HomeMy WebLinkAbout04-1225
SHELBY MORRILL,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO .QLl- J~ Ci vil
DALE S. MORRILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE,
PENNSYLVANIA 17013.
IF YOU DO NOT WISH TO 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.
COURT ADMINISTRATOR, 4TH FLOOR
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 240-6200
SHELBY MORRILL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.04 - /:z.~ C~c.J~L ~~
CIVIL ACTION - LAW (
DALE S. MORRILL,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
AND NOW COMES the above-named Plaintiff, by Lori K.
Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce
from the above-named Defendant, upon the grounds hereinafter more
fully set forth:
COUNT I
DIVORCE
1. Plaintiff is Shelby Morrill, who currently resides at
58 Sinclair Road, Mechanicsburg, Cumberland County, Pennsylvania
17055, since 1996.
2. Defendant is Dale S. Morrill, whose last known address
was 58 Sinclair Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
3. plaintiff has been a bona fide resident in the
Commonwealth for at least six months immediately previous to the
filing of this Complaint.
4. The plaintiff and Defendant were married on September
14, 1996, in Cumberland County, Pennsylvania.
5. The Plaintiff has been advised of the availability of
counseling and that she may have the right to request that the
Court require the parties to participate in counseling.
6. There have been no prior actions of divorce or for
annulment between the parties.
7. The marriage is irretrievably broken.
8. The Defendant is not a member of the Armed Services of
the United States or any of its allies.
9. The Plaintiff and Defendant are both citizens of the
United States.
10. Plaintiff avers that there is one child of the parties
under the age of 18, namely Zachary R. Morrill, born July 12,
1997.
WHEREFORE, the Plaintiff prays your Honorable Court to enter
a Decree in Divorce from the bonds of matrimony.
COUNT II
CUSTODY
11. Paragraphs one through ten are hereby incorporated by
reference herein.
12. Plaintiff believes that the best interest of the
parties' child, Zachary R. Morrill, will best be served by
granting primary physical and shared legal custody of the child
with the Plaintiff with liberal partial custody rights to
Defendant.
13. The child presently resides with the Plaintiff at 58
Sinclair Road, Mechanicsburg, PA 17055.
WHEREFORE, Plaintiff respectfully requests that primary
physical and shared legal custody of the child be confirmed with
the Plaintiff.
Respectfully submitted,
AI2~. ~.
L~~ratelli, Esquire
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Road
Suite 201
Harrisburg, PA 17110
(717) 540-9170
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statement made in the foregoing Complaint
in Divorce are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to
authorities.
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SHELBY MORRILL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLN,D COUNTY, PENNSYLVANIA
vs.
NO. 04-1225 CIVIL
DALE S. MORRILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICJ~
I, Lori K. Serratelli, Esquire, being duly sworn according to
law, depose and say that I served the Divorce Complaint in the
above-captioned matter, by depositing it in the United States mail,
Certified Mail, Restricted Delivery, Return Receipt Requested,
addressed as follows:
Dale S. Morrill
207-C Mulberry Drive
Mechanicsburg, PA 17055
The return receipt card is
'l-S-rJ~
attached hereto.
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Lo i . Serratelli, Esquire
S RRATEL:~I, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Road
Suite 201
Harrisburg, PA 17110-9483
(717) 540-9170
Attorney for Plaintiff
Dated:
Sworn and Subscribed to
before me this ~ day
of ~ ,2004.
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NOT ARI.~l SEAL
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SUSquehanna Twp.. Dauphin County
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so that we can return the card to you.
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or on the front if space permits.
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SHELBY MORRILL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 04-1225 Civil
DALE S. MORRILL,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION FOR EOUITABLE DISTRIBUTION
AND NOW COMES Shelby Morrill, Plaintiff in the above captioned action, by her
attorney, Lori K. Serratelli and the law firm ofSERRATELLI, SCHIFFMAN, BROWN &
CALHOON, P.C. who petitions this Court for equitable distribution and in support thereof,
avers as follows:
COUNT I
1. The Plaintiff filed a Complaint in Divorce on March 23, 2004.
2. Plaintiff states that the Plaintiff and Defendant possess various items of both real and
personal marital property which is subject to equitable distribution by the Court.
WHEREFORE, Plaintiff requests that this Court:
(a) Equitably distribute all property, personal and real owned by the parties; and
(b) For such further relief as the Court may deem equitable and just.
Respectfully submitted,
J~ ,1tl.
Lo' . rratelli, Esquire
SE TELL!, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Road, Suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Plaintiff
VERIFICATION
I verify that the statements made herein are true and conrect. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.s:. Section 4904 relating to
unsworn falsification to authorities.
.JJl...t~ rn.()~_:'.Il.R
SHELB ORRILL
CERTIFICATE OF SERVICI~
I, Lori K. Serratelli, Esquire, do hereby certify that on JuneZt':-'to04, I served a
copy of the foregoing upon the Defendant by depositing it it! the United States mail,
postage prepaid, addressed as follows:
Dale S. Morrill
207-C Mulberry Drive
Mechanicsbur~, P A 17055
?ill.
Lori atelli, Esq.
SE TELL!, SCHIFFMAN, BROWN
& CALHOON, P.C.
2080 Linglestown Ro:ad, Suite 201
Harrisburg, P A 1711 I)
(717) 540-9170
Attorney for Plaintiff
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SHELBY MORRILL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: No. 04-1225 CIVIL
DALE S. MORRILL,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
SHELBY MORRILL. (X) Plaintiff ( ) Defendant moves the court to appoint a Master with respect to the
following claims:
(x ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
(x ) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
and in support ofihe motion states:
1. Discovery (x ) is ( ) is not complete as to the claims(s) for which the appointment of Master
is requested.
2. The non-moving party ( ) has ( ) has not appeared in the action ( ) personally (x) by hislher
attomey Linda A. Clotfelter, Esquire.
3. The statutory ground(s) for divorce is/are 330I(c).
4. Check the applicable paragraph(s) by check mark:
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims: N/A
(x) The action is contested with respect to the foJlowing claims:
Divorce and Equitable Distribution
5. The action ( ) involves (x ) does not involve complex issues of law or fact.
6. The hearing is expected to take
(hours)
Y, (dZlYS)
7. Additional information, iran)', relevant to the motion;
Dated: r"J J.;) r/ 0 .,.
I
. ..\C D t
) Plaintiff ( ) Defendant
~~~ .::::>
~:'5 -n
<.n
(;';?
C',
-
ORDER APPOINTING MASTER
AND NOW, ,200 _,
appointed Master with respect to the following claims:
, Esquire, is
BY THE COURT:
J.
MOVING PARTY
NON-MOVING PARTY
Name: Shelby Morrill
Name: Dale S. Morrill
Attorney's Name:
Lori K. Serratelli, Esq.
Attorney's Name:
Linda A. Clotfelter, Esq.
Attorney's Address:
2080 LingJestown Road, Suite 201
Attorney's Address
5021 East Trindle Road, Suite 100
Attorney's Telephone #
(717) 540-9170
Attorney's Telephone #
(717) 796-1930
Attomey's E-Mail:
Iserratclli(lU,ssb c-Ia w. co m
Attorney's E-Mail
Unknown
Party's Address and Telephone #
if not represented by counsel:
Party's Address and Telephone #
ifnot represented by counsel:
CERTIFICATE OF SERVICE:
I, Lori K. Serratelli, Esquire, do hereby certify that on ~ ;:;1i
served a copy of the foregoing upon the Defendant by depo,iting it in the United States
, 2005, I
mail, postage prepaid, addressed as follows:
Linda A. Clotfelter
5021 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
~ U-U4~itr )bJ
on K. Serratelh, Esq.
SERRATELLI, SCH][FFMAN, BROWN
& CALHOON, P.c.
2080 Linglestown Road, Suite 201
Harrisburg, P A 1711 0
(717) 540-9170
Attorney for Plaintiff
c
SHELBY MORRILL
,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 04-1225 Civil
DALE S. MORRILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY AND APPRAISE!![ENT
OF
SHELBY MORRILL
(X) Plaintiff ( ) Defendant files the following inventory and
appraisement 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.
(X) Plaintiff ( ) Defendant verifies that the statements made
in this inventory and appraisement are true and correct.
(X) Plaintiff
Defendant understands that false statements
herein are made subject to the penalties of 18 Pa. C. S. 4904
relating to unsworn falsification to authorities.
)l'Jl~1.t-:?c;: 7n~~~:'.R.e
(X) P :intiff ( ) Defendant
Page -1-
ASSETS OF PARTIES
(X) plaintiff
items applicable to
following pages.
( ) Defendant marks on the list below those
the case at bar and itemizes the assets on the
Real Property
Motor Vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market savings certificates
Contents of safe deposit boxes
Trusts
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,
workman'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
Page -2-
21. Litigation claims (matured and unmatured)
22. Military/V.A. benefits
23. Education benefits
X) 24. Debts due, including loans, mortgages held
X) 25. Household furnishings and personalty (include as a
total category and attach itemized list if
distribution of such assets is in dispute)
26. Other
Page -3-
MARITAL PROPERTY: (X) Plaintiff ( ) Defendant lists all marital
property in which either or both spouses ha,ve a legal or equitable
interest individually or with any other person as of the date this
action was commenced.
ITEM NO. 1
Susquehanna Valley Federal
DESCRIPTION: Credit Union 401(k) (Wife)
12-31-03 (Sep. 1-1-04)
DATE OF VALUATION: ---1Exhibit A)
VALUE: 9.652
NON-MARITAL PORTION:
None
AMOUNT/NATURE OF ANY LIEN:
None
ITEM NO. 2
DESCRIPTION:
1998 Chevrolet Truck (Husband)
VALUE:
3775
DATE OF VALUATION:
Present (Exhibit B)
NON-MARITAL PORTION: None
Susquehanna Valley FCU
AMOUNT/NATURE OF ANY LIEN: $3114 (4/12/04)
ITEM NO. 3
DESCRIPTION:
1996 Nissan Maxima (Wife)
VALUE:
4813
DATE OF VALUATION:
Present (Exhibit C)
NON-MARITAL PORTION: None
Susquehanna Valley FCU
AMOUNT/NATURE OF ANY LIEN: $2988 (4/28/04)
ITEM NO. 4
DESCRIPTION:
Personal Property in Possession
of Wife
VALUE:
545
DATE OF VALUATION: Present (Exhibit D)
NON-MARITAL PORTION:
None
AMOUNT/NATURE OF ANY LIEN:
None
ITEM NO. 5
DESCRIPTION:
Personal Property in Possession
of Husband
VALUE:
500
DATE OF VALUATION: Present (Exhibit D)
NON-MARITAL PORTION:
None
AMOUNT/NATURE OF ANY LIEN:
None
Page -4-
ITEM NO. 6 DESCRIPTION: PW50 Yamaha Motorcycle (Son)
VALUE: Unknown DATE OF VALUATION: Unknown
NON-MARITAL PORTION: None
AMOUNT/NATURE OF ANY LIEN: Unknown
Page -5-
NON-MARITAL PROPERTY: (x) Plaintiff Defendant lists all
property in which a spouse has a legal or equitable interest which
is claimed to be excluded form marital property.
