SCDU and mailed to:
Pa SCDU
P.O. Box 69110
Harrisburg, Pa 17106-9110
Payments must include the defendant's PACSES Member Number or Social Security Number
in order to be processed. Do not send cash by mail.
Page 2 of 4 Form OE-518 Rev.4
Service Type M Worker ID 21103
STETTER V- STETTER PACSES Case Number: 866109706
The monthly support obligation includes cash medical support in the amount of $250 annually
for unreimbursed medical expenses incurred for each child and/or spouse. Unreimbursed
medical expenses of the obligee or children that exceed $250 annually shall be allocated
between the parties. The party seeking allocation of unreimbursed medical expenses must
provide documentation of expenses to the other party no later than March 31 st of the year
following the calendar year in which the final medical bill to be allocated was received. The
unreimbursed medical expenses are to be paid as follows: 55 % by defendant and
45 % by plaintiff. O Defendant O Plaintiff O Neither party to provide medical
insurance coverage. Within thirty (30) days after the entry of this order, the (j)Plaintiff
O Defendant shall submit to the person having custody of the child(ren) written proof that
medical insurance coverage has been obtained or that application for coverage has been made.
Proof of coverage shall consist, at a minimum, of : 1) the name of the health care coverage
provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4)
the address to which claims should be made; 5) a description of any restrictions on usage, such
as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of
the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments;
and 8) five copies of any claim forms.
Other Conditions:
1. ORDER AND THE EFFECTIVE DATE OF THE ORDER ARE BASED ON PARTIES AGREEMENT.
Defendant shall pay the following fees:
Fee Total
$ 10.oo
$ 25.00
$ 0.00
$ 0.00
$ 0.00
Fee Description
for JUDICIAL COMPUTER FEE
for COURT COSTS
for
for
for
Payment Freauenc
Payable at $ 10 . o o
Payable at $ 2 5.0 0
Payable at $ 0. 0 o
Payable at $ 0.0 o
Payable at $ o . o o
X
per ONE TIME
per ONE TIME
per
per
per
Page 3 of 4 Form OE-518 Rev.4
Service Type M Worker ID 21103
STETTER
V. . rETTER
PACSF- ? -ase Number: 8 6 610 9 7 0 6
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND
THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT
TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING,
BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF
PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY
WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN
CONTEMPT OF COURT, AND MAYBE FINED OR IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST
ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF
YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE
FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY
(ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION.
ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING
UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY
PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN
ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT
OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN
THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND
AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY
OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL
PROPERTY.
IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be
arrested and brought before the Court for a Contempt hearing; payor's wages, salary,
commissions, and/or income may be attached in accordance with law; this Order will be
increased without further hearing by o % a month until all arrearages are paid in full. Payor
is responsible for court costs and fees.
Copies delivered to parties
Date
V
Plaintiff's Attomey
Defdnd nt's Attorney
.
BY 1 COURT:
12TH DAY OF FEBRUARY, 2008
Date
Service Type M
Page 4 of 4
Judge
Form OE-518 Rev.4
Worker ID 21103
Consented:
EXHIBIT T
isle, sccurate, , -site 2008 W-2 and EARNINGS SUMMARY - 1
, wit the 11,13 Web °ASTt use at wwrvlrs pov/eBle. r ,: , ,
Et1i $Ibyeo;Reforonog Cop TMs Blue Ear" lags Summary geotlen !s Included wfth.your W 2 to help desotfbe,portlons In more data
L Wegq and' Tax Q t The tevdese eldalnoludes"ileoeral lriforj tl`oq thaf you.may aHolfuh1
W.e?. 2
Q 1, The following Iriformatfoneliecri Your lflna12008 'Pay Stub pllre'ahY aditistrilerr(ti iubmltted {iY vrour employe
d Control number ytt Cote, twployw ass on
700859 70/F4P 47001 A 4322
r Employer's name, address, end ZIP code
NORTHWESTERN HUMAN
SERVICES OF PENNSYLVANIA
620 EAST GERMANTOWN PIKE
LAFAYETTE HILL- PA 19444
Batch #02100
41 Employee's name, ad**", wA ZIP code
MATTHEW STETTER
1029 KATHRYN AVE.
)AUPHIN,PA 17018
Employer's FeD 10 number
23- • m • SGA r
*=.50.7533
Wages, Ups, other oomp Pedsral income tax wRhheld
64217.79 4792.97
Social security wages 4 Soolol esaarttytax wIthhetd
64455.48 3996.24
Medloare wages, and tips M ciloare tat wllh
64455.48 934.60
Seol•I securlty tips a Aitoeabd Upe
Advance EIC payment 10 Dependent ogre Ns,
1 Nonquallfted plans es, IwAractionat 1 er
L, 179
-
7-19
1 Other 1
5
r NE is wMdot
i State Employer's, scats, ID no. 18 Stets wages, spa, etc
PA 1553 0793 84375.86
stato Income tax S Looal wages,11^ eta.
1976.38 04373.66
Local Income tax 20 Loeallfy nams,
1267.60 SSQUEfiNA
Oro$$'pay: ` `66992, 58 ' $dclM 8w-.4r 3998.24 ` PA: SIAN (ncotnej Tax: ` 1928:38
.
Tax.With Id l Btix 17 of *2
' ft 4 of YV ..' f Local Incoriw Tax 1287 60
Fed. fneome t' 97 Medlcan Tax t s 934 80 BOX 1,9 01 w 2 '?
4792
'
TarF Wkhheld ,
.
Wlthhefal $i1l(BDi -,3060
.
Box 2 of Vii 2 j Box 8 of W 2 ?ao(:14 of w 2
..
2. Your Orosi Pay weie adlpstpd as, follows to produce your W-2 8tat4m6e
Wages l'tpKother 8gelel Secui l if Medicare f?A. state Wages, S$Q(IEHNA
Compansat!on .. Wages Wages Tips, Eto. Local Wage
Bbx 1. of W!-2 Boz 3 of W-2 Box-5 of W.2 'Box 16 of W-2 1'Ipe; Etc:
Box 18 Of VV
Orods F'ay : 65,992.58 86,892;68 8$,992;;68' 65 892 b6 ;.65832:
Plus OTL (C-Box 14 79:82 79:82 79:82 N/Al N
Le$s 401". (D-Bp02) 237:69 NIA N/A
1 N/A N
Less Mockal F3A : 300.04 - 300.04 ,
300.04 300:04 300.1
Less Oter h Cafe.126 1,318.88 1, 316.86 316.88 ; 1, 31688 1, 3.18:
Reported W-2 Wages 84,217.79 ` 84 458.
