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04-1276
REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff GREGORY S. HAINES, Plaintiff V. REBECCA A. HAINES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 64- /a7L 01rjZL`-r&vq 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff GREGORY S. HAINES, Plaintiff V. REBECCA A. HAINES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 -1 a? (o CIVIL ACTION - LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff GREGORY S. HAINES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 4nR" l27 1= l., ,P?zo -?41 REBECCA A. HAINES, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 1. Plaintiff is Gregory S. Haines, an adult individual who currently resides at 2907 Market Street, 3rd Floor, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Rebecca A. Haines, an adult individual who currently resides at 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 4, 1985, in Windber, Somerset County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there are (2) children of this marriage under the age of eighteen years, namely David J. Haines, date of birth March 20, 1989, and Alex M. Haines, date of birth December 16, 1995. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. COUNTI EQUITABLE DISTRIBUTION 12, Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 14. The parties have acquired marital debt during their marriage. 15. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. Respectfully submitted, REAGER & ADLER, PC Dated: X/ 2 2106 By: D r Deniso tor, Esquire A orney I.D, o. 66378 2331 Market Street Camp Hill, PA 17011 Telephone No. (717) 763-1383 Attorneys for Gregory S. Haines VERIFICATION I, Gregory S. Haines, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: L Gregory n¢s V ?O c C p1 f r Q 1 O Cl? V n r 's N F Ja c.n cn ?f]Is s? u? 0 7-'1l m -? m V GREGORY S. HAINES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 04-1276 REBECCA A. HAINES, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Debra Denison Cantor, Esquire of REAGER & ADLER, P.C. do hereby certify that I served a certified copy of the Divorce Complaint on the Defendant Rebecca A. Haines, by Certified Mail, Restricted Delivery on the 27th day of March, 2004, as is evidenced by the signature of the Defendant on the Return Receipt card attached hereto as Exhibit "A." Said Complaint in Divorce was mailed to Defendant by depositing a true and exact copy thereof in the United States mail, first class, Certified Mail, Restricted Delivery, Return Receipt Requested postage prepaid, addressed as follows: Rebecca Haines 2711 Logan Street Camp Hill, PA 17011 Date: 24/po4 Atty. ID No fi6? REAGER & IDLER, P.C. 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorneys for Plaintiff Gregory Haines EXHIBIT A ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: IRCec.e.e. Naha, a`?Il LcoSan Sircj Corn p Will, PA I'101? A. P - ad by (Please Prr;t 9*ey) I & Date of /1?? C. S' ture ? Agent // ? ?/1 X 4-C • W ? Addre"" D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail ILWagistered ? Return Receipt for MerciandM Insured Mail ? C.O.D. 4., Restricted Delivery? (Extra Fee) W'es 2. Article Number (Copy from service label) -nnn 1(n') h nni C)I(sle 1S((aG PS Form 3811, Juy 1999 Domestic Return Receipt 102595-00-M-0952 c) a O 3- n -q ci ? n o O n ?j GREGORY S. HAINES, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA VS No. 04-1276 REBECCA A. HAINES, : CIVIL ACTION - LAW Defendant : IN SUPPORT PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please kindly withdraw the appearance of Debra Denison Cantor, Esquire as counsel for Plaintiff, Gregory S. Haines, in the above-captioned matter. Date: Skipfeme Court I # REAGER & ADLER, P.C. 2331 Market Street Camp Hill, PA 17011-4642 Telephone No.(717) 763-1383 PRAECIPE TO ENTER APPEARANCE DTHONOTARY: e kindly enter the appearance of Jane M.Alexander, Esquire as counsel for gory S. Haines, in the above-captioned matter. 0 61 submitted, reme Court ID # 07355 1 8 S. Baltimore Street 0. Box 421 Dillsburg, PA 17019-0421 (717) 432-4514 .. \/? Y? GREGORY S. HAINES, plaintiff vs. REBECCA A. HAINES, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA : NO. & 17,- /J 2 ? Civil Term : CIVIL ACTION - LAW : IN CUSTODY 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 GREGORY S. HAINES, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA VS. : NO. Civil Term REBECCA A. HAINES, : CIVIL ACTION - LAW Defendant : IN CUSTODY NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar acci6n dentro de veinte (20) dias a partir de la fecha en que recibi6 la demanda y el aviso. Usted debe presenter comparecencia esrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificaci6n por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensaci6n reclamadas por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS RAPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 GREGORY S. HAINES, Plaintiff vs. REBECCA A. HAINES, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA NO. Civil Term CIVIL ACTION - LAW IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, TO WIT, this ay of .2006 comes the Plaintiff, Gregory S. Haines, by and through his attorney, J M. Alexander, Esquire, and files this Complaint of which the following is a statement: 1. Plaintiff is Gregory S. Haines, an adult individual residing at 2917 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Rebecca A. Haines, an adult individual residing at 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant were married May 4, 1985, Plaintiff filed for divorce in the Court of Common Pleas of Cumberland County, Pennsylvania to Number 04-1276 and on March 25, 2006, a decree has not yet been granted. 4. There is no prior order of court concerning the custody of the two (2) children born of the marriage: David J. Haines, born March 20, 1989, age 17, and Alex M. Haines, born December 16, 1994, age 11. 5. The children are presently residing with mother and father his visitation without an agreed upon schedule. 6. Father desires to have more time with his sons and is seeking joint legal custody and joint physical custody of the children with holidays shared. 7. The children were not born out of wedlock. 8. During the past two years the children have been residing with the Defendant at 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011. 9. The relationship of the Plaintiff to the children is that of natural father. 10. The relationship of Defendant to the children is that of natural mother. 11. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in any other court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the children will be best served by granting the relief requested because the father believes a more structured joint custody arrangement would substantially benefit both children. He wishes to have greater involvement in their day-to-day activities. WHEREFORE, Plaintiff requests your Honorable Court to grant an order giving the parties joint legal custody and joint primary physical custody of the subject children with scheduled holidays and special events. Respectfully submitted, 7 7 e M. Alexandet, Esquire ttorney for Plai tiff ttorney I.D. #07355 148 S. Baltimore Street Dillsburg, PA 17019-0421 (717) 432-4514 VERIFICATION I verify that the statements made in this Petition for custody 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 autho ' ies. 2/ ` DATE: ??/D (o a Greizo . Haines COMMONWEALTH OF PENNSYLVANIA S. S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Gregory S. Haines who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, formation and belief. Sworn to and subscribed before me t Ws /ay of .2006. .. Public Notarial Seal Leslie K. Neidig, Notary Public Warrington Twp. `/ork County My Commission Expires Feb. 4, 2007 Member. Permsylvania Association Of Notaries -d', d O `?f l" C V h -C N G13 O -n n t'1'1 --i --G GREGORY S. HAINES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-1276 CIVIL ACTION LAW REBECCA A. HAINES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Friday, May 19, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, June 19, 2006 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 uj - C t K. ./ E M I e? z t CV LL LU c apr t ;"I" j tic 6 - LL- IX) C= :D © C C-J C3 D it , _, GREGORY S. HAINES, IN THE URT OF COMMON PLEAS Plaintiff OF :12 B COUNTY, PA VS. N6 Civil Term REBECCA A. HAINES, CIVIL A ON - LAW Defendant IN CUSTO Y AND NOW, this 3 o4? day of a?_ appeared Jane M. Alexander, Esquire who swears according copy of a COMPLAINT FOR CUSTODY was caused to be return receipt requested upon the said, Rebecca A. Haines 2711 Logan Street Camp Hill, PA 17011 2006 personally law, that a true and correct by certified mail with on May 19, 2006 by leaving the same at the Dillsburg Post ffice with postage pre-paid thereon as evidenced by the mailing receipt and return receip hereto attached and made a part hereof. 148 S. Bat Dillsburg, (717) 432• Sworn and subscribed before me this 3o`i ` day of 2006. Notary Public . OMMONWEAI,TN Of PENNSYILV NotarW SOW I Nanimd Akxwdw Notary RA* Omsburg Bnro, York County My Commission Expires Apr. 7,010 Member, Pennsylvania Association of Notarles lore Street 17019-0421 14 Q p d T1 _ f . r?C) ;:-t CJ GREGORY S. HAINES, Plaintiff VS. REBECCA A. HAINES, Defendant IN TH OF CL NO. 0, CIVIL IN CU COURT OF COMMON PLEAS [BERLAND COUNTY, PA 1276 Civil Term - LAW b In M S (0 FLE 17(Q ?1 M .A Pomp. $ $0.63 M C.d01ed Fes 9-SIC 0 O =?^ MFes $1.85 (Entlore.meM Req?Y?ed) C3 R,,Mftd ne iHery Fes 13.70 M1 (Endonx3nNt MRequ lrod) ° Tow Po.mpe A F.. $ 16.58 S 0 POBNAar -a7t( Logfo PR 7004 0750 0003 056 4358 o n r 1 1 , ? ?C13 C.7t a• GREGORY S. HAINES, vs. REBECCA A. HAINES, Plaintiff Defendant CIVIL ACTION-LAW IN CUSTODY AGREEMENT AND STIPULATION OF CUSTODY This Agreement and Stipulation made this day of 2006 by and between Gregory S. Haines of 2917 Chestnut Street, Camp 1, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Father") and Rebecca A. Haines of 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Mother"), having reached an agreement to mutually settle and resolve the issue of custody of their minor children, David J. Haines, age 17, bom March 20, 1989, and Alexander M. Haines, age 11, born December 16, 1994, as herein after set forth in this agreement, desiring to legally obligate themselves to the terms of said agreement, and WHEREAS, Gregory S. Haines is the natural father of said minor children; and WHEREAS, Rebecca A. Haines is the natural mother of said minor children; and WHEREAS, there is no prior order of court or agreement in regard to this children; and WHEREAS, Father has filed a Petition with the Court of Common Pleas of Cumberland County, Pennsylvania to the above captioned number and term and a conciliation conference has been scheduled for June 19, 2006 and the parties, having reached an agreement and are desirous of avoiding further legal proceedings and are desirous of entering into a Custody Stipulation for entry as a Court Order. NOW THEREFORE, it is hereby stipulated between Gregory S. Haines and Rebecca A. Haines as follows: LEGAL CUSTODY: The parties shall share legal custody of their minor children, David J. Haines, age 17, : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA NO. 04-1276 Page 1 of 10 bom March 20, 1989, and Alexander M. Haines, age 11, bom December 16, 1994. Each parent shall participate in the major decisions concerning the moral, physical, emotional, medical, education and religious aspects of the children's upbringing. These decisions shall not be made by either parent unilaterally. The parents agree that all decisions shall be made by them jointly, after discussion and consultation with each other, with a view towards obtaining and following a harmonious policy in the children's best interest. Each parent agrees to keep the other parent informed of progress of the children's education and social adjustments. Each parent agrees not to impair the other parent's right to share legal custody of the children. Each parent agrees to give support to one another in their role as parent and to take into account the consensus of the other for physical and emotional well being of the children for the other parent. The parents agree not to attempt to or alienate the affections of the children for the other parent. Each parent shall notify the other of any activity that could reasonably be expected to be significant concern to the other parent. The children will not be barred from contacting the non-custodial parent by telephone. Either parent may, during that parent's physical custody of the children, make decisions required by emergency or sudden illness. Each parent shall immediately communicate to the other the existence of any medical, legal or educational emergency that may occur with respect to the child. Each parent shall also have the duty to immediately contact the other regarding the illness. For purposes of this Order, the word "illness" shall mean disability that confines the children to bed under direction of a licensed physician for a period in excess of twenty-four (24) hours or any serious injury to the child that would require emergency room or other immediate treatment which requires hospitalization. Each parent shall have equal right and access to visit the children if the children are confined to a medical institution, consist with medical advice. If a children is confined a home by reason of illness for a period of more than twenty-four (24) hours, the other parent shall have the opportunity to visit the children. Educational and legal emergencies shall include those situations where there is an imminent threat to a children's well being or any change of the current school or institution. Each parent shall, as soon as practicable, make disclosure to the other of the facts and circumstances pertinent to a children's upbringing and welfare of which that parent has Page 2 of 10 knowledge or notice. Each shall provide the other with copies or duplicate originals of records pertaining to the children, including but not limited to: a. Medical Diagnosis and Treatment; b. Psychological/Psychiatric Diagnosis and Treatment; c. Dental and Orthodontic Records; d. School Records, including Schedules of Events; e. Legal Records. Each parent shall have the right to obtain such records directly from the school, health providers or other entity keeping such records without permission of the other and without further Order of the Court. PRIMARY PHYSICAL CUSTODY Mother shall have primary physical custody of the children with Father having custody for the purpose of visitation under the following schedule; SCHEDULE FOR PARTIAL CUSTODY 1. Alternate Weekends: The Father shall have rights of partial custody of the children on alternate weekends beginning with the weekend of Friday, June 23, 2006 from 6:00 P.M. through Sunday evening at 6:00 P.M. 2. Week Day and Week Night Visit: Father shall have rights of partial custody of Alexander every Tuesday evening. Alexander will spend the night and return home or to school by 8:30 A.M. on Wednesday. David will stay overnight as his schedule permits. 3. Alternate Holidays: The parties shall have rights of partial custody on alternate holidays throughout the year. The holidays shall include the New Year's Day, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day. The Father's next holiday shall be Labor Day 2006, and the Mother's next holiday shall be Fourth of July 2006. The parties shall alternate custody on Page 3 of 10 holidays thereafter. Custody on these holidays shalt be exercised from 8:00 A.M. to 8:00 P.M. In the event that a parent who would otherwise have custody of the children during a weekend which immediately precedes or follows one of the alternating holidays on which that same parent would also have custody, the parent need not relinquish custody until the conclusion of the entire three-day period. 4. Mother's Work Schedule: In the event Mother's work schedule requires her to be out of town over night she shall notify Father of those dates and times and the children will stay with Father. 5. Mother's Dav: Mother shall always have the right of partial custody on Mother's Day. The rights of partial custody shall be exercised by Mother from 8:00 A.M. until 8:00 P.M. 6. Father's Dav: Father shall always have the right of partial custody on Father's Day. The rights of partial custody shall be exercised by Father from 8:00 A.M. until 8:00 P.M. 7. Easter: The Easter vacation shall be shared as equally as possible, giving consideration to the length of the vacation as determined by the school calendar. 8. Christmas: During Christmas in odd numbered years, the father shall have rights of partial custody from noon on December 24th until noon on Christmas Day, and the mother shall have custody from noon on Christmas Day until noon on December 26th. In even numbered years, the schedule shall be reversed. 9. Summer Vacation: Summer is defined by the Court as the first evening following the last day of school and if Friday evening is the last day of school then the last day of school to the Friday evening which concludes the last full week preceding the first day of school. During the summer months each of the parents may have two (2) weeks of Page 4 of 10 vacation, not necessarily consecutive, each party shall notify the other by June I" each year what weeks they wish to have vacation with the children. 