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HomeMy WebLinkAbout09-2001'- COREY EDWARD KING, PLAINTIFF VS. BARBARA DAWN KING, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA 09 -tea 1 NO. CIVIL TERM : CIVIL ACTION -LAW : ACTION FOR 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 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 the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 1-800-990-9108 COREY EDWARD KING, PLAINTIFF VS* BARBARA DAWN KING, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA 0 c? X'60 ( NO. CIVIL TERM : CIVIL ACTION -LAW : ACTION FOR DIVORCE COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, COREY EDWARD KING, by and through his counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and makes the following consolidated complaint in divorce for divorce. 1. Plaintiff is COREY EDWARD KING, an adult individual, who currently resides at 812 Market Street, Unit B, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is BARBARA DAWN KING, an adult individual, who currently resides at 1825 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 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 lawfully married on May 10, 1986. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and of the right to request the court require the parties to participate in counseling. Plaintiff has chosen not to engage in, or to request any counseling. 8. Defendant has never been a member of the United States Military Services. Plaintiff has been a member of the United Stated Military for twenty-one (21) years. 9. There are two (2) children from this marriage. Both children are over the age of eighteen (18) years and therefore are not a part of this action. COUNT I - REQUEST FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference thereto. 11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may also file such an affidavit. COUNT H - REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(OF ) HE DIVORCE CODE 12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference thereto. 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff, COREY EDWARD KING, respectfully requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: March 2009 Susan Kay CandiNiffff Counsel for Pla' PA I .D. # 6499 4010 Gl P e Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. DATED: 3 2 (, zoo 9 COREY EDWARD 6) W Cn1 ? W V' d O T tT/ d -71 ?n O COREY EDWARD KING, PLAINTIFF V3. BARBARA DAWN KING, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 2009-2001. CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR DIVORCE AFFIDAVIT OF SERVICE CERTIFIED MAIL Be it known, that on April 6, 2009, comes, SUSAN KAY CANDIELLO, who states as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania. 2. I represent Corey Edward King, Plaintiff in the above-captioned matter. 3. On April 2, 2009, a true and correct copy of the Complaint for No-Fault Divorce Under Section 3301(c) of the Divorce Code, was deposited for delivery with the U.S. Postal Service in Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7008 1 140 0000 8398 7477, and addressed to the Defendant, Barbara Dawn King, 1825 Bridge Street, New Cumberland, Pennsylvania, 17070. 4. The return receipt card signed by the Defendant, Barbara Dawn King, showing a date of service of April 3, 2009, is attached hereto as Exhibit "A". 5. Service by certified mail meets the requirements of Pa.R.C.P. 404(2) and Pa.R.C.P. 403. 0 A. M_ntritu ? AWM X ? Adams... B. R caMd by (RM d . e) C. Dams of D*,wy D. b d*jwy address d ftm rtom awn 17 ? Yes K YES, enter dwkwy ad C, 1 bebw: ? No &map- Tfio ?T Iq 1-70-70 0 k 0 mow md coo. 6 ??phft hems 1, 2, and & Also cc iplele DoNvery Is desked. ¦ Print your name and address on the reverse so that vm can return the card to you. ¦ Attach this card to the bade of the nre"m or on the front N apace permtts. 1. A ole Addrsowd to: r ?J ?? 4ul? Z Arum Numtw Momm r Aar aarrb hbo .. Reestclsd Dslrwyt tee. Fear p Ym 7008 1140 0000 8398 7477 Fri trarrrt 3811. February 2004 Dorrmdc Rstum Recelpt rasessossaaraw Exhibit "A" 2009 APR -8 AM ! 1: 51 VVmb7 f ??1 3,V 7 ? Frank C. Sluzis, Esquire Attorney ID No. 43829 SCARINGI & SCARINGI, P.C. } r 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 - telephone (717) 657-7797 -facsimile 3 j frank@scaringilaw.com Attorney for Plaintiff COREY EDWARD KING, Plaintiff V. BARBARA DAWN KING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2009 - 2001 CIVIL ACTION - LAW IN DIVORCE INVENTORY OF PLAINTIFF Plaintiff files the following Inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real property (X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts (X) 9. Life insurance policies (indicate face value, cash surrender value, and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director 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) (X) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) (X) 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 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 Description Number of Property Names of All Owners E ? Corey E. King 1 1825 Bridge Street, New Cumberland Barbara D. King ?. ............................................................................................... ........ Corey E. King 2 512 Aquinas Avenue, Fayetteville, North Carolina Barbara D. King 3 NCFCU Checking Account #8683 - Barbara D. King ------------ .. .... NCFCU Savings Account #8683 ............__........._............ ..... ....... ........................................ g.... _ _.... ..................... ---- _-.................._.. _._......... Barbara D. Kin g 5 NCFCU Checking Account #0525 - ...... ......_...._..... _ ._....._................ .............. ............ ... Corey E. King 6 .. ........ -- NCFCU Money Market Account #0525 , Corey E. King -__--- ..... Corey E. King 7 NCFCU Checking Account #4466 --- i Barbara D. Kin - -- 8 19 NCFCU Savings Account #4466 -1_ _- 'Fort Bragg FCU Savings Account #9468 - ?_ Corey E. King Barbara D. King Corey E. King Barbara D. King Corey E. King 10 Fort Bragg FCU Checking Account #9468 Barbara D. King 11 Thrift Savings Plan Account #2307 Corey E. Kin 12 }West Shore Family Dentistry Retirement Plan Barbara D. King -? 113 Ameriprise Roth IRA #2082 --------- - --- - `--??------ -- Barbara D. King ---- ------ Corey E. King 14 ING Investment Account #3245 ( Barbara D. King NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: PROPERTY TRANSFERRED Item Description Date of Person to Number of Pro ert_ _ Transfer Consideration Whom Transferred 1975 Chevrolet Corvette 1 Stingray 8/7/2010 $0.00 Erin McAvaney 2 1982 Chevrolet Corvette 10/11/2010 $0.00 Erin McAvanev .. ..... . ........ I......... ................. ......... ........ .. _... LIABILITIES Item Description Names of Names of Number of Property All Creditors All Debtors 1 Flagstar Bank Mortgage #382-4 Flagstar Bank -- - -- Corey E. King Barbara D. Kin g -... Corey E. King 1 2 EverHome Mortgage #8339 EverHome Mortgage Barbara D. King Fort Bragg FCU Line of Credit Corey E. King 13 #9468 (Loan 146) Fort Bragg FCU Barbara D. King _ Corey E. King 4 { NCFCU American Express #4466 NCFCU .._............ .............................. Barbara D. King NCFCU Loan #0525 NCFCU ............................................. ............ Corey E. King 6 NCFCU Loan #0525 (second) NCFCU Corey E. King Dept. of Veterans 7 Dept. of Veterans Affairs Debt Affairs Corey E. King VERIFICATION I, Corey Edward King, verify that the statements made in the foregoing Inventory are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. i4M&-4 20 1? Corey id?Zd King Bate C? COREY EDWARD KING vs. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 BARBARA DAWN KING 2001 Defendant MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a master with respect to the following claims: ? 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 (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Samuel L. Andes E squlre). 3. The staturory ground (s) for divorce is -y , Section 3301(d) - Two year separation -03: a _- d 4. Delete the inapplicable paragraph (s): A ?X B ?X C ? ra :Z M ....t a. The action is not contested. c?s? t•J ?, b. An agreement has been reached with resnect to the following claims: --4 < = C. The action is contested with respect to the following claims: =C) ?C _... C7 - r Equitable Distribution ' D 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one (1) days 7. Additional information, if any, relevant to tl mo n: Date: S?r Attor ey for Plaintiff AND NOW Frank C. Sluzis, Esquire Print Name ORDER APPOINTING MASTER 20 is appointed master with respect to the following claims: Esquire, By the Court, J. D t l fJ r? L Frank C. Sluzis, Esquire T., P t 0 y H 0 0 TA R Attorney ID No. 43829 SCARINGI & SCARINGI, P.C. 2011 BEAR 23 AN 11: 26 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 C'UMBERLAND COUNTY (717) 657-7770 - telephone PENNSYLVANIA (717) 657-7797 -facsimile frank@scaringilaw.com Attorney for Plaintiff COREY E. KING, V. BARBARA D. KING, Defendant : No. 2009-2001 AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 30, 2009. 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. 4- Date: Corey King, Plain iff IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA U a :L ED-6F ?. Frank C. Sluzis, Esquire °1?J 01) I? 1 Attorney ID No. 43829 SCARINGI & SCARINGI, P.C. ???t (? ; 2 r,5 2000 Linglestown Road, Suite 106 H i ????? COUNTY arr sburg, PA 17110 (717) 657-7770 - telephone ???????vA??Q (717) 657-7797 -facsimile frank@scaringilaw.com Attorney for Plaintiff COREY E. KING, V. BARBARA D. KING, Defendant No. 2009-2001 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER & 3301(c) AND-4- ND & 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: % (L; rj j ec N 1?7 i / -? 1 1 Corey E.? ng, Plaintiff IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA O E -OFFICE Frank C. Sluzis, Esquire st.m i?R0TH N0TAh r' Attorney ID No. 43829 SCARINGI & SCARINGI, P.C. t # AR 2 3 AIN I I : 2 5 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 r; MBERLAND COUNTY (717) 657-7770 - telephone OP N S Y LVA N I A (717) 657-7797 -facsimile frank@scaringilaw.com Attorney for Plaintiff COREY E. KING, V. BARBARA D. KING, Defendant No. 2009-2001 NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 8, 2009 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: ?-? ??? Corey ?'. King, Pla nt? iff IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 09- 02001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COREY EDWARD KING vs. Plaintiff BARBARA DAWN KING : NO. 2009 2001 Defendant MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a master with respect to the following claims: ? 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 (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Samuel L. Andes 3. The staturory ground (s) for divorce is Section 3301(d) - Two year separation 4. Delete the inapplicable paragraph (s): A ?X B ?X C ? 0 a. The action is not contested. b. An aereement has been reached with resnect to the followine claims: L C. The action is contested with respect to the following claims: Equitable Distribution 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one (1) days 7. Additional information, if any, relevant to tl mo n: 1f Date: 4 ? Attor ey for Plaintiff Esquire). M nm XM <a C ? rtz Funk C. Sluzis, Esquire AND NOW Print Name rnco Vo - ORDER APPOINTING MASTER Zr a y , 20?, to 1 ]Z' uire, is appointed master with respect to the following claims: &,) n 4 -v ,Soari r9 i + Soar in i , AC oiamue! L . Anal?es, By the Court, 2 •?' Cil N?"o C, J. ??O?" a?? `?rS a C, P-? -f 010 Q-n 4F3 ....lr'`t A =M - John J. Connelly, Jr., Esquire ;r F C Attorney I.D. No. 15615 -C> r- Cn --w CD. James Smith Dietterick & Connelly, LLP a P.O. Box 650 Hershey, PA 17033 Attorneys for Plaintiff - .L7 COREY EDWARD KING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-2001 BARBARA DAWN KING, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO WITHDRAWAPPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel for the Plaintiff, Corey Edward King, in the above-captioned action. JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: I By: C?4 ?'u I =.tte?, Jr. 5615 P.9. Box 650 Hershey, PA 17033-0650 (717) 533-3280 (phone) (717) 298-2053 (fax) COREY EDWARD KING, Plaintiff V. BARBARA DAWN KING, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA • cool NO.09-2*H CIVIL IN DIVORCE PRE-TRIAL STATEMENT OF PLAINTIFF, COREY EDWARD KING PURSUANT TO PA.R.C.P. 1920.33(b) r7j 1. Statement of Case C_ -= The parties were married on May 10, 1986. The parties separated on -, March 8, 2009. Husband filed a Complaint in Divorce on March 30, 2009. Thy complaint raised the grounds for divorce of irretrievable breakdown of the marriage arri also raised the economic claim of equitable distribution. Husband filed an Affidavit of Consent pursuant to 3301(c) and 3301(d) on March 23, 2011. On March 23, 2011, Husband filed his Inventory and Motion for Appointment of Master. By Order of Court dated March 24, 2011 (Hess, J.), E. Robert Elicker, Il, Esquire was appointed master. II. Marital Assets (more fully set forth in King Asset Analysis spreadsheet attached hereto) Description/Titled Real estate situate at 1825 Bridge St., New Cumberland, PA (J) Real estate situate at 512 Aquinas Ave. (J) Value Lien 218,000.00 184,437.45 Flagstar Bank Acct. No. 382-4 95,000.00 Everhome Acct. No. 8339 1 NCFCU Acct. No. 8683 - Share 4 Checking (W) 370.27 NCFCU Acct. No. 8683 - Share 1 Savings (W) 54.99 NCFCU Acct. No. 4466 - Share 4 Checking (J) 5,380.44 NCFCU Acct. No. 4466 - Share 1 Savings (J) 284.45 NCFCU Acct. No. 0525 - Share 1 Savings (H) 1,113.51 NCFCU Acct. No. 0525 -- Share 3 Money 0.84 Market (H) Fort Bragg FCU Acct. No. 9468 (J) 20.95 Fort Bragg FCU Acct. No. 9468 (J) 1,457.29 1975 Chevrolet Corvette Stingray (H) 12,620.00 1982 Chevrolet Corvette (H) 9,700.00 2007 Saturn Vue (W) 12,000.00 12,477.18 NCFCU Acct. No. 0525 Thrift Savings Plan Acct. No. 2307 (H) 27,800.00 Army National Guard Pension (H) 189,146.00 West Shore Family Dentistry Retirement Plan (W) 50,280.84 Ameriprise Roth IRA Acct. No. 2082 (W) 1,155.12 ING Acct. No. xxxx (J) 8,000.00 Contents of Bridge St. Home (J) 8,287.00 III. Marital_ Debts(more fully set forth in King Asset Analysis spreadsheet attached hereto) Description/Titled Balance NCFCU American Express (J) 5.53 NCFCU Platinum Visa (H) 0.00 2 NCFCU Acct. No. 0529 (H) 8,062.99 NCFCU Acct. No. 0525 (H) 12,477.18 Fort Bragg FCU Acct. No. xxxx (J) 278.48 Flagstar Bank Acct. No. 382-4 (J) 184,437.45 EverHome Acct. No. 8339 (J) 45,361.65 Dept. of Veterans Affairs (H) 15,827.43 2009 Federal Taxes (J) 6,100.00 Payments for bedroom furniture (H) 4,000.00 TOTAL NET VALUE OF MARTAL ESTATE 364.121.79 NET VALUE OF ESTATE ATTRIBUTED TO W 214,671.78 (59%) NET VALUE OF ESTATE ATTRIBUTED TO H 149,450.01 (41%) IV. Non-Marital Assets Description/Owner Reason for Exclusion All guns including gun safe (H) pre-marital Wooden hand carved gun cleaning kit (H) pre-marital Collection of pint beer glasses (H) pre-marital Coca-Cola clock (H) pre-marital Kenwood stereo with speakers (H) pre-marital Personal books, e.g., school yearbooks, pre-marital college books, etc. (H) Personal photograph collection from parents (H) pre-marital All personal documents, e.g., military awards, pre-marital decorations, plaques, financial, etc, (H) Keys and all related parts associated with pre-marital 1982 Corvette (H) 3 Dart board (H) pre-marital Carved wooden beer sign (H) pre-marital Military trunk with army memorabilia (H) pre-marital Palm tree lamp (H) pre-marital All military federal property owned by United States government *All of the above items are in possession of W. V. Expert Witnesses Plaintiff (H) does not anticipate calling any expert witnesses in his case-in-chief. Plaintiff reserves the right to retain additional expert witnesses as may be required prior to trial and to cross-examine any expert witness retained by Defendant (W) for trial. VI. List of Fact Witnesses Plaintiff (H) anticipates calling only the parties as witnesses. Plaintiff reserves the right to cross-examine any witness called by Defendant (W) at time of trial and to offer rebuttal witnesses at time of trial in response to Defendant's presentation. Plaintiff reserves the right to supplement this response prior to trial. VII. List of Exhibits (all attached hereto) (corresponds to numbers on King Asset Analysis spreadsheet) 1. Appraisal of 1825 Bridge St., New Cumberland, PA real estate (J) 2. Appraisal of 512 Aquinas Ave., Fayetteville, NC real estate (J) 3. NCFCU Acct. No. 8683 Share 4 Checking statement (W) 4. NCFCU Acct. No. 8683 Share 1 Savings statement (W) 5. NCFCU Acct. No. 4466 Share 4 Checking statement (J) 6. NCFCU Acct. No. 4466 Share 1 Savings statement (J) 4 I % 7. NCFCU Acct. No. 0525 Share 1 Savings statement (H) 8. NCFCU Acct. No. 0525 Share 3 Money Market statement (H) 9. Fort Bragg FCU Acct. No. 9468 statement (J) 10. Fort Bragg FCU Acct. No. 9468 statement (J) 11. 1975 Chevrolet Corvette Stingray Blue Book Value statement (H) 12. 1982 Chevrolet Corvette Blue Book Value statement (H) 14. Thrift Savings Plan Acct. No. 2307 (H) 15. Army National Guard Pension Analysis (H) 16. West Shore Family Dentistry Retirement Plan statement (W) 17. Ameriprise Roth IRA Acct No. 2082 statemetn (W) 18. ING Acct. No. xxxx statement (J) 19. Appraisal of contents of Bridge St. home (J) 20. NCFCU American Express statement (J) 21. NCFCU Platinum Visa statement (H) 22. NCFCU Loan Acct. No. 0525 statement (H) 23. NCFCU Loan Acct. No. 0525 statement - Saturn Vue (H) 24. Fort Bragg FCU Acct. No. xxxx statement (J) 25. Flagstar Bank Mortgage Acct. No. 382-4 statement - Bridge St. prop. (J) 26. EverHome Mortgage Acct. No. 8339 statement - North Carolina prop (J) 27. Dept. of Veterans Affairs statement (H) 28.2009 Federal Tax statement (J) VIII. Parties' Incomes The current Cumberland County Domestic Relations Section Spousal Support 5 Order (Order No. 00313-5-2010) (PACSES Case No. 988111625) found Plaintiff s (H) net monthly income to be $6,061.97 and Defendant's (W) net monthly income to be $4,227.28. IX. Parties' Expenses Aside from the disproportionate amount of marital debt that Plaintiff (H) has been forced to assume pending final resolution of the divorce case, Plaintiff s expenses are ordinary in nature. A list of Plaintiff s expenses will be submitted at trial. It is averred that Defendant's (W) expenses are ordinary in nature. X. Proposed Economic Resolution Husband's Army National Guard Pension will be shared equally by the parties by way of QDRO. Wife will receive the Bridge St. real estate and will refinance the mortgage obligation currently secured by the real estate. Husband will receive the North Carolina real estate and will refinance the mortgage obligation currently secured by the real estate. Wife will retain the 2007 Saturn Vue currently in her possession and refinance the loan obligation currently in the name of Husband. All other bank accounts and loan/debt accounts will be the sole responsibility of the party in whose name the obligation is titled. Wife will retain her pension with West Shore Family Dentistry. The parties will retain as their respective sole property the items currently in his/her possession with the exception of the following items, which will become the sole property of Husband: 6 1. All items listed under Non-Marital Assets above; 2. The following items listed on the appraisal of the contents of the Bridge St. property (identified by item no. as listed on appraisal): a. Item No. 25 - 62 in. Mitsubishi television and television table b. Item No. 13 - grandfather clock c. Item No. 4 - prints d. Item No. 10 - print e. Item No. 42 - stereo f. Item No. 53 - work table g. Item No. 54 - tools Respectfully submitted, GI, P.C. By: C I Fr 9fi ' C. Sluzis, Esquire orney for Plaintiff PA ID# 43829 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: 717.657.7770 Fax: 717.657.7797 Email: frankgscaringilaw.com 7 COREY EDWARD KING, Plaintiff V. BARBARA DAWN KING, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2011 CIVIL IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 27th day of June, 2011, I, Frank C. Sluzis, Esquire, do hereby state that I served a true and correct copy of the foregoing document upon the following individuals in the manner indicated. VIA FIRST CLASS U.S. MAIL. POSTAGE PRE-PAID Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 E. Robert Elicker, II, Esquire Divorce Master Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 Respectfully submitted, SCAR)NGIA JCARINGI, P. By: Fr C. Sluzis, Esquire orney for Plaintiff eA ID# 43829 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: 717.657.7770 Fax: 717.657.7797 Email: frank(?,scaringilaw.com 8 1 u 1 1 1 I 1 ' r m m a N O Main Rle No. 10-0621 R-1 Pa a #1 APPRAISAL OF REAL PROPERTY LOCATED AT. 1825 Bridge St Deed Book 268 Page'772 New Cumberland, PA 17070.1126 FOR: Samuel L. Andes, Attorney at Law PO Box 168 Lemoyne, PA 17043 AS OF: 11/9/10 BY: Dennis L Stover PA Certified Residential Real Estate Appraiser Certification Number RL 138906 Clauser Real Estate Appraisals PO Box 777 Camp Hill, PA 17001-0777 Form 6A1-'MnTOTAL' appraisal software by a la mode, inc. - 1 -800-ALAMODE Main File No. 10-0621 R-1 Pa a #2 Samuel L. Andes, Attorney at Law PO Box 168 Lemoyne, PA 17043 Re: Property: 1825 Bridge St New Cumberland, PA 17070-1126 Client Samuel L. Andes, Attorney at Law File No.: 10-0621 R-1 In accordance with your request, we have appraised the above referenced property. The report of that appraisal is attached. The purpose of this appraisal is to estimate the market value of the property described in this appraisal report, as improved, in unencumbered fee simple title of ownership. This report is based on a physical analysis of the site and Improvements, a locational analysis of the neighborhood and city, and an economic analysis of the market for properties such as the subject. The appraisal was developed and the report was prepared in accordance with the Uniform Standards of Professional Appraisal Practice. The value conclusions reported are as of the effective date stated in the body of the report and contingent upon the certification and limiting conditions attached. It has been a pleasure to assist you. Please do not hesitate to contact me or any of my staff if we can be of additional service to you. Sincerely, Dennis L. Stover PA State Certified Residential Real Estate Appraiser Certification Number RL 138906 Main File No. 10-0621 R-1 Pa a #3 TABLE OF CONTENTS Cover Page ............................................... Letter of Transmittal ................................. Table of Contents ..................................... Summary of Salient Features ..................... USPAP Identification ................................. GP Residential .......................................... Subject Photos ............................................ Subject Photos Interior ............................... Subject Photos Interior ............................... Subject Photos Interior ............................... Subject Photos Interior ............................... Subject Photos Interior ............................... Building Sketch (Page -1) .......................... Comparable Photos 1-3 .............................. Location Ma Appraisal Addendum - Special Conditions_ Statement of Limiting Conditions ............... Electronic Signaturre Compliance ................ Certificate .................................................... Qualifications .............................................. Qualifications .............................................. Invoice .......................... Form TOCNP- VinTOTAL' appraisal software by a la mode, Inc. -1-800-ALAMODE .......... 1 .......... 2 ........... 3 ........... 4 .......... 5 ........... 6 .......... 9 10 .......... 11 .......... 