ITEM NO. 1
DESCRIPTION:
58 Sinclair Road
Mechanicsburq, PA 17055
VALUE: 145.000
DATE
OF VALUATION: ~praisal 2-28-01
(Exhibit E)
Per Mid-Nuotial Aqreement - 6-25-1997
REASON FOR EXCLUSION:
l)Mortgage/National City Mortgage in
Joint Names
2)Home Equity/Susquehanna Valley Feu
AMOUNT/NATURE OF ANY LIEN: in Joint Names
ITEM NO. 2
DESCRIPTION:
PW50 Yamaha Motorcvcle (Son)
VALUE:
Unknown
DATE OF VALUATION:
N/A
REASON FOR EXCLUSION: Son's prooertv
AMOUNT/NATURE OF ANY LIEN: Unknown
ITEM NO.
DESCRIPTION:
VALUE:
DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
ITEM NO.
DESCRIPTION:
VALUE:
DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
ITEM NO.
DESCRIPTION:
VALUE:
DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
Page -6-
PROPERTY TRANSFERRED: (X) Plaintiff ( ) Defendant lists all
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 NO. 1
DESCRIPTION: Suzuki Four Wheeler
NAME OF OWNER(S) :
Titled in Husband's Name for Son
DATE OF TRANSFER: Unknown
CONSIDERATION:
Unknown
PERSON TO WHOM TRANSFERRED:
Unknown
ITEM NO. 2 DESCRIPTION: 1991 Honda Accord
Titled in Husband's name; however gift from
NAME OF OWNER(S): Wife's brother durinq marriaqe
Unknown (See Exhibit
DATE OF TRANSFER: Unknown CONSIDERATION: F for NADA Value
PERSON TO WHOM TRANSFERRED:
Unknown
ITEM NO.
DESCRIPTION:
NAME OF OWNER(S) :
DATE OF TRANSFER:
CONSIDERATION:
PERSON TO WHOM TRANSFERRED:
Page -7-
LIABILITIES: (X) Plaintiff ( ) Defendant lists all liabilities of
either or both spouses alone or with any person as of the date of
separation.
ITEM NO.
1
DESCRIPTION:
National City Mortgage
First MortGaCle (Joint Names)
AMOUNT OF DEBT PRESENTLY:
Aoorox. $57,000 (6/23/04)
$57,225.67 (12/15/03)
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
10/1997 - Construction Loan converted to MortGaGe
$605 x 7 ~
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: $4235
ITEM NO.
2
DESCRIPTION:
Susquehanna Valley Federal C.U.
Home EQUity Loan (Joint Names)
AMOUNT OF DEBT PRESENTLY:
$53,869.22 (6/23/04)
AMOUNT OF DEBT AT SEPARATION:
$54,121.88
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
10/01/01 - Credit Card Debt (Exhibit G)
$532 x 7 ~
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: $3724
Susquehanna Valley F.C.U.
ITEM NO. 3 DESCRIPTION: (Husband)
AMOUNT OF DEBT PRESENTLY: $3114 (4/12/04) (Exhibit H)
AMOUNT OF DEBT AT SEPARATION: $3710 (Ao'Drox. ) (Exhibit H)
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
5/12/2000/$10425/1998 Chevrolet Truck Loan
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Aoorox. $1000
Page -8-
ITEM NO.
4
DESCRIPTION:
Susquehanna Valley F.C.U.
(Wife)
$2988 (4/28/04) (Exhibit I)
$3834 (Auorox. ) (Exhibit I)
AMOUNT OF DEBT PRESENTLY:
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
8/16/2000/$10000/1996 Nissan Car Loan
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Aoorox. $1035
ITEM NO.
5
DESCRIPTION:
Susquehanna Valley F.C.U.
(Wife)
$1789 (5/12/04) (Exhibit J)
$2086 (ADi:Jrox. ) (Exhibit J)
AMOUNT OF DEBT PRESENTLY:
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
1/23/2003/$3000/Unsecured Loan
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Aoorox. $450
ITEM NO.
6
DESCRIPTION: Sears (Husband's Name)
AMOUNT OF DEBT PRESENTLY:
Unknown
AMOUNT OF DEBT AT SEPARATION:
Aoorox. :,800
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
Onooino Credit Card Charoes bv Husband durino marriaoe
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION:
Unknown
ITEM NO.
7
DESCRIPTION:
Sears Mastercard (Husband's Name)
AMOUNT OF DEBT PRESENTLY:
Unknown
AMOUNT OF DEBT AT SEPARATION:
Aoorox. $12,000
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
Onooino Joint Credit Card Charoes durino marriaoe
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION:
Unknown
Page -9-
ITEM NO. 8 DESCRIPTION: Havt. Havt & Landau (Husband)
AMOUNT OF DEBT PRESENTLY: Unknown
AMOUNT OF DEBT AT SEPARATION: Approx. $17.000
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT: Premarital Debt/Repossessed Vehicle
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Unknown
ITEM NO. 9 DESCRIPTION: Home Depot (Husband)
AMOUNT OF DEBT PRESENTLY: Unknown
AMOUNT OF DEBT AT SEPARATION: Approx. $1300
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT: Onqoinq Credit Card Charqes bv Husband durinq marriaqe
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Unknown
ITEM NO. 10 DESCRIPTION: Nextel (Husband)
AMOUNT OF DEBT PRESENTLY, Unknown
AMOUNT OF DEBT AT SEPARATION: Approx. $1224
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT: Phone Charqes bv Husband's Friend durinq marriaqe
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: Unknown
Page -10-
CERTIFICATE OF SERVIC]~
I, Lori K. Serratelli, Esquire, do hereby certify that on ..L_\", ;;).<:1... , 2005, I
,
served a copy of the foregoing upon the Defendant by depositing it in the United States
mail, postage prepaid, addressed as follows:
Linda A. Clotfelter
5021 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
t Q)
Lori I Se atellt, Esq.
SE TELL!, SCHIFFMAN, BROWN
& CALHOON, P.e.
2080 Linglestown Roa.d, Suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Plaintiff
006613 . a . 0000019712 - FBP
SUSQUEHANNA VAllEY FCU
lARRY STONER
3850 HARTZDAlE DRIVE
CAMP Hill, PA 17011
Focus on Your FutureSM
SHELBY R MORRill
58 SINCLAIR RD
MECHANICSBURG. PA 17055
For the period October I. 2003 - December 31,2003
? Every effort has been made to report information accurately.
. Should you notice any error, please advise your Benefits
Department within 1.0 days so that records can be corrected.
'" To access your account via the automated phone line,
'u call1-800-MYKPLAN (1-800-695-7526).
III Visit the Web at www.mvkplan.com
~For transactional details, please visit the web site.
Plan Number: 006613
Employee Number: 7523
Vesting Start Date: 12/26/1995
Pre-Tax Deduction: 0%
Location:
Date of Hire:
FBP
03/10/2000
Your Account At A Glance
As of December 31, 2003
This
Period
y ear 1~o
Date
Beginning Balance
Contributions
Investment Earnings
Ending Balance
$8,069.35
523.58
1,058.95
$9,651.88
$4,539.26
2,890.(;:1
2,222.00
$9,651.88
Vested Balance
$9,651.88
This statement includes contributions through payroll date 12/10/2003.
Allocation Of Account
The 'Allocation of Account' is how your current account balance was invested as of the end of the statement period. For
Future Contribution Allocations, see page 2.
Account Allocation
As of December 31. 2003 Investment Type
$0.00 0.00% Income
$0.00 0.00% Growth & Income
Aggressive Growth
$6,555.73 67.92% Growth
$3,096.15 32.08% Aggressive Growth
Growth $9,651.88 Total
SHELBY R MORRilL
bQJj)
Page 1 of6
For the period October 1, 2003 - December 31,2003
Allocation Of Account Detail
The 'Account Allocation' column is how your current account balance is invested. The 'Future Contribution Allocation' column
shows the latest investment elections you made regarding Mure contributions" You should periodically compare your Account
Allocation to your Future Contribution Allocation to determine if the investment options and categories in your Account
Allocation continue to reflect your investment objectives.
Investments
Account Allocation
As of December 31. 2003
0.00%
Income
SSgA Govemment Money Market Fund
SSgA Stable Value Fund
Scudder Rxed Income Fund. A
Growth & Income
The George Putnam Fund of Boston - M
Growth
Rdelity Advisor Equity Income Fund - T
American Century Inc & Grwth Fund. Adv
SSgA S&P 500 Index Fund
SSgA l1lrge Cap Core Equity Fund
Rdelity Advisor Growth Opp Fund - T
Janus Adv Cap Appreciation Fund - I
T. Rowe Price Mid-Cap Value Fund. R
Strong Opportunity Fund. Advisor Class
Scudder Mid Cap Fund - A
Aggressive Growth
Putnam OTC & Emerging Growth Fund - M
Rdelity Advisor Overseas Fund - T
Janus Adviser Worldwide Fund - I
PIMCO NFJ Small-Cap Value Fund. A
SSgA Russell 2000 Index Strategy Fund
Scudder Small Cap Fund - A
AllianceBemstein Technology Fund - A
$0.00
0.001%
$0.00
$0.00
$0.00
0.00%
$0.00
67.92:%
$0.00
$0.00
$934.73
$2,819.25
$2,801.75
$0.00
$0.00
$0.00
$0.00
32.08%
$0.00
$3,096.15
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$6,555.73
$3,096.15
Future Contribution
Allocation
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
70.00%
0.00%
0.00%
9.68%
29.21%
29.03%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
10.00%
30.00%
30.00%
0.00%
0.00%
0.00%
0.00%
30.00%
0.00%
32.08%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Total
$9,651.88
Important Message
Now you can sign up today to have your before-tax contribution percentage increased automatically each year with Save
Smart. It's a convenient and painless way to get yourself to save mon~ for your future. For more information about this
feature, visit your Participant Web site.
SHELBY R MORRILL
Page 2 016
For the period October 1. 2003 - December 31.2003
..... Average Annual Total Return Through the Quarter Ending December 31, 2003
Inception Year Since
Investments Date 3 Months to Date 1 Year 3 Y'~ars 5 Years 10 Years Inception
Income
SSgA Govemment Money Market Fund 0.09% 0.44% 0.44% 1.72% 3.09% 3.84% N(A
SSgA Stable Value Fund 0.68% 3,07% 3.07% 4.22% 4.65% 5,00% N/A
Scudder FIXed Income Fund - A 06(28(02 0.30% 4,04% 4.04% N(A N(A N(A 5.70%
Growth 8< Income
The George Putnam Fund of Boston. M 12(01(94 7.72% 16,90% 16.90% 2,13% 2,92% N(A 9.75%
Growth
Rdellty Advisor Equity Income Fund. T 09(10/92 13,60% 28.41% 28.41% 1.87% 3.59% 10.93% 11.94%
American Century Inc & Grwth Fund - Adv 12(15(97 13.22% 29.33% 29.33% -V69% -0.05% N(A 4.26%
SSgA S&P 500 Index Fund 11.98% 27,84% 27.84% -4.72% -1.26% 10.28% N(A
SSgA Large Cap Core Equity Fund 10.88% 25,39% 25.39% -2,30% -1.71% 9.11% N(A
Rdellty Advisor Growth Opp Fund. T 11(18(87 10.95% 29.25% 29.25% .524% -6.29% 6.38% 12,33%
Janus Adv Cap Appreciation Fund - I 05(01(97 9.11% 18.92% 18.92% .7.86% 1.69% N(A 12.24%
T. Rowe Price Mid-Cap Value Fund - R 09(30(02 17.04% 38.26% 38.26% N(A N(A N(A 38.45%
Strong Opponunity Fund - Advisor Class 02(24(00 11.74% 37.26% 37.26% -1.70% N(A N(A 1.64%
Scudder Mid Cap Fund - A 06(28(02 9,07% 28.34% 28.34% N(A N(A N(A 5.74%
Aggressive Growth
Putnam OTC & Emerging Growth Fund. M 12(02(94 7.93% 34.17% 34.17% .2l.i32% -12.01% N(A 0,02%
Rdellty Advisor Overseas Fund - T 04(23(90 16.45% 44,11% 44.11% -2.88% 1.17% 5.04% 6,04%
Janus Adviser Worldwide Fund. I 05(01(97 12.62% 22.83% 22.83% -1D.48% 0.04% N/A 5.72%
PIMCO NFJ Small.Cap Value Fund. A 01(20(97 14.27% 30.22% 30.22% 1657% 12,33% N(A 11.53%
SSgA Russell 2000 Index Strategy Fund 14.25% 44.87% 44,87% 5.05% 5.88% 8.33% N(A
Scudder Small Cap Fund - A 06(28(02 9.83% 22.07% 22.07% N(A N(A N(A 3.15%
AllianceBemstein Technology Fund - A 03(01/82 10.27% 41.67% 41.67% -15.'10% .4.95% 11.46% 15.18%
Performance returns assume funds were invested for the entire period. Actual returns on your account may differ
because your investments are made over time through payroll deductions. Performance information for all publicly
traded mutuai funds, excluding Money Market Funds, is provided by Mornlngsta,@*. Performance information for Money
Market funds and certain other types of funds are provided by the respective fund manager. The funds' investment
returns and principal values will fluctuate so that an an investor's shares, when redeemed, may be worth more or less
than the original cost. Each of the funds involves special risks. Please refer to the fund's prospectus for a description
of these risks. There may be other disclaimers related to the performance of specific funds under your plan. Please
see your plan sponsor for additional information. Past performance is no guarantee of future results.