10. Holiday Pri ority: The periods of partial custody for holidays, vacations, or other special days set forth in this agreement shall be in addition to, and shall take precedence over, but shall not alter the schedule or sequence of regular periods of partial custody for that parent set forth previously in this agreement. Holidays and other special days for custody set forth in this agreement shall take precedence over vacations. TRANSPORTATION The transportation shall be shared by the parties, as the parties shall from time to time agree as required by their respective work schedules. At all times, the children shall be secured in appropriate passenger restraint. No person transporting the children shall consume alcoholic beverages prior to or while transporting the children. No person transporting the children shall be under the influence of any alcoholic beverage or controlled substance while transporting the children. LATE EXCHANGE In the event any party is more than 20 minutes late for scheduled custody exchange, in the absence of a telephone call or other communication from the party, the other party may assume that the parent who is late has chosen not to exercise that period of custody, the period will be forfeited, and the other party will be free to make other plans with the children. EXTRACURRICULAR ACTIVITIES Each party shall provide to the other at least forty-eight (48) hours advance notice of school or other activities, whenever possible. Both parties shall agree to honor and participate in the activities that the children wish to engage in. During the times that the parents have custody of the children, they will make certain that the children attend any extracurricular activities. The parties agree that they will be supportive of the activities and will transport the Page 5 of 10 children to and from such activities and the preparations and practice for the activities that are scheduled, in such time so that the children is able to participate in those events. Neither parent, however, shall sign up the children for any activity unless the children definitely desire to attend that activity. Participation in activities which take place during the school year is contingent upon the children maintaining passing grades in school. Neither parent shall sign up the children for activities that fall on the other parent's period of custody, without the consent of the other parent, which consent shall not be unreasonably withheld. If the children is involved in an activity which occurs during both parents' periods of custody, both parents shall cooperate in providing transportation of the children to the activity. However, the custodial parent shall not be required to take the children to that activity if the custodial parent and children are out of town during that activity, for a previously scheduled vacation. In the event that the custodial parent is unable to deliver the children to the particular activity, the parent who has custody of the children at that time shall notify the non-custodial parent, who shall be entitled to pick up and deliver the children to the designated activity. The custodial parent shall make certain that the children are ready for pickup in time sufficient to enable the children to timely attend the activity. TELEPHONE CALLS Both parties are urged to use common sense in scheduling telephone calls to talk to the children. Both parties are hereby directed to refrain from preventing the parent who may be calling from talking to the children, or preventing the children from calling the other parent, provided that the phone calls are not excessively frequent, nor too long in duration that they disrupt the children's schedule. Phone calls should be kept to a maximum of twenty (20) minutes, and a maximum of three (3) calls per week. DISPARAGING REMARKS Each of the parties and any third party in the presence of the children shall take all measures deemed advisable to foster a feeling of affection between the children and the other Page 6 of 10 party. Neither party shall do nor shall either parent permit any third person to do or say anything which may estrange the children from the other parent, their spouse or relative, or injure the children's opinion of the other party or which may hamper the free and natural development of the children's love and respect for the other parent. The parties shall not use the children to convey verbal messages to the other parent about the custody situation or changes in the custody schedule. FINANCIAL CARE OF CHILDREN In the event that a significant matter arises with respect to the medical care, education, or financial care of the children, such as a change in occupation, health insurance, educational expenses, or residence of a party, those matters shall be discussed with the other parent before any change is made by either parent. MUTUAL CONSULTATION Each party shall confer with the other on all matters of importance relating to the children's health, maintenance, and education with a view towards obtaining and following a harmonious policy in the children's education and social adjustments. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the children and visitation. Each party agrees to supply the name, address and phone numbers of any persons in whose care the children will be for a period in excess of seventy-two hours (72), and for each person or entity which may provide day care for the children. ILLNESS OF CHILDRENREN Emergency decisions regarding the children shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the children at any time, any party then having custody of the children shall immediately communicate with the other party by telephone or any other means practical, informing the other party of the nature Page 7 of '10 of the illness or emergency, so the other parent can become involved in the decision making process as soon as practical. During such illness, each party shall have the right to visit the children as often as he or she desires, consistent with the proper medical care of the children. The term 'serious illness' as used herein shall mean any disability which confines a children to bed in for a period in excess of twenty-four (24) hours and which places the children under the direction of a licensed physician. WELFARE OF CHILDREN TO BE The welfare and convenience of the children shall be the prime consideration of the parties in any application of the provisions of this Order. Both parents are directed to listen carefully and consider the wishes of the children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. SMOKElDRINK Neither party shall smoke in confined area when the children are present and neither party shall permit another person to smoke in a confined area when the children are present. Further, neither party shall use non-prescribed controlled substances or excessively use alcohol while the children are in their custody and control. REMOVAL FROM AREA Neither parent shall transport the children over the state line nor remove to a point more than 100 miles from home of the other parent for any reason without notification to the other parent. Party removing children shall provide to the other parent an address and/or phone number where the children can be reached. MOVING OF Neither party shall move their place of residence without giving the other party at least thirty (30) days written notice of the new residence. If the new residence is more than 50 Page 9 of 10 miles from the current residence appropriate adjustments in custody, visitation schedules should be made prior to the move. MODIFICATION OF ORDER The parties are free to modify the terms of this Order but in order to do so the Court makes it clear that both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. The parties further stipulate and agree that this agreement and stipulation of Custody shall be presented to the court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania with the understanding and request that the Court approve this agreement and stipulation and enter the same as an Order of Court. IIV WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and veaf first above written. M. for Defendant Esquire Page 9 of 10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK SS On this &A K day of CTS 1 _ , 2006, before me, the undersigned officer, a Notary Public, personally appeared Gregory S. Haines known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. Notary Public COMMONWEALTH OF PENNSYLVANIA My Commission Expires: Notarial Seel Narumal Alexander, Notary Pudic Dilisburg Boro, York CW* My Owvnirion Expires Apr. 7, 2010 Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS On this day of , L&) cp? , 2006, before me, the undersigned officer, a Notary Public, personally appeared Rebecca A. Haines, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. Notary Public My Commission Expires: 1 OF PENNSYLVANIA Memr1 eest Page 10 of 10 P .] ' (?`• ) l_ Y} "1? ?: - -_ rl /;l (eJ - C.{ ?,ii GREGORY HAINES IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 04-1276 CIVIL ACTION LAW REBECCA HAINES Defendant IN CUSTODY ORDER AND NOW, this 19th day of June , the conciliator, being advised by plaintiff s counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for June 19, 2006, is cancelled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator ?J ?? ! ?J ? 'T'3 -{ ? ? ? . ? W i:J a?f?, ..J h.r 't Y JUL 31 2006 GREGORY S. RAINES, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNA YS. : NO. 04-1276 REBECCA A. RAINES, : CIYH. ACTION-LAW Defendant : IN CUSTODY ORDER I AND NOW, to wit, this 2.,?- day v S , 2006, upon consideration of the foregoing Agreement and Stipulation of Custody of Gregory S. Haines and Rebecca A. Haines and on motion of Jane M. Alexander, Esquire, counsel for Plaintiff, it is hereby ordered, adjudged and decreed that the terms, conditions and provisions of the attached Agreement and Stipulation of Custody of the parties dated June 16, 2006 are adopted as an Order of Court as if set forth herein at length. By the Court ?? _ r !i l.) 4° F ??? ?_ p? s' `? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA GREGORY S. HAINES, CIVIL ACTION - LAW Plaintiff v5. IN DIVORCE REBECCA A. HAINES, No. 04 $ 1276 __O{tJt Defendant MOTION FOR APPOINTMENT OF MASTER Gregor}- S. Haines. Plaintiff. moves the court to appoint a master with respect to the following claims: (X) Divorce ( X) Distribution of Property ( ) Annulment ( ) Support ( } Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discover} is complete as to the claims for which the appointment of a master is requested (2) The defendant has appeared in the action by his attorney; Jordan D. Cunning igm. Esquire _--- (3) The statutory ground's) for divorce is Section 3301(c) no fault. (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) t has een reached with respect to 4he fe4lowing (c) The action is contested with respect to the following claims: Distribution of Property (5) The action does not involve complex issues of law or fact. (G) The hearing is expected to take one (1) day. (7) Additional information, if any, relevant to the motion: By the Court: is appointed master with respect to the following claims: MOVING PARTY Gregory S. Haines Jane M. Alexander, Esquire 148 S. Baltimore Street Dillsburg, PA 17019 -(717) 432-4514 NON-MOVING PARTY Rebecca A. Haines Jordan D. Cunningham, Esquire 2320 N. Second Street Harrisburg, PA 17110 (717) 238-6570 .ems y -. e c-n ? + , ^ l-. DO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INCOME AND EXPENSE GREGORY S. HAINES No, 04 S 1276 Plaintiff VS. REBECCA A. HAINES Defendant INCOME AND EXPENSE OF GREGORY S. HAINES Gregory S. Haines files the following income and expense account of all earned income and other sources of income Gregory S. Haines verifies that the statements made in this income and expense are true and correct. Gregory S. Haines understands that false statements herein are made subject to the penalties of Pa. C. S. §4904 relating to unswom falsification IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY S. HAINES, PLAINTIFF No. 0_ S 1276 VS. Civil Action -Law REBECCA A. HAINES, DEFENDANT Action in Divorce INCOME AND EXPENSE STATEMENT - R C P -1920.31 (a) (1) Gregory S. Haines Plaintiff 2917 Chestnut Street Street and number Docket No. 04 S 1276 Statement of Gregory S. Haines Party filing statement Camp Hill, PA 17011 City-State-Zip VS. Rebecca A. Haines Defendant 2711 Logan Street Street and number Camp Hill, PA 17011 City-State-Zip Jane M. Alexander, Esquire Plaintiffs attorney March 27, 2004 Date Complaint served Jordan D. Cunningham, Esquire Defendant's attorney 148 S. Baltimore Street Street and number Dillsburg, PA 17019 City-State-Zip (717) 432-4514 Phone number 2320 N. Second Street Street and number Harrisburg, PA 17110 City-State-Zip (717) 238-6570 Phone number (Income and expease soa ctutnt under Pa. R.C.P. 1920.31(.).) IN TIM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CTM ACTION - LAW - ACTION IN DIVORCE GREGORY S. HAINES, PLAINTIFF VS. No. 04 $ 1276 REBECCA A. HAINES, DEFENDANT INCOME AND EXPENSE STATEMENT UNDER Pa. R.C.P. 1920.31(a) This Form Must Be Completed (If you are self-aVloy ed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement which appears on the last page of this Income and Expense Statement) INCOME AND EXPENSE STATEMENT OF Gregory S. Haines INCOME: Other (specify) Employer: American Home Bank Address: 3840 Hemmland Road M ountville PA 17554 Type of Work: Loan Sp?cialist Payroll Number. 280177 Pay Period (weekly, biweekly, etc.) BI-weeW Gross Pay per Pays Period: $5.200 Itemized Payroll Deductions: Federal Withholding $ Social Security $ Local Wage Tax $ Retirement $ Savings Bonds $ Credit Union $ Life Insurance $ Health Insurance $ $1,837.28 $ . Net Pay per Period $ 3,400.00 Other Income: None (fill in appropriate column) Week Month Year Interest $ $ _ $ Dividends Pension Annuity Social Security Rents Monthly Yearly Expenses: Mortgage/rent: 500 $6,000 Maintenance 120 $1,440 Utilities: $81 50 $978 Electric . $120 $1440 Gas $20 $240 Propane Telephone $220 $2640 Water/Sewer $60 $720 Trash Removal $22 264 Employment: Public Transport n/a $1440 Lunch $120 Taxes: Real Estate n/a Personal Prpprty $20 $240 Income Insurance: Homeowners n/a Auto $355 $4,260 Life n/a Accident n/a Health n/a Other n/a Automobile: Payments n/a Fuel $160 $1,920 Repairs $100 $1,200 Medical: Doctor $90 $1,080 Dentist $59 $700 Orthodontist $530 _ Hospital $300 Medicine $117 $1,404 Education: Continuing Education Religious 66.66 800 Personal: Clothing $100 $1,200 Food $400 $4,800 Hairdresser $25 $300 Credit Card Payments: Americhoice Visa Bank of America $250 $3,000 $25 $300 Capital One $370 $4,440 Chase $274 $3,288 Citi Cards $40 $480 Discover Card $168 $2016 MBNA $30 $360 $1,157.00 $13,884.00 Memberships $91 $1,092 Loans: n/a Household help n/a Child Care n/a Peers/Books Magazines 50 600 Entertainment $75 $900 Pgy TV n/a Vacation $75 $900 Gifts $150 $1800 Legal Fees $334 $4,005 Charitable Contributions $62.50 $750 Other Child support $1.244 $14.928 Alimony Total Expenses: Form Department of the Treasury - Internal Revenue Service tl? !lti` , 1040 U.S. Individual Income Tax Return ' 1 ???? :0 5 9 IRS Use Only - Donot wrlteor staple inthis space, For the year Jan. 1-Dec. 31, 2005, or other tax year be innin 2005, end In 0 OM13 No.1545-0074 Label Your social security number Use the IRS GREGORY S HAINES 210-48-2513 label. 2917 CHESTNUT STREET Spouse's social security number Otherwise , lease print PA 17011 CAMP HILL p or type. , ?fUg A vou, l la0ove. Presidential Checking a box below rill not h ange your l r re und. Election Campaign ? Check here if ou or ourspouse if filin jointly, w ant to o to this fund (seepage 16 ? You Souse 1 X Single Fi i S 4 Head of household (with qualifying person). (See page 17.) ng tat l us 2 Marr ied filing jointly(ev person is a chAd but not your dependent, enter this Checkonly 3 Married filingseperately. low. U 1 one box. 1 ` n widow er with depend en t child (seepage 17 6a X tiw t: Yourself. If someon cl a de k Boxes checked 1 o not check b a on sa and sb } Exem Lions {f b Pou, an- Y •. spouse :?[ No. of children h c Dependents: (2) Dependent's (3) Dependents on Sc w o: (4 it qual *lived with you ! First name Lastname social security number relationship to child for a did not live with you due to divorce or separation If more than four Dependents dependents, on sc not e 19 See pa entered above . g Add numbers d Total number ofexemobonscl?? o lines h t,?„? ii, 7 Wages, salaries, bps, Income 8a Taxable interest Attach edul,O_W_rred1wy?. Attach Forms b Tax-exempt interest Do a ottie 8a 's?? ::r •:.-::> ?f W-2here.Also 9a Ordinary dividends. Attach Schedule B if required attach Forms W- 2G and b Qualified dividends (seepage 23) . . . . . . . . . . 9b 1099- R if tax 10 Taxable refunds, credits, or offsets of state and local income taxes (see page 23) . . . . . . was withheld. 