5.4
6 64r .75,E
64,455.40:'64'375. 6
3. Employee W-4 Pronle. To chance your Employee W-4 Profile Information.1119 a now. W-4.with your payroll dept
MATTHEW STETTER
1029 KATHRYN AVE
DAUPHIN,PA 17018
o xo" ADP. tnlo. - '
Social Security, Number.. 20250-7533
TAxable:Mwltel Status: MARRIED
' Exempdons/Allowances:
FEDERAL'
STATE:: '
LOCAL: 6
----------------------
- -----------------
Copy _? ?4 - .m!irras+numu- - C, for emplayass neoeds
Fwm M2 Waae and Tax S"mod 2008
0 Control mflufter 0426 -8479 oye s name, addron. and zip a s 8apertmet of The Tre"ury - Intsmal Revenue Imtos
000094-000011 COUNTRY CLUB OF HARRISBURG OMB Me. 15411-MB
b 401 FISHING CREEK VALLEY RD
202-30-7533
23-0496560
r
HARRISBURG PA 17112
ZF0011101111 nsaas utwl
5316,84
,
Mean $mpg 500141 SM811Y 11-K =*11
1 8916.84 515.65
17
a rs- w, ox 12 74 K s Employ Ws name, addiess.'and Mrs care wages am Medicare
PASUI 4.98 MATTHEW A
ST8TT4R 120.62
.
1029 KATHRYN AVUB 7 oci a•curily tips B Allocated UPI
DAUPHIN PA 11020
Advance EIC payment sps m we benefits
n plans
16 Bbte Empioyer's slab 10 No. iB 6pb wagon. Bps, ato. 17 2kie leoome tax 10 Loaf wages, tips. sto. 10 Local lnaotne x
la 20 Load" name
PA 11474509 8316.84 253.36 8316.84 66.31
1 PA ytDPAX-CTCB
filslafameaat wB•Y1g foMMdd blbebYtrsl Reaatale eerie
Copy 0, to he filed with employees FEDERAL tax rotum
Farm W-2 Waaa and Tax statement 2008 '
a one* number 9426-8473 Vold a mployor's name. address, and ZIP code Department of IM treasury - Internal Revenue Service
'000094-000011 COUNTRY CLUB OF HARRISBURG
' ONBNo.1646-0008
m syws e s secs ne new 401 FISHING CREEK
VALLEY RD
- 7 HARRISBURG PA 17112 gas. UK o er as>oeasaeos
68 14 2 e noome lax
wowd
oegryM pha° M*d
boom t"curity wagsa T=
taw {yZax •
8316.84 515.65
12 es, strs. or ox 12 14 other s mp se's name, addrass. and ZIP code Medicare wages and tips cars x e
98
PASUI 4 MATTHEW A STETTER $316.84 120.62
. 1029 KATHRYN AVEN.pE 7 Social security tips 8 Adopted tips
DAUPHIN PA 17018•
Advance IC payment 10 gem ant are benefits
11 nil ant
16 Stan Employer's wte 10 No. 10 Stab wag". Bps. Mo. 17 state incomo,tax 18 Local wage, tips. •te. iB Local income tax 20 Locality name
PA 11474509 8316.84 X235.36 8316.84 166.31 PA NDPAX-CTCB
t
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this day of , 2009, I, Katherine A. Frey,
Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Defendant, hereby certify that
a copy of the within document has been served, by depositing a copy of the same in the
United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the
following addressee:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
Attorney for Plaintiff
By:
Katherine A. Frey
?? ?, ?. ,
?? :f !
v i i i f' +?,. v
?_ ?..?
J
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE
DEFENDANT 's _ INCOME AND EXPENSE STATEMENT
UNDER RULE 1920.31
I hereby file the Statement of Income and Expenses required under Rule 1920.31 and
verify that the information therein contained is true and correct to the best of my knowledge,
information and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. 4904, relating to unsworn falsification to authorities.
Date:
Ma hew A. tt
0
INCOME AND EXPENSE STATEMENT
OF
MATTHEW A. STETTER
Employer: NHS Human Services
Address: 4391 Sturbridge Drive, Harrisburg, PA 17110
Type of Work: Human Services
Payroll Number: 700859
Pay Period (weekly, bi-weekly, etc): bi-weekly
Gross Pay Per Pay Period:
Itemized Payroll Deductions: $2,424.47
Federal Withholding -$367.59
Social Security -$146.39
Local Wage Tax -$47.16
State Income Tax -$72.39
Unemployment -$1.45
Medicare Tax -$34.24
Retirement (401 k)
Savings Bonds
Credit Union
Life Insurance -$2.00
Health Insurance -$47.37
Dental -$4.31
Vision -$1.25
Med Flex Spend -$13.47
U-Way -$12.00
Pension Contribution
Support -$494.61
Net Pay Per Pay Period: $1,180.24
Other Income:
Monthly
Interest - CD & Bonds
Dividends
Yearly
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Unemployment Compensaion
Workmen's Comp.
Gifts
Child Support
Spousal Support/Alimony
TOTAL $2,555.22 $30,662.64
EXPENSES
Monthly Yearly
HOME:
Mortgage/Rent $1,038.00 $12,456.00
Maintenance & Lawn
Utilities:
Electric $135.00 $1,620.00
Gas/Coal $23.33 $280.00
Oil $54.00 $648.00
Sewer $25.00 $300.00
Telephone
Cell Phone $50.00 $600.00
Water
Refuse City $18.75 $225.00
EMPLOYMENT:
Public Transportation
Lunch
TAXES:
Real Estate
Personal Property
2008 Tax Liability
INSURANCE:
Homeowners
Automobile(s)
Life
Accident
Health
Other
AUTOMOBILES:
Payments
Fuel (all vehicles)
Repairs
MEDICAL:
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special Needs (glasses
braces, etc.)
$120.00 $1,440.00
$166.67 $2,000.04
$416.66 $5,000.00
$35.00 $420.00
$70.00 $840.00
$313.56 $3,762.72
$160.00 $1,920.00
$150.00 $1,800.00
$30.00 $360.00
EDUCATION:
Private School
Parochial School
College
Religious
PERSONAL:
Clothing
Food
Barber/Hair Dresser
Credit Card
Charge Accounts
Memberships
LOANS:
Roof
Line of Credit
MISCELLANEOUS:
Child Care/Babysitting
Papers/Books/Magazines
Entertainment
Pay TV - Cable
Vacation
Gifts
Legal Fees
Charitable Contributions
Child Support
Alimony/Spousal Support
$50.00 $600.00
$30.00 $360.00
$300.00 $3,600.00
$200.00 $2,400.00
$80.00 $960.00
$55.00 $660.00
$167.00 $2,004.00
$0.00
$1,050.00 $12,600.00
Tax Preparation $1.75 $21.00
Pet Expenses $50.00 $600.00
TOTAL EXPENSES $4,789.72 $57,476.76
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1029 KATHRYN AVE.
DAUPHIN, PA 17018
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Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this c2 day of , 2009, I, Katherine A. Frey,
Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Defendant, hereby certify that
a copy of the within document has been served, by depositing a copy of the same in the
United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the
following addressee:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
Attorney for Plaintiff
By. _ ?-
Katherine A. Frey
"j, II F P.- TAPY
2 P 01 d 25 F N 2= 5 l
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-4289
CIVIL ACTION -LAW
IN DIVORCE
INVENTORY
UNDER RULE 1920.33
Defendant, Matthew A. Stetter, files the following inventory of all property owned
or possessed by either party at the time this action was commenced and all property
transferred within the preceding three years.