For the most up to date ({) Call the automated phone line at 1\1 Visit the Web at
investment results: 1-800-695-7526 '-- www.mykplan.com
SHELBY R MORRill
Page 3 of 6
For the period October 1, 2003 - December 31,2003
Investment Summary
Fidelity Fidelity
SSgA SSgA Large Advisor Growth Advisor
sap 500 Cap Core OIPportunities Overseas
Index Fund Equity Fund Fund - T Fund - T Totals
Beg. Price $10.805434 $10.538852 $25.850000 $13.650000
Beg. Units/Shares 72.6814 227.1310 91.9242 184.1799
Beg. Balance $785.35 $2,393.70 !;2,376.24 $2,514.06 $8,069.35
Contributions 52.32 157.10 157.08 157.08 523.58
Investment Earnings 97.06 268.45 268.43 425.01 1,058.95
Transfers 0.00 0.00 0.00 0.00 0.00
Ending Balance $934.73 $2,819.25 !;2,801.75 $3,096.15 $9,651.88
Ending Price $12.100160 $11.685123 $28.640000 $15.790000
End. Units/Shares 77 .2494 241.2683 97.8266 196.0830
Contribution Summary
Activity By Employee Employer Profit
Money Source 401(k) Match Sharing Total
Beginning Balance $2,722.38 $2,722.38 l;2,624.59 $8,069.35
Contributions 261.79 261.79 0.00 523.58
Investment Earnings 362.16 362.16 334.63 1,058.95
Ending Balance $3,346.33 $3,346.33 ~i2,9S9.22 $9,651.88
Vested Balance $3,346.33 $3,346.33 ~i2,959.22 $9,651.88
YTD Contributions $993.27 $993.27 $904.08 $2,890.62
SHELBY R MORRILL
Page 4 of6
For the period Octol.er 1, 2003 - December 31,2003
Fund Descriptions
SSgA Government Money Market Fund
Primarily invests in direct obligations of the U.S. Treasury, U.S. Government aglmcies, repurchase agreements
and money markets with maturities of 13 months or less. (The fund itself is not insured or guaranteed by the
U.S. Government.)
SSgA Stable Value Fund
Primarily invests in investment contracts held at book value (issued by insurance companies, banks or other
financial institutions). and high quality short investment products. SSgA Stable Value Fund is a portfolio
consisting of Guaranteed Investment Contracts. SSgA is the investment manager for the Stable Value Fund. This
fund is managed exclusively for participants in certain plans for which ADP Retirement Services provides
record keeping and related services.
Scudder FIxed Income Fund - Class A
Management uses a bottom-up approach, focusing on selection of issues it believes to be undervalued relative
to the market. The process is based on a value~driven philosophy and does not rely on market variables such as
interest rates. By examining various risk factors, management assigns an individual security a fair value, based
on its creditworthiness, structure and liquidity; looks to exploit any inefficiencies between intrinsic value and
market price; and makes independent investment decisions that culminate in sector weightings that are a
residual of where value is found at the issue level.
The George Putnam Fund of Boston. Class M
Fund invests in a well-diversified combination of value-:orientated stocks and bonds.
Fidelity Advisor Equity Income Fund. Class T
The fund normally invests at least 80% of total assets in income-producing equity securities.
American Century Income 8. Growth Fund - Advisor Class
Stock selection process utilizes quantitative management techniques, drawing heavily on computer modeling
technology, combining value and growth characteristics. The fund targets stocks with a higher expected dividend
yield and higher overall return potential than the S&P 500 Index, without assuming significant risk.
SSgA S8.P 500 Index Fund
The fund invests in individual U.S. common stocks in identical proportions to the Standard & Poor's 500 Index
(equity index).
SSgA Large Cap Core Equity Fund
The Fund holds approximately 90 to 140 carefully selected stocks that exhibit strong earnings growth and
represent good values in their industry. Stocks within the portfolio are chosen from a true large cap core
investable universe of approximately 1,000 names.
Fidelity Adyisor Growth Opportunities Fund - Class T
This fund is composed primarily of stocks with above average growth potential plus special situations, debt
securities and cyclicals.
Janus AdYlser Capital Appreciation Fund - Class I
Invests in a concentrated stock fund portfolio. Primarily selects stocks for their growth potential.
T. Rowe Price Mld-Cap Value Fund - R Class
The fund will invest at least 80% of its net assets in companies whose market capitalization falls within the
range of companies in the S&P Mid Cap 400. The fund focuses on companies with the following: Attractive
operating margins, sound balance sheet and financial management, and stock ownership by management.
Strong Opportunity Fund - Advisor Class
The fund is primarily comprised of mid-sized companies that are selling at discounts to their private market
value (i.e., undervalued stocks) with excellent growth characteristics.
Putnam OTC 8. Emerging Growth Fund - Class M
Invests mainly in stocks traded over-the-counter (OTC) of small- to medium-sized emerging growth companies.
The fund's focus on rapidly growing small and midsize companies makes it Putnam's most aggressive growth
product.
Scudder Mid Cap Fund - Class A
The portfolio management team uses a "bottom-up" approach to picking securities that focuses on individual
selection of stocks rather than industry selection. The team uses an active inve:stment process to evaluate
individual growth prospects and competitive strategies. Each portfolio manager has sector responsibilities with
investment discretion over securities. The team focuses on mid-cap stocks with superior growth prospects and
above-average performance potential.
Fidelity Advisor Overseas Fund - Class T
This fund primarily invests in equity securities located outside North America.
Janus Adviser Worldwide Fund - Class I
Primarily invests in equities of companies located within and outside the United States.
SHELBY R MORRilL
Page 5 of6
For the period October 1. 2003 - December 31.2003
Fund Descriptions
PIMCO NFJ Smal~ap Value Fund - Class A
The fund normally invests in undervalued smaller capitalization common stocks (approximately 100 holdings)
with a market capitalization between $100 million and $1.8 billion. Each stock is required to pay a dividend.
SSgA Russell 2000 Index Strategy Fund
The Russell 2000 Index Strategy employs a replication approach to construct a fund whose returns closely track
those of the Russell 2000 Index.
Scudder Small Cap Fund - Class A
Under normal circumstances, the Fund invests at least 80% of its total assets in the equity securities of U.S.
smaller capnalization companies. The investment advisor defines the small capitalization equity securities
universe as the bottom 20% of the total domestic equity market capitalization (at the time of investment), using
a minimum market capitalization of $10 million. The Fund may also invest up to 20% of its assets in the stocks
of non-U.S. companies and up to 20% of its assets in large capitalization stocks. Under normal conditions,
these two tactics would not comprise major elements of its strategy.
AlllanceBemstein Technology Fund - Class A
Invests primarily in securities of companies that use technOlOgy extensively in the development of new or
improved products/processes. Within this framework, the fund may invest in any company and industry, as well
as in any type of security with potential for capital appreciation. The Fund can invest in well-known, established
companies or in new or unseasoned companies.
For complete information about these funds, including fees and expenses, please see the prospectus. Read it
carefully before selecting an investment option in the plan.
*@2003 Morningstar, Inc. All Rights Reserved. The information contained herein: (1) is proprietary to
Morningstar and/ or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be
accurate, complete, or timely. Neither Morningstar, ADP nor their contl:mt providers are responsible for any
damages or losses arising from any use of this information. Past performance is no guarantee of future results.
SHELBY R MORRILL
Page 6 of6
Vehicle Summary Trade Value
Page 1 of 1
N.A.D.A. Official Used Car Guide
Vehicle Summary Trade Value
5/15/2004
I998 CHEVROLET TRUCK
SIO PICKUP-V6
FLEETSIDE 6'
Region: Eastern 05-2004
Stock #:
VIN:
N.A.D.A. Base Trade-In
Mileage (75,001 )
Accessories
$3,775
$0
-$400
N.A.D.A. Trade-In Value
$3,375
Optional Equipment:
Alum! Alloy Wheels
Wlout 3rd Door
W/outAuto. Trans.
$50
-$125
-$325
Option Total:
-$400
All NADA values are reprinted with pennission of
N.A.D.A. Official Used Car Guide@ Company Copyright@NADASC 2000
http://www.nada.com!b2b/VV /V sedCar/reports/tradeval.htrn
5/15/2004
Vehide Sum~ary Trade Value
1996 NISSANIDATSUN
MAXIMA-V6
SED 4D GLE
N.A.D.A. Base Trade-In
Mileage ( 88,000 )
Accessories
N.A.D.A. Trade-In Value
Optional Equipment:
Option Total:
Page 1 of 1
N.A.D.A. Official Used Car Guide
Vehicle Summary Trade Vallue
5/15/2004
Region: Eastern 05-2004
Stock #:
VIN:
$4,375
$438
$0
$4,8I3
$0
All NADA values are reprinted with pennission (If
N.A.D.A. Official Used CarGuide@CompanyCopyright@NADASC2000
http://www.nada.comIb2bNViUsedCar/reports/tradeval.htm
5/15/2004
'"
,
o MCIIfJl3
:i!..
"M ';)"d %O~
S3/l::J3S 00006
~
('
i
;;
Personal Prooertv in Possession of Wife
1. Couch & Matching Chair
2. Refrigerator
3. Washer & Dryer
4. Queen Bed, Dresser & Nightstand
(At least 10 years old)
5. Dresser
6. T.V.
7. T. V. Stand
8. Computer and Printer
9. Computer Desk
10. Grill
11. Digital Camera
12. 35 mm Camera
13. Stereo
Personal Prooertv in Possession of Husband
1. Riding Lawnmower
2. T.V. (Gift from Wife's Mother)
3. Oak Bench (Gift from wife's Mother)
4. VCR
5. Stereo
Estimated Value
-0-
50
50
200
75
-0-
20
75
10
20
25
-0-
20
$545
500
Unknown
Unknown
-0-
-0-
$500
M~NUYnALAGREEMENT
THIS AGREEMENT is made this ~ 5 day of -J '" ^ c , 1997 between Shelby R.