11 Alimonyreceived . . . . . . . . . . . . . . . . . . . 12 Business income or (loss). Attach Schedule C or C- EZ . . . . . . . . . 13 Capital gaint(loss). Attach Seh D. if not required check here . . . . . . . . . . ? ? 14 Othergainsor ttach `' 7. ?`^• r }},.• {'•'?,'. If you did not k ,', ?xiyt?t{ti get a W- 2 15a IRA distributio" 15a , b:MIK a b I a la jam. . . . see page 22. 16a Pensions an nuitie 164 M --_-? :..: ir?_k able a£ . :`2v . 17 Rental real e` x , ro , a er ; S corpo ` one._tt ed E Enclose, butdo 18 Farm incom ttacF . ., not attach, any 19 Unemployment compensation . payment. Also, please use t + 20a Social security benefits L 20. I 1 b Taxable amt . _ . . . . Form 1040- V. 21 Other income. List type and amount (seepage 29)_ 23 Adjusted Educator expenses (sea page 29) . . . . . . . . . . 24 GfOSS Certain business expenses ofreq#?rto' l g " ts, and pp?t%1 14' e Income fee-basis government officials chForm or, 6-EZ`t 25 Health savings account dedu , }t Foi88a ... , 26 Moving expenses. Attach For `903 . ? . { 27 ? One half of self- employmen . Attach S • ul >''t 28 Self- employed SEP, SIMPLE, and qualified plans . . . . 29 Self-employed health insurance deduction (seepage 30) . . . 30 Penalty on early withdrawal of savings. . . . . . . . 31a Alimonypaid b Recipient'sSSN ? 171-42-4563 32 IRA deduction (seepage 31) . . . . . . . . . 33 Student loan interest deduction (seepage 33) . . . . . , 34 Tuition and fees deduction (seepage 34) . . . . . . . . 35 Domestic production activitiesdeduction. Attach Form 8903 36 Add lines23 through 31 a and 32 through 35 . . . . . . 110. 71,687. 9a 10 386. 11 12 13 14 15b 1st 2,494. 17 18 19 168. KSA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, seepage 78. Form 1040 (2005) 1040x(2005) FD1040-1V 1.25 Form oftwale Copyright 1996 - 2005 H&R Block Tax Services, Inc. 1-orm1u4u zuub tstcrvvr? .? •???••?••• 1 . . • income) t d d 7 38 -- 71,399. . . . . . . 1 gross jus e (a 38 Amount from line 3 Tax and Credits 39a Check You were born before January 2,1941, ? Blind. Total boxes I T chocked ? 39a Spouse was born before January 2,1941, Blind. if. Standard b if your spouse itemizes on a separate return or you were a dual- status alien, see pg 35 &check here 0' 39b Deduction for- our standard deduction (see left margin) . om Schedule A) or (f ti d i d d 40 . 11 7_01 e People who y ons r e uc ze 40 item . . . . 40 from line 38 t li 4 S b 41 5 9 , 6 9.8.._ checked any . . . . . . . . . . . . trac ne u 1 box on line 42 If line 38 is over $109,475, or you provided housing to a person displaced by Hurricane Katrina, 39a or 39b or 200 by the total number of exemptions claimed online 6d multi l $3 Otherwise 37 42 3,200. b y , p , . seepage e who can If line 42 is more than line 41, enter - 0- Subtract line 42 from line 41 ble Income 43 T x 43 5 6 , 4 9 8 . claimed as a dependent . . a a Check if any tax isfrom: a ? Form(s) 8814 b ? Form 4972 . . . . . . 44 Tax 44 10,784. , see page 36. . 39 45 Alternative minimum t ?1 45 ? ll ? ^ 46 Add lines 44 and 45 A . ;;t: ? ;? ? 46 10,784. hers: 0 Allot . Single or 47 Foreign tax credit Atta orm 11161 uired Married filing aratel se ant a si3s? h? 2441 48 Creditfor child and dap p y, , 49 Credit for the elderly orth d.Att edult?. Married tiling ointl or 50 Education credits. Attach Form 8863 . 50 y j Qualifying 51 Retirement savings contributions credit.Attach Form 8880 51 widow(er), 510,000 52 Child tax credit (see page 4l ). Attach Form 8901 if required . . . 52 Head household 53 Adoption credit. Attach Form 8839. 53 , S7,300 54 Creditsfrom: a ? Form 8396 b ? Form 8859 . . 54 55 Other credits. Check ap licable box(es): a ? Form 3800 b ? Form 8801 c 55 AN 56V--* 55.Thgt alt ayourt cr > : •\ v c Zx 56 " . 57 Subtract line 56 from line. . line 4 ter-0- k t? 0- 37 10 784. 58 Self- employment tax. A . ' 1 o 58 ,.i :, Other ..;,;Y?; 59 Social security and ti p itfi?soma n?tfifeporl% lo %swas ge >.Attach Form 4137 . . . 59 Taxes 60 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required . . . 60 61 Advance earned income credit payments from Form(s) W- 2 . . . . . . . . . . 61 62 Household employment taxes. Attach Schedule H . . . . . . . . . . . . . 62 63 Add lines 57 through 62. This is your total tax. ____ ___ ^ ? 63 10,784. Payments 64 Federal income tax withheld from Forms W- 2 and 1099 . . . . 64 14,485. 65 2005 estimate , ants applied fro 4 rettp if you have a , ..., w :.v .°: `' `. Mi ..... s 66a Earned into redi x' t i;? qualifying ` ' -; 66a ><? ' i child attach b Nontaxablec atpa _ n ? 4 "<-< : :x ` >`• Schedule ElC. 67 Excess socie curl RRI? withhel ' e p ` 9) 67 : a' fit, 68 Additional eEi tit a I L A Atf 8812 _.,_ - : ,'•. < a... 69 Amount paid with request for extension to file (see page 59 69 70 Paymentsfrom: aLiForm243s b?Form4136 :M orm88as 70 71 Add ins 64, 85, 66a & 671hrou h 70. These are our tat Payments . ? 71 14,485. Refund 72 If line 71 is more than line 63, subtract line 63 from line 71. This is the amount you overpaid . , . 72 3,701. 73a Amount of line 72 you want refunded to you - ' . 0. 73a 3,701. Directdeposit? See page 59 ? b Routing number 0 31315 0 3 6 ? c Type: X Checking ? Savings and fill in 73b, ? d Account number 14 7 0 0?zu = :.?^ 73c,and73d. 74 Amount of line 72 uwant a to our2' as' atedt 74 Lmount 75 Amount you owe. Subtract li 11 76 Estimated tax penalty see a _0) 8IR- 1' °' >1-Es T6 Do you want to allowan other persorr.'Wsdiscuss thiR4urrr.W&-*'?*'5`' 81 X Yes. Complete the following. Third Parry )- L-J No Designee Designee'sname Phoneno. Personal ID number ? HR BLOCK ? (717) 509-7876 (PIN)10- 36518 Sign Under penalties of perjury, 1 declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) Is based on all information of which preparer has any knowledge. Here Your signature Date Youroccupation Daytime phone number Jointreturn? For Info Only-Do not file MORTGAGE BROKE Seepage 17. 17 Keep acopy for Spouse's signature. If ajoint return, both must sign. Date Spouse'soccupation ourrecords. For Info Only-Do not file Preparer's Date 1 Check Pre arer'sSSN or PTIN P signature 2 3/2 0 0 6 self-employed f P 0 0 0 7 9 0 8 0 Pre parer's Firm'sname (or ?LEMQYNE, H AND R BLOCK EASTERN ENTERPRISES EIN 43-1862224 Use Only yours if seif- em toyed), address an 1 cc de PA 17043 Phone no. 717 730-3998' Form 1040 (2005) 1040(2005) FD1040-2V 1.25 Form Software Copyright 1996 - 2005 H&R Block Tax Services, Inc. we atxwrete, ebeft 2005 W-2 and EARNINGS SUMMARY 'ASTI Use - at wwwdrs.gm. This blue Eanings Summary section is included with your W-2 to help describe portions in more del m '*+yee Reft?rence AN reverse, side includes general information that you may also find helpful. ?A `Wage and Tax The YY YY Statement oua No. 1545_oooe 1. The following information reflects your final 2005 pay stub plus any adjustments submitted by your employ I Control number Dept Corp. Employer use only )01263 05NG3 007004 1A 76 Employer's name, address, and ZIP code AMERICAN HOME BANK N A PO BOX 4454 LANCASTER PA 17604 Batch #01211 if Employee's name, address, and DP code 3REGORY S HAINES !917 CHESTNUT STREET :AMP HILL,PA 17011 s F to number d mooyee's nu r Wages, tips, otMr comp Federal income tax withhold 52293.36 10897.39 Social Security wages 4 Social security tax withheld 52293,36 3242.19 Medicare wages and Ups 5 Medicare tax withheld 52293.36 758.25 Social security tips 8 Allocated tips Advance EIC payment 10 Dependent care benefas Nonqualified plane 12a Sea I for box 12 C 26.89 12b Other 12c I 03 PA SUI 50 12d . 1 tat eanj Rat. rd party ski pay State Employds Nate ID no 8 Staff wages, tips, etc. PA 9116 1545 52266.54 State Income tall 18 Local wages, tips, etc. 1604.62 52266.54 Local income tax 20 Locality name 522.72 CARLIS B Gross Pay - Income Tax - 55591.78 Social Security 3242.19 PA- tate g 1604. E Tax Withhold 7 of W-2 x Box 4 of W-2 Local Income Tax 522.7 Box 19 of w-2 Fed. Income Tax Withheld 10897.39 Medicare Tax 758.25 Withheld SUI/SDI 50. C Box 2 of W-2 Box 6 of W-2 Box 14 of W-2 2. Your Gross Pay was adjusted as follows to produce your W-2 Statement. Wages, Tips, other Social Security Medicare PA. State Wages, CARLIS B Local W4 Etc s Ti W Compensation Wages Box 1 of W-2 Box; of W-2 , . p ages Box 5 of W-2 Box 16 of W-2 Bps 8 of Gross Pay 55,591.78 55,591.78 55,591.78 55,591.78 55,59- Plus GTL (C-Box 12) 26.82 26.82 26.82 N/A Less Other Cafe 125 3,325.24 3,325.24 3,325.24 3,325.24 3,32: Reported W-2 Wages 52,293.36 52,293.36 52,293.36 52,266.54 52,26E 3. Employee W-4 Profile. To change your Employee W-4 Profile Information, file a new W-4 with your payroll de GREGORY S H A I N E S Social Security Number: 210-46-2513 2 917 CHESTNUT STREET Taxable Marital Status: SINGLE CAMP HILL, P A 17011 Exemptions/Allowances: FEDERAL: 0 STATE: LOCAL: 0 O 2005 AUTOMATIC DATA PROCESSING, INC. --------------- '---------------------------------------- =------------------------------------- D t of the Treasu roamel Revanue Service noodo ?[ n Walge wW ,Tax ?oo? 1 Wages,tps othercompe,11 . 2 Fadefal'ind0rttelbArsie@l : orosNO.,tia5-coca 14911.2 i 2542.07 F S¦w( orm Statement Copy C For EMPL""' F'S RECORDS. (See Notice to 7 Soc al secur ry tips 3 Sodatsecurity waQee 4 Social security tax wRhheld' Employe ort."acor6fCopy B). 14911.2` 924.49 a Employers fete, addre s, and ZIP code 8 Allocated tips 5 Medicare wages 04 BPS 6 Medicare tax adfiFteld 14911.2 216.22 Integrity Bank 9 Advance E(C payment 10 Dependent care benefits 11 Norqualdied plans 3314 Market Street Suite 305 Camp Hill PA 17011 $2a SeeinsnucBOrrsforbox,z ?2b 2c , ,lptoyae's n w*, address, and ZIP code... j2d 13 Statutory anrement s(cx pay 14 .Other Gre or Haines S a Sul - 13.43 g y . 2717 Chestnut Street b Ernpioyer identification number (EIN) d Empivyee's social security nurnbef _ 52-2389022 210''-48-2513 Camp Hill, PA 17011 Tlds bdormadon is Daft furnished W the Internal Revenue Samoa. B you are requved to file a ter resxrt, a negligence penally of ocher sarxtion may De imposed on you if this income k taxable end you fail to repel it. 1 _.915j6 73-87___--- -----14911.2 -----A5Z.7fi __--1-4911.2 ? ---_216-.22 tWeSt-Sho Emolover'sstate 1.0. number 16 State wages, tips, etc. 17 Slate income tax 18 Local wages, tips. etc. 19 Local inCOme tek 20 . LOCatayrlmne • Y N a91` p In ni N ? fll S. a C N a V 0 9 O T ^t1 c'a 2-5 *z ! ``-3 ,.• rl Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INVENTORY AND APPRAISEMENT GREGORY S. HAINES No. 04 664,P 1276 Plaintiff VS. REBECCA A. HAINES Defendant INVENTORY AND APPRAISEMENT OF GREGORY S. HAINES Gregory S. Haines 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. Gregory S. Haines verifies that the statements made in this inventory and appraisement are true and correct. Gregory S. Haines understands that false statemens herein are made subject to the penalties of Pa. C. S. §4904 relating to unswom fajsifi, tion to authorities. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INVENTORY AND APPRAISEMENT MANDATED BY R. C. P. 1920.33 Gregory S. Haines No. 04 S 1276 Plaintiffs full name 2917 Chestnut Street Street and number Gregory S. Haines Name of party filing Camp Hill, PA 17011 City-State-Zip VS. Rebecca A. Haines Defendant's full name 2711 Logan Street Street and number Camp Hill, PA 17011 City-State-Zip Jane M. Alexander, Esquire Plaintiff s attorney March 27, 2004 Date Complaint served Date this form filed Jordan D. Cunningham, Esquire Defendant's attorney 148 S. Baltimore Street Street and number Dillsburg, PA 17019 City-State-Zip (717) 432-4514 Phone number 2320 N. Second Street Street and number Harrisburg, PA 17110 City-State-Zip (717) 238-6570 Phone number ASSETS OF THE PARTIES plaintiff marks on the list below those items applicable to the case at bar and itemizes the asset: on the following pages. If an item has been appraised, a copy of the appraisal. report is attached. ( X ) 1. Real property ( X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value cash surrender value and current beneficiaries) ( ) 10. Annuiteis ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/directo positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, workers compensation claim/award ( ) 17. Profit sharing plans ( X) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 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 MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced Item Number 1 . Item Number 2 Item Number 3 marital residence at Volvo Subaru Description of Property 2711 Logan Street Camp Hill, PA 17011 Names of All Owners Gregory S. Haines Gregory S. Haines Gregory S. Haines Rebecca A. Haines Rebecca A. Haines Rebecca A. Haines ate of Acquisition 1995 1993 1999 ost or Value as of ate of Acquisition 90,000 Values as of Separation approx. 145,000 2,105 6,745 Value 30 Days Prior to approx. 160,000 Hearing Stipulated between parties none mount of anny Lien National. City Mortgage $80,405 Form of Attached Documentation printout of National. City Mortgage Loan information Fannie Mae appraisal Comments rr, 1 C_ J r_wu" CJJ • Jl Al FannieMd- DeaMep Under • T1itS3UlIf1sAR1lAPlRAtdfAlRE 2055 f7WVE BY INTERIOR TERIOR L?lMen S.bpraon ?J Resat prop"vou" Mwu*M9 So " ? IDa•Wa•tJ ? Eby AGE PRICE AG Orsr75% 7SaS% ? Wtoa 25M Domenw3upoly Sl.etuyp A M Pis.nG.r Owrauppy b (00d ) s(0061 t?r%1 ete Rape Slabl, SI.. Merban time Underlteva' 3.6r1w, O,r1ma Low ' M Lan 7oa?7wudwm MEATTAGHE0 A00EN2UM 400 W 1w hall kPrwoomwi. -_ Predomlrnra 190 tl0i11 as GEE LECALD&ScRIPT" fie re..19 ACRES Shoe RECTANGULAR rF L arpttrtce ® Leg al ? Lp9Mfart =MnpMq (Gnmilsow ed 11100A taAeld-014b'en No sa irg ww bw um stage M ftowed a C amassed my rA ebb x ? use. ra7eh eescr. Ptoas Ognr Kok Other p , as Type Public Pmre eWear ® ASPHALT Q 13 aN K ft- aLkn- shear aces No y tard rr ptyrtll Marbuastalca d Vapoof 10.nr and asuiar tl?ectan Ealbna lespactM ham streak PM.rbus appraisal (iks u P I o.ww tales 2 Mawfae.e e k woody em M a 7 wa FIN. O ew&M 0*vxw ' 1 , m w a mtdlwa vo wetda wisa tas N9Ya s =WW Vo"of the oprwcmcr a or pn IMabley al Via property? BEN ATTACH D AOOBWWJM s e My hPie"ad.bna on*9moutal =%Own NbUdaA waeas, umor suastanecs, aw cse bn the sir. a r Me k Y otad aM auyoe mono area fa ww*U Msilov. d aw aloe as um nest sl o for end aroshoelo to dN %Nm propelb. nfi5 ijjMtD5 loff rnadapt rargeqIn ectioft imm f 1S440Wo s 159. of the tY f rialtos roactle to wi M MECt SAL1 STILE 2 TURE SU fEATIUK SALE GM STREET 3120 LINCOLN WMEI 2161 MANE ROAD 2172 CHESTNUT STREET WA ADD s 115.2113 29.9011 IL TNOUCDRTNO RECO OL RTk10USE RECORDSIMLS UEAUX 0 1011 DESCI?iION . s D pTEIN s D RIPTION ut Saes ofFlrwKtq CONVENTIONAL 1 CONVENTIONAL enNVENTIDNAL. ' Cenrsaa.... .. • NANLRKMOWN . NONE KNOWN . NONE KNOWN A1e.e G+Ne rW ` at4 1. r r ArN ' M • Mho r?n aw hum. 7 .04 i__3 Room Caralk 1 T a l i r 1 00 0as Ap 1 . rd Son . F I + S . PI J rULLwariMENT GULL5MEMENT FULLBASE?MENT BASEMENT iwiewhI UM PARTC MUM ISNPO i t • S n 100 • `; 16100 / s 1.500 PNee Gross:4,2% rpm! I " ; a s5 149.100 Nast. 16-A s 153,100 Nau. '1.011 ans M)NEVATHIN WOWS WITNCH NONE WITHN NONE WITHIN Sala s 36 MONTH I S IYNM S 1 YEA1 Y6AR ty aum.l.gr-i - .f ..M, apthm, a RAN W SEE ATIACH6D F?AODENDUM, ales owporisat No vale sa MAbri: 90 Mokik 1 31 3 3194. Mara manes dW& the three Ttusaetulsal hmeda W 'bull, a Q s+bJWletsppepmpe/pMSaa4s1at0eabfMenNabs4MSaygeAafkNeMapMtMeth?Yfgreurursshwasa.mm?paul ar d tat conou r. A D NO M SAUDONAN M91OR?EOTI0a1FROUTIESTREETORAN Nit R1aR1Y?FXtE160RNS>?iM7sLIEliMA7EY1EMaRifETYAL?7ErLSOER?ER Or THEMALPROPERTVTNATISTNESUtaiEn o"MaREPORTTOOC1145,000 AS OF APRfL ff. 21104 lout PA491 OF 3 Fang. H.. Fm,.2ps5 gAfi aM.e.M. W./W4aa Aaa?r Ma?.w rr. dpi l l MAY-20-2004 98:58 96% P.01 MH Y -GI6--06164 01J: 15-1 1/ 20155DWSBYIM AJOWeXTERWR } Oaak = u ndarn_,ibr anairvuladwa AMIIWAIS Awwsaage.l o?.... i Paq)eet itsaarrrsatteet y??11Ge fir 4wkobie}.6, tin di vdaprAusdv in colonel N pro ttat'e Ownms' AsmeWd" fiioA)) Yes !b Prtsrkls nee tobakq kdemslYan for PUDs oMy Nerve ddanJOperAmWdat b In taneel a etc Nf)A ism the sutgats Preµrbr tt en coached orreting unk: Tar nimlQOt phs.ta Tow naabr el ladle Tow lumbr, al wilts sold Tear mallmrdi tlikt etetmt Tow number of wilts for slid DWS Sotses(s) the poJtsLaaatad bytlu oanrrsten at so" Widow into a PU1TT ? Yos Was Fb byaS arts dam sf mnsersnn; DanuepgpGtwealth MgrelohFdMOYN0ww ? Yes 0No oft Soldier Ast ilia eMMM slansrmtr rontpwed7 ? Yes Q Na a lie, tlasrdae tutee fir tampbriell; An any common s[ortoats listed to of by nha 4seta Omwtas' A0+sou-7 Yea No If yep atrweh wra aiumtwcrmrrg rased p ryp and clowns. Daaales eonrnan aiesrenu rne,.s.au.,,atfwdirrc: PryeotisisersesalawtorCaademWtrae Of appi whim).