12 13 14 15 16 17 18 19 21 22 23 24 25 Main File No. 10-0621 R-1 Pa a #4 SUMMARY OF SALIENT FEATURES Subject Address 1825 Bridge St Legal Description Deed Book 268 Page 772 City New Cumberland County Cumberland State PA Zip Code 17070-1126 Census Tract 42041-0107.00 Map Reference 25420 Sale Price $ NA Date of Sale NA Client Samuel L. Andes, Attorney at Law Owner Corey E. & Barbara D. King Size (Square Feet) 2,196 Price per Square Foot $ Location Suburban Age 68 Condition Avg Total Rooms 9 Bedrooms 4 Baths 2.5 Appraiser Dennis L. Stover Data of Appraised Value 11/9110 Final Estimate of Value $ 218,000 Form SSD -'WInTOTAV appraisal software by a la mode, Inc. -1-800-ALAMODE GEORGE CLAUSER APPRAISAL AND REPORT IDENTIFICATION Main File N110-0621 R-1 P- e #5 This Appraisal Report is !?tilt of the following types: ? SOB Contained (A written report prepared under Standards Rule 2-2(a) , persuant to the Scope of Work, as disclosed elsewhere in this report.) ® Summary (A written report prepared under Standards Rule 2-2(b) , persuantto the Scope of Work, as disclosed elsewhere in this report.) ? Restricted Use (A written report prepared under Standards Rule 2-2(c) , persuant to the Scope of Work, as disclosed elsewhere in this report, restricted to the stated Intended use by the specified client or intended user.) Comments on Standards Rule 2-3 I certify that, to the best of my knowledge and belief: The statements of fact contained in this report are true and correct The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. • I have no (or the specified) present or prospective interest in the property that is the subject of this report and no (or the specified) personal interest with respect to the parties involved. I have no bias with respect to the property that is the subject of this report or the parties involved with this assignment My engagement in this assignment was not contingent upon developing or reporting predetermined results. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result or the occu f , rrence o a subsequent event directly related to the intended use of this appraisal. My analyses, opinions and conclusions were developed and this report has been prepared, in conformity with the Uniform Standards of P f i l ro ess ona Appraisal Practice. I have made a personal inspection of the property that is the subject of this r t epor No one provided significant real property appraisal assistance to the person signing this certification. (If there are exceptions, the name of each individual providing significant real property appraisal assistance is stated elsewhere in this re ort) p Comments on Appraisal and Report Identification Note any USPAP related Issues requiring disclosure and any State mandated requirements: APPRAISER: Signature: L JG Name: Dennis L. Stover Date Signed: November 17, 2010 State certification #: RL 138906 or State License State: PA Expiration Dale of Cedification or License: 6/30/2011 Effective Date of Appraisal: SUPERVISORY APPRAISER (only if required): Signature: Name: Date Signed: State Certification or State license #: State: Expiration Dale of Certification or License: Supervisory Appraiser Inspection of Subject Property; ? Did Not ? Exterior-only from street ? Interior and Exterior Form ID06 - "WinTOTAL" appraisal software by a la mode, inc. -1-800-ALAMODE GEORGE CLAUSER RIFSIDENTIAL APPRAISAL SUMMARY REPORT 1 Main File No. 10-0621 R-1 Pane #6 10-0621 R-1 Flle No.: 10-0621 R-1 F ° - - tin : NeW Cumberland State: Pq T Code: 17070-1126 Goan Cumberland Le al Descri'on: Deed Book 268 Page 772 w I ' 1 1 Assessor's Parcel #: 26-22-0820-053 Tax Year: 10-11 R.E. Taxes: $ 3,001 Special Assessments: $ NA Borrower if a licable : Samuel L Andes Att : M y. . om Current Owner of Record: CoreE. & Barbara D. Kin Occupant: Owner Tenant vacant ManufacturLaw ed Housin Proct Type: PUD Condominium Cooperative Other describe HOA: $ NA er ear er mordh Market Area Name: New Cumberland Boro h ug Ma Reference: 25420 Census Tract 42041-0107.00 The purpose of this appraisal is to develop an anion of Market Value as defined), or other type of value describe This report reflects the following value if not Current, see comments ; Current the Inspection Date is the Effective Date Retrospective Pros ective ?•, p ?ppTaches developed for this appiralsal: Sales Comparison Approach Cost Approach Income Approach See Reconciliation Comments and Scope of Work ' " Property Rights Appraised: Fee Simple Leasehold Leased Fee Other describe Intended Use: The intended use of this appraisal report is for the client to evaluate the property that is the subject of this appraisal to establish a fair market value. Intended Users b name or e : The Intended user of this appraisal report is the client and no other users are intended . Client Samuel L. Andes Attorney at Law Address: PO Box 168, Lemoyne, PA 17043 Appraiser.- Dennis L. Stover Address: P. O. Box 777, Cam Hill PA 17001-0777 Location: Urban Subufian Rural Predominant One-Unit Housing Present Land Use Change in Land Use Built up: E] Over 75% R 25-75% E] Under 25% Occupancy z; Growth rate: PRICE AGE One-Unit 85% ? Not Likely ? Rapid R Stable ? Slow R Owner $(000) (yrs) 2 4 U i s=; - n t 5% Likel Property values: Increasing ® Stable ? Y ®In Process ? ? Declining ? Tenant 70 Low 0 Multi-Unit 5% * To: vacant land to Demand/supply: ? Shortage ® In Balance ? Over Su l ® V H pp y acant (0-5%) 1.000 High 150 Comm'I 5% residential development Marketing time: Under 3 Mos 3-6 M O . os. ver 6 Mos. Vacant >5% 165 Pred 35 % u+ Market Area Boundaries, Description, and Market Conditions (including support for the above characteristics and trends): The subject neighborhood is the B h f oroug o New Cumberland in the West Shore School District Shopping schools and churches are located within 10-15 minutes of the ' property. Full service shopping is available at the Camp Hill and Capital City malls approximately 10-15 minutes Public school students attend the West Shore School District. Employment centers are located in Hamsbu Cam Hill York and Mechanicsbu . Market conditions i h Y n t e subject neighborhood are considered moderately active with low mortgage interest rates being the primary catalyst Sales in recent weeks have been moderatel a ti T i c ve y yp cal financing for residential properties Includes 80% to 90% loan 1-3 points 5.5-6 5% mortgage . interest rates for up to 30 years Typical marketing time is between 30 and 90 days I : Dimensions: From County Records Site Area: .15 Acres Zoning Classification: R-1 Description: Residential Zoning Compliance: R Legal L at nonconforming randfathered III al ? No zoning Are CC&Rs applicable? Yes No Unknown Have the documents been reviewed? ? Yes ? No Grou d R t d a n en a erobia $ / Highest & Best Use as improved: R Present use, or ? Other use (explain) Actual Use as of Effective Date: Residential Use as appraised in this report Residential z, Summary of Highest & Best Use: The highest and best use of the sublect is the present use O : a Utilities Public Other Provider/Description Of -site Improvements Type Public Private Topography Av 9 Electricity R ? PPL Street Macadam R ? Size Av 1 Gas R ? Natural Curb/Gutter Concrete R ? Shape Av Water R ? Public Sidewalk Concrete D rainage A Sanitary Sewer R ? P bli u c Street Lights Yes Yew A L u Storrs Sewer Yes Ad None Other site elements: Inside Lot Comer Lot Cal de Sac Underground Utilities ? Other describe FEMA Spec'] Rood Hazard Area Yes No FEMA Flood Zone X FEMA M # 42041 C0282E FEMA Ma Date 3/16/2009 Site Comments: There are no apparent easements, encroachments, special assessments slide areas or illegal or legal nonconforming uses k ' nown. General Description E t i D x er or esaiptlon Foundation Easement Heating None L , # of Units One ? Acc.Unft Foundation Concrete Block Slab 0 Area Sq. FL 726 Type FWA # of Stories 2 Exterior Walls BrIckMnyf Crawl Space 0 % Finished 45% Fuel Gas Type R Dot ? Att ? Roof Surf . ace Shingle Basement Partial Calling Sus/Open Design (Style) Traditional Gutters & Dwnspts. Aluminum Sump Pump ? NA Wall s Block/D al cooling R Existing E] Proposed ? Und.Cons. Window Type p No Evid Double Hun Dam ness -1 Roar enc Ca et/Con Central CA Actual Age (Yrs.) 68 StomVScreens Stomi/Existi Settlement No Evidence Outside Entry NA Other ui . ? rs 15 Imestation No Evidence Interior Description Appllances Attic ? None Am mes Car Storage ? None Floors Laminate/Carpet Refrigerator ? Stairs ? Fireplace(s) # 1 FP Woodstove(s) # Garage # of cars ( 2 Tot) Walls Plaster/Drywall Range/Oven R Drop Stair ? Patio Attach . 1 Trim/Finish Wood Disposal R Scuttle R Deck Rear Detach . _ Bath Floor Unyl Dishwasher R Doorway ? Porch Bit In ' : _ Bath Wainscot CT/FG FaDMood R Roar ? Fence p Carport Doors Wood Microwave R Heated ? Pool Drivewa 1 l y m Washer/D er Finished Surface Macadam Finished area above arade contains: 9 Rooms 4 Bedrooms 2 5 Bath . s 2196 S uare Feet of Gross Living Area Above Grade Additional features: Dwelling appears to be well maintained with good housekeeping. An exercise room has been added to the rear of the garage. it has heat and Air Conditioning. For this naport it will not be considered art of the GLA but will be given a value . Describe the condition of the property (including physical, functional and external obsolescence): Subject is a traditional style dwellin i g n average condition with a one car garage. Physical: Depreciation due to age and condition Functional: None External: No adverse locational fe t a ures noted This report is NOT a home inspection and the appraiser only performed a visual inspection of accessible area and that the i appra sal cannot be relied upon to disclose conditions and/or defe t I th c s n e property i ¦ nrrlnrnaraes CW1dde02W7MaIsmode.utThisimmmvhemwAlrrnllmmmm ?..w ZMLnL.71vL14 11P%L ,-...-_ °„ .nog wmauwnmeeeamp Form GPRES2 -'WinTOTAI' appraisal software by a la mode, inc. - 1-800-ALAMODE 3/2007 2007 Main File No. 10-0621 R-1 Pa a #7 RESIDENTIAL APPRAISAL SUMMARY REPORT 10-0621 R-' (" Flle No.: 100621 R-1 VfPCP'J-rl AiA AiA....e ........1 __.. __:____.__. . ... - Q bx -• W, r'.. Pw arula ul Uju auuloet plupeny fur me mree years pnor to the effective date of this appraisal. Data Sources : Cumberland Coun Tax Assessment Office 1st Prior Sub' ct SlIe/Transfer Analysis of sale/bansfer history and/or any current agreement of sale/listing: Date: Not in the last Price: three ears. t w V) Sources : CCTAO 2nd Prior Subject Sale/Transfer , Date: Price: Sources : SALES COMPARISON A FEATURE Address 1825 Bridge New Cumbe Proximity to Sub' ct PPROACH TO VALUE (11 SUBJECT St rland PA 17070-112 de L] The Sales Com oris COMPARABLE SALE # t 204 Haldeman Ave. New Cumberland 019 miles E on Approach was not develo ad for this a COMPARABLE E#2 702 Drexel Hills Blvd. New Cumberland 1 06 i isal. COMPARABLE SALE # 3 8 Drexel Hills Circle New Cumberland Sale Price Sale Price/GLA $ - NA $ /sq. ft " S $ 116.88 /s .1t 205 000 . m les S - $ $ 98 20 /s ft ' 223 200 0.95 miles S _ " S ft $ 218 500 Data Sources Verification Sources VALUE ADJUSTMENTS Sales or Financing Concessions Date of SaloMme Inspection NA DESCRIPTION NA NA NA CPML Courthouse Realtor DESCRIPTION FHA Sellers Help 4/2 Realtor + - $ Adjust. -5 000 . . CPML Courthouse Realtor DESCRIPTION FHA None Known .. Realtor + - $ Adjust. 97.54 /s . CPML Courthouse Realtor DESCRIPTION FHA Seller Help _ Realtor + - $ Adjust -13,00 0 ' ` ` . Rights Appraised Location Site Yew Design (Style) Quality of Construction Age Condition Atwve Grade Fee Simple Suburban .15 Acres Av Traditional Avg 68 AM Toth Bdrms Baths 2/10 MT 27 Fee Simple Suburban .15 Acres E ual Traditional Avg 60 E uaI Total Bdrms Baths 6123/10 MT 75 Fee Simple Suburban .39 Acres E ual Traditional Av 47 Inferior/Dated Bath Total Bdrms Baths 2,500 5.00 0 +5 000 2/26/10 MT 87 Fee Simple Suburban .38 Acres E ual Traditional A 51 Inferior/Dated K&B Total Bdrms Baths 2,500 000 + 10 000 Room Count Gross Li i A 9 4 2.5 6 4 2 +310001 10 5 2.5 9 5 2.5 y ' v ng rea Basement & Finished Rooms Below Grade Functional UBI' Heating/Cooling Energy Eiflcfant Items Gara Ca ort Poroh/Patio/Deck Rre lace Accesso Roam 2,196 s .ft Partial Part Finish RR/Stor/Meth Av GFWA/CA Insulation 1 Car Attached Deck 1 FP Exercise Room 1,754 s .ft Full Part Finished GameRm/Stor/Mec Av GFWA/CA Insulation NA Patio 1 FP NA +8.84 p 2 00 +4,00 0 2,273 s .ft. Full Unfinished Store e/Mech aCA !Built-in NA -1,540 +2,00 0 +3 000 -2 000 +4,00 0 2,240 s .ft Full Part Finished PR/Stor e/Mech Av GHW/NoCA Insulation 2 Car Built-in Patio 1 FP NA 880 +1,000 -2 000 +4 000 EY - n Net Ad stment otal ' - + $ 12840 + $ 2960 + $ 5 380 Adjusted Sale Price Nets _ x 2 : of Com ambles' G Ste. ; 11 1 . ` S 217 840 Grc1SS 11 ?% $ 226160 a G[Q a a18 9 % $ 213 120 `. Summary of Sales Comparison Approach Sales used were all reasonably similar style dwelings in the same neighborhood and subject to reasonably similar amenities. Adjustments were based on market extraction and/or judgment The indicated value range on the above grid extends from $213.120 to $226.160. The indicated market value Is estimated to be less than the upper end of the value range and at $218,000. After an extensive search of available data bases all three comparable sales used were deemed "BEST AVAILABLE" hldlr" V" Selo risal h = 218 000 r%r r a1!" IL a'"a a ¦ Codnlohro 2007 by a la mode. hr.. This time __-'--' - - - _. - . __...._, __ ._ . __.___ ........................Y.n ycnmcaat, iN"c-, d m 11-ak I must ae aQPmmeapa ana aae W Form GPRES2 - WInTOTAL' appraisal software by a la mode, Inc. -1-800-ALAMODE 3/2007 kL APPRAISAL SUMMARY REPORT Main File No. 10-0621 R-1 Pa a #8 10-0621 R-1 File No.: 10-0621 R-1 il? •........ , v ?c 11 u.ra vs, I uu uu51 acn was nor aevelo d Tor thls appraisal. Provide adequate information for replication of the following cost figures and calculations. Support'for Iiie opinion of she value (summary of comparable land sales or other methods for estimating site value): MarketICCTAO ' p a; ESTIMATED REPRODUCTION OR REPLACEMENT COST NEW ource of cost data: NA Qual' rafin from cost service: NA Effective date of cost data: NA Commends on Cost Approach (gross living area calculations, depreciation, etc.): OPINION OF SITE VALUE .............. _----.. _$ 35 000 ------ - ----------------------- -- -- DWELLING S .Ft. $ =$ _ g .Ft @ $ =$ ' o NA 5 .Ft @ S S .F. $ =$ Gera e/Ca ort S .R $ -.- _$ Total Estimate of Cost-New _ =$ Less Physical functional Eztemal De reciation =$ Depreciated Cost of Improvements ..................... _.............. =$ "As4s" Value of Site Improvements .. ._ ....................... $ =$ s ka M, a _$ Estimated Remainin Economic Life rf required): 40 Years INDICATED VALUE BY COST APPROACH INCOME APPROACH TO VALUE If developed The Income A roach was not developed for this appraisal. Estimated Month Market Rent $ NA X Gross Rent Multiplier NA = $ Indicated Value Inwme Approach Summary of Income Approach (including support for market rent and GRM): 1 00 PROJECT INFORMATION FOR PUDa If applicable) 0-The-11 ub act is rt of a Planned Unit Development m Legal Name of Project o Describe common elements and recreational facilities: M Indicated Value : Salsa Comparison Approach $ 218,000 Cost Approach (if developed) $ ND Income Approach (if developed) $ ND Final Reconciliation Insufficient market data was available to process the Income Approach The Sales Comparison Approach is deemed most reliable and given greatest weight. z o . ` a a v w This appraisal is made "as is", ? subject to completion per plans and specifications on the basis of a H t ypothetical Condition that the improvements have been completed, ? subject to the following repairs or alterations on the basis of a Hypothetical Condition that the repairs or alterations have been completed, ? subject to the following required inspection based on the Extraordinary Assumption that the condition or deficiency does not require alteration or repair. If property is sold, <, subject to satisfactory termite and radon certifications with appraised value based on clear test results This report is also subject to other Hypothetical Conditions and/or Extraordinary Assumptions asspecified in the attached addenda. Based on the degree of Inspection of the subject property, as indicated below, defined Scope of Work, Statement of Assumptions and Limiting Conditions, and Appraiser's Certifications, my (our) Opinion of the Market Value (or other specified value type), as defined herein, of the real property that Is the subject of this report Is: $ 218,000 ,as oi: 11/9/10 , which is the effective date of this appraisal. If Indicated above, this Opinion of Value Is subject to Hypothetical Conditions and/or Extraordinary Assumptions Included in this reporL See attached addenda. A true and complete copy of this report contains 25 pages, including exhibits which are considered an integral part of the report. This appraisal report may not be property understood without reference to the Information contained in the complete report Attached Exhibits: ® Scope of Work ® Limiting CondJCertifica6ons ? Narrative Addendum ® Photograph Addenda ® Sketch Addendum ® Map Addenda ? Additional Sales ® Cost Addendum ? Flood Addendum ? Manuf. House Addendum H 'cal Conditions rdinary Assu ons ? ? Client Cordact Samuel L. Andes, Attorney at Law Client Name: Samuel L. Andes. Attorney at Law E-Mail: LavvAndes aol.com Address: PO Box 168, Lemoyne, PA 17043 APPRAISER SUPERVISORY APPRAISER 'required or CO-APPRAISER (ff applicable) ) w tY ppraiser Name: Dennis L. Stover Company: Clauser Real Estate Appraisals Supervisory or Co-Appraiser Name: Company: Phone: (717) 737-7300 Fax (717) 730-0922 E-Mail: dstovermax0comcast.net Phone: Fax E-Mail: Date of Report (Signature): November 17, 2010 License or Certification #: RL 138906 State: PA Designation: Dale of Report (Signature): License or Certification #: State: Designation: Expiration Date of. License or Certification: 6/3012011 Inspection of Subject ® Interior & Exterior ? Exterior Only ? None Data of Ins 11/9110 Expiation Date of License or Certification: Inspection of Subject ? Interior & Exterior ? Exterior Only ? None papa of Inspection: . r%r a a? r-a PWe A ¦ Ca WWW 2007 6Y a IN Min 1W. Thk fmm -- ti , .,...m,..a - ............?_ ---'_-'-- `_.-- . Ift Form GPRES2 -'WinTOTAL' appraisal software by a Is mode, inc. -1-800-ALAMODE 312007 Subject Photo Page Main File No. 10-0621 R-1 Pa a #9 Subject Front 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg Site .15 Acres Oualily Avg Age 68 Subject Rear Subject Street Form PICPO(.SR -'WMTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Main File No 10-0621 R-1 Pzae #101 Subject Interior 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg Site .15 Acres Quality Avg Age 68 Subject Interior Subject Interior Form PIQPDCSI - VmTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Subject Interior Photo Paqe Main File No. 10-0621 R-1 Pa a #11 Subject Interior 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg Site .15 Acres Quality Avg Age 68 Subject Interior Subject Interior Form PIGPD(.SI -'INinTOTAL' appraisal software by a la mode, inc. -1-8DD-ALAMODE Subject Interior Photo Page Main File No. 10.0621 R-1 Pa a #12 Subject Interior 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg site .15 Acres Quality Avg Age 68 Subject Interior Subject Interior Form PICPD(.SI -'WmTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Subject Interior Photo Page Main File No710-0621 R-1 Pa 8#13 Subject Interior 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg Site .15 Acres Quality Avg Age 68 Subject Interior Subject Interior Form PICPDCSI -'OnTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Subject Interior Phntn Perna Subject Interior Photo Pane Main File No. 10-0621 R-1 Pa a #14 Client Samuel L. Andes Attorney at Law ProPertY Address 1825 rid a St C New Cumberland County Cumberland State PA Zip Code 17070-1126 Owner Core E. & Barbara D. Kin Subject Interior 1825 Bridge St Sales Price NA Gross Living Area 2,196 Total Rooms 9 Total Bedrooms 4 Total Bathrooms 2.5 Location Suburban View Avg Site .15 Acres Quality Avg Age 68 Subject Interior Form PICPD(.SI - * MnTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Subject Interior Building Sketch Main File No. 10-0621 R-1 Pa e #15 1825 BRIDGE ST. s t].ar 13- FIRST FLOOR SECOND FLOOR BASEMENT ,v.ar g t cAR DARVws g $ tv.ar ? FAAUr ROOw BEOROOw DEN BATH A BATH t4 ]]AB' IOfONEN ].b g R g Bmaoow eAtN ? LNNG ROO. ONMO ROOw A Rm ROaw rroRADE p BmR00Y wBO1W1M.tLs BED 0 aaa ]xar ]sar NOTF TANDNOTTO- I 9]M b/Apq N" Comments: AREA CALCULATIONS SUMMARY Code Description Not Sin Not Totals GxAl First Floor 1192.00 1192.00 GLA2 Second Floor 1003.50 1003.50 Saw Hasemant 726.00 726.00 GAR Attached Garage 351.00 Exercise Rom -229.50 121.50 Net LIVABLE Area (Rounded) 2196 LIVING AREA BREAKDOWN Breakdown Subtotals First Floor 33.00 x 34.00 112200 . 5.00 x 14.00 70 .00 Second Floor 19.00 x 35.50 674.50 14.00 x 23.50 329.00 4Items (Rounded) 2196 Form SKT.BIdSId -'WInTOTAL' appraisal sottvare by a Is mode, inc. -1-800-ALAMODE Main File No. 10-0621 R-1 Pa a #16 Comparable 1 204 Haldeman Ave. Prox. to Subject 0.19 miles E Sale Price 205,000 Gross Living Area 1,754 Total Rooms 6 Total Bedrooms 4 Total Bathrooms 2 Location Suburban View Equal site .15 Acres Quality Avg Age 60 Comparable 2 702 Drexel Hills Blvd. Prox to Subject 1.06 miles S Sale Price 223,200 Gross Living Area 2,273 Total Rooms 10 Total Bedrooms 5 Total Bathrooms 2.5 Location Suburban View Equal Site .39 Acres Quality Avg Age 47 Comparable 3 8 Drexel Hills Circle Prox to Subject 0.95 miles S Sale Price 218,500 Gross Living Area 2,240 Total Rooms 9 Total Bedrooms 5 Total Bathrooms 2.5 Location Suburban View Equal site .38 Acres ' Quality Avg Age 51 Form PIMUR - VinTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Comparable Photo Page Location Man Main File No. 10-0621 R-1 Pa a #17 GJent Samuel L. Andes Attome at Law Prop!rty Tess 1825 rid a St Icy New Cumberland Cou Cumberland State PA Zip Code 17070.1126 Owner Core E. & Barbara D. Kin a la mode inc: p 4 e%.?':. r ' ¢ 'A .: 4 . me,e,x.r a.lenf.Ne,weyy a t`\`... 5 .. ? ? a _ s low • • 1, 1 •" *1 \ p ¢ . ', ; p p r MM•• ` Vp y Iy O N ? p ?,Y' ' Q.. .,. ?a '1 ?u,ir?h B 4^A •.. y ?, _ T'°°Mbfa ?. ? 4 ST"PUtI 1ts y 4q h ?. ... ,- RP?'?pp9 GMYpyn?.__ \ 11r p • l, \p ? a-S l N. y ?i 1 •- ? ' ?' ¢ P 1 q \ '? "all. bury -,'6 4 ooll" .. t \M1$ ? dD? \\ \Y CIyIWnE P.k ?. . a ,tee CNwlry w°"- Mwly . ' .6 a _- O o / (. M1d 34 *. Pmei.R_ _ PiMn81 _ .-. _- q ? 1 • oo n y x'. Y* w y'. NZI.Y "Al a IIN \ :, a t?' 4 s ' y?<1 b *41 Z dy, a ak a a 4 fM r w p A C/f ?c+roa.a. . ._;? -_.CeaeHa__- - c.d Ciff t as t7 e-f" w; G-Wn F.- $ A `m .a a s3 4 e ! [e f7 W'M"n 4 O 4.tny ..?\ 10 0 enE ? ? pp g ? ?a r ? ,t ii N Prk 7 C ? C gNr.M ? - 4 ' ?8 qk i 40 finF uedlM l,. _._. - Form MAPIOC - NIfInTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Snecial f:nnrlifinnc Main File No. 10-0621 R-1 Pa a #18 Samuel L. Andes Attorney at Law me no. i u-uozi n-1 Prooerty Address 1825 Bridge St Ci New Cumberland County Cumberland State PA Zi Code 17070-1126 Owner Core E. & Barbara D. Kin SPECIAL CONDITIONS ADDENDUM The following checked items are speck special conditions that were identified by the appraiser during the inspection of the subject property, the incomparable sales, and their neighborhoods and locations. 1. The subject is located in a rural area and is less than 25% built-up. The condition is typical and common for the area and DOES NOT affect the market value. 2. Commercial uses are located within the subject's neighborhood. These uses are typical of similar neighborhoods and DO NOT affect the market value. 3. Industrial uses are located within the subject's neighborhood. The presence of industrial uses, is typical for the neighborhood and DOES NOT affect the market value. X_ 4. Vacant and underdeveloped land uses are located within the subject's neighborhood. These uses are typical for the area and DO NOT affect the market value. 