Morrill (hereinafter referred to as "Shelby", of Cumberland County, Pennsylvania, and Dale S.
Morrill (hereinafter referred to as "Dale"), of Cumberland County, Pennsylvania, in order to
settle and adjust all rights each may have or claim in the property of the other by reason of their
marriage.
WHEREAS, Shelby and Dale were married on September 14, 1996; and
WHEREAS, Shelby has acquired real estate, known as RRI, Lot 2, Sinclair Road,
Mechanicsburg, Pennsylvania 17055 as a gift from Robert B. Weber and Cheryl Carey Weber;
WHEREAS, Dale owned no real property prior to the marriage and currently owns no
real property;
WHEREAS, each party has fully advised the other of the nature and probable value of his
or her property; specifically;
Dale represents that the attached Exhibit "A" fully and fairly discloses his income,
property and liabilities.
Shelby represents that the attached Exhibit "B" fully and fairly discloses her income,
property and liabilitites.
WHEREAS, Shelby has consulted Lori K. Serratelli, Esquire and Dale has been
advised that he has the right to have his own attorney to advise and represent him.
Each party has been fully advised of the rights he or she would have under Pennsylvania
law with respect to the property of the other by reason of their marriage, if this Agreement were
not made, including, but not limited to the following:
a. Rights of surviving spouse to specified portions and amounts ofa deceased spouse's
property; and
b. The right to seek a court order of payment of maintenance (alimony and support) and
making a just and equitable division of the property of the parties upon the dissolution of
their llllIlTiage.
Each party has also been advised that he or she may havll or acquire other rights granted
to spouses under the laws of other states and countries in which the parties, or either of them,
may reside or own property, and that such other rights may be limited or forfeited by this
Agreement.
NOW THEREFORE, in consideration of the mutual promises and undertakings herein
contained and for other good and valuable consideration, the receipt and sufficiency of which is
hereby acknowledged respectively, and the covenants and agreements herein contained, it is
agreed as follows:
1. REAL ESTATE
Except as provided herein, the parties agree that, notwithstanding any contrary provisions
of the law of Pennsylvania, or any other state or country, the provisions of this Agreement wiu
determine the rights, if any, that each party will have in the real e:state located at RR 1, Lot 2,
Sinclair Road, Mechanicsburg, Pennsylvania deeded to Shelby on February 18, 1997 and
recorded February 20, 1997 in Deed Book 153, Page 576, Cumberland County Recorder of
Deeds Office.
Further, Dale acknowledges that the property located atRR 1, Lot 2, Sinclair Road,
Mechanicsburg, Pennsylvania, including any appreciation then~on throughout the marital
coveture period, shall be the sole property of Shelby in consideration of the fact that the funds
used to purchase said property were borrowed from National City Mortgage Company in the
amount of Sixty-Two Thousand ($62,000.00) Dollars and that said debt shall be the full liability
of Shelby. Further, Shelby agrees to indemnity Dale and hold him harmless from any and all
liability arising from said debt.
Further, any taxes, utilities, costs and maintenance and upkeep with regard to the property
shall be the full liability of Shelby.
In the event of separation and/or divorce, Shelby agrees to pay to Dale a sum
representing one-half of any contributions made to Shelby for payment of the mortgage and any
improvements with regard to the residence only. Said payment shall not exceed one-half of the
appreciation as defined by the difference between the current value of Seventy Six Thousand
($76,000.00) Dollars and the appraised value at separation. Dalf~ specifically waives any and all
interest in the land, including appreciation and the remaining appreciation, after application of the
above formula, on the residence.
2. RIGHT TO POSSESSION OF MARITAL RESmENCE DURING
SEPARATION OR DIVORCE
Dale acknowledges he has made no financial contribution to the real estate located at RR
I, Lot 2, Sinclair Road, Mechanicsburg, Pennsylvania, but ,'lil! continue to have the right to
reside in the residence during the parties' marriage.
In the event of separation and/or divorce, Dale agrees that upon ninety (90) days written
notice from Shelby requesting the separation or divorce, that he will vacate the residence at RR
1, Lot 2, Sinclair Road, Mechanicsburg, Pennsylvania and that he waives any claim under the
Pennsylvania Divorce Code to exclusive possession of said residence.
3. RIGHTS UNDER THE 1980 DIVORCE CODE OFPENNSYL VANIA.
AS AMENDED
The parties acknowledge that except for the real estate located at RR 1, Lot 2, Sinclair
Road, Mechanicsburg, Pennsylvania, all other real estate whi(;h may be acquired during the
marriage, all other personal property, and all other intangible marital property such as pensions or
retirement funds will be treated as marital property as defined under the Divorce Code, with the
exception of gifts from third parties or inheritances, subject to equitable distribution.
Dale and Shelby shall retain all their rights to spousal support from the other, alimony,
alimony pendente lite and counsel fees from the other in the event of divorce.
4. DEATH
In the event Shelby predeceases Dale, and the parties have not separated or divorced, the
property known as RR 1, Lot 2, Sinclair Road, Mechanicsburg, Pennsylvania, shall be
included in Shelby's estate for purposes of distribution to her h,~irs at the time of death.
5. ENTIRE AGREEMENT
This Agreement constitutes the entire understanding between the parties, and there are no
covenants, conditions, representations or agreements, oral or written, of any nature whatsoever,
other than those herein contained.
6. LEGALLY BINDING
It is the intent ofthe parties hereto to be legally bound hl~reby and this Agreement shall
bind the parties hereto and their respective heirs, executors, administrators and assigns.
7. FULL DISCLOSURE
Each party assets that she or he has made a full and complete disclosure of all the real and
personal property of whatsoever nature and wheresoever located belonging in any way to each of
them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all
sources and amounts of income received or receivable by each party, and of every other fact
relating in any way to the subject matter of this Agreement. Tht:se disclosures are part of the
consideration made by each party for entering into this Agreem~nt.
8. COSTS TO ENFORCE
In the event that either party defaults in the performanC4~ of any duties or obligations
required by the terms of this Agreement and both extra-judicial and judicial proceedings are
commenced to enforce such duty or obligations, the party found to be in default shall be liable for
all expenses, including reasonable attorneys fees, incurred as a result of such proceedings.
9. AGREEMENT VOLUNTARILY AND CLEARLY UNDERSTOOD
Each party to this Agreement acknowledges and declares that he or she respectively:
(l) Is fully and completely infonned as to the facts relating to the subject matter and their
Agreement as the rights and liabilities of both parties;
(2) Enters into this Agreement voluntarily after receiving the advice of independent
counsel; except that Husband has been advised by Wife's attorney that he has the right to
independent counsel and has voluntarily chosen not to be represented and has acknowledged that
he fully understands that Wife's attorney represents only Wife's interests and not his own and he
has nonetheless chosen to be unrepresented in this matter;
(3) Has given careful and mature thought to the making of this Agreement;
(4) Has carefully read each provision of this Agreement;
(5) Fully and completely understands each provision oft!J~s Agreement, both as to the
subject matter and legal affect.
10. AMENDMENT OR MODIFICATION
This Agreement may be amended or modified only by written instrument signed by both
parties.
11. SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his
or her obligations under anyone or more of the paragraphs here:in, with the exception of the
satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of
the parties.
12. LAW APPLICABLE
This Agreement shall be governed, construed and enfomed under the statute and case law
of the Commonwealth of Pennsylvania.
13. HEADINGS NOT PART OF AGREEM...EK!
Any headings preceding the text of the paragraphs and subparagraphs herein, are inserted
solely for convenience of reference and shall not constitute a part of this Agreement nor shall they
affect its meaning, constructions or effect.
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING
READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY
ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS
BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER
A FULL HEARING.
IN WITNESS WHEREOF, the parties have executed this Agreement the day and year
first written above.
WITNESS:
-f1t-2:ot. f / /:i:, ""'::? /,"1.
'/' A'
1/ (/
__________- . I
/_____ !,.t~-------/
1 ~(
,l..J.. .L.Lj)"~ vI.. '.r/1,(,~...r.~~..( ,.(
, SHELBYR MORRILL
9&/ .1 /Ju;,~J:)
DALE S. MORRILL
COMMONWEAL'ffi OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
On this 25th day of June, 1997, before ne, a Notary Public, the undersigned
officer, personally appeared Shelby R. M:>rrill and Dale S. M::>rrill, known
to rre to be persons whose names are subscribed to this instrurrent and acknowledged
they executed the same for the purposes therein contained. -._--,--
Notanal Sea!
Cathy M S~mse~:, Notal} Public
Lower Allen Twp__ CUfl"lbenand County
My CommiSSion Expires Dee. 4. 2000
Men t....r PCflR3]1,,,,.,w, AssoGiation of Notaries
r)r"' ..
/ I '--:"'--~ '-
~_.~ L._'":jln.........,,_J..-____ .;::-___'
Notary Public
EXHIBIT "A"
Income:
$785.84 Bi-Weekly - Workman's Compensation
Property:
None
Liabilities:
a. Pennsylvania National Bank (Car Loan)
b. MBNA America - $2,000.00
c. First Bankcard Center - $3,500.00
d. Direct Merchants - $1,000.00
EXHIBIT "B"
Income:
$15,500.00
Property:
RR 1, Lot 2 Sinclair Road
Mechanicsburg, PA 17055
Liabilities:
a. National City Mortgage Co. - $62,000.00
b. America Honda Finance Corp. (Car Loan)
c. Capital One - $2400.00
d. Prime Option - $900.00
Monill.M..
Vehicle LoaD. Value Summary
199I HONDA
ACCORD
SED 4D LX
N.A.D.A. Base Loan
Mileage ( 130,001 )
Accessories
N.A.D.A. Loan Valne
Optional Eqnipment:
Option Total:
N.A.D.A. Official Used Car Guide
Vehicle Loan Value Summllry
8/11/2004
Region: Eastern August, 2004
Stock #:
VIN:
$I,400
$0
$0
$1,400
$0
All NADA values are reprinted with permission of
N.A.D.A. Official Used Car Guide@ Company Copyright@NADASC 2000
hrtp://www.nada.comIb2b/VVlUsedCar/reports/loanval.htm
Page 1 of 1
8/11/2004
Loan/Credit Card Pavoff Date Debtor Amount
l. Susquehanna Valley F.C.U.
Payoff Personal Loan for
Lawnmower 3/13/01 Joint $1691
2 . WFNNB-Victoria's Secret 3/13/01 Wife 288
3 . WFNNB-Express 3/13/01 Wife 205
4. Citibank 3/13/01 Wife 8733
5 . Fleet 3/13/01 Wife 4681
6. Hecht's 3/13/01 Wife 303
7. Walmart 3/13/01 Wife 971
8. Wards 3/13/01 Wife 723
9. First USA Bank, NA 3/13/01 Wife 7178
10. The Bon Ton 3/13/01 Wife 145
11. Discover Card 3/13/01 Wife 7640
12. Toys R Us 3/13/01 Wife 597
13 . Boscov's 3/13/01 Wife 216
14. HFC 3/13/01 Wife 4605
15. Qcard 3/13/01 Wife 66
16. Capital One/5291151749998744 3/13/01 Wife 280
17. Kohl's 3/13/01 Wife 172
18. Capital One/4388641828720750 3/13/01 Husband 206
19. MBNA American 3/13/01 Husband 6820
20. First National Bank 3/13/01 Husband 9545
2l. Lowe's 3/13/01 Husband 679
22. Direct Merchants 3/28/01 Husband 3600
Subtotal Joint: $ 1691
Subtotal Wife: 36,803
Subtotal Husband: 20.850
TOTAL: 59,344
SUSQUEHANNA VALLEY
05!J3/2004 09:47
Account History Print
L.;enhOlder: 5ustueha..,..",a.. VdLl\6y F.c:..u..
