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HomeMy WebLinkAbout08-6109STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. DIVORCE ACTION NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17103 (717) 240-6195 STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. OF-610? &kwd DIVORCE ACTION COMPLAINT COUNT I -DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Stephanie T. Bower, is an adult individual who currently resides at 1022 Country Club Road, Camp Hill, PA 17011. 2. Defendant, Bradley A. Bower, is an adult individual. Plaintiff is uncertain as to the current residence of defendant. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on September 11, 1999, in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in Counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Stephanie T. Bower, urges this Honorable Court to enter a Decree of Divorce. COUNT II - CUSTODY 9. Plaintiff seeks custody of the following child: Name Present Residence Collin J. Bower 1022 Country Club Road Camp Hill, PA 10. The child was born of the marriage. Age 6 (DOB: 4/20/02) 11. The child is presently in the custody of the Plaintiff who resides at the above referenced address. 12. During the past five (5) years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Plaintiff 1022 Country Club Road 6/08-present Camp Hill, PA Parties 1022 Country Club Road Prior 5 years Camp Hill, PA 13. The Mother of the child is the Plaintiff. She is currently married but separated from the Defendant. 14. The Father of the child is the Plaintiff. He is currently married but separated from Plaintiff. 15. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with herself, her mother and the child, at the above referenced address. 16. The relationship of the Defendant to the child is that of father. Plaintiff is unsure of Defendant's current living arrangements. 17. Plaintiff has not participated as a party or witness or in another capacity in other litigation concerning custody of the child in this or another Court. 18. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of the Commonwealth or any other state. 19. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 20. The best interest and permanent welfare of the child will be served by granting the relief requested because mother has been the primary caregiver and has played an active and nurturing role in the development of the child and the continued relationship would be in the best interests of the child. Further, father has a drinking problem does not have suitable living arrangements and has recently been hospitalized after a suicide attempt. 21. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, Stephanie T. Bower, requests the Court to grant her sole legal custody of the child, award her primary physical custody of the child and award Defendant periods of supervised custody. By. Respectfully s NEALON 8James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: October 10, 2008 VERIFICATION I, Stephanie T. Bower, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. STEP ANIE T. BOWER Dated: ((9 1rD lp r*.N ?.? 3 W i x r,i C Rr OD -- CD VVV ^ ``4 C , V QD STEPHANIE T. BOWER, PLAINTIFF- Petitioner V. BRADLEY A. BOWER, DEFENDANT-Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. DIVORCE ACTION PETITION OF STEPHANIE BOWER FOR EMERGENCY RELIEF 1. Petitioner, Stephanie T. Bower ("Wife"), is an adult individual who currently resides at 1022 Country Club Road, Camp Hill, PA 17011. 2. Respondent, Bradley A. Bower ("Husband"), is an adult individual who is currently hospitalized at the Holy Spirit Behavioral Health Center, Camp Hill, Pennsylvania 17011. 3. The parties were married on, September 11, 1999, in Carlisle, Pennsylvania. 4. During the course of the marriage, the parties acquired a residence located at 1022 Country Club Road, Camp Hill, PA 17011. 5. The parties are the parents and natural guardians of one (1) minor child, Collin J. Bower, (DOB 4/20/02). 6. The parties separated in June of 2008. Since that time, Husband has lived with his parents and with friends. 7. Respondent is an alcoholic. 8. Recently, Respondent attempted suicide. Respondent ingested a large amount of prescription medication and alcohol. 9. As a result, on October 7, 2008, Respondent was admitted to the Behavioral Health Department of the Holy Spirit Hospital. 10. Respondent is currently receiving treatment. Petitioner has been advised that the average stay is 5 to 7 days. 11. During the course of his stay, Respondent has been indicating that he plans to return to the marital residence. 12. Due to Respondent's alcohol addiction and recent behavior, Petitioner does not feel safe in the marital residence if Respondent returns. 13. The parties' minor child is a first grade student at the East Pennsboro Elementary School. Petitioner has no other residence within the school district to relocate in the event that Respondent returns to the marital residence. 