•fa the tNretaptrhai{4asr 1. sontrw arm* Nome Ownru' Aamclateon (NDAi7 Yes No provloa the Ioa rv Iefdmtium far all condononl as Ptrl(tift Tear tssnprar pha= Tow sum e, of wilts Taal rtumbar of uais said Taw raanaor ol uras mold Toot number of wits tr sale Data Seunals) WAS the trnlasl utuad try ate Convrsion of Rowell sum"c Into a eorcw" m7 Yss No M tat aata or oa iketsim: haiast Typo ? MMMy Raided. ? Saone Bone or Iiectewfartal O Rea a Teem muse ? Gordon ? rtroee Wq roe candkma to tke pajo,b ritr.wy of CorptruWod, wN rile, di.., Afetheawwronelerrtentsmntprata(ii Yes 11oNNo,dssutbaawWCmraetplaxMl Are any co mom. Wantamis Isosad to or by the Norse Owners' Asiaaiotion7 Yas No It yes, admen aa0end,an deselbb,p remal terms and onion., ().eater araani0h contents and folraeumal rawilesl PURPOSE OF APPRAISAL: The purpose of this appraisal is to estimate tree market value of the real property that 11 the subject of tole report based on a quantitative sales comparison analysis for use in the mortgage finance uansaction. DEFINITION OF MARKET VALUE: The most probable price which a property should bring In a competitive and open market undor all eonaltdons roqulSlte to a fair Sala, ulna buyer and seller, each along prudently, knowledgeably and assuming the price Is nut arfactod by Undue stimulus. implicit n, this definition 15 the eohsutamoVan oft sale as of a specified date and the passing of title tram StIlui to buyer under conditions wharabyt (1) buyer and seller ere typically motivated: (z) both pardvs are well informed or well advised, and mace acting in what he considers his own best Interest; (3) a reasonable tuna is allowed for exposure In the open market: (4) payment lit htadt in terms of cash ire U.S. dollars or In trams of flnoncbl arrangements Comparable thereto; and (5) the piles reprasenta the normal eonsldoration for the property cold unaffected by special or Creative fnanciny or sales concessions' granted by anyone associated with the sate, ' Adjusanoais to the comparablms must be made for SPeelrl or creative fimmncing or vales concessions, No adjustments are necessary [of those costs which are normally paid by salters as a result of tradition or law in a market arse; these costs are readily identifiable since the seller pays these costs In vtrttastly all sales transactlonc, Special or Creative financing agJustments can be made to the comparable property by comparisons to financing terms offered bye third party Institutional lender that is not already invotvad in the property or transaction. Any adjustment should not be calculated on a moo AVACal dollar for dollar r.031 of the financing or concesslon but the dollar amount of any adjustment .house approximate the market's reaction to the financing or cdneesbiens 17,0306 on the appraiser's judgment. STATEMENT OF LUTING CONDITIONS AND APPRAISER'S COM!"ICATION CONTINGENT AND UVATING CONDiT10NS: The appraisers cartincddonthat appears to the appraisal report is subject to the following conditionst i. The appraiser will not be responsible for :hatters of a legal nature that effect either the preporty being appraised or the title to It. Trip appraiser assumes that the title Is good end mafk?lablt and. therefore, will not rencof any opinions about the title. The property is appraised on the basis or It being under responsible ownership, 2- The appraiser has provided any required skotch in the appraisal report to show approximate dimensions of the improvements and this sketth is Included only to 0:3131 the reader of toe report in visualizing the property and understanding the appraiser's determination of Its size. 3. The appralsar will not give testimarny of appear In court because he or she made an appraisal of the property In question, unless spoclfle arrangements to do so have been made beforehand. C The appraiser has noted in the appraisal report $fly adverse conditions (such is, but not limited to, needed repairs, the prrstnce of ha><srdous wastes, IONIC substanea, Ott.) observed during the inspection of the subject property or that he or she became aware of dyeing the normal research Involved In performing the appraisal. Unless otherwise ;fated in the appraisal report, the appralser nas no kDowtedge of any hidden or unapparant eoildtdens or the property or adverse environmental conditions (Including the presence of havardbua wastes, toxic substances, ate.) that would stake the property more or lass valuable, slid has asaumsd Inky. there are no such condttions ana makes no guarantees or warranties, expressed er implied. regarding the Condition of the property. The appralser will not be responsible for any such conditions that do axis[ or for any engineering of tsidng that might be required to discover whether such conditions exist. Because the Appraiser is not an tapen in the field of environmental hazards, the appraisal report must not be considered as an onvifismhantal assessment of the property, 5. The appralser obtained the Information, estimates, and opinions that were expressed in the appraisal report from sourees that he or she considers to to reliable and believes Thant to be true and correct. The appraiser does not assume respontlbhity for me aceuraty or such Items that wore furnished by other parties, A. The appraisal will not disclose tilt contents of the appraisal report except as provided far in the Uhifarm Standards of Professional Appraisal Practice. 7. The sporaisor must provide his or her prior written consent omfort the feMoflellent soarlfted In the appraisal report can distribute the appraisal report (including conclusions about the property value, the appraiser's identity and professional designations. and refafenees to any professional appraisal organizations or the firm with which the appraiser is associated) to anyone other than the borrower; the mortgagee or Its successors and assigns: the morigagt Insular; consultants., professional appraisal organisations, any state or retfarolly approved nitancfal Institution, or any department, agency, of Instrumentality of the United Stetel 6e any state or the District of Columbia; Vocalist that the Isndericlient may distribute the report to data collection or reporting service(s) without having to ebtsin the appraisers prior written consent. The appraiser's written consent and approval must also he obtaynaa btrare*the appm sisal can be cOnveysd by anyone to the public through advertising, public falatlons, news, sales, at other media, H. the Appraiser has based fits or her appraisal report and valuation Canelusten for an appraisal that is •.ubjoot to completion par pions and specifications on the basis of a hypothetical condition that the Improvements newt been completed. 9. The apprimisaT has based his or her appraisal report and valuatloh concldslon for an appraisal that is subject to completion, ropolrs, or alterations on the assumption that compiadon of Via ImproYements will be perlormed in a workmanlike manner. PAGE Z gf 7 rlaaia ?laa focal InaS tt•pe ?W Vococasaesriurwawe? P. 03/11 MAY-20-2084 08'-59 96% P-02 P.04/11 I ,n t -GU-GUrJ`? vJ7. JG tt.?..-- Zo3SDRIVEflV1NTI:ftIOPV87lTER10R Un" ...its aAV snlUatlvs f nefteb Ap?IfRl .1ERTfFICATION: nor Appraiser c¦rtiflas ana agrees than: 1. 1 performed this appraisal by (1) personally Inspecting Iran the street the subject property ind nolghbornooo and each of she comparable sales (urdesa I have otherwise htdkated In this ropost that I also tinplated the Interior of the subject property), (2) eotecvUng, confirming, and analyzing date from fellable public ardor private sources. and (3) feporting the results of my inspaGtlOn and analysis In this summary appraisal report. I further certify that I have adequate Information about the physical GMracturistIcs or the subject property and the comparable sates to develop This appraisal. 2. 1 have rusearchad amid enalyx¦a the comparable stalay find offeringsflislings In the subject market area one have reported tho comparable sales In this report that are the best available far the subject property. I further certify that adequate comparable market data exists In the general market ores to develop a ralfobls sales comparison analysis For the subject property. 3. 1 hove Takao into consideration ins doctors that have an impact on value in my develbpmanl of the 0311mato of merges value In tnc opprelsei Floors. I further cortify that I have noted any apparent or known adverse, conditions in the subject Improvement..-, on the subject site, or on any site within the immediate vicirdfy of the s+IDJeet property of which i am aware, have considered chase adverse condldo(ss in my analysis of the property value to the extent that I had market evlderiCs to support Them, and have commented about the effect of the advene conditions on the marketability of the subject praparty, I have not knowingly witnheid any significant information from the appraisal report and I believe, to the Dart of my knowledge, that all ststements and information In the appraisal report are true and reflect, d. 1 stated M Clio appraisal report only my D*n personal, unbiased, and peofo9sional analysis, opinions, and conclusions, which utL subject only to Ina contingent and limiting conditions spovi ied In this farm. 5. I )keys no present or prospective Interest In the praparty.that is she sutdoot or this report, and I hove no ptecont or prospeetive parsanal Interest or bias with fsapact to the participants to the transaction. I did not bass, either partially or completely, my analysis andiar the estimate of market vahfe In the appraisal report utt life rota, ester. religion, sex, age, marital status. handicap, FAMIUAI Rtatus, or national origin of either the prospective owners or occupants or the subject property or of me present owners or occupants of the propertlus M the vicinity of the subJoct property or on any other besis prohibited by law. S. I hers no present or contemplated future interest In rho subject property, ono neither my current or future employment nor my compensation for performing this appraisal is Contingent on the appralsed value of the property. 7. 1 Was nut required to report a predetermined value or direction in value that favors the cau;p or the client or any related patty, the amount of the value estimate. the attainment of a specific result, or the occurrence of a subsequent event in ardor to receive my rompons Basim andfof employment rot performing the appraisal. I did not base the appraisal report an a reeuestmd minimum vatundon, a specific voiuetlon, or the need to approve a specific mottyage loan, 6. 1 estimated the market value or rife real property that Is the suW*r% as this report based on the soles comparison approach to value. I further certify that I considered the cost and income approaches to value. but, through mutual agreement with the client. did scut develop then,, unless 1 nave noted otnDrwlas In des report. S. 1 performed this oppralsal as a limited appraisal, subject to the Departure Provision of the Uniform Standards of prore:Mlonal Appraisal Practice that ware adopted sad promulgated by the Appraisal Standards Board or The Appraisal Foundation and that wars in the place as or Ube effective data of the appraisal (unless t have otherwise indieated.in tills report that the appraisal i5 d Lunnplute appraisal, in which toss. the Departure Provls(o l does not apply). 10. 1 atknowlodga that an estimate of it reasonable time for eapoauro in the open market Is a condition In the deflnitlun at market value, Tree exposure time associated with the eslimata of market value for the subject property Is aonsistant with the markefiha time noted in the 14etghborhood section of this report. The matitcing period concluded for the subject property at she astimotoe market value is also can%istant with tna marketing time noted in the Naighbarhood section, 11, 1 personally prepared all conolu7lon'. and opinions about the real estate that wets set forth In the appraisal report. I further cattily that no one provided srgnlflCant professional assistance to me In the daVelDpmant of this oppraisal. SUPESMSORY APPRAISC" CERT1pICATIDNb E a supervisory appraiser signed the appraisal report. he or she cardflea and agrees that, I olractiy supervise the appraiser who prepared the appraisal report, nave examined Ina appraisal report for campllance with the Uniform Standards of Professional Appraisal Practice, sgra? with the stotenants end conclusions or the appraiser, agree to bit truund by the appraisei s cdrtlficatior s numbarcd S through 7 above, and are taking full rosponsibitity fur the appraisal and the appraisat teposi. APPRAISER: Swature: Name: TIMOTHYJ. SWARTi XP 4mlm%,Q _ Copp" Worm; THE APPRMULYtRAA. INC. Company Address 1YJ W-MAIN STREET kA1DDL8TOWN, PA 17037 Data of Report/SignaturcAPIeL I& =04 Soto Certifications #-FIL-OOT111112-1. or State Llcw%w R SWMPA Expiration Dale or CetteketWn or lkenset JUNE 30.21104 ADDRESS OF PROPERTY APPRAISED; S(JPERVISORY APPRAISER; 2711 LOOM STREfiT SMECT PROPERTY CAMP MLL PA 17011 Did hoc Inspect subjati-t property Did Inspect eatedor or supjoa property from street APPRAMED VALUE OF THE SUR1ECT PROPERTYS 149.0e0 Did iropeet Interior and exterior Of subjace prt,pcny EFFECTIVE, DATE OF APPRAISAILMSPECTION 4WJW COMPARABLE SALES 8 Did not Inspect exterior of comparable sties From street LENDERICLIENT: Old inspect ornerier or comparable sales from street Names C-unWar>y Narrow: COYINERCE YANK Corm early Address; 41IMGYNE DRIVE LEMOVN@ PA Ind$$ 10tH. PAGE 3 OF I Fannie THE AI'MMAI L I", M. SUPERVISORY APPRAISER (ONLY IF R1=pU*W); Stw-ARe: Name: Co"""y Nan w, Company Address! Rapom/sigrtaeinr Dale of 5ute Cerafipdont or State kkorelp stop Eapfrodets Dan of Cerdlkaeon or Uceasel s-ss MAY-20-2004 0859 915% P.03 1 11-1 I -e_u -GYJYJ4 VJ7 • JG P.05i11 FannieM: - 2065 DRIVB 9Y WiT RIORIEXTER,pR Desktop Undkwrftr QI mUlaUve Andwals Aaaealaal ao mvt - - T 4 - - SALE 6 2711 L+OGAN OTREC7 AMM CAMP MIL PA 17011 b S Ewa PNee WA &MMELwima- -W" Oda ivio1. Swo or Fir*-Ong OESCAIPTION Cwwmlon Swa or p ¦ 2" NORTH 2#TH STREET r" HILL. PA MI ENE - . $ s lcm 0 COUMOM! 5C .H? CONVENTIONAL : NONE LWOWN 0810D M s N t ESCRIPIION .w lift v "A r ; imgm- She A .19AG VG. 1 AbW Ate >_. 7. STORWAVO, t 4TOPIYMVC. 00 owwm AWrafxade RwmCaun fflafta sir' l+aw ` M1?c 7 1 a T.O6 xr r.. Mar I i 4 1 ' .g .. •1.500 T,'' Dvna ` w1r bar t ` ew1. 1 . Ft FL; 5 FL it: Ywmm"AmWod R- 11- FULLBASEMNT uNRIN1af1ED N PWJ.EASSMENT ' UNFI NS OW ayt+ruSalesPma ME Cbmbwmbhn Oats d P- S- PON MI ft SON 1 NO FPMO CA C PORCH . NO WITHIN 3 94 MONTIO 4Vf Fv Y .C*aa>G•1?1,',% MON9 %WTMIN = .7,600 f 111F/I5 ?7st7. f 3 CvaR; ksl: s f -02"-Mm6a 4 1 142, +l wm ??Mr IOMR ?Ir27NR11?.YYr. MAY-20-2004 09*00 97i P.64 i-rn i -au-e-uv i vJ7. ')0 P.06i11 Nelloberhoad oeYnderles Tan subjea nelgnbernaad It dW*d M Camp i4M DOW* TAY suburban nelphbmhood ties most Pubic uUMm avalaets. rdalhrely easy atomme to neproyr wii wW errvkm and is comooNse WM Mar neghher waft in the general crew. ~ Neva publla U=ba. No uotavaraWe buiore Observed whkim would afeWm1y stied meewtabiriy. Ptyelval Oeae:6now Cameitanta Tba subOwt sws aonWdareded b be in owras average cond ftOn Tna katlran Is pmedeled aced in good aorWhton end the Ov" room flop hat reeanay bar, repbp" wvlim h i rr g ood The e9WANe hem, else been updated. Tna sutyect hce naso.rrma ml vfamdcws end to wo eppws to b In Otwd oondNlvn. The ascend floor Walls appear b be in noaO OtPairok,g, some hew born pawned. The bathroom lws bean dryweltad ON *MR needs DOW MW 0e10ts0. Met wneldednp awt bat0 Peden of ems horse are barter them eve" ens some etenewhet tees Mnn wmpa, the" 1 coatddon fv%V Was vvnsidamd to be average. aawrae Fnukenwerstal Comawnbr Al tlw Yens of the a ape - than were no vdwomble (eaten Wows to Ova uppralser. In the absence of ewe borkigs, at ouwr lees, a five bwe aeadaoed Niel then arena mkt.rel dtsnrwAs sn• saasn?alrwttae uarderlykrg flee wgleet prepMy. For ace same meson. N nee been dame u?rrad gtet therm are no meNAUN sub-so/ GCaldlltlefmt Or heRatekers smDetnltes that leoald atlrrtsMy attest morkehbaity ardlvr 1ne mensal vahme of ice aubj.cl. Anm"ft of Curnord Agmenwn4 The su*ct properly has not been kled or sold wtihlh Me last 36 monW&. The compmMa hew not sold within ens year of the most rwwt sale. Sales Irdiarmsdon was verilled through salea agem and/Cr aallervvtwn poseble. CoodWone of the Report This &Mmk el has been pmWed v/th nw w upwV In 10 ke canditlaa Ire aubjW has not saW wANn the past 12 months. No Personal property included In Nde valuation. IplmmFwldt MAY-20-20844 0900 97% P.05 I'IF1 I -G?J?G!`JU4 IJ7 JJ SUBJECT PROPERTY PHOTO ADDENDUM aortuw , MAIMS r Ct7M4097 F rQPWW AddreSS:2r I 4GGAN S) 4ciFT se No.' Cf: cwn WILL 5MM: PA hoer com%RCE R"K ' 17011 FRONT VIEW OF SUBJECT PROPERTY Appraised Date! APRIL a, 2004 Appraised Valuc: S 1411,6M REAR VIEW OF SUSJECTPROPERTY STREET SCENE P.07/11 MAY-20-2001 09=01 9?% P.06 1'IYi I -4VJ-eKJ?..14 U 'Z% - JJ COWARABLE PROPP W ONnTn Anneunow EkkermW HAI E Ik h . Pro ddnm:M11 LOOAN ZTRm ase Me.: citr, M t4ILL isle PA Zb' 11b11 Len . c-ommROE RANK COMPARABLE SALE t1 3120 LINCOLN STREET CAMP MILL. PA 1T011 Sale Duce, 4-302am Sale Price: S W.= COMPARABLE SALE #2 2958 MAPLE ROAM CAMP NIL.4 PA 17011 Sale Oats: !I, 1 8 Sae Price: $ 1T1 sou COMPARABLE SALE #3 21n CMEbTNUT STREET CAMP HILL. PA 17011 Saie Date: z•is-zw* Sale Ptiw s 14a.Dw P.08i11 MRY-20-2804 09:02 977. P.07 VIN I -eu-GYJ?J4 VJ'7 • J4 rY]YDAOAw# a pebrusan V Ounvn Annwiura fu 1 , NAINSS Menu.. COIrr067 rooerw es$-VI 1 60W STREET Case No. CI : CAII/? MILLGE DANK $WIL" PA Pip: 17011 aed 1 Coft"h COMPARABLE SALE #S 243 NORTH 24TH STREET CAMP NILb PA 17011 Sale Date: 12-W2= Sale Prko: 3 18E.4DD COMPARABLE SALE tS Sam Dam: Sala Pnoe: $ COMPARABLE SALE #6 Sale Data Sam Prke: S P. 09/11 MAY-29-2004 09:02 97% P. 08 1'lM I -, Yrj-4UU14 VJ7 • J,r4 P. 10/11 MAY-20-20M 139'- 02 97/. P. 09 in cv cvv-r VJ' J-r I-'. 