5. The predominant value in the neighborhood is less than that of the market value of the subject property. This condition DOES NOT have an adverse affect the market value. 6. The subject property is located In a F. I. A. Identified Flood Zone. 7. Dampness is noted in the basement of the subject. Standing or running water was not present on basement floor. _X_ 8. The subject is older than five(5) years old. All mechanical systems including the heating, electrical and plumbing system appears upon a visual exterior inspection to be in working order. No warranties are implied in this statement. 9. The electrical system was not connected during inspection. -10. The water service was not connected during inspection. 11. The heating system was shut down during inspection. 12. Well and septic are common to the area. 13. Repair items were noted in the comments section of the report. These comments on repair items are for descriptive purposes only and are not required repairs. The repair items are cosmetic in nature and DO NOT affect the market value. _ 14. Subject is new construction and was 90% completed on date of inspection. Compliance and completion inspections suggested prior to settlement. 15. Should property be sold, termite and radon certifications are suggested, with appraised value based on clear results. 16. The land value exceeds 30% of total value due to the high demand for vacant land in this neighborhood. This condition is considered common and typical for the neighborhood and DOES NOT affect the market value. 17. The land value exceeds 30% of total value. This is due to the large size of the site. this condition is considered to be typical and common and DOES NOT affect there market value. 18. Individual adjustments were required that exceed 10%. These adjustments were required due to the lack of more similar comparables on that individual rating. All three comparables are the BEST AVAILABLE. 19. Total adjustments exceed 15%. This is due to the lack of comparables on that Individual rating. All three comparables are the BEST AVAILABLE. _X_ 20. One or more comparable sales are older than six(6) months old. Although there are comparable properties in the subject area, none have sold recently, therefore, sales in excess of six (6) months old had to be used. X_ 21. One or more of the comparables used were in excess of one(1) mile from the subject property. Although there are comparables in the immediate area, none have sold recently. Therefore, it was necessary to use comparable sales outside of the immediate area. All comparables used are located in similar neighborhoods and within the same marketing area. All three comparables used were the BEST AVAILABLE. _ 22. Roofing certification is suggested. _ 23. Plumbing certification is suggested. 24. Electrical certification is suggested. 25. Heating certification is suggested. _ 26. Flood Hazard Insurance is suggested. _ 27. Seller is paying part or all of closing cost. This DOES NOT affect the market value. 28. All comparable sales are closed sales. X_ 29. The subject property has not transferred in the past three years.. 30. This appraisal is a Summary Report with complete data retained in appraisal file. Form SUP -'WinTOTAV appraisal software by a la mode, inc. -1-800-ALAMODE Main File No. 10-0621 R-1 Pa a #19 , r DEFINITION OF MARKET VALUE: The most probable price which a property should bring in a competitive and open market under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeably and assuming the price is not affected by undue stimulus. Implicit in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby. (1) buyer and seller are typically motivated; (2) both parties are well informed or well advised, and each acting in what he considers his own best interest; (3) a reasonable time is allowed for exposure in the open market; (4) payment is made in terms of cash in U.S. dollars or in terms of financial arrangements comparable thereto; and (5) the price represents the normal consideration for the property sold unaffected by special or creative financing or sales concessions* granted by anyone associated with the sale. * Adjustments to the comparables must be made for special or creative financing or sales concessions. No adjustments are necessary for those costs which are normally paid by sellers as a result of tradition or law in a market area; these costs are readily identifiable since the seller pays these costs in virtually all sales transactions. Special or creative financing adjustments can be made to the comparable property by comparisons to financing terms offered by a third party institutional lender that is not already involved in the property or transaction. Any adjustment should not be calculated on a mechanical dollar for dollar cost of the financing or concession but the dollar amount of any adjustment should approximate the markets reaction to the financing or concessions based on the appraiser's judgement. STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION CONTINGENT AND LIMITING CONDITIONS: The appraiser's certification that appears in the appraisal report is subject to the following conditions: 1. The appraiser will not be responsible for matters of a legal nature that affect either the property being appraised or the title to it. The appraiser assumes that the title is good and marketable and, therefore, will not render any opinions about the title. The property is appraised on the basis of it being under responsible ownership. 2. The appraiser has provided a sketch in the appraisal report to show approximate dimensions of the improvements and the sketch is included only to assist the reader of the report in visualizing the property and understanding the appraiser's determination of fts size. 3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency (or other data sources) and has noted in the appraisal report whether the subject site is located in an Identified Special Flood Hazard Area. Because the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding this determination. 4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question, unless specific arrangements to do so have been made beforehand. 5.. The appraiser has estimated the value of the land in the cost approach at its highest and best use and the Improvements at their contributory value. These separate valuations of the land and Improvements must not be used in conjunction with any other appraisal and are invalid if they are so used. 6. The appraiser has noted in the appraisal report any adverse conditions (such as, needed repairs, depreciation, the presence of hazardous wastes, toxic substances, etc.) observed during the inspection of the subject property or that he or she became aware of during the normal research involved in performing the appraisal. Unless otherwise stated in the appraisal report, the appraiser has no knowledge of any hidden or unapparent conditions of the property or adverse environmental conditions (including the presence of hazardous wastes, toxic substances, etc.) that would make the property more or less valuable, and has assumed that there are no such conditions and makes no guarantees or warranties, express or implied, regarding the condition of the property. The ' appraiser will not be responsible for any such conditions that do exist or for any engineering or testing that might be required to discover whether such conditions exist Because the appraiser is not an expert in the field of environmental hazards, the appraisal report must not be considered as an environmental assessment of the property. 7. The appraiser obtained the information, estimates, and opinions that were expressed in the appraisal report from sources that he or she considers to be reliable and believes them to be true and correct The appraiser does not assume responsibility for the accuracy of such items that were furnished by other parties. 8. The appraiser will not disclose the contents of the appraisal report except as provided for in the Uniform Standards of Professional Appraisal Practice 9. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that Is subject to satisfactory completion, repairs, or alterations on the assumption that completion of the improvements will be performed in a workmanlike manner. ' 10. The appraiser most provide his or her prior written consent before the lender/cikrd specified in the appraisal report can distribute the appraisal report (including conclusions about the property value, the appraiser's identity and professional designations, and references 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 mortgage ' insurer, consultants; professional appraisal organizations; any state or federally approved financial institution; or any department agency, or instrumentality of the United States or any state or the District of Columbia; except that the lender/client may distribute the property description section of the report only to data collection or reporting service(s) without having to obtain the appraiser's prior written consent The appraiser's written consent and approval must also be obtained before the appraisal can be conveyed by anyone to the public through advertising, public relations, news, sales, or other media. oume Mac rurm WIN o-yli Page 1 of 2 Fannie Mae Form 10048 6-93 GEORGE CLAUSER Form ACR - "WinTOTAL" appraisal software by a la mode, inc. -1-800-ALAMODE Main Flle No. 10-0621 R-1 Pa a #20 I' I APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees that: 1. 1 have researched the subject market area and have selected a minimum of three recent sales of properties most similar and proximate to the subject property for consideration in the sales comparison analysis and have made a dollar adjustment when appropriate to reflect the market reaction to those items of significant variation. If a significant item in a comparable property is superior to, or more favorable than, the subject property, I have made a negative adjustment to reduce the adjusted sales price of the comparable and, if a significant hem in a comparable property is inferior to, or less favorable than the subject property, I have made a positive adjustment to increase the adjusted sales price of the comparable. 2. 1 have taken into consideration the factors that have an impact on value in my development of the estimate of market value in the appraisal report I have not knowingly withheld any significant information from the appraisal report and I believe, to the best of my knowledge, that all statements and information in the appraisal report are true and correct 3. 1 stated in the appraisal report only my own personal, unbiased, and professional analysis, opinions, and conclusions, which are subject only to the contingent and limiting conditions specified in this form. 4. 1 have no present or prospective interest in the property that is the subject to this report, and I have no present or prospective personal interest or bias with respect to the participants in the transaction. I did not base, either partially or completely, my analysis and/or the estimate of market value in the appraisal report on the race, color, religion, sex, handicap, familial status, or national origin of either the prospective owners or occupants of the subject property or of the present owners or occupants of the properties in the vicinity of the subject property. 5. 1 have no present or contemplated future interest in the subject property, and neither my current or future employment nor my compensation for performing this appraisal is contingent on the appraised value of the property. 6. 1 was not required to report a predetermined value or direction in value that favors the cause of the client or any related party, the amount of the value estimate, the attainment of a specific result, or the occurrence of a subsequent event In order to receive my compensation and/or employment for performing the appraisal. I did not base the appraisal report on a requested minimum valuation, a specific valuation, or the need to approve a specific mortgage loan. 7. 1 performed this appraisal in conformity with the Uniform Standards of Professional Appraisal Practice that were adopted and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place as of the effective date of this appraisal, with the exception of the departure provision of those ' Standards, which does not apply. I acknowledge that an estimate of a reasonable time for exposure in the open market is a condition in the definition of market value and the estimate I developed is consistent with the marketing time noted in the neighborhood section of this report, unless I have otherwise stated in the reconciliation section. 8. 1 have personally inspected the interior and exterior areas of the subject property and the exterior of all properties listed as comparables in the appraisal report I further certify that I have noted any apparent or known adverse conditions in the subject improvements, on the subject site, or on any site within the immediate vicinity of the subject property of which I am aware and have made adjustments for these adverse conditions in my analysis of the property value to the extent that I had market evidence to support them. I have also commented about the effect of the adverse conditions on the marketability of the subject property. 9. 1 personally prepared all conclusions and opinions about the real estate that were set forth in the appraisal report ti 1 relied on significant professional assistance from any individual or individuals in the performance of the appraisal or the preparation of the appraisal report, I have named such individual(s) and disclosed the specific tasks performed by them in the reconciliation section of this appraisal report I certify that any individual so named is qualified to perform the tasks. I have not authorized anyone to make a change to any item in the report, therefore, I an unauthorized change is made to the appraisal report, 1 will take. no responsibility for it J SUPERVISORY APPRAISER'S CERTIFICATION: If a supervisory appraiser signed the appraisal report, he or she certifies and agrees that I directly supervise the appraiser who prepared the appraisal report, have reviewed the appraisal report, agree with the statements and conclusions of the appraiser, agree to be bound by the appraiser's certifications numbered 4 through 7 above, and am taking full responsibility for the appraisal and the appraisal report Signature: _J. z Signature ADDRESS OF PROPERTY APPRAISED: 1825 Bridge St, New Cumberland PA 17070-1126 APPRAISER: SUPERVISORY APPRAISER (only if required): Name: Dennis L. Stover Name: Date Signed: November 17. 2010 Date Signed: State Certification #: RL 138906 State Certification #: or State License or State License #: State: PA State: Expiration Date of Certification or License: 6/30/2011 Expiration Date of Certification or License: ? Did ? Did Not Inspect Property Freddie Mac Form 439 6-93 Page 2 of 2 Fannie Mae Form 10048 6-93 Form ACR - WOW appraisal software by a la mode, Inc. -1-800-ALAMODE J i Main File No. 10-0621 R-1 Pa a #21 Sinnntwn rmmnlaannn -' ------' - f116 IYU. 1 V-VOL 1 R- I Lkut Samuel L. Andes Attorney at Law Property Address 1825 Bridge St Ci New Cumberland Coun Cumberland State PA Zi Code 17070-1126 Owner Core E. & Barbara D. Kin ' ELECTRONIC SIGNATURE COMPLIANCE Wintotal and Project 2000 are fully ASB (Appraisal Standards Board) compliant in their security. The signatures on this report have not been altered in any way and the digital signatures are to be considered as original. J Form SUP - "WinTOTAL' appraisal software by a la mode, inc. -1-800-ALAMODE Main File No. 10-0621 R-1 Pa a #22 Certificate .,dent Samuel L. Andes Attorney at Law Property Ad ss 1825 ld a St city New Cumberland GOUfltY Cumberland State PA Zip Code 17070-1126 Owner Core E. & Barbara D. Kin Commoaweaith of Pennsylvania Dept nen State Bureau of Profeisionsiidat€onal Affairs P4 Bos 2941arr3 rg.P `0105-2649 Certificate Type CertMed Residential Appraiser f` DENNIS L MVER Certiffeate USADEM ST Number ABDDLETOWN PA; POP RL138906 t.R utthor¢uFad.rt omyWio.d I 08 10589527 Certiiieate status Active Initial Certification Hate 1112612003 Expiration Date. 06MO12011 Form MAP.PLAT -'WinTOTAL' appraisal software by a Is mode, inc. -1-8D0-ALAMODE Qualifications Main File No. 10-0621 R-1 Pa a #23 Dennis L. Stover, GRI, CSP PA Certified Residential Real Estate Appraiser Certification Number RL 138906 CLAUSER REAL ESTATE APPRAISALS, LLC PO Box 777 Camp Hill, PA 17001-0777 Phone (717) 737-7300 Fax (717) 730-0922 E-mail address: dstovermax@comcast.net www.claus§EVRn?usals.com QUALIFICATION SHEET EDUCATION: Harrisburg Area community College Associate in Business Administration Graduate Realtor Institute GRI Designation New Home Sales Professional Course CSP Designation Institute of Real Estate Studies USPAP- March 1998 USPAP- January 2002 Basics of Residential Valuation & Sales Comparison Approach-April 2002 Basic Income Property Valuation-January 2002 Advanced Income Property Valuation-January 2002 Residential Constnrction-September 2002 National USPAP-September 2003 All courses to complete Pennsylvania State Residential Certification- All continuing education courses to maintain current license PROFESSIONAL MEMBERS AMSIGNATION- Pennsylvania State Certified Residential Real Estate Appraiser #RL 138906 Pennsylvania Real Estate Salesperson- License #RS 150605A National Association of Realtors® Pennsylvania Association of Realtors® Greater Harrisburg Association of RealtorsO Form MAP.PLAT -'WinTOTAL' appraisal software by a la mode, Inc. -1-B00-ALAMODE Main File No. 10-0621 R-1 Pa a #24 Qualifications 1 11 1 REAL ESTATE EXPER 2003-Present 2004-Present 1997-2003 1991-2004 1986-1991 IENCE: PA State Certified Residential Real Estate Appraiser, George C. Clauser Real Estate Appraisals Realtor, Union Realty, Inc., Middletown, PA Assistant to the Appraises, George C. Clauser Real Estate Appraisals Realtor, RE MAX Realty Professionals, Harrisburg, PA Realtor, The Homestead Group Realtor, Middletown/Harrisburg TYPES OF APPRAISALS COMPLETED: RESIDENT1AIr Single Family Residences, Multi-family 14 units, and land. Appraisal samples upon request. APPRAISALS HAVE BEEN COMPLETED FOR: Adams County National Bank National City Mortgage Allied Home Mortgage Capital Corp. National Penn Bank Americhobe Federal Credit Union Northwest Savings Bank Centric Bank Omega Bank Community First Fund Orrstown Bank First National Bank Pennsylvania State Bank First National Bank of Marysville PNC Fulton Bank Province Bank Graystone Bank Prudential Relocation Harbortown Mortgage PSP Financial rte9?Y k Sovereign Bank Jonestown Bank Sterling Financial Corp. Legacy Bank Wachovia M & T Bank Wells Fargo Mellon Bank Members First Federal Credit Union Mid Penn Bank Members First Federal Credit Union Metro Bank Form MAP.PLAT-'MnTOTAL' appraisal software by a Is mode, inc. -1-800-ALAMODE Main File No. 1101080 Page #2 of 27 SUMMARY APPRAISAL REPORT LOCATED AT: 512 AQUINAS AVE FAYETTEVILLE, NC 28311-1125 LOT # 2, SEC 1, COLLEGE DOWNS II FOR: COREY KING 118 LEE ANN CT ENOLA, PA 17025 AS OF: 02/01/2011 BY: KEITH HADDING ARSENAL APPRAISAL, INC. Form GA1 LT - "WinTOTAL" appraisal software by a la mode, inc. -1-800-ALAMODE Hadding Realty & Appraisal Services a' File No. 101080 P e o 7 Uniform Residential Anoraisal Renort Fnolf 11mnan The pu ose of this summa appraisal report is to provide the lender/client with an accurate, and adequately supported, opinion of the market value of the subject property. ProAddress 512AQUINASAVE C' FAYETTEVILLE State NC Zip Code 28311-1125 Borrower KING COREY Owner of Public Record KING COREY & BARBARA County CUMBERLAND Le al Descrilion LOT $ 2 SEC 1 COLLEGE DOWNS II Assessor's Parcel # 0521-92-2321 Tax Year 2010 R.E. Taxes $ 903.57 Neighborhood Name COLLEGE DOWNS II Ma Reference 22180 Census Tract 0025.04 Occupant Owner Tenant Vacant Special Assessments $ N/A PUD HOA $ per year per month " Property Rights Appraised Fee Simple Leasehold Other describe Assignment Type Purchase Transaction Refinance Transaction ® Other describe DIVISION OF ASSETS Lender/Clent KING COREY Address 118 LEE ANN CTENOLA PA. 17025 Is the subject property cure offered for sale or has it been offered for sale in the twelve months prior to the effective date of this appraisal? Yes No Report data sources used, offering price(s), and dates . A SEARCH OF LOCAL MILS DID NOT REVEAL ANY CURRENT LISTING FOR SUBJECT. I ? did ® did not analyze the contract for sale for the subject purchase transaction. Explain the results of the analysis of the contract for sale or why the analysis was not performed. NO CONTRACT WAS MADE AVAILABLE OR IS KNOWN. Contract Price $ N/A Date of Contract N/A Is the property seller the owner of pubic record? Z Yes ? No Data Sources I Is there any financial assistance (ban charges, sale concessions, gift or downpayment assistance, etc.) to be paid by any party on behalf of the borower? ® Yes ? No If Yes, report the total dollar amount and describe the items to be aid. Note: Race and the mist com ition of the ne hborhood are not a isal factors. low -'WoRaMe Location Urban Suburban Rural Property Values Increasing Stable Declining PRICE AGE One-Unit 75% BuiR-U Over 75% 25-75% Under 25% Demand/Supply Shortage In Balance Over Supply $(000) yrs 2-4 Unit % Growth Rapid Stable Slow Marketing Under 3 mths 3-6 mths Over 6 mths 3o Low 0 Multi-Family % Neighborhood Boundaries DE PAUL DR TO THE NORTH KENNICOT RD TO THE EAST ANDREWS 200 High 60 Commercial % RD TO THE SOUTH AND MCARTHUR RD TO THE WEST. 100 Prod. 30 Other 25% Neighborhood Description THE SUBJECT PROPERTY IS IN THE TOWN OF FAYETTEVILLE AND HAS CLOSE ACCESS TO HWY 401. SUBJECT PROPERTY IS WITHIN 10-15 MINUTES TO AMENITIES BUSINESS SHOPPING PLACES OF WORSHIP AND SCHOOLS. ` OTHER PRESENT LAND USE VACANT Market Conditions (including support for the above conclusions I HAVE CONSIDERED RELEVANT COMPETITIVE LISTINGS AND/OR CONTRACT OFFERINGS IN THE PERFORMANCE OF THIS APPRAISAL AND IN THE TRENDING INFORMATION REPORTED IN THIS SECTION. IF A TREND IS INDICATED, I HAVE NOTED AND PROVIDED RELEVANT DATA ON 1004 MC. Dimensions SEE PLAT MAP Area .29 ACRE Shape SEE PLAT MAP View RESIDENTIAL S ec'db Zoni Classification PND Zoning Description PLANNED DEVELOPMENT Zon' Com ante Legal Legal Nonconforming Grandfathered Use) 0 No Zoning Illegal describe Is the highest and best use of subject property as improved or as proposed per plans and specifications) the resent use? Yes No If No, describe lhNfOes Public Other (describe) Public Other describe) Off-sae lm rovements-Tye Public Private Electric' Water Street ASPHALT Gas 0 [0 BOTTLED Sanity Sewer ® SEPTIC Alley 11 FEMA Special Fbod Hazard Area Yes No FEMA Flood Zone X FEMA M # 3720052100J FEMA M Date 12118/2007 Are the utilities and off-site improvements typical for the market areal Yes No If No, describe Are there a adverse site conditions or external factors easements, encroachments, environmental conditions, land uses, etc.)