14. This Honorable Court has the authority pursuant to Section 3502(c) of the Divorce Code to grant a party exclusive possession of the marital residence. 15. Contemporaneously with the filing of this Petition, Petitioner has filed a Divorce Complaint. 16. No Judge has ruled on any other issue in this matter or a related matter. 17. Counsel for Petitioner cannot contact Respondent due to his current hospitalization. WHEREFORE, Petitioner, Stephanie T. Bower, urges this Honorable Court to grant her exclusive possession of the marital residence pursuant to Section 3502(c) of the Divorce Code. Respectfully submitted, NEALON GOVER & PERRY By: J%nes CT Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: 10 1 10 1 (D<Z- VERIFICATION I, Stephanie T. Bower, verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. P ANTE T. BOWER Dated: t (q/ 6 `C) tr na .i ? - ?? , ?-- "t'1 i ?? f,, ? .i? ~? ?...,? ? ?'.G,' ' OCT Vao8 STEPHANIE T. BOWER, : IN THE COURT OF COMMON PLEAS PLAINTIFF- Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. NO.UW,?JOJ b4'A''W^ BRADLEY A. BOWER, DIVORCE ACTION DEFENDANT-Respondent j?ORDER AND NOW, this_' day of October, 2008, upon consideration of Petition for Emergency Relief filed by Stephanie T. Bower, it is hereby ORDERED and DECREED that a hearing is scheduled for day of 2008, at o'clock. P. ft). JA- r ? (.. 'J. 6C •0 V 9 ! 130 BOQZ -31141 JO 30Li-40--031H r. , . STEPHANIE T. BOWER, : IN THE COURT OF COMMON PLEAS PLAINTIFF- Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 08-6109 Civil Term BRADLEY A. BOWER, : DIVORCE ACTION DEFENDANT-Respondent : AFFIDAVIT OF SERVICE 1, (All .e.VA4 E/`Fl do hereby certify, subject to the penalties of 18 Pa. C. S. Section 4904, relating to Unsworn Falsification to uthorities, that I am a competent adult and that on the /J "`4 day of QC, toLc.^ , 2008, at about 3r) 7- o'clock a.m. / p.m., I served true and correct copies of the following documents in the above-captioned matter: A Divorce Complaint and a Petition for Emergency Relief in the following indicated manner: by personally handing said copies to and leaving same with the said by personally handing said copies to and leaving same with the following named adult member by leaving said copies at the last known address of the ultimate recipient said last known address at the following location: and said copies being specifically placed at : TO BE FILLED IN BY PERSON ACCEPTING SERVICE: Received the herei c ' d documents on ?O 3 U (Date) .04 Signature: a A. Bower Date Received: / 0 i 30 / ,?' 1 y., 1- cli r cv m STEPHANIE T. BOWER, IN THE COURT OF COMMON PLEAS OF' Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA v NO. 08-6109 CIVIL TERM CIVIL ACTION - LAW BRADLEY A. BOWER, Defendant/Respondent DIVORCE ACTION IN RE: PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 27th day of October, 20C8, upon consideration of Plaintiff's Petition for Emergency Relief filed by Stephanie T. Bower, and pursuant to an agreement of the parties reached in open court, with Plaintiff being c resent and represented by James G. Nealon, III, Esquire, and Defendant being present and representing himself, it is hereby ordered and decreed as follows: 1. Respondent, Bradley A. Bower, is hereby evic?:ed from 1022 Country Club Road, Camp Hill, PA, 17011; and 2. Absent an agreement of the parties or further Order of Court, Bradley A. Bower may not enter 1022 Country club Road, Camp Hill, PA, 17011. By the Court, i r J. Wesley ler, Jr., J. v ? James G. Nealon III Esquire 2411 North Front Street op lim rrulvicl Harrisburg, PA 17110 For Plaintiff/Petitioner 10/,Z$/ee ,/'Bradley A. Bower f 900 Market Street Lemoyne, PA 17043 Defendant/Respondent mae ?? t! . oL STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6Y-6109-CV : DIVORCE ACTION NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17103 (717) 240-6195 STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 6? -(0 log-CV DIVORCE ACTION AMENDED COMPLAINT COUNT I -DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Stephanie T. Bower, is an adult individual who currently resides at 1022 Country Club Road, Camp Hill, PA 17011. 2. Defendant, Bradley A. Bower, is an adult individual who currently resides at 2215 A Orchard Road, Camp Hill, PA 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on September 11, 1999, in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in Counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Stephanie T. Bower, urges this Honorable Court to enter a Decree of Divorce. COUNT II -DIVORCE UNDER SECTION 3301(a) OF THE DIVORCE CODE 9. Paragraphs 1 through 8 above are incorporated herein by reference. 