11/ 11 / LOCATION PAAP Borrower; HAWED fl No.: COM4oaT N CRY, CAMP HILL State: PA lo: 17411 Lauder COMMIRItC4 DANK w \ 4?4 Nv £ LM FA r $ O ??G J 4 ! S Y > S ? V cc? ? ?v ?A w \?v p 1 ? G MAIN T a ON WS I R t4NSA GU ??' M a9ENryr4TE 5 1i te ?`` ?a Na ri i . ? L q ? q4 ?y M tM a? ?ii b?K G1 4 -' ° ? Kt e?IOM 1S ^ w' ` S ° F MpFOa ? ? yl Na ? N J r ? !an¦? y a ? M +3, Y = CNS t f col Sut ? n w aV 0 C NTVA V? ? . t ` f P ' ? rat Ce?oA ? ?.L 1 •? 1p 9 ?• "`'? ? A ?v / `f S L 11 ?,. 11 pp L?RL1't ' •J OR r.-+ f 1 QEC r56U ra I'1 It c6 y / ? r / Ra? i ? ' yrgy R s? r W?(L)tee TEL9 ATLAS 2.42 mi lea Pf9DWbd W. TM Appn4I0e1)TM. ROM 117.4440630 n ¦ u r "Mim 2711 t"A11 sr Up. ¦JA 7 4 1 0.00 NX i 9114 u sr 4-3"003 144600 7 3 1 1408 0.27 ?a Q 2 2062 mp" RG "a-1409 17troo 7 3 1.9 3492 0.24 rQ MR 3 2172 C M79M a1' 2-19-2004 144000 7 3 1 1024 0.46 ILL CiE 4 743 M 14TH CT 12-30-2003 164400 a 4 119 1812 D, 2s W2 we Tbig APPK&AAL FIRM, INC. 19 WEST MAIN SITIM, MIDCI,MINK PA 17067 PHONE: 717'94"aM FAX; T1T-4+(6 i9a3 TOTAL P.11 1Vauonal uty mortgage lo - Loan uuormauon Loan Information for Loan Number 9397083 Saturday, May 20, 2006 Loan Number: 9397083 Borrower Name: Gregory S Haines Co-Borrower Name: Rebecca A Haines Borrower SSNMN: 210-48-2513 Co-Borrower SSNMN: 171-42-4563 Contact Information Home Phone: (717) 737-7799 Mailing Address: 2917 CHESTNUT ST CAMP HILL,PA 17011-4525 "Borrower email: Other Phone: (717) 649-8667 Property Address: 2711 LOGAN ST CAMP HILL,PA 17011 'Co-Borrower email: If mailing address or telephone numbers are incorrect, please click here to update. All other information, please send us an email. * Your email address will be added to our database as a means of contacting you and may be used to contact you about information concerning your mortgage loan with National City Mortgage Co. General Loan Information Current Principal Balance: Loan Origination Date: 11/19/1998 First Payment Due Date: 01/01/1999 Maturity Date: 12/2018 Payment Information Scheduled Payment Breakdown: Next Payment Due: 06101/2006 Principal & Interest: $687.78 Hazard Insurance: $54.58 City Tax: $38.38 Other Tax: $113.54 Shortage: $24.12 Total Scheduled $918.40 Loan Type: Conventional Fixed Rate Current Interest Rate: 6.00000% Original Loan Amount: $96,000.00 Payment Method: Coupons Last Pavment Breakdown: Date Payment Received: 05/15/2006 Principal: $327.51 Interest: $360.27 Fees/Late Charge: $0.00 Addt'I. Principal: $0.00 Payment: Year-To-Date-Totals Principal: $1,621.33 Interest: $1,817.57 Property Taxes: Hazard Insurance: Back Logout CWyii9M O 2000-2008. Fidelity Infomuition Services, Inc. All Rights Reserved. r? EOlNAl11?tSIhIG LENDER $482.24 $0.00 rw1of1 https://customercare.fnffismd.com/nationalcity/CSI/CCNCSIcurrentinfo.asp 5/20/2006 Loan Number: 9397083 Borrower Name: Gregory 8 Haines Co-Borrower Name: Rebecca A Haines Borrower 210-48-2513 Co-Borrower 171-42-4563 SSN/TIN: SSNITIN: • I8.. XX /P. YPPVV. r• •,. rv.vv Escrow Balance: $1,001.00 Escrow Advance Balance: $0.00 Unpaid Late Charges: $0.00 < due. are that funds represent necessarily not do and paid have you reflect history payment the within displayed transactions The Disclosure:> * Other can include Life Insurance, Accident and Health Insurance, Late Charges, and Suspense (Unapplied Funds). Date Due Transaction Transa Princl Princ Inter Escro Escr Escro ction pal ipal eat w ow w Amoun Batan Amo Amo Amou Adva Bolan Paid Date Description Other t ce :4nt: unt . , 1W;1 . -nee co' 05/15/ 05/2 Payment $918.40 $71,72 $327. $360$230.6 $0.00 $1,00 2006 006 6.89 51 .27 2 1.00 04/12/ 04/2 Payment $72,05 $325. $361 $230.6 $770.$8.00 Late $926.40 $0.00 2006 006 4.40 88 .90 2 38 Fee/Other Fee 03/17/ 04/2 City Tax $482.24 $72,38 $0.0$482.2 $539. $0.00 $0 00 2006 006 Disbursement 0 4- . - 0.28 76 03/15/ 03/2 Payment $72,38 $324. $363 $230.6 $1 02 $12.00 Late $930.40 00 $0 2006 006 . 0.28 26 .52 2 2.00 Fee/Other Fee 02/14/ 02/2 Payment $72,70 $322. $365 $230.6 $791. $918.40 00 $0 2006 006 . 4.54 64 .14 2 38 01/05/ 01/2 Payment $73,02 $321. $366$230.6 $560. $918.40 00 $0 2006 006 . 76 7.18 04 74 2 12/06/ 12/2 Payment $73,34 $319. $368 $202.7 $330. $890.57 00 $0 2005 005 . 8.22 44 34 g 14 11/01/ 1112 Homeowners $655.00 $73,66 $0.0$655.0 $127. 00 $0 00 $0 2005 005 Ins Disb . 0 0- ' - 7.66 35 10/31/ 11/2 Payment $890.57 $73,66 $317. $369 $202.7 $0 00 $782' 2005 005 . 7.66 85 .93 9 35 09/30/ 10/2 Payment $73,98 $316. $371$202.7 $579. $890.57 00 $0 2005 005 . 5.51 27 .51 9 56 09/12/ 09/2 Payment $74,30 $314. $373$202.7 $376. $890.57 00 $0 2005 005 . 1.78 70 08 g 77 08/16/ 08/2 School Tax $1,362. $74,61 $0.0$1,362 $173. 00 00 $0 $0 2005 005 Disbursement . . 98 50- 6.48 0 .50- 08/12/ 08/2 Payment 57 $74,61 $313. $374$202.7 $0 00 $1,53 $890 2005 005 . . 6.48 13 .65 9 6.48 07/06/ 07/2 Payment $890.57 $74,92 $311. $376$202.7 $0 00 $1,33 2005 005 . 9.61 57 .21 9 3.69 06/24/ 06/2 Payment $924.96 $75,24 $310. $377 $202.7 $0 00 $1,13 $34.39 Late 2005 005 . 1.18 02 .76 9 0.90 Feet-Other Fee 06/16/ 06/2 Late Charge $75 55 $0 0 $928.$34.39- Late $0.00 00 $0 00 $0 00 $0 2005 005 Assessed 0 . . . 1.20 11 Fee/Other Fee 05/13/ 05/2 Payment $890.57 $75,55 $308. $379$202.7 $0.00 $928 2005 005 1.20 48 .30 9 11 03/31/ 0412 Payment $75,85 $306. $380 $202.7 $725. $890.57 $0.00 2005 005 9.68 95 .83 g 32 03/15/ 04/2 City Tax $460.61 $76,16 $0.0$460.6 $522. $0 00 $0.00 2005 005 Disbursement 0 1- . - 6.63 53 03/10/ 03/2 Payment $76,16 $305. $382 $202.7 $983. $890.57 00 $0 2005 005 . 6.63 42 .36 g 14 02/22/ 03/2 Late Charge $76,47 $0.0 $780.$34.39 Late $0 $0.00 00 $0 00 $0.00 ' 2005 005 Adjustment 0 . . 2 05 35 Fee/Other Fee 02/17/ 02/2 Payment $76,47 $303. $383$202.7 $780. $890.57 00 $0 2005 005 . 2'05 90 .88 g 35 02/16/ 02/2 Late Charge 00 $577.$34.39- Late 00 $7677 $0 00 $0.0 $0 $0 00$0 2005 005 Assessed . . . . 5.95 0 56 Fee/Other Fee 01111/ 01/2 Payment $76,77 $302. $385 $202.7 $577. $890.57 00 $0 2005 005 . 5.95 39 .39 9 56 12/07/ 12/2 Payment $77,07 $300. $386 $200.3 $374. $888.09 00 $0 2004 004 . 8.34 88 .90 1 77 11/05/ 11/2 Repay Of Esc $77 37 $0.0$25.85 $174. $0 $0.00 00 $0 00 2004 004 Advance . 0 - . 9 22 46 11/05/ 11/2 Payment 09 $77,37 $299. $388 $200.3 $25.8 $200. $888 2004 004 . 9.22 39 .39 1 5 31 11/02/ 11/2 Escrow $77,67 $0.0 $25.8 $25.85 $0 00 $25 85 $0 00 2004 004 Advance 0 5 . . . 8'61 11/02/ 11/2 Homeowners $586.00 $77,67 $0.0$586.0 $25.8 00 $0 00 $0 2004 004 Ins Disb . 0 0- . 5- - 8.61 10/11/ 10/2 Payment $888.09 $77,67 $297. $389 $200.3 $0 00 $560. 2004 004 . 8.61 90 .88 1 15 09/07/ 09/2 Payment 09 $77,97 $296. $391$200.3 $0 00 $359. $888 2004 004 . . 6.51 42 .36 1 84 08/12/ 08/2 School Tax $1,229. $78,27 $0.0$1,229 $159. 00 00 $0 $0 2004 004 Disbursement ' . 35- 2.93 0 .35- 53 08/061 08/2 Payment $888.09 $78'27 $294• $392$200.3 $0 00 $1,38 2004 004 . 2.93 94 .84 1 8.88 07/06/ 07/2 Payment $888.09 $78'56 $293. $394$200.3 $0 00 $1,18 2004 004 . 7.87 47 .31 1 8.57 05/28/ 06/2 Payment $888.09 $78,86 $292. $395 $200.3 $0 00 $988. 2004 004 . 1.34 01 .77 1 26 CapAW a 2000, M. FW-y I1fOR1YtlOfl ft'W , W. AN Rfs RnWvo . nMUSHM= LENDER MARITAL PROPERTY Plaintiff. lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced Item Number 4 Item Number 5 Item Number 6 ption of Property of All Owners various personal property of Acquisition ost or Value as of ate of Acquisition as of Separation alue 30 Days Prior to earing pulated between rties ount of anny Lien Mutual of America Pension Gregory S. Haines $28,602.46 pension Rebecca A. Haines orm of Attached ocumentation list of items Quarterly Statement omments further documentatim to be provided by opposing ply Inventory of Contents for Gregory Haines at 2711 Logan Street Ship Pilswer Glass Martini Glass From Badens Wooden Tool Carriers from top of Hutch Wooden Tool Box's Old Frame and Art From My Mother in Dining Room Photo of Mom and Dad Haines Brass and Iron Bed 2 Photos of DJ in closet (Peewee Football) Locking Pliers Jag Saw Blades-Hammer and Drywall Saw in Closet Wood Shims in Closet Other Pocket Knives (Blade From my Father) Lead Crystal Wine Glasses 7 Foot Step Ladder Mantas with Accessories All Golf Clubs True Value Garden Rake Flat Edge Hoes Blue Hoe Axe Lawn Spreader True Value Spade Sears Tent Plastic Drop cloth's Blue Tarps Jack Stands Metal Step Ladder in Garage Car Care Kit in Black Case Metal Sign Stakes Lawn Spreader Plastic Grain Shovel Tackle Box Shop Vacuum Electric Drill Pipe Wrenches 3 Paint Rollers 2 Paint Pans 2 Four Foot Levels All Screw Drivers All Wrenches including adjustable and locking pliers Bar Clamps Wood Chisels Router, Table and Bits Cordless Drill, Case and Batteries All Drill Bits Dremel Tool and Accessory case Needle Nose Pliers, Slip Joint Pliers, Lineman's Pliers, and Jewelers Pliers Allen Wrenches Compound Miter Saw Hand Saws Mouse Sander Work Bench Table Saw Hand Held Circular Saw Coleman Lantern Propane Stove All Halogen Work Lights Wood Shims Dust Mask with Filters Wooden Clamps Roto Zip Saw Hedgehog Trimmers All Bungee Cords All Electrical Testers All Drywall Tools and Scrapers Red Tool Box including sockets, ratchets, wrenches, etc... Fishing Rods Bamboo Fly Rods All Reels Pry Bars Torpedo Levels Grinder Wooden Box of Fasteners Cock Gun Sharpening Stones Chicago Cutlery Lock Blade on Bench Jigsaw Yellow Handled Rivet Gun Tin Snips Pipe Cutters Jack Planes Orbital Sander Tape Measures Rasp and Files Chalk Line with Chalk Jig Saw blades Wood Chisels Yellow Box of Fasteners Airless Paint Sprayer Heat Guns Deck Lantern Spring Clamps Carpenter Square Propane Torch Walnut Cabinet with Doors and Hardware Snake Flashlight Number and Letter Punch Set Hammers Hunting Knife in Work Area Drywall Sander Christmas Tree Ornaments from my parents (Can Wait till Christmas) Green and Pink Igloo Cooler 100 Foot extension Cord State Quarters to Hold for Children with Wooden Box The Old Can Cooler All Brown Glasses Hinkle Cleaver Title to Volvo 850 Pint Glasses Coffee Press Flask with leather case Looney Toons Glasses Old Martini Glasses (From my Grandmother's Bar) All of the Ridgeway Brown China from my Grandmother Hinkle Stake Knives Martini Glass that Was gift from Badens Martini Pitcher Red Wine Glasses The Cut Martini Glasses from my Grandmother's Bar Pewter Flask that was gift from brother Sterling Silver Utensil set with Wooden case that was gift from my parents Large Wearever Skillet Marlboro Cookbook How to Grill Cookbook Black Lab Glasses MUTUAL OF AMERICA Quarterly Statement 12/31/2003 - 3/31/2004 Questions? Contact: Patrick J. Byrne Blue Bell Executive Campus 470 Norristown Road, Suite 301 Blue Bell, PA 19422 (610) 834-1754 -or- Customer Service (800) 468- Gregory S. Haines 2711 Logan St Z-?-' Camp Hill PA 17011-2944 Iv_ Balance Summary Plan Type Employer Plan; Closing Dollar Balance Flexible Annuity Plan 050175-J-03 28,602.46 Total $28,602.46 Fl xiblb Annuity Pien Employer Number: 050175-J-03 Employer: The Arthritis Foundation Central Pennsylvania Chapter Plan Summary Allocation of Future Contributions Description Dollar Balance Description Allocation%a Opening Balance 28,399.00 Administrative Charges 6.00- Investment Earnings 209.46 Closing Balance $28,602.46 General Account Activity General Account 100% Date Description Dollar Amount 12/31/03 Opening Balance - Employer 28,399.00 01/31/04 Administrative Charge 2.00- 02/29/04 Administrative Charge 2.00- - - „?_:_:_?..._ .+?.....,. 2.00 Page 1 (statement continued on next page) PN 45 QS 0038158 ?? ?naianun?ni?i?IngllululnllKIINNINInI?II? MUTUAL OF AMERICA Date Description Dollar Amount 03/31/04 Investment Earnings 209.46 03/31/04 Closing Balance - Employer 28,602.46 Closing Balance $28,602.46 The effective annual yield on amounts allocated to the General Account under this plan is currently 3.009/6. Interest is compounded daily to produce the stated effective annual yield. Availability of amounts reported above are subject to the vesting provisions of your employer's plan. For more details, refer to your Summary Plan Description or call us at the numbers listed on page one. Please refer to Separate Account No. 1 Performance Data Insert. Mutual of America We Insurance Company is exempt from requirements to be a member of the Securities Investor Protection Corporation. Thank you for using Mutual of America's services. www.mutualofamerica.com Quarterly Statement 12/31/2003 - 3/31/2004 Page 2 IN PN 45 QS 0038159 a IIII{?NII?III?IIIIN?NN ? ?{{{III{?INI?INN LIABILITIES OF THE PARTIES Plainti.ffI marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. ( x) 1. Mortgages/Home Equity Loan ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other Liabilities ( x) 5. Credit Card Balances ( ) 6. Purchases ( ) 7. Loan Payments ( ) 8. Note Payable ( ) 9. Other Liabilities Contingent or Deferred: 10. Contracts or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other Liabilities LIABILITIES Plaintif lists all liabilities of either or both spouses alone or with any person as of the date this action was commenced Item Number 1 Item Number'. 2 Item Number 3 National City Nbrtg. Americhoice Acct various credit card Description of Liability Acct 4339397083 6040300003036953 debts Names of All Creditors or Gregory S. Haines Gregory S. Haines Gregory S. Haines Debtors Rebecca A. Haines Rebecca A. Haines Rebecca A. Haines Date Liability was Incurred Amount of Liability When Incurred Amount Due as of Separation 80,408.00 46,174.00 Current Amount Due Pate Balance is Due ayment Date and mount CERTIFICATE OF SERVICE I hereb certify that on this date a copy of the foregoing Inventory and Appraisement was served on :. ; Wenda ?oOjnsel in the manner indicated below: First Class Mail addressed as follows: Jordan D. Cmdngbam, Esquire 2320 North Second Street Harrisburg, PA 17110 Date: BY: Jane M. Alexander, Esquire Attorney for • Plaintiff ID #07355 148 S. Baltimore Street Dillsburg, PA 17019 Phone (717) 432-4514 r-a ? } . c:"' --? Cl7 `ij -ri ? • : , r,-? ?.:, ?T ? ? ? . 'YJ -?-?1 i ?. _ ? t ?? `?? ( -} ? ? _ M ?? y ? `. ? tyY C' y .^{ w ?? rv,4 .00 SEP 2 g 2006 d- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY S. HAINES. : CIVIL ACTION - LAW Plaintiff VS. : IN DIVORCE REBECCA A. RAINES, No. 04 ?- 1276 Defendant MOTION FOR APPOINTMENT OF MASTER Gregor- S. Haines, Plaintiff, moves the court to appoint a master with respect to the following claims: (X) Divorce ( X) Distribution of Proper ( ) Annulment ( } Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims for which the appointment of a master is requested (2) The defendant has appeared in the action by his attorney, Jordan D. Cunning,,.m. Esquire. (3) The statutory ground`s) for divorce is Section 3301(c) no fault. - (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reaehed with fespee4 the following (c) The action is contested with respect to the following claims: Distribution of Property (s) The action does not involve complex issues of law or fact. (G) The hearing is expected to take one (1) day. (7) Additional information, if any, relevant to the motion: Date: r for AND NOW. b a6ao Esquire, is appointed master ith respect to the following claims: L?L,Q? ???? ,,G???'? ?,' '' 3 3 , I } MOVING PARTY NON-MOVING PARTY Gregory S. Haines Rebecca A. Haines Jane M. Alexander, Esquire Jordan D. Cunningham; Esquire 148 S. Baltimore Street 2320 N. Second Street Dillsburg, PA 17019 Harrisburg, PA 17110 (717) 432-4514 (717) 238-6570 ? ? h ' .i `i`i . ` ?, _ . __, ? -? _ ' _ r i.` _ --r3 w. _ i'?,i - ;w ?? d °'1ri y V SEP 2 6 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY S. HAMS. Plaintiff VS. REBECCA A. HAINES, Defendant CIVIL ACTION - LAW IN DIVORCE No. 04 $ 1276 MOTION FOR APPOINTMENT OF MASTER Gregory- S. Haines, Plaintiff, moves the court to appoint a master with respect to the following claims: ( X ) Divorce ( X } Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery- is complete as to the claims for which the appointment of a master is requested (2) The defendant has appeared in the action by his attorney, Jordan D. CunningLrnm. Esquire. (3) The statutory ground's) for divorce is Section 3301(c) no fault. - (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) A n nt has been `shed ' ';ti. .-pec4 to the f ile lv7 s :.z agreement (c) The action is contested with respect to the following claims: Distribution of Property (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one (1) day. (7) Additional information, if any, relevant to the motion: Date: r for ?o AND NOW, a ilh-1w /I /J 0? Esquire, is appointed master ith respect to the following claims: 90 - old 6Z 81S 90OZ ,.ff17i GREGORY S. RAINES, Plaintiff/Petitioner VS. REBECCA A. HAINES, Defendant/Respondent : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA NO. 04-1276 : CIVIL. ACTION - LAW : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, TO WIT, this ?3ts? day of 2007 comes the Plaintiff/Petitioner, Gregory S. Haines, by and through his attorney, Jane M. Alexander, Esquire, and files this Petition for Modification of Custody Order upon a cause of action of which the following is a statement: 1. Plaintiff/Petitioner is Gregory S. Haines, an adult individual, who currently resides at 2917 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant/Respondent is Rebecca A. Haines, an adult individual, who currently resides at Dickinson Street, Camp Hill, Cumberland County, Pennsylvania, continue to receive mail at 2711 Logan Street, Camp Hill, PA 17011. 