? Yes No If Yes, describe NO APPARENT ENCROACHMENT OR SITE CONDITIONS WERE OBSERVED. SEPTIC ARE PERMANENT ADEQUATE & CUSTOMARY FOR THIS AREA. Units One One with Accesso Unit Concrete Slab Crawl Space Foundation Weis BRICK & BLCK/AVG Floors CPT/LINO/AVG # of Stories 1 Fun Basement Partial Basement Exterior Walls FRAME/AVG Walls DRYWALUAVG Type Det At S-Det./End Unit Basement Area s .it Roof Surface COMP SHNGL/AVG TriMFlnish WOOD/AVG Existino F1 Prosari Under Const Basement Finish % Gutters & Dowre outs NONE Bath Floor LINO/AVG Design (Style) RANCH Outside Entry/Exit Sum Pump Window Type VINYLIAVG Bath Wainscot 1 PC/ AVG Year Built 1993 Evidence of f-I Infestation Storm SasMnsulated INSULATED/AVG Storage None Effective A rs16 ass ? Settlement Screens SCREEN 1AAVG vewa # of Cars 1 Attic None Heating FWA IL4 HWBB Radiant Amenities Woodstove s # [Day Surface CONCRETE DroStair Stairs Other Fuel ELEC Rre ce s # 1 Fence PART ra e # of Cars 1 Floor Scuttle Cooli Central Air Conditiod Patio/Deck Porch ort # of Cars Flnished Heated Individual 10 Other ? Pool ? Other ? Dot ? Built-in Appliances Refrigerator Range/Oven Dishwasher Disposal Microw ave E Washer /Dryer Other describe RANGE HOOD Finished area above grade contains: 6 Rooms 3 Bedrooms 2 Baths 1,127 Square Feet of Gross Living Area Above Grade Additionalfeabures (special energy efficient items at.). PARTIAL PRIVACY FENCE ONE SIDE IN REAR CATHEDRAL CEILING ONE PC TUBS GARAGE DOOR OPENER. Describe the conclbn of property mclodi needed repairs, deterioration, renovations, remodeln etc.. SUBJECT IS OF AVG QUALITY AND DESIGN IMPROVEMENTS ARE IN OVER ALL GOOD CONDITION. NO DEFERRED MAINTENANCE WAS NOTED OR OBSERVED. Are there any physical deficiencies or adverse conditions that affect the livability, soundness, or structural integrity of the property? Yes 13 No ff Yes, describe Does the property generally conform to then ' hborhood (functional utility, style, condition, use, construction, etc.)? Yes No If No, describe Freddie Mac Form 70 March 2005 Page 1 of 6 Fannie Mae Form 1004 March 2005 Form 1004 - "WinTOTAL" appraisal software by a la mode, inc. -1-800-ALAMODE Uniform Residential Appraisal Report He# 1101080 There ke 13 'comparable properties currently offered for sale in the subject neighborhood ranging in price from $ B2,000 to $ 174,900 There are 9 comparable sales in the subject neighborhood within the past twelve months ranging in sale rice from $ 77,000 to $ 105,000 FEATURE SUBJECT COMPARABLE SALE # 1 COMPARABLE SALE # 2 COMPARABLE SALE # 3 Address 512 AQUINAS AVE FAYETTEVILLE NC 28311-1125 704 APPALACHIAN DR FAYETTEVILLE NC 28311 6615 RADLIFF CT FAYETTEVILLE NC 28311 1010 XAVIER DR FAYETTEVILLE NC 28311 Proxim' to Subject APPROX..04 MILE SW APPROX..19 MILE SW APPROX..48 MILE W Sale Price $ N/A $ 107,000 ,. $ 77,000 102,000 Sale Price/Gross Liv. Area $ s .fL $ 83.86 s .ft " $ 64.11 Data Sources MLS REALTOR MLS REALTOR MLS REALTOR Verification Sources SITE DOM 22 SITE DOM 161 SITE DOM 120 VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION + - $ Adjustment DESCRIPTION + - $ Adjustment DESCRIPTION + - $ Adjustment Sales or Financing Concessions VA NO KNOWN FHA NO KNOWN CONV NO KNOWN Date of Sale?Tme 10/01/2010 01/2512011 1112212010 Location COLLEGE DW COLLEGE DW COLLEGE DW COLLEGE DW Leasehold/Fee Simple FEE SIMPLE FEE SIMPLE FEE SIMPLE FEE SIMPLE Site .29 ACRE < 1 ACRE .28 < 1 ACRE .26 < 1 ACRE .27 Mew RESIDENTIAL RESIDENTIAL RESIDENTIAL RESIDENTIAL Des' n Style) RANCH RANCH RANCH RANCH Quality of Construction AVERAGE AVERAGE AVERAGE AVERAGE Actual Age 18 17 -500 35 +8,500 36 +9,000 Condition GOOD GOOD AVERAGE +5,00 0 GOOD Above Grade Total - - Bdrms. Baths Total 8drms. Batlis Total Bdrms . Baths Toth Bdrms. Baths Room Count 6 F3 2 5 3 2 6 3 2 6 4 1.5 +1,000 Gross Living Area 1,127 s .ft. 1,276 s .ft -5,200 1,201 s .ft. -2,600 1,333 s .ft -7,200 Basement & Finished Rooms Below Grade NONE NONE NONE NONE Functional Utility AVERAGE AVERAGE AVERAGE AVERAGE Heatiooti FWA/CAC FWAICAC FWA/CAC FWA/CAC ,• Energy Efficient items AVERAGE AVERAGE AVERAGE AVERAGE Garage/Carport SGL GAR ATT SGL GAR ATT SGL CPT ATT +2,000 SGL GAR ATT Porch/Pa6NDeck PCH DK ALM SCPCH PCH -2,000 PCH STP +1.00 0 PCH PAT +500 • AMENITIES FIR, PT FEN FP +500 NONE +1,50 0 FEN +500 • Net Adjustment (Total) + - $ -7,2001 + I s 15,400 +- ? - $ 3,800 Adjusted Sale Price of Co arables Net Adj. 6.7% Gross Ad', 7.7% $ 99 800 Net Adj. 20.0%1 Gross Adj, 26.8 %1 $ 92 400 Net Adj. 3.7% Gross Adj. 17.8%, $ 105,800 I did did not research the sale or transfer his to of the subject property and comparabl e sales. 0 not, o plain M research did did not reveal any prior sales or transfers of the subject property for the twee ears dorto the effective date of this appraisal. Data Solaces MLS DEED research did did not reveal a prior sales or transfers of the comparable sales for the year prior to the date of sale of the comparable sale. Data Sources MLS DEED Report the results of the research and analysis of the Prior sale or transfer history of the subject roand co arable sales (report additional nor sales on Page 3). ITEM SUBJECT COMPARABLE SALE #1 COMPARABLE SALE #2 COMPARABLE SALE #3 Date of Prior Sale/Transfer NO KNOWN X 36 MO NO KNOWN X 12 MO NO KNOWN X 12 MO NO KNOWN X 12 MO Price of Prior SaWTransfer N/A WA NIA N/A Data Sources PER PUB REC DEED PER PUB REC DEED PER PUB REC PER PUB REC DEED Effective Date of Data Sources 02/02/2011 02/0212011 02102/2011 02/02/2011 Analysis of prior sale or transfer his of the subject property and comparable sales NO KNOWN TRANSFERS OF SUBJECT IN PREVIOUS 36 MONTHS. NO OTHER KNOWN TRANSFERS OF COMPS IN THE PREVIOUS 12 MONTHS AND NONE ARE CURRENTLY LISTED FOR SALE EXCEPT THOSE NOTED AS CURRENT ACTIVE LISTINGS. Summa of Sales Comparison Approach THE COMPS SELECTED ARE LOCATED IN SAME MARKET AREA AND PROXIMITY TO SCHOOLS SHOPPING AND EMPLOYMENT CENTERS. THEY ARE CONSIDERED THE BEST AND MOST RECENT INDICATORS OF VALUE FOR THE SUBJECT PROPERTY. NO PERSONAL PROPERTY WAS GIVEN ANY VALUE CONSIDERATION IN FINAL RECONCILIATION OF VALUE. DUE TO LOW VALUE RANGE AND NUMBER OF REQUIRED ADJUSTMENTS SOME ADJUSTMENTS EXCEED PREFERRED RANGES. Indicated Value b Sales Comparison Approach $ 95,000 Indksaed Value . SNes Com ouch $ 96,000 Cost A roach (If develo ) $ 95 85o Income Approach (ti devel ) $ 95,250 GIVEN PREDOMINANCE OF OWNER OCCUPANCY & PRESENCE OF MARKET DATA THE SALES COMPARISON APPROACH SERVES AS THE BEST INDICATOR OF MARKET VALUE. THIS APPRAISAL IS NOT A HOME INSPECTION NOR A GUARANTEE OF CONDITION. This appraisal is made [9 'as is", [] subject to completion per plans and specifications on the basis of a hypothetkal condition that the improvements have been completed, E] subject to tie following repairs or alterations on the basis of a hypothetical condition that the repairs or alterations have been completed, or ? subject to the folbwi red inspection based on the ahordirmy assumption that the condition or deficient does not require alteration or air. Based on a complete visual Inspection of the interior and exterior areas of the subject properly, defined scope of work, statement of assumptions and limiting condftlom and approlser's certification, my (our) opinion of the marled: value, as defined, of the red properly that is the subject of this report is $ $ 95,000 seat 02/01/2011 wh)ch Is the date of inspection and the effective date of this aooralmi Freddie Mac Fonn 70 March 2005 Page 2 of 6 Fannie Mae Form 1004 March 2005 Form 1004-'WinTOTAL' appraisal software by a la mode, inc. -1-B00-ALAMODE Uniform Residential Appraisal Report Fde# 1101080 THE'INTENDEDt1SER OF THIS APPRAISAL REPORT IS THE CLIENT. THE INTENDED USE IS TO EVALUATE THE PROPERTY THAT IS THE SUBJECT OF THIS APPRAISAL FOR DIVISION OF ASSETS SUBJECT TO THE STATED SCOPE OF WORK PURPOSE OF THE APPRAISAL REPORTING REQUIREMENTS OF TFIIS APPRAISAL REPORT FORM AND DEFINITION OF MARKET VALUE. NO ADDITIONAL INTENDED USERS ARE IDENTIFIED BY THE APPRAISER. 71 Provide adequate information for the Iender/clientto replicate the below, cost figures and calculations. Support for the opinion of site value (summary of comparable land sales or other methods for estimating site value SINGLE FAMILY SITES IN THIS MARKET AREA RANGE FROM $10,000- $25,000 DEPENDING ON AMENITIES RESTRICTIONS INGRESS EGRESS AND TOPO. SUBJECT IS TYPICAL FOR THIS AREA. SUBJECT SLOPES SLIGHTLY TO REAR AND HAS GOOD EGRESS. ESTIMATED REPRODUCTION OR REPLACEMENT COST NEW OPINION OF SITE VALUE ...... .......................................... _................... =$ 18,000 . Source at cost data MARSHALL & SWIFT DWELLING 1 127 5 .Ft @ $ 80.00 ............. =$ 90,160 Oua' rating from cost service AVG Effective date of cost data 12/2009 S .Ft $ ............. =$ Commends on Cost Approach (gross living area calculations, depreciation, etc. APPLIANCES PCH DK FEN............. =$ 8,000 AVG QUALITY IN GOOD CONDITION ADJUSTED FOR Garage/Carport 367 S ,FL $ 20.00 ............. =$ 7,340 REFINEMENTS AND ROUNDED. Total Estimate of Cost-New ............ =$ 105,500 Less Physical Functional Edemal THE COST APPROACH IS NOT APPLICABLE OR RELIABLE FOR Depreciation 31,6501 =$ 31,650) HOUSES OVER ONE YEAR OLD DUE TO THE NECESSITY OF D reciam Cost of Improvements .... ............................................... =$ 73,850 LARGE DEPRECIATION ESTIMATES FOR OLDER HOUSES. "As-is" Value of Site Improvements .................... ......_..... =$ 4,000 Estimated Remaining Economic Life (HUD and VA only 42 Years INDICATED VALUE BY COST APPROACH ._____...... _....................... =$ 95,850 Estimated Monthly Market Rent $ 750 X Gross Rent Multiplier 127 = $ 95,250 Indicated Value b Income Approach Summary of Income Approach tndudi support for market rent and GRM LIMITED RENTAL DATA IN THIS AREA AVAILABLE ON PUBLIC RECORDS AND THEREFORE DATA WAS OBTAINED DIRECTLY FROM MANAGEMENT AND REALTORS IN THIS MARKET AREA. Is the d er/bullder in cordml of the Homeowners' Association OA ? Yes No Unit e s Detached Attached Provide the following information for PUDs ONLY 'd the develoer/buiMer is in control of the HOA and the subject property is an attached dwelling unit Legal Name of Pro' ct Total number of phases Total number of units Total number of units sold Total number of units rented Total number of units for sale Data souroe s Was the prooct created b the corxersion at edsti building(s) into a PUD1 Yes No If Yes, date of conversion. Does the project contain a multi-dwelling urits7 Yes No Data Source Are the units, common dements, and recreation tacilities complete? Yes No If No, describe the status of completion. Are the common elements leased to orb the Homeowners' Assoclation? Yes No If Yes describe the rental terms and options. Describe common demerits and recreational facilities. Freddie Mac Farm 70 March 2005 Page 3 of 6 Fannie Mae Form 1004 March 2005 Form 1004 -'WInTOTAL' appraisal software by a la mode, inc, -1-800-ALAMODE Main File No.1101080 P 6 of 27 Unitorm Residential Appraisal Report Fle# 1101080 This report form is designed to report an appraisal of a one-unit property or a one-unit property with an accessory unit; including a unit in a planned unit development (PUD). This report form is not designed to report an appraisal of a manufactured home or a unit in a condominium or cooperative project. This appraisal report is subject to the following scope of work, intended use, intended user, definition of market value, statement of assumptions and limiting conditions, and certifications. Modifications, additions, or deletions to the intended use, intended user, definition of market value, or assumptions and limiting conditions are not permitted. The appraiser may expand the scope of work to include any additional research or analysis necessary based on the complexity of this appraisal assignment. Modifications or deletions to the certifications are also not permitted. However, additional certifications that do not constitute material alterations to this appraisal report, such as those required by law or those related to the appraiser's continuing education or membership in an appraisal organization, are permitted. SCOPE OF WORK: The scope of work for this appraisal is defined by the complexity of this appraisal assignment and the reporting requirements of this appraisal report form, including the following definition of market value, statement of assumptions and limiting conditions, and certifications. The appraiser must, at a minimum: (1) perform a complete visual inspection of the interior and exterior areas of the subject property, (2) inspect the neighborhood, (3) inspect each of the comparable sales from at least the street, (4) research, verify, and analyze data from reliable public and/or private sources, and (5) report his or her analysis, opinions, and conclusions in this appraisal report. INTENDED USE: The intended use of this appraisal report Is for the lender/client to evaluate the property that is the subject of this appraisal for a mortgage finance transaction. INTENDED USER: The intended user of this appraisal report is the lender/client. DEFINITION OF MARKET VALUE: The most probable price which a property should bring in a competitive and open market under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeably and assuming the price is not affected by undue stimulus. Implicit in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby: (1) buyer and seller are typically motivated; (2) both parties are well informed or well advised, and each acting in what he or she considers his or her own best interest; (3) a reasonable time is allowed for exposure in the open market; (4) payment is made in terms of cash in U. S. dollars or in terms of financial arrangements comparable thereto; and (5) the price represents the normal consideration for the property sold unaffected by special or creative financing or sales concessions* granted by anyone associated with the sale. *Adjustments to the comparables must be made for special or creative financing or sales concessions. No adjustments are necessary for those costs which are normally paid by sellers as a result of tradition or law in a market area; these costs are readily identifiable since the seller pays these costs in virtually all sales transactions. Special or creative financing adjustments can be made to the comparable property by comparisons to financing terms offered by a third party institutional lender that is not already involved in the property or transaction. Any adjustment should not be calculated on a mechanical dollar for dollar cost of the financing or concession but the dollar amount of any adjustment should approximate the market's reaction to the financing or concessions based on the appraiser's judgment. STATEMENT OF ASSUMPTIONS AND LIMITING CONDITIONS: The appraiser's certification in this report is subject to the following assumptions and limiting conditions: 1. The appraiser will not be responsible for matters of a legal nature that affect either the property being appraised or the title to it, except for information that he or she became aware of during the research involved in performing this appraisal. The appraiser assumes that the title is good and marketable and will not render any opinions about the title. 2. The appraiser has provided a sketch in this appraisal report to show the approximate dimensions of the improvements. The sketch is included only to assist the reader in visualizing the property and understanding the appraiser's determination of its size. 3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency (or other data sources) and has noted in this appraisal report whether any portion of the subject site is located in an identified Special Flood Hazard Area. Because the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding this determination. 4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question, unless specific arrangements to do so have been made beforehand, or as otherwise required by law. 5. The appraiser has noted In this appraisal report any adverse conditions (such as needed repairs, deterioration, the presence of hazardous wastes, toxic substances, etc.) observed during the Inspection of the subject property or that he or she became aware of during the research involved in performing the appraisal. Unless otherwise stated in this appraisal report, the appraiser has no knowledge of any hidden or unapparent physical deficiencies or adverse conditions of the property (such as, but not limited to, needed repairs, deterioration, the presence of hazardous wastes, toxic substances, adverse environmental conditions, etc.) that would make the property less valuable, and has assumed that there are no such conditions and makes no guarantees or warranties, express or implied. The appraiser will not be responsible for any such conditions that do exist or for any engineering or testing that might be required to discover whether such conditions exist Because the appraiser is not an expert in the field of environmental hazards, this appraisal report must not be considered as an environmental assessment of the property. 6. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfactory completion, repairs, or alterations on the assumption that the completion, repairs, or alterations of the subject property will be performed in a professional manner. rreauie mac corm ru marcn zuuo Page 4 of 6 Fannie Mae Form 1004 March 2005 Form 1004-"WInTOTAV appraisal software by a la mode, inc. -1-800-ALAMODE Main File No. 11010 0 Pa a #7 of 27 Uniform Residential Appraisal Report File# 1101060 APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees that: 1. 1 have, at a minimum, developed and reported this appraisal in accordance with the scope of work requirements stated in this appraisal report. 2. 1 performed a complete visual inspection of the interior and exterior areas of the subject property. I reported the condition of the improvements in factual, specific terms. 1 identified and reported the physical deficiencies that could affect the livability, soundness, or structural integrity of the property. 3. 1 performed this appraisal in accordance with the requirements of the Uniform Standards of Professional Appraisal Practice that were adopted and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place at the time this appraisal report was prepared. 4. 1 developed my opinion of the market value of the real property that is the subject of this report based on the sales comparison approach to value. I have adequate comparable market data to develop a reliable sales comparison approach for this appraisal assignment. I further certify that I considered the cost and income approaches to value but did not develop them, unless otherwise indicated in this report. 5. 1 researched, verified, analyzed, and reported on any current agreement for sale for the subject property, any offering for sale of the subject property in the twelve months prior to the effective date of this appraisal, and the prior sales of the subject property for a minimum of three years prior to the effective date of this appraisal, unless otherwise indicated in this report 6. 1 researched, verified, analyzed, and reported on the prior sales of the comparable sales for a minimum of one year prior to the date of sale of the comparable sale, unless otherwise indicated in this report. 7. 1 selected and used comparable sales that are locationally, physically, and functionally the most similar to the subject property. 8. 1 have not used comparable sales that were the result of combining a land sale with the contract purchase price of a home that has been built or will be built on the land. 9. 1 have reported adjustments to the comparable sales that reflect the market's reaction to the differences between the subject property and the comparable sales. 10. 1 verified, from a disinterested source, all information in this report that was provided by parties who have a financial interest in the sale or financing of the subject property. 11. 1 have knowledge and experience in appraising this type of property in this market area 12. 1 am aware of, and have access to, the necessary and appropriate public and private data sources, such as multiple listing services, tax assessment records, public land records and other such data sources for the area in which the property is located. 13. 1 obtained the information, estimates, and opinions furnished by other parties and expressed in this appraisal report from reliable sources that I believe to be true and correct. 14. 1 have taken into consideration the factors that have an impact on value with respect to the subject neighborhood, subject property, and the proximity of the subject property to adverse influences in the development of my opinion of market value. I have noted in this appraisal report any adverse conditions (such as, but not limited to, needed repairs, deterioration, the presence of hazardous wastes, toxic substances, adverse environmental conditions, etc.) observed during the inspection of the subject property or that I became aware of during the research involved in performing this appraisal. I have considered these adverse conditions in my analysis of the property value, and have reported on the effect of the conditions on the value and marketability of the subject property. 15. 1 have not knowingly withheld any significant information from this appraisal report and, to the best of my knowledge, all statements and information in this appraisal report are true and correct. 16. 1 stated in this appraisal report my own personal, unbiased, and professional analysis, opinions, and conclusions, which are subject only to the assumptions and limiting conditions in this appraisal report. 17. 1 have no present or prospective interest in the property that is the subject of this report, and I have no present or prospective personal interest or bias with respect to the participants in the transaction. I did not base, either partially or completely, my analysis and/or opinion of market value in this appraisal report on the race, color, religion, sex, age, marital status, handicap, familial status, or national origin of either the prospective owners or occupants of the subject property or of the present owners or occupants of the properties in the vicinity of the subject property or on any other basis prohibited by law. 18. My employment and/or compensation for performing this appraisal or any future or anticipated appraisals was not conditioned on any agreement or understanding, written or otherwise, that I would report (or present analysis supporting) a predetermined specific value, a predetermined minimum value, a range or direction in value, a value that favors the cause of any party, or the attainment of a specific result or occurrence of a speck subsequent event (such as approval of a pending mortgage loan application). 19. 1 personally prepared all conclusions and opinions about the real estate that were set forth in this appraisal report. If I relied on significant real property appraisal assistance from any individual or individuals in the performance of this appraisal or the preparation of this appraisal report, I have named such individual(s) and disclosed the specific tasks performed in this appraisal report. I certify that any Individual so named is qualified to perform the tasks. I have not authorized anyone to make a change to any item in this appraisal report; therefore, any change made to this appraisal is unauthorized and I will take no responsibility for it. 20. 1 identified the lender/client in this appraisal report who is the individual, organization, or agent for the organization that ' ordered and will receive this appraisal report. Freddie Mac Form 70 March 2005 Page 5 of 6 Fannie Mae Form 1004 March 2005 ' Form i D04- "WinTOTAL" appraisal software by a k mode, inc. -1-800-ALAMODE Min File No 01080 Pa a #8 of 27 Uniform Residential Appraisal Report File# 1101080 ' 21. 'The lender/client may disclose or distribute this appraisal report to: the borrower; another lender at the request of the borrower; the mortgagee or its successors and assigns; mortgage insurers; government sponsored enterprises; other secondary market participants; data collection or reporting services; professional appraisal organizations; any department, agency, or instrumentality of the United States; and any state, the District of Columbia, or other jurisdictions; without having to t obtain the appraiser's or supervisory appraiser's (f applicable) consent. Such consent must be obtained before this appraisal report may be disclosed or distributed to any other party (including, but not limited to, the public through advertising, public relations, news, sales, or other media). 22. 