Defendant verifies that the statements made in this inventory are true and correct.
Defendant understands that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Matthq4v A. Stetta
Date: B2-
ASSETS OF PARTIES
DEFENDANT MARKS ON THE LIST BELOW THOSE ITEMS APPLICABLE TO
THE CASE AT BAR AND ITEMIZES THE ASSETS ON THE FOLLOWING PAGES.
(X) I. Real Property
(X) 2. Motor Vehicles
(X) 3. Stocks, bonds, securities and options
( ) 4. Certificates of Deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings
certificates
() 7. Contents of safe deposit box(s)
() 8. Trusts
() 9. Life insurance policies (indicate face value, cash
surrender value and current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage
of ownership, and officer/director positions held
by a party with company)
() 16. Employment termination benefits - severance pay,
worker's compensation claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and
date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
() 21. Litigation claims (matured and unmatured)
() 22. MilitaryN.A. benefits
() 23. Education benefits
(X) 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a
total category and attach itemized list if distri-
bution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
DEFENDANT LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AS OF THE DATE OF THE SEPARATION OF THE PARTIES:
ITEM NUMBER DESCRIPTION NAMES OF
OF PROPERTY ALL OWNERS
1. 1029 Kathryn Avenue Husband and Wife
Dauphin, PA 17018
2. 2003 Honda Odyssey Husband and Wife
2. 2003 Ford Explorer Sport Trac Husband and Wife
3. ING Direct/Sharebuilder Husband
5. PSECU Checking Acct. Husband and Wife
5. Members 1 st Checking Acct. Wife
6. PSECU Savings Acct. Husband and Wife
6. Member's 1 st Checking Acct. Wife
19. Retirement w/ Northwestern Husband
19. Retirement w/ Highmark Wife
25. Household goods and furnishings Husband and Wife
NON-MARITAL PROPERTY
DEFENDANT LISTS ALL PROPERTY IN WHICH A SPOUSE HAS A LEGAL OR
EQUITABLE INTEREST WHICH IS CLAIMED TO BE EXCLUDED FROM MARITAL
PROPERTY:
ITEM NUMBER DESCRIPTION REASON FOR
OF PROPERTY EXCLUSION
PROPERTY TRANSFERRED
DEFENDANT LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAD A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AND WHICH HAS BEEN TRANSFERRED WITHIN THE PRECEDING
THREE YEARS:
ITEM DESCRIPTION DATE OF CONSIDER- PERSON TO
NUMBER OF PROPERTY TRANSFER ATION WHOM
TRANSFERRED
LIABILITIES
DEFENDANT LISTS ALL LIABILITIES OF EITHER OR BOTH SPOUSES ALONE OR
WITH ANY PERSON AS OF THE DATE OF SEPARATION:
ITEM DESCRIPTION NAMES OF
NUMBER OF PROPERTY ALL CREDITORS
24. 1029 Kathryn Avenue Wells Fargo
Dauphin, PA 17018
24. 2003 Honda Odyssey PSECU Loan No.
0202507533:24
24. 2003 Ford Explorer Sport PSECU Loan No.
020507533:22
24. Loan for Roof PSECU Loan No.
202507533:21
24. Credit card Bank of America
No.5490352874405427
24. Credit card Member's 1 st Visa
No.4121449991508255
NAMES OF ALL
DEBTORS
Husband & Wife
Husband & Wife
Husband & Wife
Husband & Wife
Wife
Wife
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
717-657-0632
Id. No. 63522
Attorney for Defendant
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this JP?_day of , 2009, I, Katherine A. Frey,
Secretary to Marianne E. Rudebusch, Esquire, Attorney for the Defendant, hereby certify that
a copy of the within document has been served, by depositing a copy of the same in the
United States mail, first class, postage prepaid, delivery at Harrisburg, Pennsylvania, to the
following addressee:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
Attorney for Plaintiff
By: 4,(4, 9?"
Katherine A. Frey
P.1 FF'L tr7 :F
2 009 KOY 25 P , 2. Iri i
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08 - 4289
MATTHEW A. STETTER, CIVIL ACTION -LAW (7 ,
Q 4.3
Defendant IN DIVORCE r.:
M
?M
AFFIDAVIT OF CONSENT - ,. =
`
71
'
A Complaint in Divorce under Section 3301(c) of the Divorce Code as fiTFd on"
July 17, 2008.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the 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 are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: 2010
CHRISTINA A. ST TTER
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
I.
2.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 4289
CIVIL ACTION -LAW
IN DIVORCE
n
k_
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
43301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
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W
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?? ca
y c'
I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn
falsification to authorities.
DATE: 4/(4 1G , 2010
r CHRISTINA A. STET R
2
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-4289
: CIVIL ACTION -LAW
: IN DIVORCE
c?
c?-
N
a
o`
s?i
W
v
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C)
2-;
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on July 17, 2008.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of Notice of
Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904
relating to unsworn falsification to authorities.
Date: a2 1 110
Ma ew A. S
CHRISTINA A. STETTER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08-4289
MATTHEW A. STETTER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
_ nip
WAIVER OF NOTICE OF INTENTION TO RE UEST EN _ i ~
OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE DIED
1. I consent to the entry of a Final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating
to unsworn falsification to authorities.
i
Date:
M hew
CHRISTINA A. STETTER, IN THE COURT OF COMMON PLE
Z
Plaintiff : CUMBERLAND COUNTY, PENNS' ?
NO. 08-4289 _r r r
MATTHEW A. STETTER, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code
was filed on July 17, 2008.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of
Notice of Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities.
Date: ` 4
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
n
NO. 08-4289 C
CIVIL ACTION -LAW
IN DIVORCE
c.
r
00
r..
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTR7? 4"=`>
OF A DIVORCE DECREE UNDER 63301(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 of the decree will be sent to me immediately
after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. §4904, relating to unsworn falsification to authorities.
Date: /-/-& 40
att tetter
-?; rrz
2C
MARITAL SETTLEMENT AGREEMENT
„
THIS AGREEMENT, made this day of , 2010, by and
between Matthew A. Stetter, hereinafter referred to as "HUSBAND", and Christina A. Stetter,
hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on November 7, 1998, in Harrisburg, Dauphin County, Pennsylvania;
WHEREAS, two (2) children were born of this marriage being Ava L. Stetter (born July
20, 2002) and Grace L. Stetter (Born August 30, 2004);
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles
and interests, claims and possible claims in or against the estate of the other.
NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
3/19/2010
1 -TV
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
SECTION I
GENERAL PROVISIONS
1. ADVICE OF COUNSEL
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection. WIFE has been independently
represented by Barbara Sumple-Sullivan, Esquire. HUSBAND has been independently
represented by Marianne E. Rudebusch, Esquire. Each party further declares that they are
executing this Agreement freely and voluntarily, having obtained such knowledge and disclosure
of their legal rights and obligations. Each party acknowledges that this Agreement is fair and
equitable and is not the result of any fraud, coercion, duress, undue influence or collusion.