10. Defendant has offered such indignities to the Plaintiff, who is an innocent and injured spouse, so as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff, Stephanie T. Bower, urges this Honorable Court to enter a Decree of Divorce. COUNT III - CUSTODY 11. Plaintiff seeks custody of the following child: Name Present Residence Collin J. Bower 1022 Country Club Road Camp Hill, PA 12. The child was born of the marriage. Aqe 6 (DOB: 4/20/02) 13. The child is presently in the custody of the Plaintiff who resides at the above referenced address. 14. During the past five (5) years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Plaintiff 1022 Country Club Road 6/08-present Camp Hill, PA Parties 1022 Country Club Road Prior 5 years Camp Hill, PA 15. The Mother of the child is the Plaintiff. She is currently married but separated from the Defendant. 16. The Father of the child is the Plaintiff. He is currently married but separated from Plaintiff. 17. The relationship of the Plaintiff to the child is that of mother. The Plaintiff currently resides with herself, her mother and the child, at the above referenced address. 18. The relationship of the Defendant to the child is that of father. Plaintiff is unsure of Defendant's current living arrangements. 19. Plaintiff has not participated as a party or witness or in another capacity in other litigation concerning custody of the child in this or another Court. 20. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of the Commonwealth or any other state. 21. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 22. The best interest and permanent welfare of the child will be served by granting the relief requested because mother has been the primary caregiver and has played an active and nurturing role in the development of the child and the continued relationship would be in the best interests of the child. Further, father has a drinking problem does not have suitable living arrangements and has recently been hospitalized after a suicide attempt. 23. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, Stephanie T. Bower, requests the Court to grant her sole legal custody of the child, award her primary physical custody of the child and award Defendant periods of supervised custody. Respectfully NEALON LA By: U?-"I " James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: January 8, 2009 VERIFICATION I, Stephanie T. Bower, verify that the statements made in the foregoing Amended Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. STEPHANIE T. BOWER Dated: I - D ? 6 ' Q C .= w l . R3 4444 ?_ y ? r ?''nn/1 STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6109 : DIVORCE ACTION MOTION FOR APPOINTMENT OF MASTER X Plaintiff ? Defendant, moves this court to appoint a Master with respect to the follow 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 X is ? is not complete as to the claim(s) for which the appointment of Master is requested. 2. The non-moving party X has ? has not appeared in the action ? personally, ? by counsel, Gary Kelly, Esquire 3. The statutory ground(s) for divorce ? is X are : Section 3301(a) 4. ? (a) The action is not contested ? (b) An agreement that has been reached with respect to the following claims: X (c) The action is contested with respect to the following claims: Divorce and equitable distribution. 5. The action ? involves X does not involve complex issues of law or f ct. s 6. The hearing is expected to take one (1) day. 7. Additional information, if any, relevant to the motion: /rte Dated: James G. Nealon, III, Esquire Attorney for Plaintiff AND NOW, this day of 12009, , Esquire, is appointed Master with respect to the following claims: BY THE COURT: J. PLAINTIFF Stephanie T. Bower James G. Nealon, III., Esquire Nealon Law Firm, PC 2411 N. Front Street Harrisburg, PA 17110 (717) 232-9900 DEFENDANT Bradley A. Bower Gary Kelly, Esquire 3117 Chestnut Street Camp Hill, PA 17011 s CERTIFICATE OF SERVICE AND NOW, this 10?day of March, 2009, 1 hereby certify that I have served the foregoing Motion for Appointment of Master on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary Kelly, Esquire 3117 Chestnut Street Camp Hill, PA 17011 James G. Nealon, 111, Esquire CD Co n may; James G. Nealon, III, Esquire NEALON LAW FIRM 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 STEPHANIE T. BOWER, Plaintiff VS. BRADLEY A. BOWER, Defendant • . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6109 CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF STEPHANIE T. BOWER Plaintiff files the following Income and Expense Statement. Plaintiff verifies that the statements made in this Income and Expense Statement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. • • INCOME: Employer: Holy Spirit Hospital Address: 502 N. 21 st Street Camp Hill, PA Type of W. Pharmacist - hospital Payroll Number: Pay Period (Weekly, Biweekly, etc.): Biweekly Gross Pay Per Pay Period: $3,845.44 Itemized Payroll Deductions: Federal Withholding: $ 439.92 Social Security $ 222.99 State Income Tax $ 110.36 Local Wage Tax $ 57.51 Medicare $ 52.15 Retirement $ 422.77 Flex Spending $ 57.70 Local Tax $ 2.00 Life