3. Plaintiff and Defendant are the natural parents of two (2) children: David J. Haines, age 17, born March 20, 1989, and Alexander M. Haines, age 12, born December 16, 1994. 4. On August 2, 2006 an order of court signed by Judge Oler was entered in the above-captioned matter and is marked Exhibit "A" and is attached hereto and made a part hereof. 5. The Order of Court confirmed the Agreement and Stipulation of Custody signed by the parties and dated June 16, 2006 as an order of court. 6. The agreed upon custody agreement provided that the parties would share legal custody and the Mother would have primary physical custody with Father having custody for purpose of visitation on a regular schedule. 6. Petitioner seeks to modify said Order of Court to secure majority physical custody for the following reasons: a) On or about December 11, 2006 Mother left the residence and went to secluded area and attempted to commit suicide. b) Mother was hospitalized, so Petitioner went to the residence at 2711 Logan Street, Camp Hill, to remove the children and found the premises to be in a grossly unsanitary condition and conditions that created a major threat to the children's health and lives. c) The children were very upset and disturbed by the events. d) The children continue to attend their same schools and live with Father. e) They are doing well in school and have overcome their stress. f) Both children have voiced a desire to continue to live with Father and have visitation with Mother. g) The property at 2711 Logan Street, Camp Hill, Pennsylvania has been cleaned up and is sold, settlement to be in February. h) Mother, as of this date has no permanent residence. i) The change of primary custody is in the best interests of the children. 7. The best interests and permanent welfare of the children will be served by granting Plaintiff/Petitioner, majority physical custody subject to Plaintiff right of partial physical custody. 8. Petitioner has and can continue to give both children a stable, home with a clean healthy environment. WHEREFORE, Petitioner respectfully requests your Honorable Court to amend the existing Order by granting him joint legal custody and primary physical custody of the subject children with Respondent having scheduled visitation. Jane M. Alex der, Esquire Attorney for ;ai ntiff/Petiti Attorney I.D. #07355 148 S. Baltimore Street Dillsburg, PA 17019-0421 (7I7) 432-4514 VERIFICATION I verify that the statements made in this Petition for Modification of Custody Order 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. DATE: O %J200 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK S.S. Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Gregory S. Haines who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his Sworn to and subscribed before me this at S r day of 2007 Notary Public Gregory/,SJ,Haines COMMONWEALTH OF PENNSYLVANIA Notarial Seal Narumol Alexander, Notary Public D7lsburg Boro, York County My Commission Expires Apr. 7, 2010 Member, Pennsylvania Association of Notaries tion and belief. I s P11.3 ? D C GREGORY S. HAINES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. REBECCA W. HAINES DEFENDANT 04-1276 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, February 16, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 15, 2007 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunday, Esq. jk Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ',,I .C 148 OZ 83.E LOOZ A Sandra L. Imhoff e__Insurance Group-__-___-__ vs. In the Court of Common Pleas of Cumberland County, Pennsylvania ____As se -t s_ _I2 ecove ry__S olu t ion s Judgment in favor of Plaintiff on __Eabx_Uar_y__4_,._ 2004 Donne l-1-- -------------------------------- for $_i,}iL6.30 ---------------P-r--i - c -- e ----------------- - -?`'T -- - No. _UT7 _ ___ QiXi l___ Term, 1.2QD-4 --- Entered ______________ kla.rch_.25 -------- 19a2_QD_4 -I --------------------------------------------------------------- Plaintiff in the above- Judgment, do appear and acknowledge tl:at this day have had and received and from _As?t_Bac?v?r_y__Snlutio?s_-_?24t71?e141__P_ra.??----------------------------------- the de:endant in the above Judi n^rt, full payment and saisfaction of the sarne, with interest and costs, and desired that satisfaction therefore shall be entered upon the records thereof. And further, I do hereby authorize and empower _-___?urtls_R.__I?nltg-------------------------- -------------------- theProthonotary of said Court, to appear ----__ f 4 r - m e ________________________------ and in my name and stead to enter full satisfaction upon the record of said judgment, as fully and effectually, to all intents and purposes, as I , could were I personally present in person to do so. And for so doing this shall be your sufficient warrant of authority. In testimony whereof, we have hereunto set our hands and seals this _-_.11-t.b`--------------------------- day of --------- F e lr ArX------------------------, - --....ter..... NOTARIAL SEAL (Seal) DEBORAH L. LINCYWILTER, fir,'mry f614: - - - ----------------------------- - I? ' 0 MaaI iftbum OWO, oxftft :nd Cc; a;ty r i.s_>` atxexs_-------- 1iIhrGC.7l1!`iS9fJgEcL+fiB^ - --------------- (Seal) Branch Claims Supervisor State of Pennsylvania - ------------------------------------------ (Seal) County of Cumberland, i Personally appeared before me, the subscriber, ____-___._____________________________________________________ ------------------------------------------------------------------------------------------------------ •---------------------------------------------------------------------------------------- ----------------- •---------------------------------------------------------------------------------------- the Plaintiff in the above judgment, and in due form of law acknowledged the within and foregoing Power of Attorney to satisfy the Judi ment sei forth, to be act and deed, and desired that th;. same shall be filed of record in the office of the Prothon- otary of the Court of Common Pleas of said County. In testimony whereof, I have hereunto set my hand and seal this ------------------------------------------- day of ---------------------------------------------- A. D. 19------- ---------------------------------------------- (Seal) rri c? c Cr c POWER OF ATTORNEY TO SATISFY JUDGEMENT I (We), Sandra L. Imhoff , do hereby appoint, authorize and empower Erie Insurance Exchange to appear and in my (our) name stead to acknowledge receipt of full satisfaction of any judgment(s) obtained on my (our) behalf against Assets Recovery Solutions and to enter full satisfaction of such judgment on the records of any Court, as fully and effectively, to all intents and purposes as I (we) could were I (we) present in person to do so. With intent to b/e legally bound, I (we) set my (our) hand(s) and seal(s) this _ °?q fA day of 0P.?? , 20 63 . WITNESS: (?1QJ x (SEAL) (Signature of Poli holder) L/ I STATE OF : SS: COUNTY OF: Personally appeared before me, the subscriber(s): and in due form of law acknowledged wili? and foregoing Power of Attorney to acknowledge and satisfy any judgment set forth therein, to be his(her) (their) act and deed, and desired that the same shall be filed of record in any Court. IN WITNESS WHEREOF, I have set my hand and seal this ? day of LQA12 204,3 NOTARY Norann M. Kauffman, Notary Public SuspuehannaTwp., Dauphin County My Commission Expires July 20, 2006 Member, Pennsylvania Association Of Notaries JORDAN D. CUNNINGHAM, ESQUIRE CUNNINGHAM& CHERNICOFF, P.C. 2320 NORTH SECOND STREET HARRISBURG, PA 17110 TELEPHONE: (717) 238-6570 FACSIMILE (717) 238-4809 EMAIL: JCUNNINGHAM &-CCt,AWPC.COM GREGORY S. HAINES, Plaintiff V. REBECCA A. HAINES, . Defendant . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 04-1276 CIVIL ACTION LAW IN CUSTODY RESPONSE TO PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, this I day of March, 2007, comes the Defendant/Respondent, Rebecca A. Haines, by and through her counsel, Cunningham & Chernicoff, P.C., and files this Response to Petition for Modification of Custody Order and in support there of makes the following statement: 1. Admitted. 1 2. Admitted. By way of further pleading, Defendant/Respondent is residing at 2420 Dixon Avenue, Camp Hill, Cumberland County, Pennsylvania and the Plaintiff/Petitioner has been aware of this address and Defendant/Respondent's contact number for several weeks and has dropped Alex off at the address on more than one (1) occasion. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. (6.)(sic) The averments of Paragraph 6 (sic) are partially admitted and partially denied. Defendant/Respondent will address each of the allegations contained in Paragraph 6 (sic) in a seriatim fashion as follows: a. The averments of Paragraph (a) are admitted. By way of further pleading, such action was as the result of Defendant/Respondent's breakdown facilitated by Plaintiff/Petitioner's constant harassment and the legal and mental health issues associated with the parties' minor child, David Haines. b. The averments of Paragraph (b) are denied. The children were not at the residence at 2711 Logan Street, Camp Hill, Pennsylvania from Friday evening, December 8, 2006 through Sunday, December 10, 2006. To the contrary, the children were at their father's residence at 2917 Chestnut Street, Camp Hill, Pennsylvania for their scheduled visitation. The children were due to be returned by the Plaintiff/Petitioner to the 2 Defendant/Respondent's residence Sunday evening, December 10, 2006 at 6:00 p.m. as per the Court Order. If the intent of the pleading is to reflect that the Plaintiff/Petitioner dropped the children off early on December 10, 2006, then, in that event, he failed to make any attempt to contact the Defendant/Respondent or to make arrangements for their safety. By way of further pleading, it was the intent of the Defendant/Respondent that she took the action she did at a time when the children were to be in a safe location and where the children would not be the ones to find her. Additionally, the Defendant/Respondent was found by 2:00 p.m. in the afternoon and Plaintiff/Petitioner was contacted by the Camp Hill Police prior to 6:00 p.m., a time when the children should have been in his custody. Defendant/Respondent denies that the premises were in a grossly unsanitary condition. It is admitted that the Defendant/Respondent had been lax in dusting, vacuuming, and cleaning dishes prior to her hospitalization, however, she made a conscientious effort and did assure that the children were fed, had clean clothing and completed their school and homework assignments. During the period prior to December 11, 2006, the children neither missed a day of school nor did the Defendant/Respondent miss a day of work. 3 As concerns the conditions which created a major threat to the children's health and lives, it is assumed that Plaintiff/Petitioner is alleging that the hot water heater in the basement was leaking both water and natural gas and that the Defendant/Respondent had intentionally ignored the situation, putting the children at risk. Defendant/Respondent was aware that the hot water heater would need to be replaced, however, she was not aware it was leaking natural gas. Defendant/Respondent had not been in the basement for a long period of time as the dryer was not working and she was taking laundry outside the home to launder. The basement door was normally kept closed and, with the door closed, neither Defendant/Respondent or the children could smell any odor indicating a natural gas leak being present in the home. Defendant/Respondent never had carbon monoxide detectors installed in the home and neither did the Plaintiff/Petitioner during the seven (7) prior years he resided in the home. In the spring of 2004, after Plaintiff/Petitioner's departure from the home, Defendant/Respondent advised Plaintiff/Petitioner that she had been advised by UGI that the hot water heater would need replaced. Plaintiff/Petitioner, even though asked for assistance by the Defendant/Respondent in the payment for a new hot water heater, refused. 4 It is admitted that the children were upset and disturbed by events, however, Plaintiff/Petitioner used this opportunity to relay to the children that the Defendant/Respondent "tried to whack herself." Moreover, Plaintiff/Petitioner also immediately brought the children to the hospital and exposed them to Defendant/Respondent's condition. Plaintiff/Petitioner returned to the hospital the following day with the parties' 11 year old son and the 11 year old son's friend, Drew. While Defendant/Respondent's sister advised Plaintiff/Petitioner that the situation was too disturbing for the children, Plaintiff/Petitioner advised Defendant/Respondent's sister that he was Alex's father and would make all decisions regarding his children. d. The averments of Paragraph (d) are denied. While the youngest child, Alex, continues to attend Camp Hill Middle School, David has resided at Brooke Glen Behavioral Hospital in Fort Washington, Pennsylvania since February 8, 2007. David has been diagnosed with bipolar, ADHD and borderline personality disorder. David was involved in an altercation at his school and was approached by a juvenile probation officer, Gail Shughart. Ms. Shughart advised David he would be receiving punishment for his actions. David, in response, became very agitated and stabbed himself in the chest with a letter opener. Subsequently, after being subdued by a number of police officers, David was transported to Harrisburg Hospital. During his transportation to the hospital, Ms. Shughart contact the Defendant/Respondent and advised her of the situation. Upon Defendant/Respondent's arrival at Harrisburg Hospital, she was advised by Ms. Shughart she had remanded custody of David to Plaintiff/Petitioner upon his arrival and, while Plaintiff/Petitioner was out of the room, David absconded from the hospital. David was found the following morning when he was taken back to Harrisburg Hospital where he was placed under a 302 Commitment. On February 20, 2007, David was released from the Brooke Glen facility and remanded into the custody of Cumberland County Juvenile Probation Office, where he was placed in the South Mountain Detention Facility. The averments of Paragraph (e) are denied. As previously stated, David is not currently in school and is suffering under incredible stress. As concerns the parties younger son, Alex, Alex's grades dropped during the time he has been living with his father. While Defendant/Respondent acknowledges some of the drop could be attributed to the stress created by Defendant/Respondent's actions, Alex has advised Defendant/Respondent he is not receiving assistance and instruction with his homework as he was receiving while he was residing with the Defendant/Respondent. Alex's performance at school has dropped from being on the honor roll while in the residence of Defendant/Respondent to a 71 % GPA in the second quarter of the year while residing with the Plaintiff/Petitioner. 6 f. The averments of Paragraph (f) are denied. David will turn 18 years of age on March 20, 2007 and is currently incarcerated. Defendant/Respondent has discussed with Alex the potential of moving with her to the new residence for which she has signed a lease. Alex has expressed that he would like things like they were previously prior to the episode experienced by his mother. Alex has indicated an interest in spending a weeknight with his father. g. The averments of Paragraph (g) are admitted. Settlement is now scheduled for March 15, 2007. h. The averment of Paragraph (h) is denied. To the contrary, it is admitted that the Defendant/Respondent has not been living at the residence located at 2711 Logan Street since her release from hospital care. The decision not to reside in the residence was part of an overall care therapy. Defendant/Respondent has been residing at the residence of a friend at 2420 Dixon Avenue, Camp Hill, Pennsylvania. Plaintiff/Petitioner has been aware of this address together with contact information and has dropped Alex, the parties' younger son, at the address for visitation on more than one occasion. By way of further pleading, Defendant/Respondent has leased an apartment located at 15 South 30`n Street, Camp Hill, PA. Defendant/Respondent takes possession of the property effective March 1, 2007 and will physically move into the property on March 11, 2007. 7 i. The averments of Paragraph (i) are denied. Defendant/Respondent do not believe the children's best interests are served by having primary custody placed with Plaintiff/Petitioner. Both David and Alex have expressed to the Defendant/Respondent and, at least in the case of David, to psychological professionals, that his father on various occasions has exhibited a volatile temper and has subjected the children to verbal and physical abuse. Defendant/Respondent has also been advised that Susan Burruss, Plaintiff/Petitioner's significant other, has, in the past, suffered emotional illness and questions her ability to provide a balanced and stable environment in which to raise the children. 