Both parties further acknowledge and agree that each has fully disclosed their respective
financial situations to the other, including their assets, liabilities and income. Each of the parties
acknowledge and agree that, after having received such information and with such knowledge,
this Agreement is fair, reasonable and equitable and that it is being entered into freely,
voluntarily and in good faith and that the execution of this Agreement is not the result of any
duress, undue influence, coercion, collusion and/or improper or illegal Agreement.
3/19/2010 2 r .
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the provisions
of this Agreement. Each may reside at such place or places as she or he may select. Each may,
for his or her separate use or benefit, conduct, carry on and engage in any business, occupation,
profession or employment which to him or her may seem advisable. This provision shall not be
taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness
of the causes which led to, or resulted in, the continuation of their living apart. HUSBAND and
WIFE shall not molest, harass, or malign the other or the respective families of each other, nor
compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with
the peaceful existence, separate from each other.
3. FINANCIAL DISCLOSURE
The parties have fully disclosed to each other the extent of each other's income, assets,
liabilities, holdings and estate. Each party warrants that the information provided has fully and
accurately described the extent of his or her holdings. Each of the parties acknowledge that he or
she is aware of his or her right to seek discovery including, but not limited to, written
interrogatories, motions for document production, depositions, and other means of discovery
available through the Pennsylvania Rules of Civil Procedure. The parties acknowledge that they
have had the right to have property fully appraised. Each party is fully satisfied that no additional
information is necessary for the execution of this Agreement.
3/19/2010 3
4. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no-fault divorce pursuant to the provisions
of Section 3301(c) of the Divorce Code of 1980, as amended and will execute the documents
necessary to effectuate a divorce under those provisions simultaneously with the execution of this
Agreement.
5. SUBSEQUENT DIVORCE
A decree in divorce, entered by the court of Cumberland County, shall not suspend,
supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions
contained herein, as well as the enforcement of said terms and conditions, shall not be contingent
upon the granting of a Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This
Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
HUSBAND and WIFE, or attempt a reconciliation. This Agreement shall continue in full force
and effect and there shall not be a modification or waiver of any of the terms hereof unless the
parties, in a writing signed by both parties, execute a statement declaring this Agreement or any
term of this Agreement to be null and void. Both parties hereto agree that this Agreement shall
be incorporated by reference but shall not be deemed merged into any judgment or decree for
divorce obtained by either party.
3/19/2010 4
v€ 5
6. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other parry, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for
the proper effectuation of this Agreement.
7. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement,
A. Each party hereby absolutely and unconditionally releases and forever discharges
the other and the estate of the other for all purposes from any and all rights and obligations which
either may have or at any time hereafter have for past, present or future support or maintenance,
alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any
other right or obligation, economic or otherwise, whether arising out of the marital relationship
or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its
supplements and amendments, as well as under any other law of any other jurisdiction, except
and only except all rights, agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provision thereof Neither party shall have
any obligation to the other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges
the other and his or her heirs, executors, administrators, assigns, property and estate from any and
all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of
the parties or otherwise, whether now existing or hereafter arising. The above release shall be
effective regardless of whether such claims arise out of any former or future acts, contracts,
engagements or liabilities or the other or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other
country. It is expressly understood, however, that neither the provisions of this release nor the
subsequent entry of a divorce decree are intended to defeat the right of either party to receive any
insurance proceeds at the death of the other of which she or he is the named beneficiary (whether
the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the
right of either party to receive any legacy, bequest or residuary portion of the other's estate under
his or her will, or to act as personal representative or executor if so named by the will of the
other, whether such will was executed prior or subsequent to this Agreement.
3/19/2010 5
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as
are expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or
demands whatsoever, in law or in equity, which either party ever had or now has against the
other.
8. SUCCESSOR'S RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
assigns.
9. SEVERABILITY
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
and effect without being impaired or invalidated in any way.
10. ENTIRE AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
3/19/2010 6
'. 4e. ?4f
11. BINDING EFFECT OF AGREEMENTIWAIVER
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to the terms of this Agreement.
The failure of either party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent default of the same or similar
nature, nor shall such failure be construed as a waiver of any other term, condition, clause or
provision of this Agreement.
12. BREACH
If either party breaches any provision of this Agreement, the other party shall have the
right, at his or her election, to sue for damages for such breach or seek such other remedies or
relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
13. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
14. TAX RETURNS
The parties agree that in the future if any penalties or interest or any liability for failure to
3/19/2010 7
declare income or the wrongful claiming of any deduction shall be assessed by the United States
Internal Revenue Service or the Commonwealth of Pennsylvania, or any other state as a
consequence of the parties' Federal and State income tax returns which were filed jointly by the
parties, said tax, penalties or interest shall be the sole responsibility of the party found to be
responsible for the mistake or failure. The party responsible for the mistake or failure shall suffer
the consequences solely and hold the opposite party harmless. However, if the liability is the
result of a computation error or an error not attributable to an intentional act or grossly negligent
conduct of either party, the parties shall share equally in all future tax liability or tax assessment,
penalties and interest.
SECTION H
EQUITABLE DISTRIBUTION
During the marriage, the parties have accumulated various assets and liabilities, the
disposition of which is intended as follows:
1. ASSETS
A. PERSONAL and HOUSEHOLD PROPERTY
HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non-
marital and marital personal and household property, including but without limitation, jewelry,
clothes, furniture, and other assets. HUSBAND agrees that all assets in the present possession of
WIFE shall be the sole and separate property of WIFE and, WIFE agrees that all assets in the
present possession of HUSBAND shall be the sole and separate property of HUSBAND. Each of
the parties do hereby specifically waive, release, renounce and forever abandon whatever claims,
3/19/2010 8
if any, he or she may have with respect to any of the above said items which are the sole and
separate property of the other.
This document shall constitute a bill of sale for said sole property.
B. REAL ESTATE
The parties jointly own property at 1029 Kathryn Avenue, Dauphin, Dauphin County,
Pennsylvania 17018. Said house is encumbered by a mortgage held by Wells Fargo in the
approximate amount of One Hundred Three Thousand Dollars ($103,000.00). The property shall
be sold. The parties agree that they shall list the property with Robert Hamilton of ReMax. The
house shall be listed for the asking price suggested by the realtor. HUSBAND shall be required
to actively promote the sale by:
a) Maintaining the house in good repair and condition;
b) Making the house available for showings with three (3) hours notice from any
realtor;
C) Allowing open houses and signage as suggested by realtors; and
d) Agree to reduce the listing price for the home as recommended by the realtor and
agreed to by WIFE until a contract for sale is secured.
The parties shall work together to evaluate what repairs are necessary to maximize the
sale price and shall make such repairs as may be required and which are mutually agreed upon by
3/19/2010 9
the parties. HUSBAND shall be solely responsible for any past, present and future mortgage
principal, interest, penalties and costs as well as any taxes, insurance and/or any debts associated
with the real estate. HUSBAND agrees to indemnify and save WIFE harmless from all such
expenses, including attorney fees, she may incur in defense of any action against her relative to
said expenses. Pending sale, HUSBAND shall make these payments in a timely manner.