Insurance $ 27.00 Health Insurance $ 191.07 LT Disablily $ 12.22 DI/UC $ 32.16 401 k Loan $ 342.05 LST Tax $ 2.00 UC Tax $ 2.31 Total Deductions $1.974.21 NET PAY PER PAY PERIOD $1.871.23 • Other Income: Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. Spousal Support Child Support TOTAL EXPENSES HOME Mortgage/Rent Maintenance Repairs 2nd Mortgage UTILITIES Electric Gas Oil Telephone Water Sewer Trash EMPLOYMENT Public Transportation Lunch TAXES School Real Estate Personal Property • Week Month Year (Fill in Appropriate Column) Week Month 1,910.22 293.33 172.38 45.26 59.08 Year 11.63 Income Total This Page 3233.59 EXPENSES Week Month Year (Fill in Appropriate Column) INSURANCE Homeowners 66.08 Automobile 104.18 Life 95.33 Accident 166.43 Health Renters AUTOMOBILE Payments 536.95 Fuel 65.00 Repairs 50.00 Maintenance Licenses Registration Auto Club 10.25 MEDICAL Doctor 7.50 Dentist 9.33 Orthodontist Hospital 63.00 Medicine 13.00 Special needs (glasses, braces, orthopedic devices EDUCATION Private Parochial School College Religious School lunches Books/misc. PERSONAL Clothing 300.00 Food 150.00 Barber/Hairdresser 70.00 Personal Care Laundry/Dry Cleaning Hobbies Credit Cards Memberships 80.00 Total this page 1,787.05 • EXPENSES LOANS Credit Union MISCELLANEOUS Household Help Child Care Papers/Books/Magazines Entertainment Pay TV Vacation Gifts LegalFees Charitable Contributions Pet Expense Lessons for Children Cell Phone Other Support Alimony Payments OTHER Child's parties, allowance, fees Total This Page TOTAL EXPENSES Week Month Year (Fill in Appropriate Column) 12.50 125.00 50.00 201.83 -W.WW 50.00 1JV.VV 55.00 V VT.JJ $ 5,684.97 CERTIFICATE OF SERVICE AND NOW, this 1,L, d y of March, 2009, 1 hereby certify that I have served the foregoing Income and Expense on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary Kelly, Esquire 3117 Chestnut Street Camp Hill, PA 17011 a James G. Nealon, III, Esquire w y c1 t 0 *1 James G. Nealon, III, Esquire NEALON LAW FIRM 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 STEPHANIE T. BOWER, Plaintiff VS. BRADLEY A. BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6109 CIVIL ACTION - LAW IN DIVORCE INVENTORY AND APPRAISEMENT OF STEPHANIE T. BOWER Plaintiff 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. Plaintiff verifies that the statements madein this inventory and appraisement are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. 0 0. ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets 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 (x) 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates O 7. Contents of safe deposit boxes () 8. Trusts () 9. Life insurance policies (indicated face value, cash surrender value and current beneficiaries) () 10. Annuities O 11. Gifts O 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home (x) 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits - severance pay, workman's compensation claim/award () 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (x) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments O 21. Litigation claims (matured and unmatured) O 22. MilitaryN.A. benefits () 23. Education benefits (x) 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) () 26. Other 0 0. LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following page: SECURED (x) 1. Mortgages ( ) 2. Judgment ( ) 3. Liens ( ) 4. Other secured liabilities UNSECURED (x) 5. Credit card balances ( ) 6. Purchases ( ) 7. Loan payments ( ) 8. Notes payable ( ) 9. Other unsecured liabilities CONTINGENT OR DEFERRED ( ) 10. Contracts or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other contingent or deferred liabilities MARITAL PROPERTY (x) Plaintiff ( ) Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Property Names of All Owners 1 Marital Residence - 1022 Count Club Road, Cam Hill, PA Joint 2 2004 Mercedes Benz L240 Wife 3 1997 Mercedes Benz Joint 4 Main Event Deli Husband's Business) Husband 5 Holy Spirit Hospital 401 k Wife 6 Roth IRA Wife 7 Household Furnishings Joint 0 0. LIABILITIES ( ) Plaintiff (x) Defendant lists all liabilities of'either or both spouses alone or with any persons as of the date this action was commenced. Item Number Description of Property Names of All Creditors Names of All Debtors 1 1S Morta e Chase Joint 2 2" Mortgage Joint 3 Car Loan MB Financial Wife 4 FIA Credit Card Fidelity Investments Wife 5 Amex Card American Express Wife 6 GM Card HSBC Wife • •. PROPERTY TRANSFERRED Plaintiff lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: None 0 0. NON MARITAL PROPERTY Wife is the owner of a small whole life policy that insures the parties' child. It has minimal cash value and was purchased for the benefit of the child. CERTIFICATE OF SERVICE AND NOW this / ?Aday of M?arch, 2009, 1 hereby certify that I have served the foregoing Inventory and Appraisement on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary 'Keliy, Esquire 3117 Oestnut Street Campl Hill, PA 17011 James G. Nealon, III, Esquire c? -r1 71: M CO r.4 ) > MAR 1 9 200196 STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6109 DIVORCE ACTION MOTION FOR APPOINTMENT OF MASTER X Plaintiff o Defendant, moves this court to appoint a Master with respect to the follow claims: X Divorce X Distribution of Property o Annulment ? Support o Alimony ? Counsel Fees o Alimony Pendente Lite ? Costs and Expenses and in support of the motion states: 1. Discovery X is o is not complete as to the claim(s) for which the appointment of Master is requested. 