1 am aware that any disclosure or distribution of this appraisal report by me or the lender/client may be subject to certain ' laws and regulations. Further, I am also subject to the provisions of the Uniform Standards of Professional Appraisal Practice that pertain to disclosure or distribution by me. 23. The borrower, another lender at the request of the borrower, the mortgagee or its successors and assigns, mortgage insurers, government sponsored enterprises, and other secondary market participants may rely on this appraisal report as part of any mortgage finance transaction that involves any one or more of these parties. 24. If this appraisal report was transmitted as an "electronic record" containing my "electronic signature," as those terms are defined in applicable federal and/or state laws (excluding audio and video recordings), or a facsimile transmission of this appraisal report containing a copy or representation of my signature, the appraisal report shall be as effective, enforceable and valid as if a paper version of this appraisal report were delivered containing my original hand written signature. 25. Any intentional or negligent misrepresentation (s) contained in this appraisal report may result in civil liability and/or criminal penalties including, but not limited to, fine or imprisonment or both under the provisions of Title 18, United States Code, Section 1001, et seq., or similar state laws. SUPERVISORY APPRAISER'S CERTIFICATION: The Supervisory Appraiser certifies and agrees that: 1. 1 directly supervised the appraiser for this appraisal assignment, have read the appraisal report, and agree with the appraiser's analysis, opinions, statements, conclusions, and the appraiser's certification. 2. 1 accept full responsibility for the contents of this appraisal report including, but not limited to, the appraiser's analysis, opinions, statements, conclusions, and the appraiser's certification. 3. The appraiser identified in this appraisal report is either a sub-contractor or an employee of the supervisory appraiser (or the appraisal firm), is qualified to perform this appraisal, and is acceptable to perform this appraisal under the applicable state law. 4. This appraisal report complies with the Uniform Standards of Professional Appraisal Practice that were adopted and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place at the time this appraisal report was prepared. 5. If this appraisal report was transmitted as an "electronic record" containing my "electronic signature," as those terms are defined in applicable federal and/or state laws (excluding audio and video recordings), or a facsimile transmission of this appraisal report containing a copy or representation of my signature, the appraisal report shall be as effective, enforceable and valid as if a paper version of this appraisal report were delivered containing my original hand written signature. APPRAISER Signature Lit Name KE w =?? Company Name ARSENAL APPRAISAL INC. Company Address P.O. BOX 1599. FAYETTEVILLE NC 28302 Telephone Number 910-814-1108 Email Address KHADDING@ARSENALAPPRAISAL COM Date of Signature and Report 02/02/2011 Effective Date of Appraisal 0210112011 State Certification # A5645 or State License # or Other (describe) State # State NC Expiration Date of Certification or License 06/3012011 ADDRESS OF PROPERTY APPRAISED 512 AQUINAS AVE FAYETTEVILLE, NC 28311-1125 APPRAISED VALUE OF SUBJECT PROPERTY $ 95,ooo LENDER/CLIENT Name KING, COREY Company Name Company Address 118 LEE ANN CT ENOLA. PA. 17025 Email Address COREYKaDATT.BLACKBERRY.NET SUPERVISORY APPRAISER (ONLY IF REQUIRED) Signature Name Company Name . Company Address Telephone Number Email Address Date of Signature State Certification # or State License # State Expiration Date of Certification or License SUBJECT PROPERTY ? Did not inspect subject property ? Did inspect exterior of subject property from street Date of Inspection ? Did inspect interior and exterior of subject property . Date of Inspection COMPARABLE SALES ? Did not inspect exterior of comparable sales from street ? Did inspect exterior of comparable sales from street Date of Inspection Freddie Mac Form 70 March 2005 Page 6 of 6 Fannie Mae Form 1004 March 2005 Form 1004- NYnTOTAL" appraisal software by a la mode, inc. -1-MO-ALAMODE 1 onr- am T ?PUbER1?J?T? L ?R@[11T (?1'?M1N Tour Comm-unity CreXzt Vnion PO Box 658, New Cumberland, PA 17070-0658 1-.800-716-2328 * wwww.ncfcuonlf ie.org`. . BARBARA D KING 1825 BRIDGE STREET ' NEW CUMBERLAND PA 17070-1126 1201, 1206? 12311 'PREVIOUS BALANCE S1-PRIMARY SHARES ATM W/D TR76621780 345 LEWISBERRY RD NEW CUMBERLND PA ;DIVIDEND THEANNUAL PERCENTAGE YIELD EARNED IS 0. ;NEW BALANCE DIVIDEND IS CALCULATE ;USING A DAILY BALANCE METHOD. * 1231 1201: 1213 1231 PREVIOUS BALANCE S4-SHARE DRAFTS VISA DR PURCHASE *900236557 JINX.COM 888-5469266 CA NEW BALANCE ¦ i STATEMENT OF ACCOUNT 1 MECHANICSBURG BRANCH OPEN 4.74. NEW/USED CAR 60 MO 5.74. HOME EQUITY TO 120 MO 6.9b. VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17 0 7 0 --11-2 AC69fJj jgNMBER l1 8o bbttffss i SOCIAL SECURITY STATEMENT PERIOD '19 1081231A EfiAR? }ISIESs„ 'B3?Z Al?Tf'$ 55490 -500;00: 5490 09 54'99 79. 5499 j 419173 -4946 370127 i 370;27 i 'Your Communky Crecl`tt ` pion PCB Box 658, New Cumberland, PA 17070-0658 1-800-716-2328,* w'W'.W.ncfcuonline.org COREY E KING 1825 BRIDGE STREET STATEMENT OF ACCOUNT MECHANICSBURG BRANCH OPEN 4.74. NEW/USED. CAR 60 MO 5.74. HOME EQUITY TO 120 MO 6.90% VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17 0 7 0 ACC9WI EMBER BARBARA D. KING ._........_.........__.........._.._.i SOCIAL SECURITY NEW CUMBERLAND PA 17070-1126 ____.- ' STATEMENT PERIOD TH10812310Tg 1201 :PREVIOUS BALANCE S 1 Savings Accou 213191 1219 ---> :AUTOMATED DEPOSIT 184 H&R BLOCK EASTER/DIR DEP 2039: 234130 1220: ;HOME BANKING TRANSFER 2500: 259130 1220` ?HOME BANKING TSFR BETWEEN 083299 2500' 28430 --> can't wait to see you 1231 :DIVIDEND 15 284,45 THEANNUAL PERCENTAGE YIELD EARNED IS 0.73. 1231 ANEW BALANCE DIVIDEND IS CALCULATE USING A DAILY BALANCE METHOD. 28445 1201. PREVIOUS BALANCE S 3 American Expr 90042 1207 * ;HOME BANKING TRANSFER -895`00; 542 12311 'DIVIDEND THEiANNUAL PERCENTAGE YIELD EARNED IS 0.73. 11' 553 1231.` ;NEW BALANCE DIVIDEND IS CALCULATE ;USING A DAILY BALANCE METHOD. 5153 1201 1128' --> * PREVIOUS BALANCE S 4 Checking Acco :ATM W/D *001 1273 130 OLD YORK RD NEW CUMBERLAN PA -186121 313506 294894 ' 1130" * :ATM W/D• *442249600 -25.41 2923'53 --> 1195 LOWTHER ROAD CAMP HILL PA 1201. ATM W/D PI04061340 -20:00; 2903153 --- 438 S THIRD STREET LEMOYNE PA 1128 * VISA DR PURCHASE *600393543 -19434 270519 ---> ALL SERVICE GARAGE NEW CUM13ERLAN PA '' 1201: ---> * ;SHARE DRAFT CLEARED 3991 MACYS PAYMENT CHECK PYMT- -9381; 26.1538 1201; * :SHARE DRAFT CLEARED 3990 -62;46; 2552:92 1201; 1202' --> * * 'SHARE DRAFT CLEARED 3994 :ATM W/D *220205103 6416 CARLISLE PIKE MECHANICSBURG PA -20600 -9736 235292 ' 225556 j 1202: * 'ATM W/D *088286069 -12,70: 2242.86 --> 128 OLD YORK RD. NEW CUMBERLND PA 1202 * VISA DR PURCHASE *1 9696 106: 224180 ---> i REDBOX DVD 012-976 OAK BROOK TR IL 1202' * ;VISA DR PURCHASE *220008035 -22;14; 221966 1 ---> GIANT FUEL #253 NEW CUMBERLAN PA **CONTINUED** STATEMENT OF ACCOUNT NEWCOUMMMM FEbFZAL CKWIT UMON Tour Commun4 Credit Union FO Box 658, New Cumberland, PA 1,7070-0658 2 1-800-716-328 ? 1NY1r3lV'I7cfCL[0nfiIiE'..i3rg MECHANICSBURG BRANCH OPEN 4.7416 NEW/USED CAR 60 MO ' 5.7496 HOME EQUITY TO 120 MO 6.90°s VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17070 x11262.5--- ACCfLWTJ?IgMBER ' COREY E KING BARBARA D. KING U ...4..bb... 1825 BRIDGE STREET soclALSecuRrTr NEW CUMBERLAND PA 17070-1126 ' STATEMENT PERIOD TA1081231A n ,? n -"ESCRIP7 'tarr F(N 6E i 1204 AUTOMATED DEPOSIT 004 1899,46; 411812 ---? DFAS-CLEVELAND /FED SALAR 1204 EACH DEPOSIT 9001644380 158211 5700,23 --> WEST SHORE FAMIL PAYROLL ! i 1204: 'ATM W/D *061503013 -1270; 568753 ---> 3760 MARKET STREET CAMP HILL PA 1203' * 1VISA DR PURCHASE *03698-002 -584; 567769 --? EL RODEO MECHANICSBURG PA 1205 'ATM W/D *442294897 -7137 560632 ---> 2150 BUMBLE BEE HO MECHANICSBUR PA ' 1205: '.SHARE DRAFT CLEARED 3995 -13;00; 5593!32 1207 * :HOME BANKING TRANSFER -5d00 554382 1207: * 'HOME BANKING TRANSFER 89500: 6438 1208 ;ACH WITHDRAWAL 0005000008 -200000; 4438'32 --> AMERICAN EXPRESS ELEC REMIT 1205 * ACH WITHDRAWAL 1510394779 -12500; 431332 ---> KING,BARBARA D ING DIRECT ' 1206: * :ATM W/D *001 7132 -4946` 4263186 --> 130 OLD YORK RD NEW CUMBERLAN PA 1205! * ;VISA DR PURCHASE *01051-012 -1500' 424886 ---> BOWMANSDALE FAMILY MECHANICSBURG PA ' 1206_: * VISA DR PURCHASE *000001014 -25;42: 4223;44 ---> THE UPS STORE #154 LEMOYNE PA 1206 * -VISA DR PURCHASE *010 9614 -38?40 41851j04 ' > PIZZA HUT #2308443 717-763-1161 PA 1208: * ATM W/D *061506071 -12'70+ 417234 ---> 3760 MARKET STREET CAMP HILL PA 1210• ;AUTOMATED TRANSFER 37341; 379893 ' 1209- * :ATM W/D *001 1106 -49.02' 3749191 1 --> 130 OLD YORK RD NEW CUMBERLAN PA 1211 SHARE DRAFT CLEARED 3998 -19;06 3730`85 ---> Bookspan Books CHECK PYMT- 1210: * SHARE DRAFT CLEARED 3996 -1600?02 2130.83 ---> FLAGSTAR BANK CHECKPYMT - I 1211. ;SHARE DRAFT CLEARED 3997 -16022: 197061 ' 1211' * ATM W/D *061509113 -12'70` 1957191 j -> 3760 MARKET STREET CAMP HILL PA 1211 * 'ATM W/D *442249831 -8584; 1872107 > 1195 LOWTHER ROAD CAMP HILL PA I **CONTINUED** "! i'f uA STATEMENT OF ACCOUNT 74S?v?a+?tihxn'L ? IAN Tour 0mm-unity Credit "Onion Pty Box 658, New Cumberl And, PA 9 7074?-0658 1-WG-715-2328 w .ncfcuonllne Or9 3 • MECHANICSB URG BRANCH OPEN 4.74% NEW/USED CAR 60 MO 5.74% HOME EQUITY TO 120 MO 6.90% VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17 0 7 0 -112-6 2 - -- ----------. y [ [ AC MBER C4 p( U Z COREY E KING BARBARA D . KING b b ._......... _ ......._..._......- .; 1825 BRIDGE STREET SOCIAL SECUIUTY NEW CUMBERLAND PA 17070-1126 STATEMENT PERIOD H108112310ti is AMOUl`il - J, J ?A ?+ _ I }?}yp /. i ' 1213; * ATM W/D *000001548 i 7;99: 186408 ---> 3501 CAPITAL CITY CAMP HILL PA 1213; * ?ATM W/D *345742740 -531. 185877 > 1200 MARKET ST. LEMYNE PA 1214; * 'ATM W/D *251469642 -2362; 1835,15 ---> STATE & MARKET STS LEMOYNE PA i 1214; * ATM W/D *088258032 -2012' 1815b03 ---> 1200 MARKET STREET LEMOYNE PA 1214; * }ATM W/D *442248984 -1600: 1799;03 ---> 1195 LOWTHER ROAD CAMP HILL PA 1215: 'ATM W/D ML74624252 -2200: 177703 ' ---> 3506 CAPITAL CITY CAMP HILL PA 1215 ° !ATM W/D *001 5405. -96.56; 1680;47 ---> 130 OLD YORK RD NEW CUMBERLAN PA 1212: * ;VISA DR PURCHASE *32880-100 -13284 1668;63 ---> ' CVS PHARMACY #1630 CAMP HILL PA i 1215' -SHARE DRAFT CLEARED 3999 -200 '00 146863 1215; * IIATM W/D *061502108 , -635; 1462128 ---> 3760 MARKET STREET CAMP HILL PA 1215: * 'VISA DR PURCHASE *200014599 -6109 1401119 ---> USPS 4134870070 NEW CUMBERLAN PA 1215' * !VISA DR PURCHASE *000001024 -2415: 1377'04 ---> THE UPS STORE #154 LEMOYNE PA 1216; ;VISA DR PURCHASE *210006509 -78;85' 1298;19 ---> HI *WINECNTRYGIFTB 866-226-0431 CA j 1216: * 4ATM W/D *44224-572 -3813 126006 ---> 1195 LOWTHER ROAD CAMP HILL PA 1217: 'ATM W/D *442249606 -9;00` 1251106 ---> 1195 LOWTHER ROAD CAMP HILL PA 1218: AUTOMATED DEPOSIT 004 189847: 314953 -> DFAS-CLEVELAND /FED SALAR 1218: :ACH DEPOSIT 9001644380 2134.65 5284118 ---> WEST SHORE FAMIL PAYROLL 1217; * ;ATM W/D *088251461 -4238 5241;80 ---> 1200 MARKET STREET LEMOYNE PA 1219 ;ATM W/D *001 7594 -8;68 523312 ---? 3301 TRINDLE RD CAMP HILL PA 12191: ATM W/D *088252724 -13;77' 521935 --- 1200 MARKET STREET LEMOYNE PA ! **CONTINUED** LNU -gym STATEMENT OF ACCOUNT o t"WWiiL o FE60AL err 0fdON Tour bmmuni crept union ' PO Box 658, New Cum.berland, PA 17070-0658 4 1-800.716-2328 * ww.ncfcuonlln'e.arg MECHANICSBURG BRANCH OPEN 4.74% NEW/USED CAR 60 MO ' 5.74°% HOME EQUITY TO 120 MO 6.90% VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17 0 7 0 -.112 6 2.5 -_.. AC qT4 NUMBER COREY E KING BARBARA D. KING _.i. 1825 BRIDGE STREET SOCIAL SECURITY NEW CUMBERLAND PA 17070-1126 ' STATEMENT PERIOD 1161081231A i _ EFFt;3YB _ i;ITZ YYESI '.gyp - J p - /R u _ AMOUNT- .. ANCe Al- C pN DATE. ... F J.L - _ D t CRAICiE ..-?. PINES -_1220 :HOME BANKING TRANSFER -5000; 516935 1220` 'HOME BANKING TRANSFER -2500 514435 12221, 'ACH WITHDRAWAL 2850411740 -183414960:94 > AT&T CARE CELLULAR 1219. * ;ACH WITHDRAWAL 1510394779 -125.00; 4835194 j ---> KING,BARBARA D ING DIRECT 12201 * ATM W/D *001 9857 -10362: 4732132 --> 130 OLD YORK RD NEW CUMBERLAN PA 1221; * ATM W/D *050377179 -62':24: 467008 ---> 5800 CARLISLE PIKE MECHANICSBURG PA ' 1221: * ATM W/D *000003901 -1323` 465685 --> 6000.CARILSE PIKE MECHANICSBURG PA 1222; ;ATM W/D *001 -149 -2933; 4627152 j 130 OLD YORK RD NEW CUMBERLAN PA 1222; * !ATM W/D *345745809 300, 4624152 ---> 1200 MARKET ST. LEMYNE PA 1223: 'ATM W/D *001 9162 -25:86; 4598166 ---> 130 OLD YORK RD NEW CUMBERLAN PA 1223 * ATM W/D PDO669-817 -100:00 449866 ---> 438 S. THIRD ST LEMOYNE PA 1224 * :ATM W D * 1 / 44224-088 -68;49: 443017 ---> 1195 LOWTHER ROAD CAMP HILL PA 1224; * SHARE DRAFT CLEARED 4004 -12721: 4302':,96 j 1226_ ;SHARE DRAFT CLEARED 4003 -18070: 412226 ' ---> VERIZON ARC CHECK PYMT- i 1226' SHARE DRAFT CLEARED 4007 -20000' 3922126 I --> CAPITAL ONE ARC CHECK PYMT- I 1226 ;SHARE DRAFT CLEARED 4000 -10000` 382226 ' ---> DISCOVER ARC PAYMENTS - 1224; ATM W/D *442247928 -2797'.: 3794129 j --> 1195 LOWTHER ROAD CAMP HILL PA 1226; SHARE DRAFT CLEARED 4008 -200.00' 359429 12291 ;ACH WITHDRAWAL 0005000008 -900,00 2694129 ---> AMERICAN EXPRESS ELEC REMIT 1229 'SHARE DRAFT CLEARED 4002 -123;24 2571105 ' ---> UGI UTILITIES UTIL PMT - 1226: * :ATM W/D *088286114 -13'77' 255728 ---> 128 OLD YORK RD. NEW CUMBERLND PA j 1226 * ATM W/D *001 3838 -33188' 2523140 **CONTINUED** i IVY f4A+ XbWN 'Four C minunity CreXit `i nii n PO Box 6.58, New Cur bodand, PA 1767"658 1-800-716-2328 0 ww,w.ncfcuonllne'.org STATEMENT OF ACCOUNT MECHANICSBURG BRANCH OPEN 4.74% NEW/USED CAR 60 MO 5.7416 HOME EQUITY TO 120 MO 6.90% VISA FOR MORE INFO WWW.NCFCUONLINE.ORG 17070-11262-5-------- - BER- - 6 aC N g COREY E KING BARBARA D. KING /4 4 6 1825 BRIDGE STREET social secuRlTY NEW CUMBERLAND PA 17070-1126 STATEMENT PERIOD i P812310T f n.,a r Y Dale DFSCRI?TTQN 1 ANI(9I?I?T1' - ? ? Nes At,Aj?T C F{AR? PE ---> 130 OLD YORK RD NEW CUMBERLAN PA i 1227: * ATM W/D *088287097 -4344 247996 ---> 128 OLD YORK RD. NEW CUMBERLND PA 1227: * ATM W/D *001 4375 -73;82- 240614 ---> 130 OLD YORK RD NEW CUMBERLAN PA 1227' * 'ATM W/D *001 7982 -1669: 238945 ---> 130 OLD YORK RD NEW CUMBERLAN PA 1228 * 'ATM W/D *345749180 -1906' 237039 ---> 1200 MARKET ST. LEMYNE PA 1228, * :ATM W/D *088251112 -1270; 2357;69 ---> 1200 MARKET STREET LEMOYNE PA 1229! 'ATM W/D *001 2993 706= 235063 ---> 3301 TRINDLE RD CAMP HILL PA 1229' 'SHARE DRAFT CLEARED 4005 -63;16'. 228747 1229' 'SHARE DRAFT CLEARED 4006 -150;00` 2137;47 1229: * ;ATM W/D *061503106 -1270; 212477 ---> 3760 MARKET STREET CAMP HILL PA 1231: 'AUTOMATED DEPOSIT 004 189846' 4023123 ---> DFAS-CLEVELAND /FED SALAR 1231; ;ACH DEPOSIT 9001644380 144751; 5470174 ' ---> WEST SHORE FAMIL PAYROLL 1230; -> * 'ATM W/D *001 8799 130 OLD YORK RD NEW CUMBERLAN PA -13148' 545726 1230' * ATM W/D *088289177 -2754: 5429172 ---> 128 OLD YORK RD. NEW CUMBERLND PA 1231. :ATM W/D *061505316 -13;77; 541595 ---> 3760 MARKET STREET CAMP HILL PA 1231: 1231: ;SHARE DRAFT CLEARED 4001 . -3700; 537895 DIVIDEND 149° 5380 THEANNUAL PERCENTAGE YIELD EARNED IS 0.50. . 44 1231?. 'NEW BALANCE DIVIDEND IS CALCULATE ' 5380'44 USING AN AVERAGE DAILY BALANCE METHO i CONTINUED** i i j i STATEMENT OF ACCOUNT NEkPCOM®ERLAND VEDYRALCREW UMON Tour Commni Credit Vnign PO Box 6, 58, New Cumberland, PA 17070-0658 1-800-716-2328 * wwtv nr-fri tondirt 6 e' 3fi5 MECHANICSBURG BRANCH OPEN 4.74. NEW/USED CAR 60 MO 5.74% HOME EQUITY TO 120 MO 6.90. VISA FOR MORE INFO WWW.NCFCUONLINE.ORG ACLQ[1N] 9MBER COREY E KING BARBARA D . KING /..4..4....6_.6.. 1825 BRIDGE STREET SOCIALSECURITY NEW CUMBERLAND PA 17070-1126 STATEMENT PERIOD THio812310T9 . D - ??N ;.: DAZe. ...; ' ?.. - : _ .. _ e ` r?' .. r . •_ ©! - CFIARC? BArtANG'E- - i ------------- ----------- SHARE DRAFT SUMMARY -.------------ 1 :3990 3991 **** 3994 3995 3996 3997 39 98 3999 4000 40014002:4003 40,04 4005 4006 4007 4008 -------------------------------------- -------- -- -------- 1201' ;PREVIOUS BALANCE S 8 Car Insurance - ------ I j 34135 1207; * ;HOME BANKING TRANSFER 50;00 391;35 1220 HOME BANKING TRANSFER 5000! 44135 1231: DIVIDEND i25 441.60 THE ANNUAL PERCENTAGE YIELD EARNED IS 0.74. 1231, ANEW BALANCE DIVIDEND IS CALCULATE 441'60 ;USING A DAILY BALANCE METHOD. a 1201< '.PREVIOUS BALANCE S9-VACATION CLUB 1231; NEW BALANCE 00 c 00 STATEMENT OF ACCOUNT NEW CUMBERLAND FEDERAL CREDIT MECHANICSBURG E PO BOX 658 CAR 60 MO 5.74% H NEW CUMBERLAND, PA 17070-0658 VISA FOR MQRJ= INF COREY E KING • 1825 BRIDGE STREET Page 1 of 2 CH' OPEN 4.74% NEW/USED EQUITY TO 120 MO 6.90%0 NVY•NCFCUONLINE.ORG; 080525 NEW CUMBERLAND PA 17070-1126 K12/01/08 ,Y x12/31/08,.) 1-M Secret Account 12/01/08 Previous balance 581.9 12/01/08 AUTOMATED DEPOSIT 105 398.0 979.9 Location: US TREASURY 220 /VA BENEFI 12/06/08 TM W/D LK6067-396 -102.0 877.9 Location: CAMP ROBINSON BUTL NORTH LITTLE AR 12/10/08 AUTOMATED TRANSFER -227.8 3 0.0 650.0 Location: XFR TO L 7 12/12/08 AUTOMATED DEPOSIT 101 374.8 1,024.95 Location: DFAS-IN IND IN/ARMY RC 12/15/08 TM W/D SU00101743 -41.5 983.45 Location: 5520 CARLISLE PIKE MECHANISBURG PA 12/18/08 MISCELLANEOUS TRANSFER -20.5 962.9 MONEY ORDERS 20.0 0.5 12/18/08 WITHDRAWAL CASH -40.0 922.9 12/23/08 RAWAL CASH -40.0 _ 882.95 12/23/08 MISCELLANEOUS TRANSFER -50.5 832.4 MONEY ORDERS 50.0 0.5 12/26/08 -IM INQUIRY FEE TR76626287 -0.5 0.5 831.9 Location: 345 LEWISBERRY RD NEW CUMBERLND A 12/26/08 TM W/D TR76626288 -100.0 _ 731.95 Location: 345 LEWISBERRY RD NEW CUMBERLND A _ 12/28/08 TM W/D PD06691069 -40.0 691.9 Location: 438 S. THIRD ST LEMOYNE PA 12/31/08 AUTOMATED DEPOSIT 105 421.0 1,112.951 Location: US TREASURY 220 /VA BENEFI 12/31/08 DIVIDEND 0.5 0.0 1113.51 For Period: 12/01/08 to 12/31/08 APR: 0.75% Average Balance: $887.14 APY: 0.75% 12/31/08 ew balance _ 1,113.511 3-S3-MONEY MARKET 12/01/08 Previous balance 0.8 12/31/08 ew balance -- 0.8 80-S80-PLATINUM VISA 12/01/08 Previous balance 0.0 12/31/08 ew balance 0.0 7-USED CAR P eriodic Rate .015753%, Annual Rate 5.750% ------ I _ 12/01/08 __ Next Due Date ,Amount $- _----_ --- - revious balance --- -- ? ------ ---------? ---- --- 8-L ----- -51.8?? 12/10/08 ( - AUTOMATED TRANSFER ocation: XFR FROM S I __ -_- 188.83 0.00 8 062.9 a nt Amt Posted: $39.00, Int Rate: 5.750% -- - -- 12/31/08 ew balance ------ - -8 062.9 1 P 8-USED CAR eriodic Rate .018493%, Annual Rate 6.750%_ STATEMENT OF ACCOUNT Page 2 of 2 NEW CUMBERLAND FEDERAL CREDIT MECHANICSBURG BRANCH OPEN 4.74% NEW/USED PO BOX 658 CAR 60 MO 5.74% HOME EQUITY TO 120 MO 6.90% NEW CUMBERLAND, PA 17070-0658 VISA FOR MORE INFO WNW:NCFCUQN.LINE.ORG COREY E KING JOINT OWNER ACCOUNT Cr 4 n CD m 3 0 c CL m 0 G Q 7 m n (D 0- d N 7 tip m n d d m Iw 0 Lq N m O ? nom: S S V.. N co N cn A n n 1 m U m rall m D C) O C Z 1 Ut NI 0 i0 f.T E N ?o 2 to h a N Cam? a a 1 i' n o m A m o ? N ?. 1 6 w ID N ID o ? to co O ;N N N O ;y i? 0 w 1 N 0 cn J 'o 0 J A J t+J [O 0 Q to N 0 co w w. to 0 0 0 ^d N 0 N N 0 J d m z O cn IV co N I? • -TA 1 , t ? (D a S ? ? o H ? y y ?i :3 1 G G S 7 n 0 I ? • I W E9 cp I I I I I I I I I I ?1 w? THRIFT SAVINGS PLAN ANNUAL PARTICIPANT STATEMENT For the year. 2009 Please review this statement for accuracy, as the information in it is considered correct unless you notify us. To correct errors in contribution allocations, interfund transfers, loans, withdrawals, your account profile, or your beneficiary information, contact the TSP. For all other corrections, contact your agency or service. 0 0 5 6.2 5 0 01 AV 0.332 "AUTO T2 0 5200 17070-168174 02 P56306112 IIIIIII'I'I'll'i"I'1'lllll l'IIIIIII"l ll'll'11111111111"1'11111 • COREY E. KING •: 812 MARKET STREET APT B NEW CUMBERLND, PA 17070-1681 ACCOUNT BALANCE HISTORY This compares your year-end total account balance for the last five years. 14,t1 i'., ?. '•11 ? It C4?, x 1s.. yl...:. v`- Account Number: 1901 9438 12307 Date of Birth: 10/17/1967 Retirement Coverage: FERS Employment Status: Separated, dated 02/04/2009 Required Vesting Service: 3years from 07/28/2002 v C D G 124 0 O LIFETIME CONTRIBUTIONS2 Your Pre-Tax Contributions $27,117.10 Your 2009 change in account value $6,724.69 Your 2009 Personal Investment Performance' 18.220/6 ACCOUNT DISTRIBUTION. Aft As of the statement date, your account balance was distributed asfollows: Funds for Stability.. G Fund - Government Securities Investment ....... 22% F Fund - Fixed Income Index Investment , , . , , , 21% Funds for Long-Term Growth C Fund - Common Stock Index Investment ........ 18% S Fund - Small Capitalization Stock Index Investment , , 19% I Fund - International Stock Index Investment ...... 20% CONTRIBUTION ALLOCATION As of the statement date, your contributions, loan payments, and rollovers were allocated as follows: Funds for Stability G Fund - Government Securities Investment ....... V F Fund - Fixed Income Index Investment ......... 11 Funds for Long-Term Growth C Fund - Common Stock Index Investment ........ 11 S Fund - Small Capitalization Stock Index Investment - . 11 I Fund - International Stock Index investment ...... 21 Funds for Long-Term Growth and Stability - Lifecycle Funds ¦ Funds for Long-Term Growth and Stability - Lifecycie Fund L 2040 Fund L 2040 Fund L 2030 Fund L 2030 Fund L 2020 Fund L 2020 Fund L 2010 Fund L 2010 Fund L Income Fund L Income Fund TSP Web Site: www.tsp.gov THRIFTLINE:1-TSP-YOU-FRST (1-877-968.3778) . Outside U.S. and Canada, call 404.233.4400 TDD:1-TSP-THRIFTS (1.877.847-4385) 00562500000001-0056462 2005 2006 2007 2008 2009 1 1 1 1 7 L_. W N i"7 C CO'o• o `W " 2 ? °.0 ? N' ?m? =m m m 'C ' o ' !V 13 y $ q o S n m Z a? C Z '17 o; g C) cr m y=a c (A V 17 Ct '+ _ . O O rt C Vii. S m ,g w 0 m C a _ =m ? y d: ° ? -I E !Z F?ogRR? m 3o Q {Y (? 4 ?i ?.?F \I m 7 B N ;? m ?7y N m C > p OYp cD c = ?? ? C? ?5'? Boa CD 0 ? 8 m e -Z G g rs . ;t cym C 3 n t ° ?' IA O1 ? ?pp ' •pp ?p' ? d cos C fD i y m fD ? 0 ? ? ? y N O IC m 0 o N• y c ?.54 c ? m a' m F K o a m ? Q= z -1 O m z z O a N C flv" V1.rL(,IUIpNVlV]G7SUU a O -Vif7-nM z n o. CL 8 S O g, Vs z O W N N V Cl) C wV?jft"V`?' OOO?D?Aw: ANON CHI iA ..a W N N N i c o o La bbb cn w"cow CJ poop O 0000 9 0°00 °0 Coo0°o ?f ? V N as V O. t0 s tl100s M O V a z C V C s W CO s V N i N z _ ? ? W W W W AA i ? W y s V O N V COT7 CO V z 7 .?j p V 0 0 V V (n ?iTTll ,0? A OnYm ,?.? 07N ;P OD d N M V A 0 z C aC C v Conrad Siegel 501 Corporate Circle • P.O. Box 5900 • Harrisburg, PA 17110-0900 ' Phone (717) 652-5633 A' C T U A R I E S Fax (717) 540-9106 www.conradsiegel.com The Employee Benefits Company Conrad M. Siegel, F.S.A. Harry M. Leister, Jr., F.S.A. January 10, 2011 Clyde E. Gingrich, F.S.A. Robert J. Dolan, A.S.A. Mr. Corey E. King David F. Stirling, A.S.A. 118 Lee Ann Court ' Robert J. Mrazik, F.S.A. Enola, PA 17025 David H. Killick, F.S.A. Frank C. Sluzis, Esq. Jeffrey S. Myer, F.S.A. Scaringi & Scaringi, P. C. Thomas L Zimmerman, F.S.A. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Glenn A. Hater, F.S.A. ' Kevin A. Erb, F.S.A. Re: Corey E. King - Military Retirement Valuation ' Frank S. Rhodes, F.S.A., A.C.AS. Dear Mr. King and Mr. Sluzis: Holly A. Ross, F.S.A. Janet M. Leymeister, CEBS I was requested to value the retirement pension earned by Corey E. King through the Military Retirement System as a member of the Army National Guard. This ' Mark A. Bonsall, F.S.A. report is based upon the following information concerning Mr. King: John W. Jeffrey, F.S.A. 1. Date of birth - October 17, 1967. Denise M. Polin, F.S.A. Thomas W. Reese, A.S.A. 2. Date married - May 10, 1986. ' Jonathan D. Cramer, F.S.A. 3. Date separated - December 2008 (assumed December 31, 2008). John D. Vargo, F.S.A. Robert M. Glus, F.S.A. 4. A letter dated November 16, 2010, from the PA Army National Guard indicates Mr. King accumulated 5,836 retirement points as of Bruce A Senft, CEBS, CFP December 31, 2008. The associated Points History Statement further Laura V. Hess, F.S.A. indicates Mr. King has over 22 years of qualifying retirement service. Vicki L Delligalti 5. Mr. King's rank/pay grade is Sergeant First Class (Grade -E-7). ' J. Scott Gehman, CEBS. William J. Shipley, F.S.A. Currently, Corey E. King is 43 years of age (age nearest birthday). Joshua R. Mayhue, A.S.A. The Military Retirement System is a defined benefit pension plan. The figure ' Charles A. Ebedin, E.A. that is marital property for divorce purposes is the present value of the pension earned during the marriage. The pension to a Guardsman is payable at age 60, Abigail S. Fortino, A.s A. and it is calculated by multiplying the total retirement points by the value per Jonathan A. Sapochak, A.S.A. point using the Member's rank Andrew S. Greenawalt, A.S.A. Based upon the value of a retirement point using the 2010 pay scale (0.288 for Trevor S. Bare, A.S.A. SFC, E-7, 22+ years of service) and reflecting the 1.4% 2011 military base pay Ashley A. Wise, A.S.A. increase, the accrued pension using 5,836 retirement points earned through ' December 31, 2008, is $1,7041mo. (5,836 x 0.288 x 1.014 = $1,704). Conrad Siegel A C T U A R I E S Mr. Corey E. King Frank C. Sluzis, Esq. January 10, 2011 Page 2 The following table shows the present value of the pension earned during the marriage (through December 31, 2008, using 2011 pay scale): Present Value of $1,704/mo. Payable at Age 60 (Marital Pension Only) $189,146 The Military Retirement System pension is indexed. Each year the benefit increases in accordance with the Consumer Price Index. I assumed a 2.25% post-retirement annual increase in the Consumer Price Index in making the present value calculations. The Consumer Price Index has increased on the average at the rate of 3.68% per year over the last 30 years, 2.78% per year over the last 20 years and 2.56% per year over the last 10 years. The present value calculations are based upon the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations in the first quarter of 2011. The interest rate is 4.07% per year for 20 years followed by 3.93% per year. Mortality rates are in accordance with the sex-distinct 1994 Group Annuity Basic Mortality Table with mortality improvement projected until 2021 using Projection Scale AA. In my opinion, the assumptions promulgated by the Pension Benefit Guaranty Corporation for annuity valuations are appropriate for the purpose of determining the present values. I am a member of the American Academy of Actuaries, a Fellow of the Society of Actuaries, and an Enrolled Actuary under ERISA, and I meet the Qualification Standards of the American Academy of Actuaries to render the actuarial opinion contained in this report. Please note that the present values stated herein are based upon the pension calculated using the 2011 pay scale, and do not consider the effect of future pay increases between 2011 and the year Mr. King is discharged from the National Guard. With best regards, Yours sincerely, b"'? C_r?' JDC:kad Jonathan D. Cramer, F.S.A. Consulting Actuary o y p a Cr ' ? ef- h K. p 'O b ?. cD m m r+ C4 CD t-e C) C 5 o C (TQ CO VJ 'Fy CD b 5' co n co o o r + o ? • m m d ? ? ?0 0 rn td ? a• m d N A 00 w ?O A k7 CD Ro n m •* ? O ? ? o m tJ 00 00 J w CT O C> rn p; O ?O O a~o Vii A w a R O i.+. P-d g Cri a N d " O ?I ? N o\ N N o m C O p r.r C) e? ' b fin' (? ? M• 0 0 0 0 0 ,b 000 °o 00 00 C) C) 00 °o y C W 0 ? G d O ? ? o 0 0 0 o C O O C) G W ° Gn b9 ? O 00 00 ?O P tC 00 O A p C C K) (n O\ ?D p, 00 vii Vii ? NO ? co , m L A ?s fD Vii y 0 00 00 ?o ? N O O p Cs o ? ?-- C o. C Oq 00 V i i V A o n a p? ?e (1) Z r? E ll!t N 0 N a 3 a 0 r O N R r To Lo Lo r IR O N O (a C 0) O O N r M c7 O C O N m ?O W o'-' NOCO7et ?-0 c p? o 5' m ff?- O ti ? N Wp 7 p U mpro 0) Lg1.- c-QD 0 E o? O , L w E cm Eat ? a ? m? ?m° m3 ? p . ?¢ yrn? aOVi? ? Nv FL-w? cNO?N -, E 5 V 2 2 ?c d L6 t L6 - a?a a ado, UC,? cov co GO co rnao m a?mmc Cbt cc?. z::5 t5 wat? N ` w O' y v ?L,'- C ro $.. l3mm 5 c? N ?$ ' d c>u .-0 20 z? 0 t 8 9 E -:t ca a W -. o x O c? a N` w c?? o m m U'? q E M = H-80)0_0 4Y c°cE a O >>.Q) c° Ur C ` N yam d 3 ! 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O O N M .D to (L o r O =01 id N N O O O E co =o Z N 'RT ? M Q N L T m o U) y N co id ? (n T d V O v N Q N 0 o- SUMMARY APPRAISAL REPORT PERSONAL PROPERTY Marital Personal Property of Barbara King & Mr. King 1825 Bridge Street New Cumberland, PA 17070 Clients: Barbara King Samuel L. Andes, Esq. 525 North 12th Street Lemoyne, PA 17043 Effective Date of Appraisal: May 27, 2011 Date of Report: May 27, 2011 Ibis Appraisal Services 145 N. HanomrSt P.O. Bar 24 Carlisle, PA 170TY (717) 243-3474 I n fo @i b i s a p pra is a l s. c o m www.ibisappraisals.com EIN.- 25-1895249 Ibis Appraisal `jerviccs Page i of 28 TABLE OF CONTENTS Table of Contents 2 Appraisal Scope of Work 3 Appraisal Extraordinary Assumptions 4 Appraisal Hypothetical Conditions 4 Appraisal Summary 5 Digital Photograph & CD-ROM Instructions 6 Marital Personal Property Listing 7 Appraisal Summary (Copy) 21 Glossary 22 Appraisal Certification 23 References 24 Privacy Notice 26 Statement of Qualifications 27 16is Appraisal Services Page 2 of 28 APPRAISAL SCOPE OF WORK I hereby certify that, upon the clients' request for the appraisal of the marital personal property of Barbara King and Mr. King, 1825 Bridge St. New Cumberland, PA 17070, that I have appraised the marital personal property to determine the Fair Market Value for the purpose of divorce distribution, effective date of May 27, 2011 and reported on May 27, 2011. The clients in this marital personal property appraisal are Barbara King and Samuel L. Andes, Esq. 525 North 12th St. Lemoyne, PA 17043. The intended users of this appraisal are Barbara King and Samuel L. Andes, Esq., the Divorce Master & Courts and any other person(s) authorized by Barbara King and Atty. Andes. The date of inspection was May 09, 2011. I have personally and physically inspected the listed personal property. The personal property was found to be in fair condition. The information and values contained in this report are based upon my experience as an appraiser and other reliable sources using a Sales Comparison Approach to determine Fair Market Value. [Fair Market Value is used in divorces and estates in the state of Pennsylvania.] A market data analysis with comparable sales transactions was used to reconcile the quality and quantity of data. Values are reported piece-by-piece, and/or as a whole. All values reported have been determined with consideration to the condition of the item, market conditions, and salability factors. All analyses, notes and paperwork are found in the workfile. pis Aprrraisat cervices C.A. irector 16is Appraisal Services Page 5 of 28 APPRAISAL EXTRAORDINARY ASSUMPTIONS cat Assumes that the items are properly identified. APPRAISAL HYPOTHETICAL CONDITIONS cue There were no hypothetical conditions used in this appraisal. 1bis Appraisal Services ragc 4 of 28 APPRAISALS Y It is in my opinion, that, as of May 27, 2011, the Fair Market Value of the marital personal property of Barbara King and Mr. King, 1825 Bridge St. New Cumberland, PA 17070: (Eight Thousand Two Hundred Eighty Seven Dollars and Zero Cents) ($8,287.00) )is Appraisal . C.A. irector The report must be read in its entirety. The Appraisal Summary ONLY is not the appraisal report. 16is Appraisal Services rage 5 of 28 1 DIGITAL PHOTOGRAPH & CD-ROM INSTRUCTIONS Ibis Appraisal Services has provided you with a CD-ROM that houses all of the digital photographs of all of the items appraised. The CD-ROM also contains a saved copy of the ' appraisal report. This CD-ROM may be kept with the paper copy of the appraisal report or kept off-site, such as a safety deposit box. ' The digital photographs are saved in the JPEG picture format, meaning that all of the file names end with a ".JPG". ' The file names correspond to the written appraisal report's Corresponding Digital Photograph File that is included at the end of each item appraised. ' Getting started with your CD-ROM 1. Insert the CD-ROM into your computer's CD-ROM Drive. If you do not have a computer or access to a CD-ROM Drive--a copy store, office supply store, or public library will be able to ' help you view and/or print your pictures. 2. Your computer may contain one or several different software programs that will allow you to view your pictures. Examples of these programs are Draw, Photo Editor, Picture It! Express, ' Photo Suite, My Photo Center, Photo Studio Lite, Photo Shop Pro, Picture CD, or Photo Deluxe. The program that is included with a digital camera is another way to view o pictures. • Select. the program for viewing digital photographs and open the program. 3. Click FILE, and Click OPEN. 4. Use the Pull-Down, "Look in" Menu and select the D Drive (D:) or whichever drive is ' designated as your CD-ROM (sometimes this may be the E Drive (E:) on your computer). NOTE • Your CD-ROM Drive is designated with a small CD-ROM graphic Icon or a cartoon ' representing the drive. • The drives of your computer can be found under My Computer section of the Pull-Down ' "Look in" Menu. Common Drives are: A Drive (floppy disc drive), the C Drive (hard disc drive), the D Drive (CD-ROM Drive), and the E Drive (sometimes CD-ROM Drive; sometimes an external drive, like a CD-ROM Writer, Zip, or Jazz Drive). 5. Double-click on the digital photograph you wish to view. I 16is Appraisal Services rage 6 of 28 MARITAL PERSONAL PROPERTY LISTING 1 Living Room Suite. Modern twentieth/twenty-first $650.00 century plush living room suite. Suite includes sofa, chair, ottoman and loveseat. Location: Living Room. Corresponding Digital Photograph Files: img 7183-img 7185 2 1 Table. Modern twentieth/twenty-first century end $35.00 table with one drawer. A Location: Living Room. Corresponding Digital Photograph File: table] 3 Floor Lamp. Modem twentieth/twenty-first century $30.00 floor lamp. Location: Living Room. Corresponding Digital Photograph File: lamp 4 Prints. Selection of modern twentieth/twenty-first century framed prints. $30.00 Location: Living Room. Corresponding Digital Photograph File: print] 16is Appraisal Services Fage 7 of 28 5 Lamp. Modern twentieth/twenty-first century table $25.00 lamp. Location: Living Room. Corresponding Digital Photograph File: lamp2 6 Clock. Modem wall clock. Maker: Bassett. Location: Living Room. $15.00 Corresponding Digital Photograph File: zing 7188 7 Fireplace Poker Set. Modem twentieth/twenty-first century fireplace poker set. Location: Living Room. $10.00 Corresponding Digital Photograph File: img 7189 8 Knick Knacks. Modern twentieth/twenty-first century knick knacks including figurines and picture frames. $25.00 Location: Living Room. Corresponding Digital Photograph File: img 7190 9 Books. Selection of modem twentieth/twenty-first century books. $35.00 Location: Living Room. Corresponding Digital Photograph File: img 7191 Ibis Appraisal Services Page 8 of 28 r? 10 Prints. Modern twentieth/twenty-first century $20.00 framed and matted prints. Location: Dining Room. Corresponding Digital Photograph File: img 7192 & img 7193 11 Aero-Garden. Modern twentieth/twenty-first century $40.00 Aero-Garden herb grower. Location: Dining Room. Corresponding Digital Photograph File: img 7194 12 Vase. Modern twentieth/twenty-first century floor $12.00 vase. Location: Dining Room. Corresponding Digital Photograph File: img 7195 13 Clock. Modern twentieth/twenty-first century tall $1,800.00 case clock. Maker: Sligh. Location: Dining Room. Corresponding Digital Photograph File: img 7196 16is App aisal 5--ices Page 9 of 28 14 Dining Room Suite. Modern twentieth/twenty-first $780.00 - -- century dining room suite. Suite includes table, four chairs and side board. Purchased at Ashley " Furniture. Location: Dining Room. Corresponding Digital Photograph Files: img 7199- img 7201 15 Jardiniere. Modern twentieth/twenty-first century $10.00 jardiniere. Location: Dining Room. Corresponding Digital Photograph File: img 7197 16 Child's Chair. Small painted child's chair with rush $20.00 seat. Location: Dining Room. Corresponding Digital Photograph File: img 7198 17 Knick Knacks. Modern twentieth/twenty-first $30.00 century miscellaneous selection of knick knacks including figurines, vases and picture frames. Location: Dining Room. Corresponding Digital Photograph File: img 7202 18 ?.x China Service. Service of modern twentieth/twenty- $30.00 first century Coastal Collection Pottery. Purchased at Kohl's Department Store. Location: Dining Room. Corre ndin Digital Photo h File: china Ibis Appraisal Services Pale 10 of 28 19 Chairs. Set of two modern twentieth/twenty-first $60.00 century island chairs. Location: Kitchen. Corresponding Digital Photograph File: img 7203 20 Mixer. Modern twentieth/twenty-first century $165.00 Kitchen Aid mixer. Location: Kitchen. Corresponding Digital Photograph File: img 7204 21 Knife Set. Modern twentieth/twenty-first century $40.00 ' y Chicago Cutlery knife set with box. Location: Kitchen. Corresponding Digital Photograph File: img 7205 22 China Service. Modern twentieth/twenty-first $60.00 century china service for eight. Maker: Pfaltzgraff. Pattern: Nature Wood. a . Location: Kitchen. Corresponding Digital Photograph File: img 7206 3 Ibis Appraisal 5ervices Page 1 1 of 28 23 Coffee Machine. Keurig coffee machine. $125.00 vo O Location: Kitchen. Corresponding Digital Photograph File: img 7207 24 Coffee Machine. Kenmore coffee machine. $35.00 Location: Kitchen. Corresponding Digital Photograph File: img 7208 25 Television. Modern twentieth/twenty-first century $125.00 Mitsubishi 72" color television. Location: TV Room. Corresponding Digital Photograph File: img 7209 26 Posters. Four modern twentieth/twenty-first century $40.00 framed and matted modem posters. Location: TV Room. Corresponding Digital Photograph Files: img 7211 & img 7213 16is Appraisal Services rage 12 of 28 27 Cabinet. modern twentieth/twenty-first century pine $30.00 cabinet with drop-down desk, one drawer and one door. Location: TV Room. Corresponding Digital Photograph File: img 7210 28 Lamn. modern twentieth/twenty-first century table $5.00 lamp Location: TV Room. Corresponding Digital Photograph File: lamp3 r a_ 29 Sofas. Two modern twentieth/twenty-first century $300.00 matching sofas. Location: TV Room. Corresponding Digital Photograph File: img 7212 30 Screen. Modem twentieth/twenty-first century rice $40.00 paper screen. Location: TV Room. Corresponding Digital Photograph File: screen 31 Table. Modem twentieth/twenty-first century table. $20.00 Location: TV Room. Corresponding Digital Photograph File: table2 1bis Appraisal Services Fage 13 of 28 32 Chair. Modern twentieth/twenty-first century plush $55.00 recliner chair. Location: TV Room. Corresponding Digital Photograph File: img 7214 33 Suitcases. Modern twentieth/twenty-first century $25.00 stacked decorative suitcases. Location: Computer Room. Corresponding Digital Photograph File: img 7215 34 Cabinet. Modern twentieth/twenty-first century pine $35.00 side cabinet with three drawers and one door. Location: Computer Room. Corresponding Digital Photograph File: img 7216 35 Lamp. Modern twentieth/twenty-first century lamp. $25.00 Location: Computer Room. Corresponding Digital Photograph File: lamp4 16is Appraisal Services Page I+ of 28 36 Desk. Modern twentieth/twenty-first century particle $40.00 board computer desk. Location: Computer Room. L Corresponding Digital Photograph File: 7217 37 Bookshelves. Modern twentieth/twenty-first century $50.00 bookshelves. Location: Computer Room. A Corresponding Digital Photograph File: img 7219 38 Books. Selection of modern twentieth/twenty-first $95.00 century books. Location: Computer Room. Corresponding Digital Photograph File: img 7219 39 Chair. Modern twentieth/twenty-first century office $20.00 chair. Location: Computer Room. Corresponding Digital Photograph File: img 7218 Ibis Appraisal crviccs Page 15 of 28 40 Bench. Modem twentieth/twenty-first century $20.00 primitive pine bench. Location: Computer Room. Corresponding Digital Photograph File: img 7220 41 Weights/Bench Press. Mid-width weight machine $75.00 and bench press. Marcy MWB848. Location: Exercise Room. Corresponding Digital Photograph File: img 7221 42 r Stereo. Modem stereo. Sony MHC-GX450. Location: Computer Room. $80.00 Corresponding Digital Photograph File: img 7222 43 Bench. Exercise bench. Fitness Gear FG200. $25.00 Location: Computer Room. Corresponding Digital Photograph File: img 7223 44 Weight Machine. Weight lifting machine. Bowflex $300.00 Ultimate. Location: Computer Room. Corresponding Digital Photograph File: img 7224 16is Appraisal 5crvicc5 Page 16 of 28 45 Elliptical. Tread Climber TC 3000 elliptical. $700.00 Location: Computer Room. Corresponding Digital Photograph File: img 7225 46 Treadmill. Weslo Cadence LX25 treadmill. $100.00 Location: Computer Room. Corresponding Digital Photograph File: img 7226 47 Grill. Outdoor gas grill. Maker: Perfect Flame. $190.00 Location: Outside. Corresponding Digital Photograph File: img 7227 48 Porch Furniture. Modern twentieth/twenty-first $90.00 century outdoor porch furniture. Four chairs, four ottomans and two tables. Location: Outside. Corresponding Digital Photograph File: img 7228 16is Appraisal 5crviccs Page 17 of 28 49 Chiminea. modern twentieth/twenty-first century $20.00 chiminea. Location: Outside. Corresponding Digital Photograph File: img 7230 50 Television. Sony 42" color television. $15.00 Location: Basement. Corresponding Digital Photograph File: img 7231 51 Washing Machine. Whirlpool Ultimate Care II $75.00 washing machine. Location: Basement. Corresponding Digital Photograph File: img 7232 52 L = ' Dryer. Whirlpool Ultima Care H clothes dryer. Location: Basement. $75.00 Corresponding Digital Photograph File: img 7233 53 Work Table. Work table. Black & Decker $15.00 Workmate P225. Location: Basement. 54 - Tools. Selection of miscellaneous household tools. $65.00 Location: Basement. Corresponding Digital Photograph File: img 7234 16-, Appraisal jervices Page I e of 28 55 Freezer. Kenmore Upright freezer. $50.00 Location: Basement. 56 Chest. Modern twentieth/twenty-first century $45.00 upright pine chest/armoire with one door. Location: Bedroom 1. Corresponding Digital Photograph File: img 7235 57 ""~t Desk. Modem twentieth/twenty-first century pine $40.00 desk with drop-front desk, one drawer and two doors. Location: Bedroom 1. Corresponding Digital Photograph File: img 7236 58 Chair. Modem twentieth/twenty-first century office chair. $15.00 Location: Bedroom I. Corresponding Digital Photograph File: img 7237 59 Bedroom Suite. Modem twentieth/twenty-first $1,150.00 century bedroom suite. Suite includes king bed, chest with mirror, television/entertainment center, tall chest and two night stands. Purchased at NB Lehmann. Location: Master Bedroom. Corresponding Digital Photograph Files: img 7238-img 7241 165 Appraisal Services Page 19 of 28 60 Chest. Modem twentieth/twenty-first century chest- $60.00 on-chest with five drawers. Location: Bedroom 2. Corresponding Digital Photograph File: img 7242 61 Bed. Modem twentieth/twenty-first century double $50.00 bed. Location: Bedroom 2. Corresponding Digital Photograph File: img 7243 62 Chair. Modem twentieth/twenty-first century wicker $45.00 chair. Location: Bedroom 1. Corresponding Digital Photograph File: img 7244 Total $8,287.00 16is Appraisal `jervices rage zo of 28 APPRAISAL SUMMARY (COPY) It is in my opinion, that, as of May 27, 2011, the Fair Market Value of the marital personal property of Barbara King and Mr. King, 1825 Bridge St. New Cumberland, PA 17070: (Eight Thousand Two Hundred Eighty Seven Dollars and Zero Cents) ($8,287.00) pis Appraisaf C.A. )irector The report must be read in its entirety. The Appraisal Summary ONLY is not the appraisal report. 16is Appraisal Services rage 21 of 28 1 GLOSSARY Extraordinary Assumption. An assumption, directly related to a specific assignment, which, if ' found to be false, could alter the appraiser's opinions or conclusions [USPAP]. Fair Market Value. The price at which a property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts [IRS Regulation Section 1.170A-1(c)(2)]. ' Hypothetical Condition. That which is contrary to what exists but is supposed for the purpose of analysis [USPAP]. ' Replacement Value. The term replacement value refers to the amount that an entity would have to pay, at the present time, to replace any one of its assets [Wikipedia]. ' Sale Comparison Approach. This approach compares an object property's characteristics with those of comparable objects that have recently sold in similar transactions [Wikipedia]. I bis Appraisal 5crviccs Page 22 of 28 CERTIFICATION OF APPRAISAL I certify that, to the best of my knowledge and belief- - The statements of fact contained in this report are true and correct. - The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. - I have no present or prospective interest in the property that is the subject of this report and no personal interest with respect to the parties involved. - I have no bias with respect to the property that is the subject of this report or to the parties involved with this assignment. - My engagement in this assignment was not contingent upon developing or reporting predetermined results. - My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. - My analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards of Professional Appraisal Practice. - I have made a personal inspection of the property that is the subject of this report. - No one provided significant personal property appraisal assistance to the person signing this certification. This appraisal was based upon the following assumptions, limitations, and conditions: 1. The information contained in this report was gathered from sources considered reliable, personal examination, research of authenticity and comparable sales and/or auction prices. 2. No responsibility is assumed for matters that are legal in nature, including, but not limited to: the representation of others concerning the value, authenticity, condition, origin, or provenance of an item appraised. 3. The appraiser assumed that a normal and careful examination of the property was sufficient to determine its quality and condition and that no extraordinary examination procedures were to be utilized, unless these were specially requested and the expenditure of funds therefore authorized. 4. The appraiser's court attendance and expert testimony report, if required, are not included as part of this report. The appraiser does have the right to refuse testimony. It is the firm belief of the appraiser that the information furnished in this appraisal report and the conclusions drawn from this information are true and correct, but they are not guaranteed. r isr? L. irector 16is Appraisal Services aisat Page 23 of 28 APPRAISAL REFERENCES Alderfer's Auction. 501 Fairground Rd. Hatfield, PA 19440.215-393-3003. http://www.alderferfinearts.com/ Conestoga Auction Company Inc. 768 Graystone Rd. Manheim, PA 17545. 717-898-7284. http://www.conestogaauction.com/auctions/ Cordier Antiques & Auctions. 2151 Market St. Camp Hill, PA 17011.717- 731-8662. http://www.cordierantiques.com Craig's List. http://www.craigslist.com eBay. http://www.ebay.com Elmer Murray Auctions. Richard P. Murray. 717-790-2240. http://www.richardmurryauctioneer.com/ Gottshall, Jr., Roy Auctions. 113 Forge Rd. Boiling Springs, PA 17007.717-258-6222. Hershey, Dan Auctioneering Service. 3 Brown Rd. Shippensburg, PA 17257. 717-532-4647. Hess Auctions. John M. Hess Auction Service, Inc. 1667 Cider Press Road Manheim, PA 17545. 717-664-5238. http://www.hess-auction.com/ I.R.S. Publication 561: Determining the Value of Donated Property. http://www.irs.gov/pub/irs- pdf/p561.pdf Kohls. http://www.kohls.com Morphy Auctions. 2000 N. Reading Rd., Denver, PA 17517. 717-335-3435. http://www.morphyauctions.com/ Ocker, Carl E. Auction. 4401 Philadelphia Ave. Chambersburg, PA 17201. 