3650 H"'-r'tzd...'", D.;Y'"
telsrc
C <<..,.,., po Hill, PA Page: 1
ID: histprt.1
17011
======================================================================~===s=====================================================
F. C. U.
?
Member#: 10378
From Date: Specific Date
Thru Date: CUrrent Business Day
Tran
Code Description
Ip Loan Payment
Ip Loan Payment
lp Loan Payment
lp Loan Payment
lp Loan Payment
lp Loan Payment
Ip Loan Payment
lp Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
lp Loan Payment
lp Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
lp Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
lp Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
svcu
User
ID
teljl
teljl
teljlp
teljls
teljlp
teljlp
teljl
telser
batch
batch
batch
batch
batch
batch
batch
batch
teljls
teljls
batch
batch
batch
batch
teljal
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
telve
batch
batch
batch
batch
Type:
: 05/12/2000
Tran
Date
04/12/2004
04/02/2004
03/29/2004
02/21/2004
02/18/2004
02/18/2004
01/20/2004
12/1S/2003
11/12/2003
10/29/2003
10/15/2003
10/01/2003
09/17/2003
09/03/2003
OS/20/2003
OS/06/2003
07/24/2003
07/24/2003
07/23/2003
07/09/2003
06/25/2003
06/11/2003
05/15/.2003
05/14/2003
04/30/2003
04/16/2003
04/02/2003
03/19/2003
03/05/2003
02/1S/2003
02/05/2003
01/.22/2003
01/0S/2003
12/24/2002
12/11/2002
11/27/2002
11/13/2002
10/16/2002
10/02/2002
09/18/.2002
09/1S/2002
09/04/2002
08/21/2002
OS/07/2002
10:33
13:38
OS:42
10:0S
09:53
09:52
09:02
09:11
08:39
08:27
08:23
08:41
OS:24
08:21
08:15
08:23
12:01
11:54
08:31
08:25
08:22
08:25
OS:42
08:27
08:07
09:14
08:30
OS:32
08:22
12 :32
08:27
08:26
OS:25
08:24
08:31
08:32
08:24
08:39
08:15
08:42
OS:14
08:20
08:19
OS: 19
Tran Draft Principal
Time Number Amt
94.99
97.93
193. "
53.33
27.00
128.78
152.67
103.10
91.13
90.93
90.73
90.54
90.34
90.14
89.94
90.48
.73
1.20
89.55
89.35
89.16
78.75
36.14
88. n
88.52
88.32
88.13
87.94
86.87
88.44
87.36
87.17
86.06
87.74
86.61
86.42
72.52
86.07
85.88
10.96
85.67
85.48
85.30
85.11
Cert/LN#: 1
Date Order?: yes
Int
Arnt
5.01
2.07
20.23
1. 67
16.80
19.91
22.30
8.87
9.07
9.27
9.46
9.66
9.86
10.06
9.52
.73
10.45
10.65
10.84
21.25
. "
11.29
11.48
11.68
11.87
12.06
13.13
11.56
12.64
12.83
13.94
12.26
13.39
13.58
27.48
13.93
14.12
14.33
14.52
14.70
14.89
20.00
20.00
20.00
20.00
Fee
Arnt
Tran
100.00
100.00
234.00
55.00
27.00
165.58
192.58
145.40
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
.73
1. 93
100.00
100.00
100.00
100.00
36.93
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
10.96
100.00
100.00
100.00
100.00
CUrrent
Arnt
Balance
3,114.20
3,209.19
3,307.12
3,500.89
3,554.22
3,581.22
3, no .00
3,862.67
3,965.77
4,056.90
4,147.83
4,238.56
4,329.10
4,419.44
4,509.58
4,599.52
4,690.00
4,690.73
4,691. 93
4,781.48
4,870.83
4,959.99
5,038.74
5,074.88
5,163.59
5,252.11
5,340.43
5,428.56
5,516.50
5,603.37
5,691.81
5,"9.17
5,866.34
5,952.40
6,040.14
6,126.75
6,213.17
6,285.69
6,371.76
6,457.64
6,468.60
6,554.27
6,639.75
6,725.05
SUSQUEHANNA VALLEY F. C. U.
05'/,)3/2004 09:47 telsrc svcu
Account History Print
Page: 2
10: histprt. 1
===m:==c===============================C===================ac===....c=......====================================================
Member#:
Account:
10378 Dale S. Morrill
1 Fully Title Secured
Tran
Code Description
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
LA Loan Add On
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
LD Loan Debit
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
Id Loan Debit
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
LD Loan Debi t
aclp ACH Loan Payment
aclp ACH Loan Payment
User
ID
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
lnsecm
batch
batch
batch
batch
batch
Inssjb
batch
batch
batch
Inssjb
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
lnssjb
batch
batch
Tran
Date
Tran Draft principal
Time Number Amt
07/24/2002 08:17
07/10/2002 08:07
06/26/2002 08:21
06/12/2002 08:21
OS/29/2002 08:12
05/15/2002 08:09
05/01/2002 08:38
04/17/2002 08:11
04/03/2002 08: 13
03/20/2002 08:25
03/06/2002 08:13
02/20/2002 08:26
02/06/2002 07:44
01/24/2002 15:22
01/09/2002 08: 13
12/26/2001 08:03
12/12/2001 08:12
11/28/2001 08: 01
11/14/2001 08: 19
11/09/2001 17:16
10/31/2001 08:28
10/17/2001 08:19
10/03/2001 08:10
09/19/2001 08:09
08/22/2001 08:20
08/08/2001 10:29
08/08/2001 08:17
07/25/2001 08:11
07/11/2001 08:27
06/28/2001 09:28
06/27/2001 08:20
06/13/2001 08:08
05/30/2001 08:23
05/16/2001 08:08
05/02/2001 08:25
04/18/2001 08:14
04/04/2001 08:23
03/21/2001 08:15
03/07/2001 08:16
02/21/2001 08:19
02/07/2001 08:18
01/24/2001 08:18
01/10/2001 08:26
12/27/2000 09:15
12/27/2000 08:12
12/13/2000 08: 15
84.93
84.74
84.56
84.37
84.19
84.00
83.82
83.64
83.45
83.27
83.09
82.91
83.96
81. 30
82.37
82.19
82.01
81.83
78.90
250.00
77.15
76.94
76.72
53.15
29.48
76.49
76.49
76.28
52.27
76.14
76.14
75.92
75.71
75.50
75.29
75.09
74.88
74.67
74.46
74.26
74.05
73.85
47.43
73.71
73.71
73.51
Int
Amt
15.07
15.26
15.44
15.63
15.81
16.00
16.18
16.36
16.55
16.73
16.91
17.09
16.04
18.70
17.63
17.81
17.99
18.17
21.10
22.85
23.06
23.28
46.85
70.52
23.51
23.51
23.72
47.73
23.86
23.86
24.08
24.29
24.50
24.71
24.91
25.12
25.33
25.54
25.74
25.95
26.15
52.57
26.29
26.29
26.49
Fee
Amt
Tran
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
250.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
From: 05/12/2000
Thru: 05/03/2004
Amt
Current
Balance
6,810.16
6,895.09
6,979.83
7,064.39
7,148.76
7,232.95
7,316.95
7,400.77
7,484.41
7,567.86
7,651.13
7,734.22
7,817.13
7,901.09
7,982.39
8,064.76
8,146.95
8,228.96
8,310.79
8,389.69
8,139.69
8,216.84
8,293.78
8,370.50
8,423.65
8,453.13
8,376.64
8,453.13
8,529.41
8,581. 68
8,505.54
8,581.68
8,657.60
8,733.31
8,808.81
8,884.10
8,959.19
9,034.07
9,108.74
9,183.20
9,257.46
9,331.51
9,405.36
9,452.79
9,379.08
9,452.79
SUSQUEHANNA VALLEY
05 '03/2004 09:47
F. C. U.
telsrc
Account History Print
Page: 3
ID: histprt.1
svcu
============================================================z==========z====================================E===::==============
Member#:
Account:
10378 Dale S. Morrill
1 Fully Title Secured
From: 05/12/2000
Thru: 05/03/2004
Tran User Tran Tran Draft Principal Int Fee Tran Current
Code Description ID Date Time N~r Arnt Arnt Arnt Arnt Balance
------------------------------ -------- ---------- -------- --------- --------- --------- ------------ -------------
aclp ACH Loan Payment batch 11/29/2000 08:28 73.31 26.69 100.00 9,526.30
aclp ACH Loan Payment batch 11/15/2000 08:49 73.10 26.90 100.00 9,599.61
aclp ACH Loan Payment batch 11/01/2000 08:23 72.90 27.10 100.00 9,672.71
aclp ACH Loan Payment batch 10/18/2000 08:22 72.70 27.30 100.00 9,745.61
aclp ACH Loan Payment batch 10/04/2000 08:21 72 .50 27.50 100.00 9,818.31
aclp ACH Loan Payment batch 09/20/2000 08:14 72.29 27.71 100.00 9,890.81
aclp ACH Loan Payment batch 09/06/2000 08:16 72 .09 27.91 100.00 9,963.10
aclp ACH Loan Payment batch 08/23/2000 08:13 71.89 28.11 100.00 10,035.19
aclp ACH Loan Payment batch 08/09/2000 08:09 71.69 28.31 100.00 10,107.08
aclp ACH Loan Payment batch 07/26/2000 08:13 71.50 28.50 100.00 10,178.77
aclp ACH Loan Payment batch 07/12/2000 08:10 71.30 28.70 100.00 10,250.27
ac1p ACH Loan Payment batch 06/28/2000 08:12 13.78 86.22 100.00 10,321.57
It Transfer Loan Payment tel pIp 05/17/2000 09:30 89.65 10.35 100.00 10,335.35
NL New Loan Inssjb 05/12/2000 10:08 10,425.00 10,425.00 10,425.00
Database ID: svcu
Start Date: 05/03/2004
End Date: 05/03/2004
Syslog Filename: 05030409300394.e
Start Time: 9:47:39 am
End Time: 9:47:39 am
Elapsed Time: 00:00:00
End of Report
L.ie....holder.. S h
,",St",e a.."....eL "Va.lley F'.c.w..
36So H tLrtz.d 4' e Drive
SUSQUEHANNA VALLEY F. C. U. Account History Print ....... t . p Page: 1
. I...,..a..""'p "011., A .
05/0: 2004 09:48 telsrc svcu ID: h~stprt.l
....;.............................................................................".................==.J.J.~J)..................
?