2. The non-moving party X has ? has not appeared in the action ? personally, ? by counsel, Gary Kelly, Esquire 3. The statutory ground(s) for divorce ? is X are : Section 3301(a) 4. ? (a) The action is not contested o (b) An agreement that has been reached with respect to the following claims: X (c) The action is contested with respect to the following claims: Divorce and equitable distribution. 5. The action ? involves X does not involve complex issues of law or f t. 1 6. The hearing is expected to take one (1) day. 7. Additional information, if any, relevant to the motion: Dated: James G. Nealon, III, Esquire Attorney for Plaintiff AND NOW, this ??`day of? 2009,(.. ej4jj5djjLPZAsquire, is appointed Master with respect to the following claims: ,AA- A&d azg BY T O T: l o't C-' S. PLAINTIFF Stephanie T. Bower A..4ames G. Nealon, III., Esquire Nealon Law Firm, PC 2411 N. Front Street Harrisburg, PA 17110 (717) 232-9900 DEFENDANT Bradley A. Bower r Kelly, Esquire 3117 Chestnut Street Came Hill, PA 17011 cr ?" ? y t co . -y ", ?' ?sz { CERTIFICATE OF SERVICE AND NOW, this ILP?day of March, 2009, 1 hereby certify that I have served the foregoing Motion for Appointment of Master on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary Kelly, Esquire 3117 Chestnut Street Camp Hill, PA 17011 James G. Nealon, III, Esquire t n 77 c3a STEPHANIE T. BOWER, PLAINTIFF v. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. D$ - 1.1 G9 DIVORCE ACTION MOTION OF PLAINTIFF. STEPHANIE T. BOWER, TO VACATE APPOINTMENT OF DIVORCE MASTER 1. On March 19, 2009, Plaintiff, Stephanie T. Bower, filed a Motion for the Appointment of the Divorce Master. 2. By Order dated March 20, 2009, the Honorable Edgar Bayley appointed E. Robert Elicker, II, Esquire, as the Divorce Master. 3. The parties have reached an Agreement as to all outstanding issues. A true and correct copy of the Agreement is attached hereto and incorporated herein by reference as Exhibit "A". WHEREFORE, Plaintiff, Stephanie T. Bower, urges this Honorable Court to revoke the appointment of the Divorce Master. Respectfully NEALON LAW By: _ James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: -7 l9 CERTIFICATE OF SERVICE AND NOW, this day of July, 2009, 1 hereby, certify that I have served the foregoing Motion to Vacate Appointment of Divorce Master on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 James G. Nealon, III, Esquire 2009 „!}L 10 1,-,c ,. 5 i STEPHANIE T. BOWER, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6109 BRADLEY A. BOWER, DIVORCE ACTION DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 10, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the 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. 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: Stephanie ower Any THr" 2 0 U 9 JI;J'L 10 Ps'- = 54 STEPHANIE T. BOWER, PLAINTIFF v. BRADLEY A. BOWER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6109 : DIVORCE ACTION 1. I 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 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: 0 3 a a `r t ± i 15- ?e1,JiY m1?p i M A t STEPHANIE T. BOWER, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6109 BRADLEY A. BOWER, DIVORCE ACTION DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 10, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the 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. 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: 3? !? t P? ;47`t_:tk e /' F 4ju} 1 t .s lit4 STEPHANIE T. BOWER, PLAINTIFF v. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6109 DIVORCE ACTION WAIVER OF NQTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. I 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 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:a Cdrd Stephanie . Bower F1 LE Fi(? E OF THE i-'r,, 'o NPY 2009 A 10 P 54 rFY STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6109 : DIVORCE ACTION MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 30 day ofd v rJ 2009, by and STEPHANIE T. BOWER (hereinafter called "Wife") and BRADLEY A. (hereinafter called "Husband"). WITNESSETH: between BOWER WHEREAS, Husband and Wife were married on September 11, 1999 in Carlisle, Pennsylvania; and WHEREAS, the Parties are the parents and natural guardians of one minor child, COLLIN J. BOWER (DOB: 4/20/2002); and WHEREAS, the parties hereto desire to fix and determine by this Marital Settlement Agreement the rights and claims that have accrued to each of them in the estate and real and personal property of the other by reason of the marriage, and all economic rights of every kind and description arising from the marital relationship, including but not limited to present and future rights of inheritance, spousal support, maintenance, alimony payment of counsel fees and equitable distribution and to accept the provisions of this Agreement in lieu of and in full discharge, settlement and satisfaction of all such rights and claims. NOW THEREFORE, in consideration of the premises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. 3. WIFES DEBTS. Wife represents and warrants to Husband that as of the date of separation she has not incurred, and in the future she will not contract or incur, any debts or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Any and all loans, and/or debts and charge accounts presently in Wife's name alone shall be Wife's sole and separate responsibility for payment thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by wife. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the date of separation he has not incurred, and in the future he will not contract or incur, any debts or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Any and all loans, and/or debts and charge accounts presently in Husband's name alone shall be Husband's sole and separate responsibility for payment thereof, and Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. 5. DIVISION OF PROPERTY. Husband and Wife agree that the following constitutes an equitable distribution of the marital property. A. Wife's Property The following property shall become the sole and exclusive property of Wife: All right, title and interest in the 2004 Mercedes Benz. Wife shall be solely responsible for all loan payments, repairs, maintenance, insurance and registration fees for the vehicle; and 2. All right, title and interest to any checking, savings, retirement, 401(k) or other accounts in Wife's name. B. Husband's Property The following property shall become the sole and exclusive property of Husband: All right, title and interest in the 1997 Mercedes Benz, subject to all liens, loans and encumbrances. Husband shall be solely responsible for all loan payments, repairs, maintenance, insurance and registration fees for the vehicle. 2. All right, title and interest in Husband's business, Main Event Deli. Husband shall be solely liable for all loans, debts, obligations or other expenses associated with the business. 3. All right, title and interest to any checking, savings, retirement, or other accounts in Husband's name. C. Marital Home During the course of the marriage, Husband and Wife acquired the property located at 1022 Country Club Road, Camp Hill, PA. 2. Husband's name is not on the mortgages but is on the deed. Wife shall be solely responsible for all mortgage payments, taxes, insurance, repairs, maintenance or other expenses associated with the property. 3. Husband will execute a deed conveying his interest in the property to Wife. The property shall become the sole and separate property of Wife. D. Other property. The parties agree that they have divided all other separate and marital property to their mutual satisfaction. As of the date of this Agreement, any and all property not specifically addressed herein shall be 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 one to the other. Each party hereby waives any and all claims to the property of the other that is either titled in the name of the other party or in the other party's possession. 6. INCOME TAX. The parties have previously filed joint federal and state tax returns. Both parties agree that in the event of any deficiency in federal, state or local income tax is proposed or any assessment of any such taxes made against either of them, each will indemnify and hold harmless the other fund and against any loss or liability for any such tax deficiency or assessment or any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be cause of the misrepresentations or failure to disclose the nature and extent of his or her separate income on the foresaid joint return. Wife shall be entitled to claim any tax exemption or deduction for Camden. 7. ALIMONYISPOUSAL SUPPORT. Both parties agree to make no claim for alimony, alimony pendente lite, spousal support or any claim for separate maintenance now or at any future time, or in connection with he pending divorce action between the parties. /8. CHILD SUPPORT. Husband agrees to pay to Wife the sum of $ !d add per week for the support of Collin. Payments shall be made directly to Wife on each and every Friday. The parties agree that they shall share equally any unreimbursed medical expenses, dental or orthodontic expenses. The parties agree that the amount of child support takes into account the needs of the child as well as the relative earnings and/or earning capacities of the parties. Absent a substantial change in the financial condition of either party or the needs of the child, the support shall not be modified. 