Upon sale, WIFE shall receive fifty-two and one-half (52.5%) percent of the net proceeds
and HUSBAND shall receive forty-seven and one-half (47.5%) percent of the net proceeds in full
and final equitable distribution of the marital home.
C. MOTOR VEHICLES
The parties acquired two (2) vehicles during the marriage being a 2003 Honda Odyssey
which is driven by WIFE and a 2003 Ford Explorer Sport Trac driven by HUSBAND. Both
vehicles are encumbered with loans due and owing to the Pennsylvania State Employees Credit
Union. The parties agree that each party shall maintain as his or her sole or separate property the
vehicle which he or she drives. Each party hereby waives, relinquishes and releases any claim in
the vehicle which shall be the'sole and separate property of the other. Each party agrees to
assume and be solely responsible for the loan encumbering his or her vehicle. If the
Pennsylvania State Employees Credit Union car loans are in joint names, both parties shall be
immediately obligated to use the proceeds from the sale of the home to satisfy any outstanding
balance on the loans encumbering his or her respective vehicles. Each party agrees to promptly
coordinate and cooperate in the transfer of titles to the vehicles.
3/19/2010 10
D. FINANCIAL ASSETS:
The parties acknowledge that the marital financial accounts which existed during the
marriage have been divided to the satisfaction of the parties. All jointly titled accounts have been
closed. Each party hereby waives, relinquishes and releases any claims to the financial accounts
in the possession of the other.
E. PENSION AND RETIREMENT ACCOUNTS:
During the marriage, WIFE accumulated certain retirement benefits through her
employment. These benefits consisted of a Highmark Investment Plan which was encumbered
with a loan at the time of separation. WIFE shall be the sole owner of said asset and HUSBAND
waives any and all claims thereto. WIFE shall be solely responsible for payment of the loan
against said plan and indemnifies and holds HUSBAND harmless from said debt.
HUSBAND has accumulated a pension account with the Northwestern Human Services
Account. HUSBAND confirms that he has neither made nor will make any withdrawals from the
account. WIFE shall receive the sum of Thirty-four Thousand Two Hundred Ninety-nine Dollars
and 21/100 ($34,299.21) which represents fifty-two and one-half (52.5%) percent of the account.
It is the intention of the parties that the rollover shall occur by a Qualified Domestic Relations
Order or such similar authorized method to effectuate a tax free rollover so that said transfer shall
not result in the imposition of any tax liability to either party. This paperwork shall be prepared
by HUSBAND's counsel at his sole cost and expense. The rollover shall be accomplished not
3/19/2010 11
?.t2
later than sixty (60) days from the date of entry of the divorce decree.
Each party further warrants that he or she has earned no retirement or other deferred
employment benefits during the marriage.
2. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnify and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities.
WIFE shall be liable and solely responsible for the following debts and will indemnify
and hold HUSBAND harmless from the same:
Bank of America Credit Card, Account No. 05427; and
2. Members First Visa, Account No. 8255.
WIFE agrees to indemnify and hold HUSBAND harmless from each of the
aforementioned debts and agrees to be responsible for all attorneys' fees incurred by HUSBAND
in defense of any claim or suit brought against him arising from any debt incurred during the
marriage.
3/19/2010 12 ,_ ,
HUSBAND shall be liable and solely responsible for the following debts and will
indemnify and hold WIFE harmless from the same:
PSECU Loan, Account No. 533:21;
2. Any loan due and owing by HUSBAND for his musical equipment; and
3. Any debts advanced post-separation on any marital credit card including, but not
limited to Lowes.
HUSBAND agrees to indemnify and hold WIFE harmless from each of the
aforementioned debts and agrees to be responsible for all attorneys' fees incurred by WIFE in
defense of any claim or suit brought against him arising from any debt incurred during the
marriage.
To the best of the parties' knowledge, the parties affirm no other joint debts exist and all
joint credit cards are terminated.
SECTION III
1. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT, MAINTENANCE AND
COUNSEL FEES
Both parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are
accepted by them in lieu of and in full and final satisfaction of any claims or demands that either
3/19/2010 13
may now or hereafter have against the other for support, maintenance, alimony, alimony
pendente lite or counsel fees. HUSBAND and WIFE further, voluntarily and intelligently, waive
and relinquish any right to seek from the other any payment for spousal support, alimony,
alimony pendente lite, maintenance or counsel fees.
SECTION IV
CHILD SUPPORT AND CUSTODY
1. CHILD CUSTODY
The parties mutually agree with respect to their minor children as follows:
A. Legal Custody: The parties agree that major decisions concerning their children's
health, welfare, education, religious training and upbringing shall be made by the
parents jointly, after discussion and consultation with each other, with a view towards
obtaining and following a harmonious policy to arrive at a decision that is in their
children's best interest. Each party agrees to keep the other informed of the progress
of their children's education and social adjustments. Each party agrees not to impair
the other parties' right to share legal custody of their children. Further, each party
agrees to give support to one another in the role as parents and to take into account
the consensus of the other parent for the physical and emotional well being of the
children. The parties agree not to either attempt or alienate the affections of their
children for the other parent. Each party shall notify the other of any activity that
could reasonably be expected to be of significant concern to the other. The parties
agree that the children will be encouraged to contact the other parent by telephone
and e-mail at all reasonable times.
B. Physical Custody:
1. Mother shall enjoy primary physical custody of the parties' minor children; and
2. Father shall enjoy periods of partial physical custody as follows:
Alternating Weekends: Father shall have physical custody of the
children on alternating weekends from Friday school to Sunday at 6:00
p.m.
3/19/2010 14
All
Weekdays: Father shall have physical custody of the children on a
mutually agreed upon day agreed upon by the parties from after school or
4:30 p.m. to 8:00 p.m. The day of the week shall be agreed upon by the
parties based on the children's and parents' schedules each Sunday.
C. Holidays: The parties shall share the major holidays in accordance with the
following plan:
Thanksgiving. In odd numbered years, Mother shall have from 10:00
a.m. on Thanksgiving Day to Sunday at 6:00 p.m.. In even numbered
years, Father shall, have from 10:00 a.m. on Thanksgiving Day to Sunday
at 6:00 p.m.
Christmas and Christmas Eve: In even numbered years, Mother shall
have custody of the minor children from 9:00 a.m. December 20 until
1:00 p.m. December 250` and Father shall have custody of the minor
children from 1:00 p.m. on December 25th until 5:00 p.m. December 26th.
In odd numbered years, Father shall have custody of the minor children
from 9:00 a.m. December 24 h until 1:00 p.m. December 25th and Mother
shall have custody of the minor children from 1:00 p.m. on December 25th
until 5:00 p.m. December 26th.
Easter: In even numbered years, Mother shall have custody of the minor
children from 6:00 p.m. the day before Easter through 2:00 p.m. Easter
Day and Father shall have custody of the minor children from 2:00 p.m.
Easter Day until the day following Easter Sunday at 9:00 a.m. In odd
numbered years, Father shall have the minor children from 6:00 p.m. the
day before Easter Day through 2:00 p.m. Easter Day and Mother shall have
custody of the minor children from 2:00 p.m. Easter Day until the day
following Easter Sunday at 9:00 a.m.