8. (7.)(sic) The averments of Paragraph 7 (sic) are denied for the reasons set forth above. By way of further pleading, Defendant/Respondent has received both psychological and psychiatric care and has now stabilized her situation to the extent that she no longer represents a danger to herself or to her minor children. 9. (8.)(sic) The averments of Paragraph 8 (sic) represent a conclusion of fact to which a response is not required. WHEREFORE, Defendant/Respondent, Rebecca A. Haines, respectfully request your Honorable Court to deny Plaintiff/Petitioner's Motion for Modification of Custody Order. Respectfully submitted, CUNNINGHAM & CI-JERNICOFF, P.C. Dated: March _i , 2007 By: Tordan Pl. Cunningham, Esquire PA I.D. No. 23144 2320 North Second Street Harrisburg, PA 17110 Telephone: (717) 238-6570 Attorneys for Defendant/Respondent F:\Home\AHEWITT\DOCS\G-I\HAINES\CUSTODY\RESPONSE TO PETITION.wpd 9 CERTIFICATE OF SERVICE I do hereby state that on the 1 day of March, 2007, I served a true and correct copy of the foregoing in the captioned matter, by placing the same in the United States mail, first-class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Jane M. Alexander, Esquire 148 Baltimore Street P.O. Box 421 Dillsburg, PA 17019 e . ewitt Legal Secretary y a Olt; <? N ? 4 -W. GREGORY S. HAINES, Plaintiff VS. REBECCA A. HAINES Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 04-1276 CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE AND NOW, this ? 44% day of P e,,6 av, 61 , 2007 personally appeared Jane M. Alexander, Esquire who swears according to law, t at a true and correct copy of a COMPLAINT IN CUSTODY was caused to be served by certified, restricted mail with return receipt requested upon the said, REBECCA A. HAINES 2711 LOGAN STREET CAMP HILL, PA 17011 On February 14, 2007 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. Sworn and subscribed before Me this day of 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Narumol Alexander, Notary Public Dillsburg Boro, York County My Commission Expires Apr. 7, 2010 Momael , F't.nrlwlva,ri;:z Association of Notaries e IVI. Alexande , Esquire ttorney I.D. #0 55 48 S. Baltimore Street /((7117) illsburg, PA 17019-0421 432-4514 GREGORY S. HAINES, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA VS. NO. 04-1276 REBECCA A. HAINES CIVIL ACTION - LAW Defendant IN CUSTODY PROOF OF SERVICE CERTIFIED 1 Q. (Domestic For delivery informatio n visit our website c at www us s om -0 L, ??? U . . p M - -a Postage $ \?' j m0 CaftedFee • Q? ?U}y. lo C 3 Return Redept Fee (Endorsement Required) ft Here lift u7 Ln Restricted Delivery Fee (Endorsement Required) . M Total Postage & Fees $ g 1 ?2- C3 Sent To A ? C3 . (rtrit? Y12 Q? orPOSoxNo a 7 (t L-4 - -'--- ' male.7JP ........... --•--- ...... (( Pik - -- - ------- t-1o t --------------- ¦ Comple item 1, 2, and 3. Aso complete a st store Kern 4 If Restricted Delivery Is desired. ¦ Prhrt the reverse *PQt x Q - Z?LI C] YOU. by (Nnted J) Dabs of ¦,Attad? the mai?iece, Mem `Cdoeft D. to delvery address dUbrent hom nwXi? ? Yea t 1. ArticlB%ddiessed to:- d YES, enter delivery address beld? 0.__ O 'a 71H /? 3. SenAoe Type Q Q i PA 1-70(( ?*d Mal ? forMatchandiea 1 0 InRegWered ured Mal y0°?C.O..D. 4. Restricted Delvery4 (Extra Fee) 2' Arlob (1lnaltm .rwa. A?bo 7M-Qw-0i 13 0003 6356 4945 wafarb Aoe? PS Forth 3811, February 2004 Dorn@Wc FkUn Aeoaipt ?ateaae?a2 law ; `-? ?n ?? G?s 1... .?..., ....? ? ? 1 S T r ? ., .%:J ? ,,5r,, ..? ?? o ? -t W ,.? V ,r ; `? ;i? r? ? .?.. ?? ? ...y r a MAR $ 6 2007 WJ GREGORY S. HAINES Plaintiff vs. REBECCA W. HAINES Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1276 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this day of m, LL. , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated August 2, 2006, incorporating the terms of the parties' Custody Stipulation dated June 16, 2006, is suspended and replaced with this Order pending further Order of Court or agreement of the parties. 2. The parties shall make arrangements for Alexander to participate in counseling with Sally Rooney. Both parents shall contact the counselor to provide information or make themselves available to meet with the counselor, as determined to be appropriate by Sally Rooney. The Father shall be responsible to schedule the Child's sessions with the counselor. The purpose of the counseling shall be to address the Child's needs with regard to the ongoing family conflict and recent events affecting the family and to provide insight and guidance to the parties as to the Child's needs with regard to custodial time with both parents. The parties shall equally share any costs of counseling which are not covered by insurance. Both parties agree to sign any authorizations deemed necessary by Sally Rooney to enable her to provide information to the conciliator. 3. The Father, Gregory S. Haines, and the Mother, Rebecca W. Haines, shall have shared legal custody of Alexander M. Haines, born December 16, 1994. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well being including, but not limited to, all decisions regarding his health, education and religion. Each parent shall be entitled to have equal access to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 4. Pending further Order of Court or agreement of the parties, the Father shall have primary physical custody of the Child. 5. The Mother shall have partial physical custody of the Child on alternating weekends, beginning Friday, March 16, 2007, from after school on Friday through Sunday at 6:00 p.m. In addition, the Mother shall have custody of the Child every week on Tuesdays and Thursdays from after school until 8:00 p.m. and at any additional times as arranged by agreement between the parties. Al v v Vr-, N NAd 80 :C Wd LZ RW LOQZ 31? JO N 6. The Mother shall have custody of the Child on Easter weekend from Saturday at 3:00 p.m. through Sunday at 12:30 p.m. 7. In accordance with their sharing of legal custody of the Child, the parties shall consult with each other and make arrangements for enrolling the Child in activities including summer camps by agreement. The parties shall exchange information pertaining to the Child's activities/camps on a timely and ongoing basis. 8. The parties and counsel shall attend an additional custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on Tuesday, May 29, 2007, at 9:00 a.m. for the purpose of reviewing the custody arrangements following the counseling provided in this Order. 9. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. 10. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc: Jane M. Alexander, Esquire - Counsel for Father Jordan D. Cunningham, Esquire - Counsel for Mother 3- d 7.6-7 BY THE COURT, i ? GREGORY S. HAINES Plaintiff VS. REBECCA W. HAINES Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1276 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexander M. Haines December 16, 1994 Father 2. A custody conciliation conference was held on March 15, 2007, with the following individuals in attendance: the Father, Gregory S. Haines, with his counsel, Jane M. Alexander, Esquire, and the Mother, Rebecca W. Haines, with her counsel, Jordan D. Cunningham, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 0 0:7 i Date Dawn S. Sunday, Esquire Custody Conciliator GREGORY S. HAINES, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA. VS. NO. 04-1276 Civil Term REBECCA A. HAINES, CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 25, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Date: -rain C-- Mr- 72, jr. r^ `a ?? GREGORY S. HAINES, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA. VS. NO. 04-1276 Civil Term REBECCA A. HAINES, CIVIL ACTION-LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: ° -re try rr•. -= G ? Fn D " C7 FILE No. 872 06/01 '07 10:05 I D : ALEXANDER LAW OFFICE FAX:5021487 GREGORY S. HAINES, VS. REBECCA A. HAINES, PAGE 2 IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA. Plaintiff N V. U4_1 A to l ivla a erg[! CIVIL ACTION-LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 4 3301(c) of the Divorce Code was filed on March 2S, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service; of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 1 verify that the statements made in the Affidavit are true and correct. 1 understand that false statements herein are made sukJoct to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: q!2:7 (2. C? ?- Rebecca A. Haines a -IrA FILE No.872 06/01 '07 10:05 ID:ALEXANDER LAW OFFICE FAX:5021087 GREGORY S. HAINES, V8. REBECCA A. HAINES, PAGE 3 IN THE COURT OF COMMON PLEAS OF Ci1MBERLAND COUNTY, PA. NO. 04-1276 Civil Term CIVIL ACTION-LAW IN DIVORCE Plaintiff Defendant WAIVED OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE. SECTION 3301(0) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3. 1 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 verily that the statements made in this affidavit, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 01,6i 1,e) 610'..7 Q_ 41? ?? Cam[ - ? & a,_ _(" _-.1 ?? ? 9 --L Rebecca A. Haines o i oy- 1a7(0 a?,ite-.- Post-Nu tial A reement THIS POST-NUPTIAL AGREEMENT, made this day of (A -r-- , 2007 by and between GREGORY S. HAINES, of 2917 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "HUSBAND") and REBECCA A. HAINES, of 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "WIFE".) WITNESSETH WHEREAS, HUSBAND and WIFE were lawfully married on May 4, 1985, in Windber Somerset County, Pennsylvania, WHEREAS, two children have been born of this marriage, to wit, David J. Haines, born March 20, 1989, and Alexander M. Haines, born December 16, 1995; and WHEREAS, differences have arisen between HUSBAND and WIFE inconsequence of which they are living separate and apart from each other; and WHEREAS, HUSBAND has entered suit for absolute divorce from WIFE on March 25, 2004 to No. 04-1276; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of personal property, and in general, the settling of any and all claims and possible claims by one against the other or against the respective estates. -1- NOW, THEREFORE, for and in consideration of these premises, and of the mutual promises, covenants, and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency 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. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to HUSBAND by his counsel, Jane M. Alexander, Esquire and to WIFE by her counsel, Jordan D. Cunningham, Esquire. Each party acknowledges that he or she has had the opportunity to receive independent legal counsel of his or her selection and that each fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and that execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. In addition, each party hereby acknowledges that he or she is aware of the impact of the Pennsylvania Divorce Code, 23 Pa.C.S.A. 3101 et. Seq., whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendent elite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, and being fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties and waives his or her respective right to have the Court of Common Pleas of Cumberland County, or any other -2- court of competent jurisdiction, make any determination or order effecting the respective parties' right to alimony, alimony pendent elite, equitable distribution of all marital property, counsel fees and costs of litigation, or any other right arising from the parties' marriage. II. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she is aware of his or her rights to engage in discovery, including but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure and each of the parties specifically waives his or her right to engage in such discovery. Each of the parties further acknowledges that he or she is aware of, and specifically waives, his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The respective parties do hereby acknowledge, recognize and accept that there has been full and fair disclosure to the other of his or her income, assets and liabilities, and each party agrees that any right to further disclosures, valuation, enumeration or statement thereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. The parties hereby acknowledge and agree that division of the marital assets as set forth in this Agreement is considered fair, reasonable and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that -3- there was a denial of any rights to full disclosure, or that there was any duress, unduinfluence, or that there was a failure to have available full, proper and independent representation by legal counsel. III. PERSONAL RIGHTS. HUSBAND and WIFE may, at tall times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other in all respects as fully as if he or she were unmarried. Each party may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. This provision shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness of the cause which led to, or resulted in, the continuation of their living apart. HUSBAND and WIFE shall not molest, harass or disturb each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. IV. MUTUAL CONSENT DIVORCE. The parties acknowledge that on March 25, 2004 HUSBAND initiated an action in divorce by filing a complaint in the Cumberland County Court of Common Pleas at No. 04-1276 which raised, inter alia, a claim for divorce under Section 3301(c) of the Divorce Code. It is the intention of the parties that by the execution of this Agreement they have satisfactorily resolved between them all economic claims raised by either of them in the pending divorce action. The parties further acknowledge that more than ninety (90) days have passed since the divorce complaint was -4- filed and served upon WIFE. WIFE agrees that she will sign and file an Affidavit of Consent to the divorce and agrees to execute a Waiver of Notice of Intention to Request Entry of Divorce Decree. Likewise, HUSBAND agrees that he will sign and file and Affidavit of Consent and a Waiver of Notice of Intention to Request Entry of Divorce Decree. HUSBAND's counsel shall file a Praecipe to Transmit Record, Vital Statistic s from and any other documents necessary to precipitate entry of the mutual consent no-fault divorce decree. V. EQUITABLE DISTRIBUTION. a) Real Estate. The real estate situate at 2711 Logan Street, Camp Hill, Cumberland County, Pennsylvania, 17011, title to which was vested in HUSBAND and WIFE, as tenants by the entireties, was sold on April 23, 2007 for $179,000.00. It is agreed between the parties that the net proceeds from said sale shall be divided 62.5 per cent to WIFE and 37.5 per cent to HUSBAND. It is further understood and agreed by the parties that should any claims be made in re joint credit card debt or medical bills on which HUSBAND was a joint obligor or guarantor, WIFE will save him harmless from said claim. All claims will be made against HUSBAND for any medical reimbursement made under the support order entered to No. 234 S2004. b) Furnishings and Personal Property. The parties have each acquired furnishings and personal property since date of separation. Personal property has been divided and no further claims will be made by either party in regard to personal property. -5- c) Motor Vehicles. 1) HUSBAND agrees that WIFE shall retain possession of and receive as her sole separate property the 1999 Subaru automobile currently in her possession, along with all rights under any insurance policy thereon and withal responsibility for payment of any outstanding liabilities or indebtedness pertaining thereto, if any, and insurance thereon, free of any right, title, claim or interest of HUSBAND. HUSBAND will promptly cooperation in the transfer of title. 2) WIFE agrees that HUSBAND shall retain possession of and receive as his sole separate property the 1993 Volvo currently in his possession, along with all rights under any insurance policy thereon and with all responsibility for payment of any outstanding liabilities or indebtedness pertaining thereto, if any, and insurance thereon, free of any right, title, claim or interest of WIFE. WIFE and HUSBAND agree to execute, acknowledge and deliver within thirty (30) days upon request of the other, any and all instruments or documents necessary to effectuate the transfer of the vehicle pursuant to the terms of this subparagraph. d) Pension/Retirement Funds. Each party will retain their respective pension funds. Neither party will make a claim against any portion of said funds. e) Cash Accounts and Other Funds. 1) WIFE agrees that HUSBAND shall retain as his sole and separate property, free from any claims or right of WIFE, the money in the Money Market account, which was realized as the result of liquidation of stocks. -6- 2) HUSBAND agrees that WIFE shall retain as her sole and separate property, free from any claim or right of HUSBAND, any bank account presently in her name or that was in her name at or before the time of separation of the parties. 