9. EFFECT OF SUBSEQUENT BANKRUPTCY. The Parties agree that none of Husband's obligations under the terms of this Agreement are intended to be a debt that is affected by a discharge in bankruptcy. They further specifically intend that Husband's obligations under the terms of this Agreement shall be non-dischargeable and not subject to discharge in bankruptcy because they acknowledge that, based upon the respective incomes, assets and needs of the Parties and their households, such are necessary for Wife to meet her financial obligations and to support and maintain her standard of living. Husband represents that there are no bankruptcy proceedings presently pending in which he is involved. Husband expressly agrees not to file a bankruptcy action prior to the completion of his obligations pursuant to this Agreement. These obligations shall not be discharged in a bankruptcy action filed by or against Husband. 10. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and the pending divorce action between the parties. 11. FINANCIAL DISCLOSURE. The parties have disclosed to each other and they are aware of the extent of each other's income, assets, liabilities, holdings and estates. Husband and Wife confirm that by executing this Agreement each forever waives any future right to set aside said Agreement, or to defend against its enforcement or any portion thereof based upon the absence of such a disclosure by the other party, or based upon any claim that it is inequitable, unconscionable or doe not make a reasonable provision for one or the other of them. 12. NO-FAULT DIVORCE. Both parties agree to execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree to facilitate entry of a divorce decree pursuant to Section 3301(c) of the Divorce Code. 13. BREACH. If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages, including attorney fees, for such breach, or seek such remedies or relief as may be available to him or her respectively. 14. ADDITIONAL INSTRUMENTS. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments, including Deeds and other real estate-related documents, titles, pension documents, or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 15. VOLUNTARY EXECUTION. The provisions of this Agreement have been read by the Parties. Each party acknowledges that the Agreement is fair and equitable, that full disclosure has been made by each respective party to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Wife and Husband acknowledge that they have been furnished with all information relating to the financial affairs of the other, which has been requested by the respectively. 16. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the martial relationship, including, without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take property against the Will of the other, and the right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims. 17. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives and assigns. This Agreement shall survive a decree of divorce between the parties in any jurisdiction and any other Order, which may be entered in accordance with this Agreement. In the event that a Decree of Divorce is entered in the Court of Common Pleas of Cumberland County, Pennsylvania or in the event that a Decree of Divorce is entered in any other jurisdiction, the parties agree to incorporate this Agreement in the Divorce Decree for purposes of enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees, costs, maintenance of insurance, equitable relief or property settlement or with regard to any other provisions hereof. In the event that any final order of court is entered in any jurisdiction with respect to the parties hereto which is contrary to the provision hereof, then the rights and responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary to conform to this Agreement. 18. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertaking other than those expressly set forth herein. 19. MODIFICATIONS AND VWAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement, shall not be construed as a waiver or any subsequent default of the same or similar nature. 20. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligation of the parties. 