Mother's Day and Father's Day: Mother shall always have Mother's
Day and Father shall always have Father's Day. These holidays shall be
from 9:00 a.m. until 8:00 p.m. the day of that holiday.
D. Vacation: Mother and Father shall each have the right to have two (2)
nonconsecutive seven (7) day periods for vacation. This shall include his or her regularly
scheduled week. Father shall give notice of his periods of custody by May 1 st each year.
E. Transportation: Father shall continue to provide transportation for his periods of
partial custody.
3/19/2010 15
SECTION V
CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually signed
by both parties
a"k--e
WITNESS
WITNESS
3/19/2010
TT W STETTER
C TINA A. ST&TW
16
ll1?
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLAND )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Matthew A. Stetter, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
Affirmed and subscribed to before me this day of 52010.
:?.?'• ? ??''? NOMIIIIA?I iEAE
NOTARY PUBLIC
?- auawewwr-TW... DAWIN GWJW
My commission expires: 8012 (SEAL)' lllrpew i IAN>a1.?Ni
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLAND )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Christina A. Stetter, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief
scribed to before me this day of 034!5a , 2010.
NOTARY PUBLIC
My commission expires: (SEAL)
COMMONWEALTH OF PENNSYLVANIA
Nolaft Seal
Barbara Sample-Suilhan, Notary Public
New QmbmIand Born. Cumberlamd Carry
My Oom"11I Nnn Expha:Nov.1612011
Member. Pennsyivanis Asaosistlan of Nfiria`
3/19/2010 1
CHRISTINA A. STETTER,
Plaintiff
VS.
MATTHEW A. STETTER,
Defendant
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 4289 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this /99-w day of - ,
2010, the economic claims raised in the proceedings having been
resolved in accordance with a marital settlement agreement
dated April 7, 2010, the appointment of the Master is vacated
and counsel can file a praecipe transmitting the record to the
Court requesting a final decree in divorce.
BY THE COURT,
---4, O1,--II.L
Kevi Hess, P.J.
cc: Barbara Sumple-Sullivan
Attorney for Plaintiff
N
Marianne E. Rudebusch
Attorney for Defendant
i/? ? f 1V ? ' Je ?
oB
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
OF t?? OTAW
2010 APR IS PM 3: 25
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
IN THE COUftft (M PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 4289
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
July 17, 2008.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the 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 are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: ? , 2010
C STINA A. ST R
OF THE PPMOORY
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
2010 APR 15 Pty 3: 25
4u * N1Y
IN THE COURT OF COW?' Of Ks
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08 - 4289
: CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
43301(c) OF THE DIVORCE CODE
I . I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn
falsification to authorities.
r
DATE: 1. 13 , 2010
CH STINA A. STETTER
RaKffpu
OF THE P O TARy
THIS AGREEMENT, made this day of , 2010, by and
between Matthew A. Stetter, hereinafter referred to as "HUSBAND", and Christina A. Stetter,
hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on November 7, 1998, in Harrisburg, Dauphin County, Pennsylvania;
WHEREAS, two (2) children were born of this marriage being Ava L. Stetter (born July
20, 2002) and Grace L. Stetter (Born August 30, 2004);
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles
and interests, claims and possible claims in or against the estate of the other.
NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
3/19/2010 -x 4ij
1010 APR IS PM 3: 25
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
SECTION I
GENERAL PROVISIONS
1. ADVICE OF COUNSEL
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection. WIFE has been independently
represented by Barbara Sumple-Sullivan, Esquire. HUSBAND has been independently
represented by Marianne E. Rudebusch, Esquire. Each party further declares that they are
executing this Agreement freely and voluntarily, having obtained such knowledge and disclosure
of their legal rights and obligations. Each party acknowledges that this Agreement is fair and
equitable and is not the result of any fraud, coercion, duress, undue influence or collusion.
Both parties further acknowledge and agree that each has fully disclosed their respective
financial situations to the other, including their assets, liabilities and income. Each of the parties
acknowledge and agree that, after having received such information and with such knowledge,
this Agreement is fair, reasonable and equitable and that it is being entered into freely,
voluntarily and in good faith and that the execution of this Agreement is not the result of any
duress, undue influence, coercion, collusion and/or improper or illegal Agreement.
3/19/2010 2 L
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the provisions
of this Agreement. Each may reside at such place or places as she or he may select. Each may,
for his or her separate use or benefit, conduct, carry on and engage in any business, occupation,
profession or employment which to him or her may seem advisable. This provision shall not be
taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness
of the causes which led to, or resulted in, the continuation of their living apart. HUSBAND and
WIFE shall not molest, harass, or malign the other or the respective families of each other, nor
compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with
the peaceful existence, separate from each other.
3. FINANCIAL DISCLOSURE
The parties have fully disclosed to each other the extent of each other's income, assets,
liabilities, holdings and estate. Each party warrants that the information provided has fully and
accurately described the extent of his or her holdings. Each of the parties acknowledge that he or
she is aware of his or her right to seek discovery including, but not limited to, written
interrogatories, motions for document production, depositions, and other means of discovery
available through the Pennsylvania Rules of Civil Procedure. The parties acknowledge that they
have had the right to have property fully appraised. Each party is fully satisfied that no additional
information is necessary for the execution of this Agreement.
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4. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no-fault divorce pursuant to the provisions
of Section 3301(c) of the Divorce Code of 1980, as amended and will execute the documents
necessary to effectuate a divorce under those provisions simultaneously with the execution of this
Agreement.
5. SUBSEQUENT DIVORCE
A decree in divorce, entered by the court of Cumberland County, shall not suspend,
supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions
contained herein, as well as the enforcement of said terms and conditions, shall not be contingent
upon the granting of a Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This
Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
HUSBAND and WIFE, or attempt a reconciliation. This Agreement shall continue in full force
and effect and there shall not be a modification or waiver of any of the terms hereof unless the
parties, in a writing signed by both parties, execute a statement declaring this Agreement or any
term of this Agreement to be null and void. Both parties hereto agree that this Agreement shall
be incorporated by reference but shall not be deemed merged into any judgment or decree for
divorce obtained by either party.
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6. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other party, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for
the proper effectuation of this Agreement.
7. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement,
A. Each party hereby absolutely and unconditionally releases and forever discharges
the other and the estate of the other for all purposes from any and all rights and obligations which
either may have or at any time hereafter have for past, present or future support or maintenance,
alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any
other right or obligation, economic or otherwise, whether arising out of the marital relationship
or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its
supplements and amendments, as well as under any other law of any other jurisdiction, except
and only except all rights, agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provision thereof. Neither party shall have
any obligation to the other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges
the other and his or her heirs, executors, administrators, assigns, property and estate from any and
all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of
the parties or otherwise, whether now existing or hereafter arising. The above release shall be
effective regardless of whether such claims arise out of any former or future acts, contracts,
engagements or liabilities or the other or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other
country. It is expressly understood, however, that neither the provisions of this release nor the
subsequent entry of a divorce decree are intended to defeat the right of either party to receive any
insurance proceeds at the death of the other of which she or he is the named beneficiary (whether
the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the
right of either party to receive any legacy, bequest or residuary portion of the other's estate under
his or her will, or to act as personal representative or executor if so named by the will of the
other, whether such will was executed prior or subsequent to this Agreement.