717-264-6578. http://www.kennysauction.com/ Pook & Pook. 463 East Lancaster Ave. Downingtown, PA 19335.610-296-4040. http://www.pookandpook.com TeWeak. http://www.terapeak.com U.S. Treasury Regulations Section 1 170A-1(c)(2)• Charitable etc Contributions and Gifts• Allowance of Deduction. http://www.taxalmanac.org/index.php/Reg._1.170A-1 Uniform Standards of Professional Appraisal Practice. http://www.appraisalfoundation.org ' 16is Appraisal Services rage 24 of 28 1 . , Wikipedia. http://en.wikipedia.org/wiki/Replacement-value 16?s APPraisa1cJ' --i,-es rage 25 of 28 PRIVACY NOTICE Pursuant to the Gramm-Leach-Billey Act of 1999, effective July 1, 2001, appraisers, along with all providers of personal financial services are now required by federal law to inform their clients of the policies of the firm with regard to the privacy of client nonpublic personal information. As professionals, we understand that your privacy is very important to you and are pleased to provide you with this information. In the course of performing appraisals, we may collect what is known as "nonpublic personal information" about you. This information is used to facilitate the services that we provide to you and may include the information provided to us by you directly or received by us from others with your authorization. We do not disclose any nonpublic personal information obtained in the course of our engagement with our clients to nonaffiliated third parties, except as necessary or as required by law. By way of example, a necessary disclosure would be to our independent contractors, and in certain situations, to unrelated third party consultants who need to know that information to assist us in providing appraisal services to you. All of our independent contractors and any third party consultants we engage are informed that any information they see as part of an appraisal assignment is to be maintained by strict confidence within the firm. A disclosure required by law would be a disclosure by us that is ordered by a court of competent jurisdiction with regard to a legal action to which you are a party. We will retain records relating to professional services that we have provided to you for a reasonable time so that we are better able to assist you with your needs. In order to protect your nonpublic personal information from unauthorized access by third parties, we maintain physical, electronic, and procedural safeguards that comply with our professional standards to insure the security and integrity of your information. 16is Appraisal `jervices Pave 26 of 28 1 STATEMENT OF QUALIFICATIONS Alyssa L. Loney, C.A. ' PRESENTLY Founder of This Appraisal Services. Owner and Director. October 2001- Present. Responsible for the management and direction of Ibis Appraisal Services. Conducts extensive on-site and in- house appraisals, valuations, assessments, and analyses of personal and cultural property. Conducts research on all objects considered personal and cultural property. Performs appraisals for divorces, estates and insurance. Performs in the service of law firms, banks, insurance ' agencies, universities, library, museums, churches, non-profit agencies and the general public. ' Responsible for the development of policies, guidelines, public programs, and standards for Ibis Appraisal Services. Takes an active role in promoting ethics in appraising. Works with local, state, national and international agencies to prevent and uncover appraisal and personal/cultural ' property fraud. Member of Institute of Appraisal of Personal Property, American Society of Appraisers, International Society of Appraisers, and Professional Coin Grading Service. ' PROFESSIONAL COURSE COMPLETIONS ISA Course Completions - Core Course in Appraisal Studies ' - Antiques & Residential Contents USPAP Completions - 2002 Uniform Standards of Professional Appraisal Practice ' - 2009 Uniform Standards of Professional Appraisal Practice (takes 15hr course, rather than update course) Archaeological Resources Protection Act Course - American Antiquities Act of 1906. - National Historic Preservation Act of 1966 - Archaeological Resources Protection Act of 1979 ' - Native American Graves Protection and Repatriation Act of 1994 PROFESSIONAL ACCOMPLISHMENTS ' * State Historical and Underwater Archaeologist for the State of Louisiana. * Attended the Conservation of Indian Artifacts Symposium sponsored by the Smithsonian Institution and the Tunica-Biloxi Indian Reservation, Marksville, Louisiana. ' * Director of the West Virginia University Historical Costume Museum. * Research Archaeologist/ Artifact Instructor for CADW (Welsh Historic Monuments)/ University of York, England. * Research and Preservation Specialist for the Maryland Historical Trust. * Presented and published works for national and international organizations including the Society for Historical Archaeology, Middle-Atlantic Archaeology Conference, Southeastern ' Archaeological Conference, Louisiana Archaeological Society, and the Maryland Historical Trust. 16is Appraisal `jervices age 27 of 28 EDUCATION B.Sc. Historical Textiles and Clothing, 1992, West Virginia University, Morgantown, West Virginia, United States. M.A. Archaeology, 1995, University of York, York, England. C.A. Certified Appraiser of Personal Property, 2001, Institute of Appraisal of Personal Property, York, Pennsylvania, United States. A.R.P.A. Archaeological Resources Protection Act, 2000. S.B.D.C. Entrepreneurial Series, 2001, Kutztown University of Pennsylvania, Small Business Development Center. 16is Appraisal 5ervicc5 Page 28 of 28 D S ro W N p it 0 A ! "] Vt ?m r+ r r? r w r 0 4 Ch 0 pl, h3 O 11 r r P.O. Box Porr Bragg, NC 910-8C PORT 1-8U0-79-P E ? Pax 910-48 wwwhrtbragg nu F FI)EKAL CR W I klxl 008479 COREY E KING BARBARA D KING 1825 BRIDGE STREET NEW CUMBERLAND PA 17070-1126 MENT OF ACCOUNTS LET FORT BRAGG FCU GET YOU BACK TO SCHOOL IN STYLE THIS YEAR! -? APPLY FOR A BACK TO SCHOOL LOAN THAT WILL HELP YOU FINANCE ALL THOSE COSTLY, BUT NECESSARY BACK TO SCHOOL ITEMS AND YOU COULD WIN $150 IN FREE GAS! RATES AS LOW AS 8.9/ APR. NOTICE: PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION SHARE ACCOUNT ACCT# 1' 06-01-09 THRU 06-30-09 PREVIOUS BALANCE 25.95 0 NEW BALANCE . 2$ 95 z I FREEDOM ACCOUNT ACCT# 2 06-01-09 THRU 06-30-09 PREVIOUS BALANCE 750.97 1 PAYMENT SHR TRANSFER 146 50.00_ 700.97 11 EFT PENNINK & STROTH PENNINK & STROTHDISBURSEME061009 675,00 1.375,97 JN15 SHARE DRAFT 8342 66.00- M 97 ?O I DIVIDEND O. 17 770.14 ***.ANNUAL PERCENTAGE YIELD EARNED FROM 0601-09 THRU 06-30-09 ON AVG. DAILY BAL ANCE OF 630_97 WAS 0.25% *YR JN30 r NEW BALANCE 776.14 1 SD# DATE AMOUNT SD# DATE AMOUNT SO# DATE AROLfft- i SDI# ` DATE Aw-R04T 8342 JUN15 600.00 '. SIGNATURE LINE OF CREDIT LN# 146 NOTE# 34989 06-01-09 Tr§NJ 06-30--W ,t-REViatz BALD 22:x.13 1 LOAN PAYMENT-TRANSFER TO-PRIN 46.71- ? 50-00 3.:9 273-43 1 LOAN CHANGE: TO-PRIN 0.00 0.00 0.00 278. 4.3 REQPMT THIS CYCLE 50.00, MINPMT 50.00, CYCLE DATE 06-01-09 0 NEW BALANCE 278_ r i DAILY PERIODIC RATE .0326G3>rs CMR:ES D& IDE'S' RATE '`. 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N N J -N J N J N Y ?-1 4\ 01 m m m m m m o, w m .A rn AP m I . o ID o 0 0 0 0 m m mm m m m o - Aa Aa Aa 1P A .P IP N N m N O N 0 N Current Information Eve florae MORTGAGE COMPANY Personal Preferences Change Personal Contact Change Password Change Security Q&A Add/Remove/Change Loan Change Email Address Notify Me Loan Servicing Center Current Loan Information Loan Activity Escrow Information Tax and Interest Amortization Schedule Year End Statement Auto Draft Payment Make a Payment Take Our Survey Log Out Current Loan Information Loan Number: 0000028339 Property Address: 512 AQUINAS AVE FAYETTEVILLE, NC 28311-0000 Borrower Name: COREY E KING Co-Borrower Name: BARBARA D KING Current Interest Rate Original Loan Amount Loan Type Payment Method General Loan Information Current Principal Balancer $45,361.65 .k. 1-din Origination Date `" ` 03/11/1994 First Payment Due Date 05/01/1994 Maturity Date 04/2024 Next ARM Adjustment 08/0112010 Payment Information Scheduled Payment Breakdown: Next Payment Due` 0310112010 Principal 8lnterest $376.89 Homeowner's Insurance(s) $42.42 County Tax $76.76 03/01/2010 Scheduled Payment $496.07 Payments received more than 15 days after the payment due date may require a late charge of $19.84. If Next Payment Due date is in the past, additional payments, charges and/or fees may be required to bring your loan current. Year-To-Date Totals Principal Interest Page Iof I 4.875% $691,500.00 VA, residential ARM Coupons Last Payment Breakdown: Principal Received $299.23 Interest Received $185.50 Escrow Received $115.27 For more detailed information, click here $597.25 Property Taxes $0.00 $372.21 Hazard Insurance $0.00 return to loan servicing center Copyright ® 2000 -2010. Lender Processing Services, Inc. All Rights Reserved. https:Hcarenet. fnfismd. com/everhome/MenuServlet?MenulD=CNAV311 %2C2%2C0%2C... 3/10/2010 C 111111 IIIII III IIIN IIIII IIIII IIIII Nil IIIII IIIII IIIII 111111 IIIII 111111 IIII 111111 IIII IIII IINI IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII IIII IIII ' DEPARTMENT OF VETERANS AFFAIRS Debt Management Center Bishop Henry Whipple Federal Building ' P.O. Box 11930 St. Paul, MN 55111-0930 JANUARY 27, 2010 COREY EDWARD KING 1825 BRIDGE STREET NEW CUMBERLAND PA 17070 File Number: 524339468 Payee Number: 00 Person Entitled: CEKING Deduction Code: 30 E-Mail Address: dmc.ops@va.gov e to your Co pensation and Pension indebtedness in the amount ?0 Refer tl5:,827.43 a?Qk ? f $ We have written to you previously about your VA debt which was created as a result of a w reduction in your benefits. Although you were notified of our intent to withhold your benefit \ payments to recoup this debt, that action did not occur because the amount available for with- , ?u holding is considered to be insufficient as a monthly payment on your debt. Therefore, we request that you now remit payment in full. ' If you cannot pay your debt in full at this time, you should contact this office within the next 30 days to establish a satisfactory repayment plan. You must complete the enclosed Financial Status Report and return it to this office in order to expedite your request for a repayment agreement with us. If you want to make arrangements to repay this debt, or if you have any questions concerning this letter, you may contact us by calling toll-free 1-800-827-0648. If sending payment in full, your check or money order for the balance due should be made pay- able to the U.S. Department of Veterans Affairs and returned in the enclosed envelope along with the remittance slip below. Please include your full name and file number on your check or money ' order to insure proper credit. Chief, Operations Division Enclosures ----------=-------=--=------=--=x------------------------------------ FOR PROPER CREDIT TO YOUR ACCOUNT, PLEASE DETACH AND RETURN WITH YOUR PAYMENT 2010027 PAYMENT REMITTANCE 524339468003003051109140727 524339468 0030 03051109140727 1582743 0 * FILE NO. .524339468 AMOUNT ENCLOSED ENTER YOUR CURRENT ADDRESS BELOW ONLY IF THE ONE ABOVE IS INCORRECT. PLEASE INCLUDE YOUR ZIP CODE. PAYEE NO. ? 00 $ PERSON ENTITLED 110- CEKING YOUR TELEPHONE NO. (Include Area Cud.) DEDUCTION CODE 100- 30 Please include this number on your check or money order. ;ICK 0 H&R BLOCK ATAGE Ar"NA. If--x 'r "ecll For Prepared By For Year- round mice, C ?. EAPSNPA Kid; HRH TAX GROUP €`a- '500 N George St 50 Newberry Co1`71MrA York: PA'.7404- C94 Ellers, PA 1 T32 9- CI(W (717)848- 6004 i ?1i}538-4644 appreciate your 5.j.... F-d thank you for !rusting me to be your tax partner. My business Continues to grog through rao?l.,i ???tons from clients like you and I'd be honored to help anyone you ,ecommend M, me"'. Today's Savings uziz Q 1 _ ; alif?ed ret€remert plan through your employer :his year and making $113.00 pretax dollars, you reduced your taxes by, ,r, simple terry =,. q ' of f.ax Bute is the tax rate that your pay or your last dollar of axab!e income. It is tree `aderal tax bracket that affects your tax calculation. The Effective Tax Rate is the pare ?, )# your total income that you paid in taxes. For 20091 your Margmai Tax Rate is 250 ar d 8.ou E"factfve 'l'ax Rate is 19°*: Total Savings,,.,...,, .......... ............ Filing, Refund and Balance Clue Information rCAt d i Tax Return ile k E- jin n Due Pa nt tr ormation De1iVe yes * "ft Due, - 1 44.?ayl?) NBR Stock ? t$20; '4) fYB a P3 anal it. .?. jb y YP. ii i3:?, ?L+V?!'?!y5h'.?JtiI'? 1ir?f S4,490- D3 Y;•• IN t ERNIAx. !? F EVENU CE Makecheckpayabieta; RO.Box37 8 UNFED STA T ES TREASURY HARTFOPD, CT 17k317C-- 00,Z, The check pa°¢ €s to Mail oe to, PADEPARTV-:NT OF PADEPAI`i'MI 0FREL> E! u-6 PnYviEN ENCLOSED REVENUE isrueby 1 REV MUE RACE 1 April 15,.2110 for HARPISBUW... FA 17 ice- :rust. 1 H& %€0 ?. Ac#vr'rsSyrB pot .: Y'Y <. :..rrytior Thai cowo t wp y oq irny3r.or* ptrur?ax ana (#r.?sSr at al4:t io<: I±s t'rir>. en?s ihw7d te. E.£!'.S r3h.'.*r^ri sr; ;.tl3 t;?'rC!i n,k tt d:;o. ..GCSE;-s W eW4 401 Vow sRiM1.+C G.+?... r;?!xncx;S rax s rvfc?s ptt0rlSC ;'"taus,. srtCal4:a.'?as of HPF Fu e3.r3 .o, le c {it#vAnYe e{ FDIIMCE-tVi.A e r 3 ?:,r rg b s ax.=Iws:p,Inc . C:heekoImage Check # 193 MIN N. W AVANIE ' 193 aae LWAM ew" ?7 > 6NOL4. PA "M ?? c? G}?t W sn tt ? STa£ Am# me Pay to the ? $ r ? ? Pik bqO ? few 1.2- ?9 q&A • ?• L0 2i 3 21" Qk9 3 ?'ODCI L 71.00.0` ?. ? 3 Tlat2 04C1QR sftVV1A & ,y T"rV ¢ ennt _ close Page 1 of I https://images.midatlanticcOTpoiatL..org/image/cheekimage_w.asp 6/2112011 OF THE t PROTHONOTARY 2011 JUN 28 AN 11 t 3S CUMBERLAND COUNTY PENNSYLVANIA COREY EDWARD KING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA DAWN KING, Defendant CIVIL ACTION - LAW NO. 09-2001 CIVIL TERM IN DIVORCE DEFENDANT'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT II - ALIMONY 2. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Defendant is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Plaintiff is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Defendant and to pay her alimony in accordance with the Divorce Code of Pennsylvania. ?-`+) a D ? d- ?Y ( ?ti+5 ?? ?l Ss WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which she has become accustomed during the marriage. COUNT III - ALIMONY PENDENTE LITE 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her reasonable alimony pendente lite during the pendency of this action. COUNT IV - COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. Samuel L. An es Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: •/1n . l BARBARA DAWN ING f_ED-01== iOv PROTHONO 2011 AUG -3 PM 2: 02 CUMBERLAND UUIJN-;_,; , ENNSYL!/At-41A 0 COREY EDWARD KING, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2001 CIVIL BARBARA DAWN KING, : IN DIVORCE Defendant SUPPLEMENTAL PRE-TRIAL STATEMENT OF PLAINTIFF COREY EDWARD KING 1. Statement of Case It is the position of the Plaintiff that the Master has no jurisdiction to hear testimony and accept evidence on the issues of alimony, alimony pendent lite, and counsel fees and expenses. The statute and applicable rule of civil procedure provides that the court may appoint a master to hear testimony for all or some issues. 23 Pa.C.S.§ 3321; Pa.R.C.P. No. 1920.51(a)(1). On March 24, 2011 the Court (Hess, J.) issued an order appointing the master with respect to the sole issue of Distribution of Property. (A true and correct copy of the Order of Court is marked as Exhibit "A", attached hereto and incorporated herein.) To date the master has not been appointed on any other issues. In the alternative, Defendant is not entitled to an award of alimony, alimony pendent lite, or counsel fees and expenses due to her own actions and/or inactions. With respect to the issue of alimony, Plaintiff raises fault grounds as a defense. Defendant subjected Plaintiff to abuse and indignities due to her constant abuse of alcohol. Defendant would get drunk every evening and on both days of the weekend. Defendant would begin drinking alcohol at 11:00 a.m. and continue until she would pass out. Defendant then would start the daily cycle of alcohol abuse all over again. Around the beginning of 2008, and due to her alcohol abuse, Defendant began to neglect household routines, e.g., laundry, grocery shopping, taking care of the pets, etc. Defendant also began to neglect her own personal hygiene. Sexual relations between the parties became nonexistent. One evening Plaintiff woke up to find Defendant urinating off the edge of the parties' bed. On some occasions when the parties did go out in public to a restaurant, Defendant would drink alcohol non-stop to the point where Plaintiff had to carry Defendant out of the establishment because she could not walk under her own power. During this time period Defendant became more and more belligerent towards Plaintiff. In or around November, 2010, after the parties had separated, Defendant was terminated from her employment with West Shore Family Dentistry due to showing up for work drunk and drinking alcohol on the job. Before she was terminated by West Shore Family Dentistry, Defendant received a salary of $70,000 per year. It is not known what efforts, if any, Defendant has made to become sober and employable since her last steady job. With respect to the issue of alimony pendent lite, Defendant is employable should she gain control of her alcohol abuse, she is a trained dental assistant and professional tax preparer. In addition, Defendant has received spousal support payments from Plaintiff since the inception of the divorce proceedings. Defendant is not entitled to an award of counsel fees and expenses due to her non- compliance with the Rules of Civil Procedure and her inactivity to respond to numerous 2 requests by Plaintiff, both by way of discovery and by way of response to settlement proposals. Defendant never has filed an Inventory despite the obligation to due so per the Rules of Civil Procedure, and despite the Master's directive to file a Pre-Trial Statement on or before June 27, 2011, Defendant ignored the deadline. In addition, the following are some examples of Defendant's non-compliance and nonfeasance: 1. Plaintiff's First Request for Production of Documents served on June 15, 2009 - NO RESPONSE BY DEFENDANT. (A true and correct copy of Plaintiff's First Request for Production of Documents is marked as Exhibit "B", attached hereto and incorporated herein.) 2. July 15, 2009 letter from Defendant's counsel to Plaintiff's counsel requesting an extension of time until the end of the first week of August, 2009 to respond to Request for Production of Documents - NO RESPONSE BY DEFENDANT. (A true and correct copy of the July 15, 2009 letter is marked as Exhibit "C", attached hereto and incorporated herein.) 3. October 28, 2010 letter from Plaintiff's counsel to Defendant's counsel again requesting response to Request for Production of Documents - NO RESPONSE BY DEFENDANT. (A true and correct copy of the October 28, 2010 letter is marked as Exhibit "D", attached hereto and incorporated herein.) 4. April 23, 2010 letter from Plaintiff's counsel to Defendant's counsel with settlement proposal - NO RESPONSE BY DEFENDANT. (A true and correct copy of the April 23, 2010 letter is marked as Exhibit "E", attached hereto and incorporated herein.) 5. June 21, 2010 letter from Plaintiff's counsel to Defendant's counsel regarding an agreement by the parties to perform certain tasks and exchange certain items of discovery. (A true and correct copy of the June 21, 2010 letter is marked as Exhibit "F", attached hereto and incorporated herein.) 6. March 8, 2011 letter from Defendant's counsel to Plaintiff s counsel providing a partial response to the agreement of June 21, 2010. (A true and correct copy of the March 8, 2011 letter is marked as Exhibit "G", attached hereto and incorporated herein.) 7. March 15, 2011 letter from Plaintiff's counsel to Defendant's counsel regarding non-compliance of Defendant to the agreement of June 21, 2010. (A true and correct copy of the March 15, 2011 letter is marked as Exhibit H", attached hereto and incorporated herein.) 8. January 13, 2011 letter from Defendant's counsel to Plaintiff- s counsel providing another partial response to the agreement of June 21, 2010. (A true and correct copy of the January 13, 2011 letter is marked as Exhibit attached hereto and incorporated herein.) 9. February 24, 2011 letter from Plaintiffs counsel to Defendant's counsel requesting counteroffer - NO RESPONSE FROM DEFENDANT. (A true and correct copy of the February 24, 2011 letter is marked as Exhibit "J", attached hereto and incorporated herein.) 4 10. March 9, 2011 letter from Defendant's counsel to Plaintiff s counsel indicating that Defendant has no settlement offer to propose. (A true and correct copy of the March 9, 2011 letter is marked as Exhibit "K", attached hereto and incorporated herein.) 11. March 11, 2011 letter from Plaintiff's counsel to Defendant's counsel indicating Defendant's lack of response to formal discovery request. (A true and correct copy of the March 11, 2011 letter is marked as Exhibit "L", attached hereto and incorporated herein.) 12. May 18, 2011 letter from Plaintiff's counsel to Defendant's counsel once again requesting a settlement proposal - NO RESPONSE BY DEFENDANT. (A true and correct copy of the May 18, 2011 letter is marked as Exhibit "M", attached hereto and incorporated herein.) 13. June 27, 2011 letter from Plaintiff's counsel to Defendant's counsel proposing another settlement offer - NO RESPONSE BY DEFENDANT. (A true and correct copy of the June 27, 2011 letter is marked as Exhibit "N", attached hereto and incorporated herein.) II. Additional List of Fact Witnesses 1. Dr. Thomas Gensbigler West Shore Family Dentistry This witness will testify that Defendant was terminated from her employment by him for showing up for work drunk and for drinking alcohol in the office during the work day. 2. Jeffrey King This witness will testify regarding Defendant's actions towards Plaintiff and treatment of Plaintiff during the course of the marriage. 3. Kevin King This witness will testify regarding Defendant's actions towards Plaintiff and treatment of Plaintiff during the course of the marriage. Respectfully submitted, SCARINGI, P. I / / ZL61,lc Frank C. Sluzis, Esquire Attorney for Plaintiff PA ID# 43829 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: 717.657.7770 Fax: 717.657.7797 Email: frank(a?scaringilaw.com 6 COREY EDWARD KING, Plaintiff V. BARBARA DAWN KING, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2001 CIVIL IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 3rd day of August, 2011, I, Frank C. Sluzis, Esquire, do hereby state that I served a true and correct copy of the foregoing document upon the following individuals in the manner indicated. VIA FIRST CLASS U.S. MAIL POSTAGE PRE-PAID Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 E. Robert Elicker, II, Esquire Divorce Master Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 S By: PA ID# 43829 Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 Phone: 717.657.7770 Fax: 717.657.7797 Email: frank(a)scaringilaw com 7 Respectfully submitted, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COREY EDWARD KING vs. Plaintiff NO. 2009 BARBARA DAWN KING 2001 Defendant MOTION FOR APPOINTMENT OF MASTER Plaintiff , moves the court to appoint a master with respect to the following claims: ? Divorce n 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 (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Samuel L. Andes Esquire). 3, The staturory ground (s) for divorce is Section 3301(d) - Two year separation CJ ?? - 1 ?; 4. Delete the inapplicable paragraph (s): A X? B ?X C ? r1 M _^I?} a. The action is not contested. 