Member#: 10378
From Date: Specific Date
Thru Date: Current Business Day
Type:
: 08/16/2000
cert/LN#: 2
Date Order?: yes
Tran
-----------------------------------------------------------------------------------.-----------------------------------------------
Balance
Code Description
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
Ip Loan Payment
Ip Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
It Transfer Loan Payment
Ip Loan Payment
acIp ACH Loan Payment
acIp ACH Loan Payment
acIp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
1a Loan Add On
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
User
ID
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
te1j1s
teIj1s
batch
batch
batch
batch
batch
te1ja1
teIjal
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
1nssjb
batch
batch
batch
Tran
Tran Draft principal
Time Number Arnt
Date
04/28/2004 08:20
04/14/2004 08:43
03/31/2004 08:29
03/17/2004 08:29
03/03/2004 08: 28
02/18/2004 08:24
02/04/2004 08: 25
01/21/2004 08: 19
01/07/2004 08:24
12/24/2003 08:35
12/10/2003 08:20
11/26/2003 08:27
11/12/2003 08:39
10/29/2003 08:27
10/15/2003 08:23
10/01/2003 08:41
09/17/2003 08:24
09/03/2003 08:21
08/20/2003 08:15
08/06/2003 08:23
07/24/2003 12:01
07/24/2003 11:54
07/23/2003 08:31
07/09/2003 08:25
06/25/2003 08:22
06/11/2003 08:25
OS/28/2003 08:34
05/15/2003 08:46
05/15/2003 08:43
05/14/2003 08:27
04/30/2003 08:07
04/16/2003 09:14
04/02/2003 08:30
03/19/2003 08:32
03/05/2003 08:22
02/18/2003 12:32
02/05/2003 08:27
01/22/2003 08:26
01/08/2003 08:25
12/24/2002 08:24
12/12/2002 15:21
12/11/2002 08:31
11/27/2002 08:32
11/13/2002 08:24
106.69
106.40
106.12
105.83
105.55
105.27
104.99
104.71
104.43
104.15
103.87
103.59
103.31
103.03
102.76
102.48
102.21
101.94
101. 66
102.36
.97
5.16
101.10
100.83
100.56
100.29
101.09
1. 07
7.61
99.73
99.46
99.19
98.93
98.66
57.22
59.34
57 .87
97.61
56.09
98.72
2,000.00
101. 73
101.44
101.16
Int
Fee
Tran
Arnt
Arnt
Arnt
8.31
8.60
8.88
9.17
9.45
5.73
10.01
10.:25
10.57
10.85
11.13
11.41
11.69
11.97
12.24
12.52
12.79
13.06
13.34
12.64
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
.97
6.13
115.00
115.00
115.00
115.00
115.00
1.07
8.68
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
2,000.00
115.00
115.00
115.00
.97
13.50
14.17
14.44
14.71
13.51
1.07
15.27
15.54
15.81
16.07
16.34
17.78
15.66
17.13
17.39
18.51
16.28
13.27
13 .56
13 .84
Current
2,988.65
3,095.34
3,201.74
3,307.86
3,413.69
3,519.24
3,624.51
3,729.50
3,834.21
3,938.64
4,042.79
4,146.66
4,250.25
4,353.56
4,456.59
4,559.35
4,661.83
4,764.04
4,865.98
4,967.64
5,070.00
5,070.97
5,076.13
5,177.23
5,278.06
5,378.62
5,478.91
5,580.00
5,581.07
5,588.68
5,688.41
5,787.87
5,887.06
5,985.99
6,084.65
6,181.87
6,281.21
6,379.08
6,476.69
6,572.78
6,671.50
4,671.50
4,773.23
4,874.67
SUSQUEHANNA VALLEY F. C. U.
05/07/2004 09:48 telsrc svcu
Account History Print
Page: 2
ID: histprt.l
==================================================================================================================-=============
From: 08/16/2000
Thru: 05/03/2004
Member#;:
Account:
10378 Dale S. Morrill
2 Fully Title Secured
------------------------------------------------------------------------------------------------------------------------------------
Tran
Code Description
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
LA Loan Add On
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
User
ID
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
lnsecm
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
Tran
Date
Tran Draft Principal
Time Number Amt
10/30/2002 08:40
10/16/2002 08:39
10/02/2002 08:15
09/18/2002 08: 14
09/04/2002 08:20
08/21/2002 08:19
08/07/2002 08:19
07/24/2002 08:17
07/10/2002 08:07
06/26/2002 08:21
06/12/2002 08:21
OS/29/2002 08:12
05/15/2002 08:09
05/01/2002 08:38
04/17/2002 08:11
04/03/2002 08:13
03/20/2002 08:25
03/06/2002 08:13
02/20/2002 08:26
02/06/2002 07:44
01/24/2002 15:22
01/09/2002 08:13
12/26/2001 08:03
12/12/2001 08:12
11/28/2001 08: 01
11/14/2001 08:19
11/09/2001 17: 11
10/31/2001 08:28
10/17/2001 08:19
10/03/2001 08:10
09/19/2001 08:09
09/05/2001 09:59
08/22/2001 08:20
08/08/2001 08:17
07/25/2001 08:11
07/11/2001 08:27
06/27/2001 08:20
06/13/2001 08:08
05/30/2001 08:23
05/16/2001 08:08
05/02/2001 08:25
04/18/2001 08:14
04/04/2001 08:23
03/21/2001 08:15
03/07/2001 08:16
02/21/2001 08:19
100.88
100.60
100.32
100.05
99.77
99.49
99.22
98.94
98.67
98.39
98.12
97.85
97.58
97.31
97.04
96.77
96.50
96.23
95.96
97.07
94.03
95.17
94.90
94.64
94.38
91. 52
250.00
89.78
89.47
89.17
88.86
88.56
88.25
87.95
87.65
87.35
87.05
86.75
86.46
86.16
85.87
85.57
85.28
84.99
84.70
84.41
rnt
Arnt
14.12
14 .40
14 .68
14.95
15.23
15.51
15.78
16.06
16.33
16.61
16.88
17.15
17.42
17.69
17.96
18.23
18.50
18.77
19.04
17.93
20.97
19.83
20.10
20.36
20.62
23.48
25.22
25.53
25.83
26.14
26.44
26.75
27.05
27.35
27.65
27.95
28.25
28.54
28.84
29.13
29.43
29.72
30.01
30.30
30.59
Fee
Arnt
Iran
Arnt
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
250.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
115.00
Current
Balance
4,975.83
5,076.71
5,177.31
5,277 .63
5,377 .68
5,477.45
5,576.94
5,676.16
5,775.10
5,873.77
5,972 .16
6,070.28
6,168.13
6,265.71
6,363.02
6,460.06
6,556.83
6,653.33
6,749.56
6,845.52
6,942.59
7,036.62
7,131.79
7,226.69
7,321. 33
7,415.71
7,507.23
7,257.23
7,347.01
7,436.48
7,525.65
7,614.51
7,703.07
7,791.32
7,879.27
7,966.92
8,054.27
8,141.32
8,228.07
8,314.53
8,400.69
8,486.56
8,572.13
8,657.41
8,742.40
8,827.10
SUSQUEHANNA VALLEY F. C. U.
05/03{2004 09:48 telsrc svcu
Account History Print
Page: 3
ID: histprt.1
================================================================================================================================
Member#:
Account:
10378 Dale S. Morrill
2 Fully Title Secured
From: 08/16/2000
Thru: 05/03/2004
------------------------------------------------------------------------------------------------------------------------------------
Tran User Tran Tran Draft Principal Int Fee Tran Current
Code Description ID Date Time Number Amt Amt Amt Amt Balance
------------------------------ -------- ---------- -------- --------- --------- --------- ------------ -------------
aclp ACH Loan pa)"ITlent batch 02/07/2001 08:18 84.12 30.88 115.00 8,911.51
aclp ACH Loan Payment batch 01/24/2001 08:18 83.83 31.17 115.00 8,995.63
aclp ACH Loan Payment batch 01/10/2001 08:26 83.54 31.46 115.00 9,079.46
aclp ACH Loan Payment batch 12/27/2000 08:12 83.26 31. 74 115.00 9,163.00
aclp ACH Loan Payment batch 12/13/2000 08:15 82.97 32.03 115.00 9,246.26
aclp ACH Loan Payment batch 11/29/2000 08:28 82.69 32.31 115.00 9,329.23
aclp ACH Loan Payment batch 11/15/2000 08:49 82.41 32.59 115.00 9,411.92
aclp ACH Loan Payment batch 11/01/2000 08:23 82.13 32.87 115.00 9,494.33
aclp ACH Loan Payment batch 10/18/2000 08:22 81.84 33.16 115.00 9,576.46
aclp ACH Loan Payment batch 10/04/2000 08:21 81.56 33.44 115.00 9,658.30
aclp ACH Loan Payment batch 09/20/2000 08:14 81.29 33.71 115.00 9,739.86
aclp ACH Loan Payment batch 09/06/2000 08: 16 81.01 33.99 115.00 9,821.15
aclp ACH Loan Payment batch 08/23/2000 08: 13 97.84 17.16 115.00 9,902.16
NL New Loan Inssjb 08/16/2000 10:58 10,000.00 10,000.00 10,000.00
----------------------------------------------------------------------------------------------------------------------------------
Database ID: svcu
Start Date: 05/03/2004
End Date: 05/03/2004
Syslog Filename: 05030409300395.e
Start Time: 9:48:12 am
End Time: 9:48:12 am
Elapsed Time: 00:00:00
End of Report
'I
'\
,
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I.
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'M'J"d%Ol
S3/H3S ??oo6
~0310AO~1
~:I,
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SUSQUEHANNA VALLEY
05/12/2004 08: 50
F. C. U.
telsrc
=:==~::;;====================E=__::=;=;=========.:===~=========_==_z:=====:==============.z================:============::====::
?
Member#: 10378
From Date: specific Date
Thru Date: CUrrent Business Day
svcu
l.lnsec.ured Deb-t w;t.h
Sl.tS 'lue ha...nl"\& V~1,e'f
Account History Print
Type:
: 01/23/2003
Cert/LN#: 5
Date Order?: yes
F ,C;......'