3/19/2010 5 ?y
UT7 e4(-
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as
are expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or
demands whatsoever, in law or in equity, which either party ever had or now has against the
other.
8. SUCCESSOR'S RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
assigns.
9. SEVERABILITY
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
and effect without being impaired or invalidated in any way.
10. ENTIRE AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
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11. BINDING EFFECT OF AGREEMENT/WAIVER
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to the terms of this Agreement.
The failure of either party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent default of the same or similar
nature, nor shall such failure be construed as a waiver of any other term, condition, clause or
provision of this Agreement.
12. BREACH
If either party breaches any provision of this Agreement, the other party shall have the
right, at his or her election, to sue for damages for such breach or seek such other remedies or
relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
13. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
14. TAX RETURNS
The parties agree that in the future if any penalties or interest or any liability for failure to
3/19/2010 7
•
•
declare income or the wrongful claiming of any deduction shall be assessed by the United States
Internal Revenue Service or the Commonwealth of Pennsylvania, or any other state as a
consequence of the parties' Federal and State income tax returns which were filed jointly by the
parties, said tax, penalties or interest shall be the sole responsibility of the party found to be
responsible for the mistake or failure. The party responsible for the mistake or failure shall suffer
the consequences solely and hold the opposite party harmless. However, if the liability is the
result of a computation error or an error not attributable to an intentional act or grossly negligent
conduct of either party, the parties shall share equally in all future tax liability or tax assessment,
penalties and interest.
SECTION II
EQUITABLE DISTRIBUTION
During the marriage, the parties have accumulated various assets and liabilities, the
disposition of which is intended as follows:
1. ASSETS
A. PERSONAL and HOUSEHOLD PROPERTY
HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non-
marital and marital personal and household property, including but without limitation, jewelry,
clothes, furniture, and other assets. HUSBAND agrees that all assets in the present possession of
WIFE shall be the sole and separate property of WIFE and, WIFE agrees that all assets in the
present possession of HUSBAND shall be the sole and separate property of HUSBAND. Each of
the parties do hereby specifically waive, release, renounce and forever abandon whatever claims,
3/19/2010 8
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if any, he or she may have with respect to any of the above said items which are the sole and
separate property of the other.
This document shall constitute a bill of sale for said sole property.
B. REAL ESTATE
The parties jointly own property at 1029 Kathryn Avenue, Dauphin, Dauphin County,
Pennsylvania 17018. Said house is encumbered by a mortgage held by Wells Fargo in the
approximate amount of One Hundred Three Thousand Dollars ($103,000.00). The property shall
be sold. The parties agree that they shall list the property with Robert Hamilton of ReMax. The
house shall be listed for the asking price suggested by the realtor. HUSBAND shall be required
to actively promote the sale by:
a) Maintaining the house in good repair and condition;
b) Making the house available for showings with three (3) hours notice from any
realtor;
C) Allowing open houses and signage as suggested by realtors; and
d) Agree to reduce the listing price for the home as recommended by the realtor and
agreed to by WIFE until a contract for sale is secured.
The parties shall work together to evaluate what repairs are necessary to maximize the
sale price and shall make such repairs as may be required and which are mutually agreed upon by
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the parties. HUSBAND shall be solely responsible for any past, present and future mortgage
principal, interest, penalties and costs as well as any taxes, insurance and/or any debts associated
with the real estate. HUSBAND agrees to indemnify and save WIFE harmless from all such
expenses, including attorney fees, she may incur in defense of any action against her relative to
said expenses. Pending sale, HUSBAND shall make these payments in a timely manner.
Upon sale, WIFE shall receive fifty-two and one-half (52.5%) percent of the net proceeds
and HUSBAND shall receive forty-seven and one-half (47.5%) percent of the net proceeds in full
and final equitable distribution of the marital home.
C. MOTOR VEHICLES
The parties acquired two (2) vehicles during the marriage being a 2003 Honda Odyssey
which is driven by WIFE and a 2003 Ford Explorer Sport Trac driven by HUSBAND. Both
vehicles are encumbered with loans due and owing to the Pennsylvania State Employees Credit
Union. The parties agree that each party shall maintain as his or her sole or separate property the
vehicle which he or she drives. Each parry hereby waives, relinquishes and releases any claim in
the vehicle which shall be the sole and separate property of the other. Each party agrees to
assume and be solely responsible for the loan encumbering his or her vehicle. If the
Pennsylvania State Employees Credit Union car loans are in joint names, both parties shall be
immediately obligated to use the proceeds from the sale of the home to satisfy any outstanding
balance on the loans encumbering his or her respective vehicles. Each party agrees to promptly
coordinate and cooperate in the transfer of titles to the vehicles.
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D. FINANCIAL ASSETS:
The parties acknowledge that the marital financial accounts which existed during the
marriage have been divided to the satisfaction of the parties. All jointly titled accounts have been
closed. Each party hereby waives, relinquishes and releases any claims to the financial accounts
in the possession of the other.
E. PENSION AND RETIREMENT ACCOUNTS:
During the marriage, WIFE accumulated certain retirement benefits through her
employment. These benefits consisted of a Highmark Investment Plan which was encumbered
with a loan at the time of separation. WIFE shall be the sole owner of said asset and HUSBAND
waives any and all claims thereto. WIFE shall be solely responsible for payment of the loan
against said plan and indemnifies and holds HUSBAND harmless from said debt.
HUSBAND has accumulated a pension account with the Northwestern Human Services
Account. HUSBAND confirms that he has neither made nor will make any withdrawals from the
account. WIFE shall receive the sum of Thirty-four Thousand Two Hundred Ninety-nine Dollars
and 21/100 ($34,299.21) which represents fifty-two and one-half (52.5%) percent of the account.
It is the intention of the parties that the rollover shall occur by a Qualified Domestic Relations
Order or such similar authorized method to effectuate a tax free rollover so that said transfer shall
not result in the imposition of any tax liability to either party. This paperwork shall be prepared
by HUSBAND's counsel at his sole cost and expense. The rollover shall be accomplished not
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later than sixty (60) days from the date of entry of the divorce decree.
Each party further warrants that he or she has earned no retirement or other deferred
employment benefits during the marriage.
2. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnify and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities.
WIFE shall be liable and solely responsible for the following debts and will indemnify
and hold HUSBAND harmless from the same:
1. Bank of America Credit Card, Account No. 05427; and
2. Members First Visa, Account No. 8255.
WIFE agrees to indemnify and hold HUSBAND harmless from each of the
aforementioned debts and agrees to be responsible for all attorneys' fees incurred by HUSBAND
in defense of any claim or suit brought against him arising from any debt incurred during the
mamage.