21. IRREVOCABILITY. It is understood and agreed to by and between the respective parties hereto that the property division-distribution effected by the herein Agreement is IRREVOCABLE and that such division- distribution shall not be affected by any future change in circumstances of the respective parties OR by other statutory or judicial alternatives which may be available to the respective parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other jurisdiction. Except as provided herein, the parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, current or future laws or case decisions. IN WITNESS and year first ;EOF, the parties have hereunto set their hands and seals the day written. Witness •%W? itne s S eNlE T. BOWER BRA LEY A. BOWER FLE::DA is r ;r p k (" 2009 J, L, 10 . JuL 1 3 toes y Z STEPHANIE T. BOWER, : IN THE COURT OF COMMON PLEAS PLAINTIFF- Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6109 BRADLEY A. BOWER, : DIVORCE ACTION DEFENDANT-Respondent ORDER AND NOW, this day of July, 2009, upon consideration of the Motion of Stephanie T. Bower, it is hereby Ordered and Decreed that the Appointment-of E. Robert Elicker, II, Es u' e as Divorce Master is hereby vacated. J. Distribution: J es G Nealon, III, Esquire, 2411 North Front Street, Harris Gary Kelley, Esquire, 3117 Chestnut Street, Camp Hill, PA 1701g1, PA 17110 Gop 1 e. s, rrz l LL 7/lq1o? It r?•T'n r i I f't, THE 2039 JUL 1 4 ?; 'i ? 1 STEPHANIE T. BOWER, PLAINTIFF v. BRADLEY A. BOWER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. OS - t.l 01 DIVORCE ACTION MOTION OF PLAINTIFF STEPHANIE T. BOWER TO VACATE APPOINTMENT OF DIVORCE MASTER 1. On March 19, 2009, Plaintiff, Stephanie T. Bower, filed a Motion for the Appointment of the Divorce Master. 2. By Order dated March 20, 2009, the Honorable Edgar Bayley appointed E. Robert Elicker, II, Esquire, as the Divorce Master. 3. The parties have reached an Agreement as to all outstanding issues. A true and correct copy of the Agreement is attached hereto and incorporated herein by reference as Exhibit "A". WHEREFORE, Plaintiff, Stephanie T. Bower, urges this Honorable Court to revoke the appointment of the Divorce Master. Respectfully submi NEALON LAW By: James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: -7 /g o CERTIFICATE OF SERVICE AND NOW, this J - day of July, 2009, 1 hereby. certify that I have served the foregoing Motion to Vacate Appointment of Divorce Master on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Gary Kelley, Esquire 3117 Chestnut Street Camp Hill, PA 17011 James G. Nealon, III, Esquire FILE'- C;: rr 2009 IUL I o i F?- STEPHANIE T. BOWER, IN THE COURT OF COMMON PLEAS PLAINTIFF- Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6109 Civil Term BRADLEY A. BOWER, DIVORCE ACTION DEFENDANT-Respondent PRAECIPE TO TRANSMIT 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) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Personal Service on October 13, 2008. 3. (Complete either paragraph (a) or (b)) (a) Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: Plaintiff June 30,2009; Defendant June 30, 2009. (b) (1) Date of execution of the affidavit required by § 3301 (d) of the Divorce Code: (2) (a) Date of filing of Plaintiff's affidavit upon respondent: )_ (b) Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: None, all claims resolved by Marital Settlement Agreement dated June 30, 2009. 5. (Complete either (a) or (b)) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice LinDivo e was ith the Prothonotary: July 10, 2009. (c) Date defendant's Waiver of Notir fil d e Prot honotary: July 10, 2009. DATED: T?L( a C 9--- - James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff AAGE; OF THEE PR71 ,h.;OTARY 2009 AUG - P 1: 36 Cum, Ty ouN STEPHANIE T. BOWER, PLAINTIFF V. BRADLEY A. BOWER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6109 DIVORCE ACTION AMENDED MARITAL SETTLEMENT AGREEMENT This Amendment to the Marital Settlement Agreement is made this day of , 2009, by and between STEPHANIE T. BOWER (hereinafter called "Wife") and%RADLEY A. BOWER (hereinafter called "Husband"). WITNESSETH: WHEREAS, Husband and Wife were married on September 11, 1999 in Carlisle, Pennsylvania; and WHEREAS, the parties entered into a Marital Settlement Agreement dated June 30, 2009; and WHEREAS, the parties desire to amend the terms of the Marital Settlement Agreement. NOW THEREFORE, in consideration of the promises and of the marriage, and in. further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. HEALTH INSURANCE. Wife currently provides health insurance for the parties and their minor child, Collin J. Bower. Wife agrees to maintain Husband on her health insurance through December 31, 2009, provided it is available through her employment and Husband remains eligible for the coverage. IN WIT SS WHEREOF, the parties have hereunto set their hands and seals the day and yea first above written. Wit s STEPH IE . OWER Of Witnes RA Y A. BOWER C, WEMnor0 21" AUG 14 PM b 51 OJANLAW CUM FB IQA" Stephanie T. Bower V. Bradley A. Bower IN THE -COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6109 Civil Term DIVORCE DECREE AND NOW, ?e_J P-I as it is ordered and decreed that Stephanie T. Bower plaintiff, and Bradley A. Bower , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, all 64.