Page: 1
ID: histprt.l
----------------------------------------------------------------------------------------------------------------------------------
Tran User Tran
Code Description ID Date
Tran Draft principal Int
Time Number Amt Amt
Arnt
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
acIp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
ip Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
Ip Loan Payment
Ip Loan Payment
lp Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
It Transfer Loan Payment
lp Loan Payment
aclp ACH Loan Payment
acIp ACH Loan Payment
aclp ACH Loan Payment
acIp ACH Loan Payment
acIp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
aclp ACH Loan Payment
NL New Loan
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
batch
teljl
batch
batch
batch
batch
teljls
teljls
teljls
batch
batch
batch
batch
batch
teljal
teljal
batch
batch
batch
batch
batch
batch
batch
batch
lnsecm
05/12/2004 08:24
04/28/2004 08:20
04/14/2004 08:43
03/31/2004 08:29
03/17/2004 08:29
03/03/2004 08:28
02/18/2004 08:24
02/04/2004 08:25
01/21/2004 08: 19
01/07/2004 08:24
12/24/2003 08:35
12/10/2003 08:20
11/26/2003 08:27
11/12/2003 08:39
10/29/2003 08:27
10/15/2003 08:23
10/01/2003 08:41
09/18/2003 09:41
09/17/2003 08:24
09/03/2003 08:21
08/20/2003 08:15
08/06/2003 08:23
07/24/2003 12:01
07/24/2003 11:56
07/24/2003 11:55
07/23/2003 08:31
07/09/2003 08:25
06/25/2003 08:22
06/11/2003 08:25
OS/28/2003 08:34
05/15/2003 08:47
05/15/2003 08:42
05/14/2003 08:27
04/30/2003 08:07
04/16/2003 09:14
04/02/2003 08:30
03/19/2003 08:32
03/05/2003 08:22
02/18/2003 12:32
02/05/2003 08:27
01/23/2003 14: 10
37.64
37.49
37.34
37.19
37.04
36.89
36.74
36.60
36.45
36.30
36.16
36.01
35.87
35.72
35.58
35.44
35.50
35.15
35.01
34.87
35.46
.74
4.54
2.52
34.56
34.42
34.28
34.15
34.79
.7'
1.23
33.86
33.72
33.59
33.45
33.32
32.35
33.91
33.78
3,000.00
Fee
Tran CUrrent
Amt Balance
7.36
7.51
7.66
7.81
7.96
8.11
8.26
8.40
8.55
8.70
8.84
8.99
9.13
9.28
9.42
9.56
9.50
.20
9.85
9.99
10.13
9.54
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
.20
45.00
45.00
45.00
45.00
.74
10.44
10.58
10.72
10.85
10.21
4.54
3.26
45.00
45.00
45.00
45.00
45.00
.7'
2.02
45.00
45.00
45.00
45.00
45.00
45.00
45.00
45.00
3,000.00
.7'
11.14
11.28
11.41
11.55
11.68
12.65
11. 09
11.22
.74
1,789.55
1,827.19
1,864.68
1,902.02
1,939.21
1,976.25
2,013.14
2,049.88
2,086.48
2,122.93
2,159.23
2,195.39
2,231.40
2,267.27
2,302.99
2,338.57
2,374.01
2,409.51
2,409.51
2,444.66
2,479.67
2,514.54
2,550.00
2,550.74
2,555.28
2,557.80
2,592.36
2,626.78
2,661.06
2,695.21
2,730.00
2,730.79
2,73:2 .02
2,765.88
2,799.60
2,833.19
2,866.64
2,899.96
2,932.31
2,966.22
3,000.00
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C'
SHELBY MORRILL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 04-1225 CIVIL,
DALE S, MORRILL,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
SHELBY MORRILL, (X) Plaintiff ( ) Defendant moves the court to appoint a Master with respect to the
following claims:
(x ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Li te
(x ) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
and in support of tile motion states:
1. Discovery (x ) is ( ) is not complete as to the claims(s) for which the appointment of Master
is requested.
2. The non-moving party ( ) has ( ) has not appeared in the action ( ) personally (x) by hislher
attorney Linda A. Clotfelter, Esquire.
3. The statutory ground(s) for divorce is/are 3301(c).
4. Check the applicable paragraph(s) by check mark:
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims: N/A
(x) The action is contested with respect to the following claims:
Divorce and Equitable Distribution
5. The action ( ) involves (x ) does not involve complex issues of law or fact.
6. The bearing is expected to take
(hours)
Y, (clays)
7. Additional information, ifany, relevant to the motion:
Dated: ~ /.;) 1/ 0 .,
I
1
\ L.~\) D i
r ( x ' ) Plaintiff ( ) Defendant
1"-.,)
~~5 ()
<.:,.,n ~n
~
(.,)
0"1
-
ORDER APPOINTING MASTER
,2006:, f:. RtlLu:t~ ' Esquire, is
respect to the following claims: a.lt ~~'1i .
pJ,
MOVING PARTY
NON-MOVn,G PARTY
Name: Shelby Morrill
Attorney's Name:
JLori K. Serratelli, Esq,
Name: Dale S. Morrill
~orney's Name:
~inda A, Clotfelter, Esq.
Attorney's Address:
2080 Linglestown Road, Suite 201
Attorney's Address
5021 East Trindle Road, Suite 100
Attorney's Telephone #
(717) 540-9170
Attorney's Telephone #
(717) 796-1930
Attorney's E-Mail:
Iserra telli({i]ss be-I a w. co m
Attorney's E-Mail
Unknown
Party's Address and Telephone #
if not represented by counsel:
Party's Address and Telephone #
if not represented by counsel:
',J
SO:2 llel
"_ I:'YI cn-'l
c... ...;.; ~ .,).... ij
jJ:i\i.L:,-::i\~.)i1 ,:Jd 3H1
:.:8:,-{:V~}'{E31!.::!
'"
:''0
CERTIFICATE OF SERVICE
I, Lori K. SelTatelli, Esquire, do hereby certify that on fJtJJ ;;y;
served a copy of the foregoing upon the Defendant by depositing it in the United States
, 2005, I
mail, postage prepaid, addressed as follows:
Linda A. Clotfelter
5021 East Trindle Road, Suite 100
Mechanicsburg, P A 17050
~ KL~~41N
on K. SelTatelh, Esq.
SERRATELLI, SCHIFFMAN, BROWN
& CALHOON, P.C"
2080 Linglestown Road, Suite 201
Harrisburg, P A 17110
(717) 540-9170
Attorney for Plaintiff
MATRIMONIAL SETTLEMENT AGREEMENT
";3 .,ci-
THIS AGREEMENT, made this ~ day of
-
,200~,
~}"r
between SHELBY RAE MORRILL, hereinafter ca]]ed "Wife" and DALE SCOTT
MORRILL, hereinafter ca]]ed "Husband",
WITNESSETH:
The paJiies hereto, being Husband aJ1d Wife were lawfully married on September
14,1996 in Cumberland County, Pennsylvania;
There was one child bom of the parties; naJnely: Zachary Robe11 Morrill, bom
July 12, 1997 ;
Diverse and unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND aJ1d WIFE to live separate and apart for
the rest of their natural lives, and the pa11ies hereto are desirous of settling fully and
finally their respective finaJ1cial and property rights and obligations as between each
other including, without limitation by specification: the settling of aJlmatters between
them relating to the ownership and equitable distribution of real aJ1d personal prope11y;
the settling of all matters between them relating to the past, present and future support,
alimony and/or maintenance of each other; and in general, the settling of any and all
claims and possible claims by one against the other or against their respective estate,
NOW THEREFORE, in consideration of the premises and mutual promises,
covenants and undertakings hereinafter set forth and for other good aJ1d valuable
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:
1
1. INCORPORATION OF PREAMBLE
The recitals set forth in the Preamble of this Agreement are incorporated herein and
made a part hereof as iffully set forth in the body of the Agreement.
2. AGREEMENT NOT TO BAR DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of HUSBAND and
WIFE to an absolute divorce on lawful grounds if such grounds now exist or shall
hereafter exist or to SllCh defense as may be available to either party. This Agreement is
not intended to condone and shall not be deemed to be condonation on the part of either
party hereto of any act or acts on the part of the other party which have occasioned the
disputes or unhappy differences which have occurred or may occur subsequent to the date
hereof, The parties aclmowledge that their marriage is irretrievably broken and that they
shall secure a mutual consent no-fault divorce pursuant to the tenns of Section 3301(c) of
the Divorce Code in Cumberland County divorce action docketed to number 04-1225.
Simultaneously with the execution of this Agreement, the parties shall execute and file all
documents and papers, including affidavits of consent, necessary to finalize said divorce,
3. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this
Agreement shall continue in full force and effect after such time as a final Decree in
Divorce may be entered with respect to the parties,
2
4, AGREEMENT TO BE INCORPORATED INTO DNORCE DECREE
The parties agree that the ten11S of this Agreement shall be incorporated into any
Divorce Decree which may be entered with respect to them.
5. NON-MERGER
It is the pmiies' intent that this Agreement does not merge with the Divorce
Decree, but rather shall continue to have independent contractual significance. Each party
maintains his or her contractual remedies as well as comi ordered remedies as the result
of the aforesaid incorporation or as otherwise provided by law or statute, Those remedies
shall include, but not be limited to, dmnages, resulting from breach ofthis Agreement,
specific enforcement of this Agreement and remedies peliaining to failure to comply with
an order of court or agreement pertaining to equitable distribution, alimony, alimony
pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or
other similar statutes now in effect and as amended or hereafter enacted,
6. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as
the date of execution by the party last executing this Agreement.
7, DISTRIBUTION DATE
The transfer of property, funds and/or documents provided herein shall only take
place on the "distribution date" which shall be defined as the date of execution of this
Agreement unless otherwise specified herein,
3
8, FINANCIAL DISCLOSURE
The parties confilID that each has relied on the substantial accuracy ofthe
financial disclosure ofthe other, as an inducement to the execution of this Agreement.
9. SEPARATION
Husband and Wife shall at all times hereafter have the right to live separate and
apali from each other and to reside from time to time at such place or places as they shall
respectively deem fit, fi'ee from any control, restraint, or interferences whatsoever by the
other. Neither pmiy shall molest the other or endeavor to compel the other to cohabit or
dwell with him or her by any legal or other proceedings, The foregoing provision shall
not be taken to be 3.11 admission on the pmi of either Husband or Wife of the lawfulness
or unlawfulness of the causes leading to their living apart, Neither party shall do or say
anything to the children of the parties which might in any way influence the child
adversely toward the other paliy, it being the intention of both parties to minimize the
effect of any such separation upon the child,
10, PERSONAL PROPERTY
The parties hereto mutually agree that they have divided all fumiture, household
fumishings, applim1ces and other household personal property between them, and they
mutually agree that each party shall from and after the date thereof be the sold and
sepm'ate owner of all tangible personal property present in his or her possession; except
4
that Husband shall be entitled to his clothes located in the bathroom and his personal
property located in the garage at Wife's residence,
11. REAL PROPERTY
The parties acknowledge that Wife is tbe sole owner of property located at 58
Sinclair Road, Mechanicsburg, Pennsylvania. Husband waives any and all interest he
may bave ill the property pursuant to a Mid-Nuptial Agreement executed by the parties
on June 25, 1997. Husband also agrees tbat he shall vacate the premises by Friday,
August 26, 2005,
12. LUMP SUM SETTLEMENT
Wife agrees to pay to Husband the sum of Three Thousand ($3,000) Dollar in full
satisfaction of all outstanding equitable distribution claims upon the execution oftbis
Agreement.
13. DEBTS
The parties acknowledge tbat they have no joint debts,
A liability not disclosed in tbis Agreement will be the sole responsibility ofthe
party who has incuned or may hereafter incur it, and each agrees to pay it as the same
shall become due, and to indemnify and hold tbe otber party and bis or her property
barmless for any and all sucb debts, obligations and liabilities.
5
14, EMPLOYEE BENEFIT PLANS
Except as may othelwise be provided herein, each ofthe parties does specifically
waive, release, renounce and forever abandon all of his or her right, title, interest or
claim, whatever it may be in any Pension Plan, Retirement Plan, Profit Sharing Plan,
401(k) Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee
benefit plan of the other party, including but not limited to Wife's Susquehanna Valley
Federal Union 40 I (k) Account, and hereafter said Pension Plan, Retirement Plan, Savings
Plan, Tax DefelTed Savings Plan and/or any employee benefit plan shall become the sole
and separate propeliy in whose name or through whose employment said plan is carried,
15, DIVISION OF BANK ACCOUNTS
The parties acknowledge that they have no joint bank accounts.
16. WAIVER OF SPOUSAL SUPPORT. ALIMONY PENDENTE LITE & ALIMONY
In consideration for the equitable distribution provided in Paragraph 12, Husband
hereby waives any and all claims to spousal support, alimony pendente lite and alimony,
17, CUSTODY
The parties agree that they shall have shared legal and physical custody oftheir
child with the parties mutually agreeing upon the exact schedule,
The pmiies both recognize that each of them needs to be fully involved in all
aspects of the child's welfare and happiness and in that regard will attempt by all possible
means to foster the child's relationship with the other parent and shall in no way say or
6
do anything in front of the child which may affect that relationship. The parties agree that
they shall not abuse drugs or alcohol in front of the child. Both parents shall fully share
infolmation including oral and/or written reports, regarding the child conceming all
aspects of the child's live including, but not limited to information concerning schooling
and education, activities, health, religion and friends, Both parents agree to cooperate to
the fullest extent possible to make their relationship regarding the child as hannonious as
possible.