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•
•
HUSBAND shall be liable and solely responsible for the following debts and will
indemnify and hold WIFE harmless from the same:
PSECU Loan, Account No. 533:21;
2. Any loan due and owing by HUSBAND for his musical equipment; and
Any debts advanced post-separation on any marital credit card including, but not
limited to Lowes.
HUSBAND agrees to indemnify and hold WIFE harmless from each of the
aforementioned debts and agrees to be responsible for all attorneys' fees incurred by WIFE in
defense of any claim or suit brought against him arising from any debt incurred during the
mamage.
To the best of the parties' knowledge, the parties affirm no other joint debts exist and all
joint credit cards are terminated.
SECTION III
1. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT, MAINTENANCE AND
COUNSEL FEES
Both parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are
accepted by them in lieu of and in full and final satisfaction of any claims or demands that either
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•
•
may now or hereafter have against the other for support, maintenance, alimony, alimony
pendente lite or counsel fees. HUSBAND and WIFE further, voluntarily and intelligently, waive
and relinquish any right to seek from the other any payment for spousal support, alimony,
alimony pendente lite, maintenance or counsel fees.
SECTION IV
CHILD SUPPORT AND CUSTODY
1. CHILD CUSTODY
The parties mutually agree with respect to their minor children as follows:
A. Legal Custody: The parties agree that major decisions concerning their children's
health, welfare, education, religious training and upbringing shall be made by the
parents jointly, after discussion and consultation with each other, with a view towards
obtaining and following a harmonious policy to arrive at a decision that is in their
children's best interest. Each party agrees to keep the other informed of the progress
of their children's education and social adjustments. Each party agrees not to impair
the other parties' right to share legal custody of their children. Further, each party
agrees to give support to one another in the role as parents and to take into account
the consensus of the other parent for the physical and emotional well being of the
children. The parties agree not to either attempt or alienate the affections of their
children for the other parent. Each party shall notify the other of any activity that
could reasonably be expected to be of significant concern to the other. The parties
agree that the children will be encouraged to contact the other parent by telephone
and e-mail at all reasonable times.
B. Physical Custody:
1. Mother shall enjoy primary physical custody of the parties' minor children; and
2. Father shall enjoy periods of partial physical custody as follows:
Alternating Weekends: Father shall have physical custody of the
children on alternating weekends from Friday school to Sunday at 6:00
p.m.
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Weekdays: Father shall have physical custody of the children on a
mutually agreed upon day agreed upon by the parties from after school or
4:30 p.m. to 8:00 p.m. The day of the week shall be agreed upon by the
parties based on the children's and parents' schedules each Sunday.
C. Holidays: The parties shall share the major holidays in accordance with the
following plan:
Thanksgiving. In odd numbered years, Mother shall have from 10:00
a.m. on Thanksgiving Day to Sunday at 6:00 p.m.. In even numbered
years, Father shall have from 10:00 a.m. on Thanksgiving Day to Sunday
at 6:00 p.m.
Christmas and Christmas Eve: In even numbered years, Mother shall
have custody of the minor children from 9:00 a.m. December 240' until
1:00 p.m. December 25th and Father shall have custody of the minor
children from 1:00 p.m. on December 250' until 5:00 p.m. December 26th.
In odd numbered years, Father shall have custody of the minor children
from 9:00 a.m. December 24th until 1:00 p.m. December 25th and Mother
shall have custody of the minor children from 1:00 p.m. on December 25th
until 5:00 p.m. December 26th.
Easter: In even numbered years, Mother shall have custody of the minor
children from 6:00 p.m. the day before Easter through 2:00 p.m. Easter
Day and Father shall have custody of the minor children from 2:00 p.m.
Easter Day until the day following Easter Sunday at 9:00 a.m. In odd
numbered years, Father shall have the minor children from 6:00 p.m. the
day before Easter Day through 2:00 p.m. Easter Day and Mother shall have
custody of the minor children from 2:00 p.m. Easter Day until the day
following Easter Sunday at 9:00 a.m.
Mother's Day and Father's Day: Mother shall always have Mother's
Day and Father shall always have Father's Day. These holidays shall be
from 9:00 a.m. until 8:00 p.m. the day of that holiday.
D. Vacation: Mother and Father shall each have the right to have two (2)
nonconsecutive seven (7) day periods for vacation. This shall include his or her regularly
scheduled week. Father shall give notice of his periods of custody by May 1" each year.
E. Transportation: Father shall continue to provide transportation for his periods of
partial custody.
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E
SECTION V
0
CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually signed
by both parties
a"?C. ?k,
WITNESS
WITNESS
3/19/2010
M TT W .STETTER
C STINA A. STE
16
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLAND )
•
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Matthew A. Stetter, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
Affirmed and subscribed to before me this day of _, 2010.
?4'm? Ap AW-1 -11 --
IWNNK
NOTARY PUBLIC "MM K L=
6UNL INMMA 1 OA1N W OOYMW
a?i a0/3 (SEAL) NIr GWAN" ftb is Mf
My commission expires: A ,
`7
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLAND )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Christina A. Stetter, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief.
fore me this day of , 2010.
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Barbara Sumpl"Whm, Notary Ptblc
NowCtmbarland Boro , Curnberland County
My CommNNat lupi ar.Nw, llf,2011
Member. Pennsylvania Assocladcn of t4ga/lae
3/19/2010
17
My commission expires:
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
rf(;kE
i
1010 APR 15 PM 3: 25
CHRISTINA A. STETTER,
Plaintiff
V.
MATTHEW A. STETTER,
Defendant
IN THE COURT OF COMMUN44MW
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 4289
CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the court for entry
of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under 3301(c) of the
Divorce Code.
2. Date and manner of service of the complaint: Acceptance of Service on
July 21, 2008.
3. Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code: by Plaintiff April 13, 2010; by Defendant April 6, 2010.
4. Related claims pending: All matters have been resolved between the
parties pursuant to the Marital Settlement Agreement dated April 7, 2010 and
incorporated, but not merged, into the Decree. See paragraph 5, page 4.
5. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with
Prothonotary: April 15, 2010. Date Defendant's Waiver of Notice in 3301(c) Divorce
was filed with Prothonotary: April 8, 2010.
tted,
DATE: April 14, 2010
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Plaintiff
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
CHRISTINA A. STETTER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08 - 4289
MATTHEW A. STETTER, CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a
true and correct copy of the foregoing Praecipe to Transmit Record in the above-
captioned matter upon the following individual(s) by first class mail, postage prepaid,
addressed as follows:
Marianne E. Rudebusch, Esquire
4711 Locust Lane
Harrisburg, PA 17109
DATED: April 14, 2010
L.
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTINA A. STETTER
V.
MATTHEW A. STETTER NO., 08 - 4289
DIVORCE DECREE
14
AND NOW, 16 , it is ordered and decreed that
CHRISTINA A. STETTER plaintiff, and
MATTHEW A. STETTER , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None. All matters have been resolved between the parties pursuant to the Marital
Settlement Agreement dated April 7, 2010 and incorporated, but not merged, into the
Decree.
By the Court,
est: J
P thonotary
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