3) WIFE agrees that HUSBAND shall retain as her sole and separate property, free from any claim or right of HUSBAND, any bank account presently in her name or that was in her name at or before the time of separation of the parties. f) Miscellaneous Pro ert . Any and all property not specifically addressed herein shall be hereafter owned by the party to whom the property is titled, and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. g) Assumption of Liabilities. 1) Except as otherwise set forth herein, HUSBAND agrees that he shall be solely responsible for all debt he has incurred in his name alone. HUSBAND further agrees that he will indemnify and hold WIFE and her property harmless from any liability, cost or expense, including attorney's fees, associated with these obligations. 2) Except as otherwise set forth herein, WIFE agrees that she shall be solely responsible for all debt she has incurred in her name alone. WIFE further agrees that she will indemnify and hold HUSBAND and his property harmless from any liability, cost or expense, including attorney's fees, associated with these obligations. 7- 3) Unless otherwise provided herein, each party hereby assumes the debts, encumbrances, taxes and liens on all the property each will hold subsequent to the date of this Agreement, and each party agrees to indemnify and hold harmless the other party and his or her property from any claim or liability that the other party will suffer or may be required to pay because of such debts, encumbrances or liens. h) Liability Not Listed. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and each party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all such debts, obligations, and liabilities. i) Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold WIFE liable for the debts or obligations assumed by HUSBAND under this Agreement, HUSBAND shall, at his sole expense, defend WIFE against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorneys fees incurred by WIFE in connection therewith. -8- j) Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold HUSBAND liable for the debts or obligations assumed by WIFE under this Agreement, WIFE shall, at her sole expense, defend HUSBAND against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorneys fees incurred by HUSBAND in connection therewith. k) Warranty as to Future Obligations. HUSBAND and WIFE shall take all steps necessary to assure that no credit cards or similar accounts or obligations exist which provide for joint liability. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any and all accounts on which joint liability may be incurred. HUSBAND and WIFE each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. Each hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including attorneys fees, incurred in the event of breach hereof. VI. CUSTODY. David J. Haines is now eighteen and is living independently. Custody of Alexander M. Haines shall be in compliance with the current custody order in the custody action filed to no. 04-1276 Civil Term. VII. CHILD SUPPORT. WIFE shall pay to HUSBAND support for the one child, Alexander M. Haines, under the support order of April 17, 2007, Docket No. 00196 S 2007 as it may be amended. -9- It is agreed that if the child, Alexander M. Haines, decides to pursue education beyond the high school lever and after scholarship and loan programs are first applied for, the parents agree to pay the cost of tuition and fees in the same proportion as their respective gross wages as reflected on Line 7, entitled "Wages and Earnings", on IRS Form 1040 personal income tax return at the time of enrollment. VIII. ALIMONY ALIMONY PENDENT ELITE AND SPOUSAL SUPPORT OR OTHER FINANCIAL MAINTENANCE. HUSBAND and WIFE do hereby waive, release and give up any rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, or maintenance. It shall be, from the execution date of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any alimony, alimony pendent elite, spousal support or maintenance from the other party. IX. COUNSEL FEES. Each party specifically waives his or her right to seek contribution from the other toward his or her counsel fees, costs and expense. X. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, effective upon the execution date, HUSBAND and WIFE each waive all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, -10- except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction, and shall include all rights under the Pennsylvania Divorce Code. XI. WAIVER OF BENEFICIARY RIGHTS. Unless otherwise specifically set forth in this Agreement, HUSBAND and WIFE each waive all rights to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final paychecks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as a beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the decreased party. XII. RELEASE OF CLAIMS. a) HUSBAND and WIFE acknowledge and agree that the property dispositions provided for herein constitute and equitable distribution of their assets and liabilities pursuant to §3502 of the Divorce Code and HUSBAND and WIFE hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces and forever abandons any claim, right, title or interest whatsoever - 11 - he or she may have in or to property transferred to the other parry pursuant to this Agreement or identified in this Agreement as belonging to the other party and each party agrees never to assert any claim to said property or proceeds in the future. However, neither party is released nor discharged from any obligation under this Agreement nor any instrument or document executed pursuant to this Agreement. HUSBAND and WIFE shall hereafter own and enjoy independently of any claim or right of the other all items of personal property, tangible or intangible, acquired by him or her from the date of execution of this Agreement, with full power in him or her to dispose of the same fully and effectively for all purposes. b) Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendent elite, alimony, equitable distribution, spousal support, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1990, its supplements and amendments, as well as any other law of any other jurisdiction, except, and only except, all rights and obligations arising under this Agreement or for the breach of any of its provisions. c) Except as otherwise provided herein, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, and administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be effective regardless of whether such -12- claims arise out of any former of future acts, contracts, engagements, or liabilities of the other, or by way of dower, courtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. XIII. MARITAL INCOME TAX OBLIGATIONS AND PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date a divorce decree is entered all financial records relating to the marital estate; and each party will allow the other party access to those records in the event of tax audit. In the event that the Internal Revenue Service or other taxing authority seeks to impose taxes, penalties, and/or interest as a result of joint tax returns filed during the marriage, HUSBAND shall indemnify and hold WIFE harmless against any liability whatsoever related to any such taxes, penalties and interest on any income he earned resulting in said additional liability and WIFE shall indemnify and hold HUSBAND harmless against any liability whatsoever related to any such taxes, penalties and interest on any income she earned resulting in said additional liability. XIV. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. XV. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. -13- XVI. BREACH. If either party hereto beaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all reasonable costs, reasonable expenses and reasonable legal fees incurred in the enforcement of the right of the non-breaching party. XVII. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. XVIII. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. Notice to WIFE will be sufficient if made or addressed to the following: 2711 Logan Street, Camp Hill, Pennsylvania 17011, and to HUSBAND if made or addressed to the following: 2917 Chestnut Street, Camp Hill, Pennsylvania 17011, and each party may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. XIX. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to choice of law provisions) in effect as of the date of execution of this Agreement. XX. BANKRUPTCY. HUSBAND and WIFE agree that in the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party -14- pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under state or federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse. Debtor-spouse hereby assigns, transfers and conveys to the creditor-spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorney's fees and costs incurred in the enforcement of this paragraph or any provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of federal or state law to the contrary, and each party waivers any and all right to assert that any obligation hereunder is discharged or dischargeable. XXI. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns and successors in any interest of the parties. XXII. ENTIRE AGREEMENT. Each party acknowledges that he or she carefully read this Agreement, including other documents to which it refers; that he or she has had the opportunity to discuss its provisions with an attorney of his or her own choice, and has executed it voluntarily; and that this instrument expresses the entire agreement between the parties concerning the subject it purports to cover. This Agreement should be interpreted fairly and simply, and not strictly for or against either or the parties. XXIII. PRIOR AGREEMENTS. The parties specifically agree that this Agreement shall supersede any and all prior agreements between the parties. -15- XXIV. INCORPORATION OF EXHIBITS. All exhibits and other instruments referred to in this Agreement are incorporated into this Agreement as completely as if they were copied verbatim in the body of it. XXV. MUTUAL COOPERATION. Each party shall on demands execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiaries of insurance policies or other benefits or assets, tax returns, pensions and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, the party shall pay to the other party all attorney's fees, costs and other expenses actually incurred as a result of such failure. XXVI. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they each have executed the Agreement on the same date. Otherwise, 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. XXVII. EFFECTIVE DATE. This Agreement shall be effective and binding upon both parties on the execution date of this Agreement. XXVIII. AGREEMENT NOT TO BE MERGED. This Agreement shall survive any divorce decree entered with respect to the parties and shall be incorporated into any final decree of divorce of the parties for purposes of enforcement only, but otherwise shall not be -16- merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under the Agreement as an independent contractor. Such remedies in law or equity specifically are not waived or released. XXIX. HEADINGS NOT PART OF AGREEMENT. Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. XXX. COUNTERPARTS. This Agreement may be executed in counterparts, each of which will be an original and which together shall constitute one and the same instrument. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound, hereby have set their hands and seals the day and year first above written Seal) e1&??Seal) Rebecca A. Haines 17- WITNESS BY: COMMONWEALTH OF PENNSYLVANIA COUNTY OF Yo P-K : S.S. On this, the CS-t' day of jwv' - 2007, before me the undersigned officer, a Notary public, in and for said Commonwealth and County, personally appeared Gregory S. Haines known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Post-Nuptial Agreement and in due form acknowledged that he executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Narumol Alexander, Notary Public Di sburg Boro, York County W Commission Expires Apr. 7, 2010 Member, Pennsylvania Association of Notaries Notary Public My Commission Expire: at't ?, 2,0 to COMMONWEALTH OF PENNSYLVANIA : : S.S. COUNTY OF DAUPHIN On this, the day ofIJUA?, 2007, before me the undersigned officer, a Notary public, in and for said Commonwealth and County, personally appeared Rebecca A. Haines known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Post-Nuptial Agreement and in due form acknowledged that she executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. Tta?r?yftblicmmissi von Expire: t%r r . cap N? _915 TACSEAL JUUEANNE AMETRANO, Notary Public - 18 - City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 ' r-? t? C ? C c_- ?? ?'= r >'. ? ? ??? -' r., ? .? ?,? ..?-' GREGORY S. HAINES, Plaintiff VS. . REBECCA A. HAINES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 1276 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2007, the economic claims raised in the proceedings having been resolved in accordance with a post-nuptial settlement agreement dated June 1, 2007, 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. cc: /ane M. Alexander Attorney for Plaintiff Xrdan D. Cunningham Attorney for Defendant 4 BY THE COURT, Q "- All_?N Edgar B. Bayley, P.J. >- J m LL1 !?i t L1 N i GREGORY S. RAINES, vs. REBECCA A. HAINES, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA. NO. 04-1276 Civil Term : CIVIL ACTION-LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) (3301(d)(1}) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: was sent certified mail, restricted delivery and was served to the Defendant on March 27, 2004, 3. (Complete either paragraph (a) or (b)) a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff June 1, 2007 ; by defendant June 1, 2007 . b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing of the 3301(d) affidavit: (3) Date of service of the 3301(d) affidavit upon respondent: 4. Related claims pending: All claims are settled and satisfied by Post-Nuptial Agreement dated June 1, 2007 s geed by both parties. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to request entry of the divorce decree, a copy of which is attached: (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: June 4, 2007. Date defendant's Waiver of Notice was filed with the Prothonotary: June 4, 2007. D Attorney I.D. 407355 148 S. Baltimore Street Dillsburg, PA 17019 (717) 432-4514 x--? C? ? ...?+ ?445,.'''?i fir/ ?'{? :. `' ?_. 1t ` ? `...I 1 ?%^' ?. }. - % JUN 0 4 2001 ae4 GREGORY S. HAINES Plaintiff VS. REBECCA W. HAINES Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1276 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this -s ft - day of "? u,a C- , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated March 27, 2007, shall continue in effect as modified by this Order. ' 2. The parties shall participate in a course of co-parenting counseling with a professional selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in developing sufficient communication and cooperation to enable them to effectively co-parent their Child and to resolve custodial issues on an ongoing basis by agreement. All costs of the counseling under this provision shall be shared equally between the parties. 3. The parties agree that the Father shall transport the Child to the Child's next appointment with Sally Rooney on June 8, 2007 and the Mother will contact Sally Rooney to schedule the following appointment during a time when the Mother is available to transport the Child to that appointment. 4. Following the completion of co-parenting counseling under this Order, counsel for either party may contact the conciliator within 6 months of the date of this Order to schedule an additional custody conciliation conference, if necessary, to address any outstanding issues concerning the custodial schedule. cc: Jane M. Alexander, Esquire - Counsel for Father Jordan D. Cunningham, Esquire - Counsel for Mother 4-11-6 7 BY THE COURT, N rte-- C 3 { C1- Lu 0- ! , s %% f GREGORY S. HAINES Plaintiff VS. REBECCA W. HAINES Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-1276 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alexander M. Haines December 16, 1994 Father 2. A custody conciliation conference was held on May 29, 2007 with the following individuals in attendance: the Father, Gregory S. Haines, with his counsel, Jane M. Alexander, Esquire, and the Mother, Rebecca W. Haines, with her counsel, Jordan D. Cunningham, Esquire. 3. The parties agreed to entry of an Order in the form as attached. -'-T 3O . ADO "7 Date Dawn S. Sunday, Esquire Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. GREGORY S. HAINES VERSUS REBECCA A. HAINES N O. 04-1276 Civil Term DECREE IN DIVORCE AND NOW, T, A I.,I , IT IS ORDERED AND DECREED THAT GREGORY S. HAINES , PLAINTIFF, AND REBECCA A. HAIM , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms and conditions of the Post-Nuptial Agreement dated June 1, 2007 attached hereto and made a part hereof, and in accordance with Paragraph XXVM of said agr mmt, shall beccme part of and be incorporated into the final decree of divorce divorcing the parties, but shall not be merged into the decree. E A g err -flJ co ? 9z-° I 41