18. DEPENDENCY EXEMPTIONS
The parties agree to alternate claiming the dependency exemption for the child for
federal tax purposes with Wife claiming the dependency exemption for tax year 2005 and
altemating between Husband and Wife thereafter. The parties shall execute the necessary
IRS f0I111S to effectuate the ten11S of this paragraph,
19, LEGAL FEES
Both paliies shall be responsible for the payment of the fees owed to their own
attomey. Husband and Wife do hereby waive, release and give up any rights which they
may respectively have against the other for payment of counsel fees,
20. OTHER WRITINGS
Each of the parties hereto agree to execute any and all documents, deeds, bills of
sale or other writings necessary to calTY out the intent of this Agreement.
7
21. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS
Each party understands that he or she has the right to obtain from the other party a
complete inventory or list of all of the property that either or both parties own at this time
or owned as of the date of separation, and that each party had the right to have all such
propeliy valued by means of appraisals or otherwise, Both parties understand that they
have the right to have a cOlui hold hearings and malce decisions on the matters covered by
this Agreement. Both parties understand that a cOUli decision conceming the parties'
respective rights and obligations might be different from the provisions of this
Agreement.
Each party hereby acknowledges that this Agreement is fair and equitable, that it
adequately provides for his or her needs and is in his or her best interests, and that the
Agreement is not the result of any fraud, duress, or undue influence exercised by either
paIiy upon the other or by aI1Y other person or persons upon either paliy, Both paliies
hereby waive the following procedural rights:
a. The right to obtain an inventory and appraisement of all marital and non-
marital propeziy as defined by the PelIDsylvania Divorce Code;
b, The right to obtain all income aIld expense statement of the other party as
provided by the PelIDsylvania Divorce Code;
c. The right to have propeliy identified and appraised,
d. The right to discovery as provided by the Pennsylvania Rules of Civil
Procedure;
e. The right to have the court detemline which property is marital aIld which is
non-mm'ital, and equitably distribute between the paliies that property which
8
the court detennines to be marital, and to set aside to a paliy that propeliy
which the court detem1ines to be that paliies' non-marital property;
f, The right to have the court decide any other rights, remedies, privileges, or
obligations covered by this Agreement and/or arising out ofthe malital
relationship, including, but not limited to possible claims for divorce, child or
spousal support, alimony, alimony pendent elite (temporary alimony),
equitable distribution, custody, visitation, and counsel fees, costs and
expenses.
22, FURTHER DEBT
Wife shall not contract or incur any debt or liability for which Husband or his
property or estate might be responsible and shall indemnify and save hannless Husband
from any and all claims or demands made against Husband by reason of debts or
obligations incun'ed by Wife.
23, FURTHER DEBT
Husband shall not contract or incur any debt or liability for which Wife or her
propeliy or estate might be responsible and shall indemnify and save ham1less Wife from
any and all claims or demands made against Wife by reason of debts or obligations
incurred by Husband.
9
24, MUTUAL RELEASE
Except as otherwise provide herein and so long as this Agreement is not modified
or cancelled by subsequent agreement, the parties hereby release and discharge absolutely
and forever each other from any and all rights, claims and demands, past, present and
future specifically from the following: spousal support from the other, alimony, alimony
pendent elite, division of property, claims or rights of dower and right to live in the
marital home, right to act as executor or administrator in the other's estate, rights as
devisee or legatee in the Last Will and Testanlent ofthe other, any claim or right as
beneficiary in any life insurance policy ofthe other, any claim or right in the distributive
share or intestate share of the other parties' estate.
25, INCOME TAX PRIOR RETURNS
The parties have heretofore filed joint federal and state income tax retUI11S from
the date of marriage through tax year 2002. Both paliies agree that in the event any
deficiency in federal, state or local income tax is proposed, or any assessment of any such
tax is made against either ofthem, each will indemnify and hold harmless the other from
and against any loss or liability for any such tax deficiency or assessment therewith, Such
tax, interest, penalty or expense shall be paid solely and entirely by the individual who is
finally detemlined to be the cause ofthe misrepresentations or failures to disclose the
nature and extent of his or her separate income on the aforesaid joint retums.
10
26. FINAL EOUIT ABLE DISTRIBUTION OF PROPERTY
The parties agree that the division of all propeliy set fOlih in this Agreement is
equitable and in the event an action in divorce is commenced, both parties relinquish the
right to divide said property in any manner not consistent with the tenus set forth herein,
It is fmiher the intent, understanding and agreement of the parties that this Agreement is a
full, final, complete and equitable property division.
27. ENTIRE AGREEMENT
This Agreement constitutes the entire understanding between the parties, and
there are no covenants, conditions, representations or agreements, oral or written, of any
nature whatsoever, other than those herein contained,
28. LEGALLY BINDING
It is the intent of the parties hereto to be legally bound hereby and this Agreement
shall bind the parties hereto and their respective heirs, executors, administrators and
assigns,
29. FULL DISCLOSURE
Each party asserts that she or he has made a full and complete disclosure of all the
real and personal property of whatsoever nature and wheresoever located belonging in
any way to each of them of all debts and encumbrances incurred in any manner
whatsoever by each of them, of all sources and amounts of income received or receivable
II
by each party, and of every other fact relating in any way to the subject matter of this
Agreement.
These disclosures are part of the consideration made by each paliy for entering
into this Agreement.
30. COSTS TO ENFORCE
In the event that either party defaults in the perfornlance of any duties or
obligations required by the terms ofthis Agreement and both extra-judicial and judicial
proceedings are cOlllillenced to enforce such duty or obligations, the party found to be in
default shall be liable for all expenses, including reasonable attorneys fees, incurred as a
result of such proceedings,
31. AGREEMENT VOLUNTARILY AND CLEARLY UNDERSTOOD
Each party to this Agreement acknowledges and declares that he or she
respectively:
(I) Is fully and completely infornled as to the facts relating to the subject matter
and their Agreement as to the rights and liabilities of both pal"ties;
(2) Enters into this Agreement voluntarily after receiving the advice of
independent counsel; except that Husband has chosen to be unrepresented in
this matter. Fllliher, Husband has been advised by Wife's attorney that he has
the right to independent counsel alld has vO]lllltarily chosen not to be
represented and has acknowledged that he fully understallds that Wife's
12
attorney represents only Wife's interests and not his own and he has
nonetheless chosen to be unrepresented,
(3) Has given careful and mature thought to the making of this Agreement;
(4) Has carefully read each provision of this Agreement;
(5) Fully and completely understands each provision of this Agreement, both as to
the subject matter 8l1d legal affect.
32. AMENDMENT OR MODIFICATION
This Agreement may be amended or modified only by a written instmment signed
by both parties.
33. SEVERABILITY
If any ten11, condition, clause or provision of this Agreement shall be deternlined
or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision shall be sl1icken from this Agreement and in all other respects this
Agreement shall be valid and continue in full force, effect and operation, Like, the failure
of any party to meet his or her obligations under anyone or more of the paragraphs
herein, with the exception of the satisfaction of the conditions precedent, shall in no way
void or alter the remaining obligations of the parties,
34. LAW APPLICABLE
This Agreement shall be govemed, constmed and enforced under the statute and
case law of the Commonwealth of Pennsylvania,
13
35, HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the paragraphs and subparagraphs herein, are
inserted solely for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, constmction or effect.
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES
HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH
PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT
SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY
THE COURT AFTER A FULL HEARING,
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the
day and year first written above.
WITNESS:
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DALE SCOT MO L
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14
SHELBY MORRILL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 04 - 1225 CIVIL
DALE S. MORRILL,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
t() -ftt
day of ,dr/l!~,
2005, the economic claims raised in the proceedings having been
resolved in accordance with a matrimonial settlement agreement
dated August 23, 2005, 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,
cc: ~ori K. Serratelli
Attorney for Plaintiff
vCinda A. Clotfelter
Attorney for Defendant
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SHELBY MORRILL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 04-1225 CIVIL
DALE S, MORRILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under Section 330l(c) of the Divorce
Code was filed on March 28, 2004.
(2 )
The marriage of Plaintiff and Defendant
broken and ninety (90) days have elapsed
filing and service of the Complaint,
is irretrievably
from the date of
(3) I consent to the entry of a final decree of divorce without
formal notice of the intention to request entry of a divorce
decree.
(4) 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,
(5) 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
correct. I understand that false
subject to the penalties of 18 Pa,
unsworn falsification to authorities,
this affidavit are true and
statements herein are made
C,S, See, 4904 relating to
9-/1.-0:J'
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Shelby Morrill
DATED
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SHELBY MORRILL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 04-1225 CIVIL
DALE S, MORRILL,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on March 28, 2004,
(2)
The marriage of Plaintiff and Defendant
broken and ninety (90) days have elapsed
filing and service of the Complaint,
is irretrievably
from the date of
(3) I consent to the entry of a final decree of divorce without
formal notice of the intention to request entry of a divorce
decree,
(4) I understand that I may lose rights conCernlng alimony,
division of property, lawyer's fees or expenses, if I do not
claim them before a divorce is granted,
(5) 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, See, 4904 relating to
unsworn falsification to authorities,
DATED
CiJ -II-O)
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Dale S, Morril
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SHELBY MORRILL,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No. 04-1225 CIVIL
DALE S, MORRILL,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT
TO THE PROTHONOTARY:
Transmit the record, together with the following information,
to the COUli for entry of a Divorce Decree:
I. Ground for divorce: 3301(c) of the Divorce Code.
2, Date and manner of service of the complaint: Certified Mail. Return Receipt
Requested signed bv Defendant on March 27, 2004 and filed with the Court on April 6, 2004.
(Complete either paragraph (a) or (b)).
(a) Date of execution of the affidavit of consent and waiver of notice of intention to
request divorce decree required by Section 3301(C) of the Divorce Code: by plaintiff: 9-12-05:
by defendant: 9- ] 2-05
(b )(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the
Divorce Code: N/A
(2) date of service of Plaintiffs Affidavit upon the Defendant: N/ A.
4. Notice of Intention to Request Entry of Divorce Decree with attached form
Counteraffidavit Waived bv Defendant and Plaintiff(see 3,(a) above)
5, Related claims pending: No Claims Remain
Dated: q - \ ~-os-
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L 'K. erratelli, Esq.
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON
2080 Linglestown Rd., Suite 201
Harrisburg, PA I71 10
(717) 540-9170
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
SHELBY MORRILL,
OFCUMBERLANDCOUNTY
STATE OF
Plaintiff
No,
VERSUS
DALE S.
MORRILL,
ARE DIVORCED FROM THE BONDS OF MATRIMONY. Further, the Agreement
executed by the parties on August 23, 2005 is incorporated herein and
the parties are Ordered to comply with the terms therein.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
Defendant
AND NOW,
DECREED THAT
AND
DECREE IN
DIVORCE
S(~~
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SHELBY MORRILL
DALE S.
MORRILL
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04-1225 CIVIL
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ORDERED AND
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, DEFENDANT,
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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NO CLAIMS REMAIN.
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