61 b. An agreement has been reached with resnect to the following claims: G. The action is contested with respect to the following claims: G7 _ Q CTS Equitable Distribution rr' CJl 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one (I) days 7. Additional information, if any, relevant to the motion: A-C FI ?. . Date: / S. Attorpey for Plaintiff Frazrk C. Sluzis, Esquire Print Name ORDER APPOINTING MASTER AND NOW MdM,h a? 20JL_> G. Robert 2 1 _ i JeR IEsquire, is appointcd master with respect to the following claims: _(Z;zI is'd a Mye TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This. y of _ M 10- , 2011 j6p U Prothonotary By the Court, L-4PAA- das, gAt4l,51T A ?. . ,? ? ? ? ? ._ ?. i L. ?... :John J. Connelly, Jr., Esquire Attorney I.D. #15615 :fames, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Attorneys for Plaintiff COREY EDWARD KING, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. BARBARA DAWN KING, Defendant NO. 2009-2001 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO: Barbara Dawn King, Defendant c/o Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Plaintiff, Corey Edward King, by his undersigned counsel, hereby propounds the following request for production of documents and tangible things pursuant to the Pennsylvania Rules of Civil Procedure. The documents and tangible things requested herein must be produced at the law offices of James, Smith, Dietterick & Connelly, LLP, within thirty (30) days. INSTRUCTIONS AND DEFINITIONS Each of the following requests is intended as a separate request. Where a request has subparts, please respond to each subpart separately and in full. Do not limit any response to the numbered request as a whole. If you have any objection to any request, please state your objection fully and set forth the factual basis for your objection in lieu of production of the documents. You must file and Ap I is /T i3 serve a written response to these requests within thirty (30) days of service of these requests upon you, regardless of the time set for production of the documents and things requested herein. You are reminded that any objections not raised within the thirty (30) day period provided for by the Rules of Court will be deemed to have been waived by you. These requests are not only for documents and tangible things that are owned by you, but also for documents and tangible things that are in your possession, custody, or control. This means that you must produce all documents and tangible things that are responsive to a particular :request and that are in your possession (regardless of whether they are your property), or over which you have control even if they are not in your possession. It also means you must produce documents and tangible things that are in the possession, custody, or control of your agents, employees, and/or attorneys. Before responding to these requests you are required to make a diligent search of your files and records to ascertain whether you have documents that would be responsive to a given .request. Your agents, employees, and attorneys must do the same. To avoid any possibility of confusion with respect to these requests, please note that the following terms have the following meanings in these requests, unless a particular request clearly indicates otherwise: "You" or "your" refer to the person to whom these requests have been addressed. "Person" means any natural person, corporation, unincorporated association, trust, partnership, and/or any other legally cognizable entity. It is contemplated that any corporation or other business entity acts only through its agents, officers, employees, and attorneys, and requests that apply to any such legal entity should be construed accordingly. "Plaintiff" means the particular plaintiff or plaintiffs in this section to whom this request is addressed, as set forth above. "Defendant" means the defendant or defendants named in this action. "Document", "record", "file", and "report" all refer to and contemplate all written, recorded, or graphic information, whether preserved in writing, on magnetic tape, by electronic means, in photographic form, on microfilm or microfiche, computer disc, or by any other means of information retrieval or storage. DOCUMENTS TO BE PRODUCED Please produce at the law offices of James, Smith, Dietterick & Connelly, LLP, counsel for Plaintiff, located at 134 Sipe Avenue, Hummelstown, Pennsylvania 17036, within thirty (30) days of the date of this Request, the following documents: Copies of all Federal and State Tax Returns for 2008 and 2009, along with all schedules, including but not limited to, W=2's, 1098's, and 1099's. 2. Proof of all sources of income, including but not limited to, bonuses, all year-to- date pay stubs, or other documentation confirming all earnings received from January 1, 2010 through the present, through your employment and H&R Block. 3. Proof of all money which you receive from your employer for not electing health insurance through your current employment. 4. Copies of all statements for any and all pensions, retirement, IRA or other retirement type investment held by you, including but not limited to, your West Shore Family Dentistry Retirement Plan and Roth IRA account #2082, from November 1, 2008 through the present. 5. Copies of all monthly statements for any bank account held by you, individually or jointly with another, including but not limited to, the New Cumberland Federal Credit Union joint account# 74466, from January 1, 2008 through the present. 6. A copy of the current balance of the EverHome mortgage, account # 0000028339, for the property located at 512 Aquinas Avenue, Fayetteville, NC. 7. A copy of the current balance of the Flagstar mortgage, account #502052382-4, for the marital residence located at 1825 Bridge Street, New Cumberland, PA 17070. Dated: t7 (? a By: Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP (717) 533-3280 Attorneys for Plaintiff Hershey, PA 17033-0650 NEALON LAW FIRM, P.C. James G. Nealon, III 2411 North Front Street Attorney at Law Harrisburg, PA 17110 (717) 232-9900 Fax: (717) 236-9119 jnealon@nealon-law.com 101 South Duke Street York, PA 17401 (717) 852-7888 July 15, 2009 Susan Kay Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 RE: King v. King Dear Ms. Candiello: The undersigned has been retained to represent Barbara D. King in the divorce action that you have filed on behalf of Corey King. Enclosed please find my Entry of Appearance that has been filed with the court. Ms. King has provided me with the discovery requests that you recently served upon her. I will be out of the office the next ten days for vacation. I would request and extension of time until the end of the first week of August to respond. Unless I hear from you to the contrary, I will assume that this is acceptable. Last, enclosed please find a Request for Production of Documents directed to you client. Thank you for your attention to this matter. JGN/bjn o6XHib1 T C James G. Nealon, III JOHN E. SLIKE ROBERT C. SAIDIS DANIEL L. SULLIVAN JOHN B. LAMPI CAROL J. LINDSAY DEAN E. REYNOSA MARYLOU MATAS JASON E. KELSO Saidis Sullivan Law A PROFESSIONAL CORPORATION CAMP HILL OFFICE 26 WEST HIGH STREET 2109 MARKET STREET CARLISLE, PENNSYLVANIA 17013 CAMP HILL, PA 17011 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 TELEPHONE: (717)737-3405 EMAIL: ATTORNEY@SFL-LAW.COM FACSIMILE: (717)737-3407 W W W.SFL-LAW. COM REPLY TO CARLISLE October 28, 2010 Samuel L. Andres, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Re: King v. King Dear Sam: Upon a thorough review of the file it appears to me that I do not have a copy of your client's response to Plaintiff's First Request for Production of Documents. Enclosed for your review is a copy of that that I have discovered in the file. This appears to have been sent to you on June 16, 2010. If you have answered that, certainly, please forward a copy of your client's response and documents. I apologize then for needing to request additional copies. If this has not already been answered and with documents provided, I will look forward to receiving these responses within the next ten (10) business days. Thank you for your attention. Very truly yours, SAIDIS SULLIVAN LAW Mary ou Ad?itas, Esquire Mild Enclosure cc: Client XIA1151000r JD I1l'V.Lt1*:1 J.'vl_,'_ C. 1J1.^.. =L1'x L.L.^.v1v.^.....,...-._.. John J. Connelly, Jr. HcPajsdc.com FAX 717.298.2053 P.O. BOX 650 HERSHEY PA 17 )3- April 23, 2010 3Courier Aodress: 4 SIPE AVENUE HUMMELSTOWN, PA 170: a TEL. 717.533.3283 VIA FACSIMILE (717) 585-6547, WWW.JSDC.coM VIA E-MAIL jnealon _,nealon-law.com AND U.S. MAIL James G. Nealon, III, Esquire P.O. BOX 771 Hummelstown, PA 17036 Re: Corey Edward King Y. Barbara Dawn King Docket No. 2009-2001 GARY L. JAMES Dear Jim: MAX J. SMITH, JR. JOHN J. CONNELLY, JR. SCOTT A. DIETTERICK It is my understanding that you are going to continue to represent Barbara King in JAMES F. SPADE MATTHEW CHABAL, III the divorce action filed by my client, Corey King. In an effort to advance this matter to NEIL W. YAHN EDWARD P. SEEBER conclusion we renew Mr. King's offer to divide all assets equally. I believe your client RONALD T. Tc MASKC K DEL may be under the understanding that a division of all assets equally would include a JARAD W. HANDELMAN division of-the monies in her 401(k). There is certainly a way to distribute these assets COURTNEY K. POWELL KIMBERLY A. BONNER equally with her retaining the 401 (??without invading g the proceeds. `) KAREN N. CONNELLY JOHN M. HYAMS CHRISTINE T. BRANN If your position is that the 401(k) will not form a part of the distributions of JESSICA E. LOWE SEAN M. CONCANNON assets, we have no way to reach an agreement and litigation unfortunately will be GREGORY A. KOGUT, JR. necessattJ • OF COUNSEL: GREGORY K. RICHARDS BERNARD A. RYAN, JR. Please let me know your position on this suggested distribution as soon as possible. Connelly, Jr. JJC/mbl cc: Corey E. King 6x14t6tT E John J. Connelly, Jr. jkc@ dc? wrrl FAX 717.2992053 P.O. BOX 650 HERSHEY, PA 17033 Courier Address: 134 SIPE AVENUE HUMMELSTOWN, PA 17036 June 21, 2010 TEL. -717.533 3280 W W W.JSDC. COfvf VIA FACSIMILE (717) 761-1435 AND U.S. MAIL Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 Re: King v. King Dear Sam: GARY L. JAMES MAX J. SMITH, JR. JOHN J- CONNELLY, JR. Given the fact that both you and your client will be going away, I wanted to SCOTT A. DIETTERICK JAMES F. SPADE summarize our discussions at the time of the meeting at your office on Wednesday, June MATTHEW CHABAL, III NEIL W. YAHN 16 2010 EDWARD P. SEEBER , . R ONALD T. TOMASKO SUSAN M.KADEL 1. 1825 Bridge Street, New Cumberland, Pennsylvania - You will be JARAD W. HANDELMAN COURTNEY K. POWELL contacting George Clauser Real Estate Appraisers to secure an appraisal on the residence. KIMBERLY A. BONNER KAREN N. CONNELLY The parties will equally share the cost of the appraisal. Mr. Clauser should be advised JOHN M. HyAms that he is doing it for both of us. As of June 1 2010 the mortgage balance on this JESSICA E. LOWE , , property was $180,040.66. SEAN M. A. KOGUTO, JR THOMAS J. CAR 2. 512 Aquinas Avenue, Fayetteville, North Carolina - My client will contact OF COUNSEL: a realtor in Fayetteville and move along the process of selling the property. Your client GREGORY K. RICHARDS BERNARD A. RYAN, JR. will provide us an updated mortgage balance. As of February 16, 2010, the mortgage balance was $45,361.65. 3. I will contact Jonathan Cramer at Conrad Siegel Actuaries and request an analysis of Mr. King's military pension. We will share equally the expense and Mr. Cramer will be advised he is doing the report for both of us. 4. Your client has a life insurance policy through Erie Insurance with a death benefit of $200,000.00. She will supply a statement confirming this is a term policy and has no cash value. 5. My client will secure information on his accrued pension benefits through the Federal Employees' Retirement System. 6. My client's approximate $15,000.00 withdrawal from his TSP will be documented as to how the funds were used. )(/A rbl7 M000 June 21, 2010 Page 2 of 2 7. Each of the parties has IRA's of approximately $1,600..00 and the appropriate party will retain their IRA. 8. Since we have decided to value ail asset as of Jmwxy 1, 2009, eaeh- of the parties will secure their year end 2008/January 2009 bank statements; my client from his Federal Credit Union Account #525, your client from her Federal Credit Union Account #466, Federal Credit Union account in her own name and the ING account. 9. ' Your client will supply a copy of her year end 2008 401(k) statement and you will calculate the current marital value of that account. subject to our review. 10, My client will establish values through NADA and Kelley Blue Book on the 1975 and 1982 Corvettes. 11. The parties will arrange to copy the photographs from the hard drive in the home computer. The photographs will be downloaded and given to my client. He will then give the encryption code for the hard drive in order to de-encrypt the hard drive. 12. The parties will share the expense of securing an appraisal of the household contents. As you will recall, I suggested Alyssa L. Loney, C.A. from Ibis Appraisal Services, 145 North Hanover Street, Carlisle, Pennsylvania 17013; (717) 243- 3474 or Erica S. Taylor at Classic Edge Auctions & Appraisal Services, P.O. Box 416, Hershey, Pennsylvania 17033; (717) 587-8000 (cell). Please let me know which appraiser is acceptable. 13. Each of the parties will provide 2008 year end credit card balances for all credit cards in their possession. My client will provide the most recent statement from the Veterans' Affairs Administration identifying the balance due on his overpayment of approximately $15,900.00. Upon the completion of the collection of information, we should be in a better position to attempt to reach a settlement since I am hopeful that this can be accomplished within the next several weeks. Upon return from your vacation, if-you have not already done so, begin to implement the portions of this letter that require action by either you or your client. Thank you for your continuing cooperation in this matter. Very truly yours, eohnConmnelly, Jr. JJC/mbl cc-. Corey E. King SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 MAILING ADDRESS: LEMOYNE, PENNSYLVANIA 17043 R O. BOX 168 LEMOYNE, PA 17043-0166 E-MAIL: L.-And-0-1.c.- 8 March 2011 Fretak Sluzis, Esquire Sc<_r.ngi & Scaringi 27 Borth Front Street Ha,,.' risburg, PA 17108 -RE: Corey & Barbara King Dc r, Frank: TELEPHONE (717) 761-5361 FAX (717) 761-1435 I am still in the process of working with Barbara King to collect the final bits of in t'( ,nation you have requested. She has had 'a good bit of difficulty getting copies of recta>.ls for her ING investment'account'and is still working on'that. I hope to have that ir1` ( ) _ iation and be We to forward t' to you within` the next few weeks. There are a few items of information that I need your help to obtain. Those are: 1. You want to have the household furnishings appraised. Let me know who you recommend we have do that. I have had some success with Alyssa Loney of Carlisle and I think we could use her if she is satisfactory to you. Let me know. 2. Y out, 6-cat still 11has much of his clothing, 'cooks, and oilier personal effects at the house. My client would like for him to come retrieve those items. The sooner he does that, the better we will be able to avoid any risk of items disappearing or being damaged. Our clients ought to be able to arrange a time when Mr. King could come to the house to retrieve those items and my client could have someone there to avoid any dispute. Please check with him and have him contact Barbara to arrange a convenient time to come -&-that. 3. The loan on my clients vehicle, which is through the New Cumberland Federal Credit Union, is in your client's name alone. As a result of that, my client has not been able to obtain any infon-nation about ov, )(M I cs/ -r G Frank Sluzis, Esquire 2 8 March 2011 the balance owed on the loan, either now or as of December 2008. Your client should be able to get that information easily simply by requesting it. Please have him do that or, in the alternative, have him sign an authorization directed to the credit union to release that information to my client. Frankly, the items for which we do not as yet have values are fairly modest. We already have appraisals for both houses, and your client's pension and we have information about the balance in your client's thrift savings plan, my client's 401 (k) Plan, and her small Roth IRA. They represent the vast majority of the value of all of the marital assets and I think we should be able to start some discussions now about settlement. The house was appraised at $218,000.00 and the mortgage balance is approximately $174,000.00 which would make the equity in the house about $44,000.00. The North Carolina house was appraised at $95,000.00 and my client believes the mortgage balance is about $40,000.00, which makes the equity in that property about $55,000.00. My client's 401 (k) Plan balance in December of 2008 was $50,281.00. The balance in her Ameriprise Roth IRA was about $1,155.00. The balance in your client's thrift savings plan, as of 31 March 2009, was $30,436.00. By far the most valuable asset is your client's National Guard pension, valued at $189,000.00. My client has no interest in sharing in your client's National Guard pension. Unless we have overlooked some major assets, therefore, I believe that if your client retains his National Guard pension, my client will get all of the other significant assets and he will still owe her a small cash payment. I believe that our settlement discussions should start with this concept. Please speak with Mr. King about this and get back to me with your and his response. In the meantime, we can keep gathering information about the secondary assets so that, at some point within the next few weeks, we should be able to have a complete picture of the assets and be able to bring our negotiations to a reasonable conclusion. Sincerely, Sa 1 L. Andes amh cc: Ms. Barbara D. King Ti-iE ATTORNEYS -_i 6 0 C ,. MARC A. SCARING[ ML-LANIL WALZ SCARING[ FRANK C, SLUZ_IS KITH E. KENDALL s ??- MARY K. U--mm, ON L NTICHOLE A. COLLINS _ A l:'ud 'S c ice L- = rnT 5 C t-- rill 2000 Linglestown Road, Suite 106 Harrisburg Pei-.nsylvania 17110 , 717-657-7770 717-657-7797 (f) March 15, 2011 Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0169 Re: King v. Kinb Dear Sam: THE ADMINISTRATIVE STAFF MARY BETH LAKE FIRM ADMINISTRATOR DOMINIC M. I UP.E ASSISTANT FIRM ADNnTISTRATOR MARY L. SNYDER LAW CLERK DESIRL-F A. BROUGHER LAW CLERK HARV.A0, BAUGHMAN PARALEGAL NEWPORT OFFICE 14 S. 2ND STREET NEWPORT. Pik 17071 Enclosed herewith is a copy of the current loan statement with respect to your client's vehicle. As you can see therein, the current loan balance is $12,477.18. The account information was previously provided by my client in his discovery responses. Concerning the two Corvettes, Mr. King received no remuneration for the vehicles. I am a little surprised that you ask the location of the vehicles since the 1982 Corvette has been since the date of separation in your client's garage. You have not responded to my previous inquiry regarding the appraisal of the household contents by your client. Please advise whether your client will abide by the agreement you and Mr. Connelly reached and was memorialized in the correspondence of June 18, 2010. Very ru? yours Fr C. Sluzis Enclosure 1. loan statement cc. Corey E. King w/enc. t ?xH??s?T N r L ?O N Q M Q C O 07 O J w J UJ Cu W N z 0 0 Z ? m . 4t} W N W P° ul m w SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 MAILING ADDRESS: P. O. BOX 166 LEMOYNE, PA 17043-0168 E-MAIL: L~ndesaaol.com Frank Sluzis, Esquire Scaringi & Scaringi 27 North Front Street LEMOYNE, PENNSYLVANIA 17043 13 January 2011 Harrisburg, PA 17108 RE: Corey & Barbara King Dear Frank: TELEPHONE (717) 761-5361 FAX (717) 761-1435 After our discussion on Wednesday, I reviewed the file. I found most of the documentation that Connelly had requested in his letter to follow up on our four-party conference back in June. Accordingly, I enclose copies of the following documents: Cumberland (Item in Connelly's letter). 2. Copies of statements for year end 2008 from the parties joint account at the Federal Credit Union (Account 466) and my client's sole account at the Federal Credit Union (Item 8). 3. A copy of the year end 2008 statement for her 401 (k) Plan with her employer (Item 9). I also enclose copies of statements for time subsequent to that so that we can verify what contributions she has made since separation to be certain they are excluded from the marital value. I do not yet have from my client a statement reflecting the cash value of her Erie Insurance life insurance policy (Item 4) or the balance in the ING account as of 31 December 2008 (Item 8) or the year end 2008 credit card statements (Item 13). To my knowledge, the household contents have not been appraised. The other items in Connelly's letter (Items 2, 3, 5, 6 and 10) are to be provided by you client and I have not received them either from John Connelly, Esquire, or from the attoley he next consulted, Mary Lou Matas, Esquire. Hopefully they are in your file and you can provide them to me. An appraisal of the residence at 1825 Bridge Street in New ?xN16iT Frank Sluzis, Esquire 2 13 January 2011 We still have some documents to exchange, but I think what I am enclosing gets you off to a good start as to the assets in my client's possession. If you will get me the items from your client, we can try to move the case forward. I look forward to receiving those documents from you. Sincerely, Samue .Andes amh / Enclosures cc: Ms. Barbara D. King THE ATTORNEYS ?-?( ??y? l.ar in 9i MARC A. SCARING] MELANIE ,WALZ SCARING( j ' N FRANK C. SLUZIS 7_7 KEITH E. KENDALi. tiarl ng-i P C MARY K. LENIMON . . NICHOLE A. COLLINS A; Full Service Law Firm W ww. s ear1LIgElaW. cold 2000 Linglestown Road, Suite 106 - Harrisburg, Pennsylvania 17110 717-657-7770 717-657-7797 (f) February 24, 2011 Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 Re: King v. King Dear Sam: THE ADMINISTRATIVE STAFF MARY BETH LAKE FIRM ADMINISTRATOR Do1`4mc M. FURE- ASSISTANT FIRM ADMINISTRATOR MARY L. SNYDER LAW CLERK DESIREE A. BROUGHER LAW CLERK HARVA 0. BAUGHMAN PARALEGAL NEWPORT OFFICE 14S.2 ND STREET NEWPORT. PA 17074 Please find enclosed herewith valuations for the 1982 Chevrolet Corvette 2 Door Coupe and the 1975 Chevrolet Corvette 2 Door Coupe. By way of further information; the vehicles are no longer in the possession of my client. He informs me of additional information regarding the vehicles as follows: 1982 Corvette 4 speed automatic, 350 small block, power windows, tilt steering wheel, alloy rims. Condition: poor - the vehicle did not run and had electrical shorts and power steering.issues. Vehicle was missing some fiber glass on the passenger side behind the front time. Interior was in bad shape and the T-tops leaked. The last known mileage was 79,000. 1975 Stingray 3 speed automatic, 350 small blcck, power windows, titl steering wheel, steel rims. Condition poor - the vehicle needed to be completely painted and was missing the emissions system. Therefore, it could not pass state inspection for roadside service. The last known mileage was 148,000. With the addition of this information, you have all the materials required by Mr. King. Despite not receiving the information from your client, I believe we are in a position to move for a master. I have instructed my client to complete the necessary documents needed for filing. Despite Mr. King forwarding a settlement offer to your client's then attorney, Mr. Nealon, by letter dated April 23, 2010, we have received no counteroffer. If your client is so inclined to make a counteroffer, please have her do so within ten (10) days of the date of the letter. If nothing is forthcoming, I will move for a master. We can sort out whatever steps are needed to be done by way of further discovery at the Pre-Trial Conference. A 14 ???T S Samuel L. Andes, Esquire February 24, 2011 Page 2 Thank you for your kind attention to thi Enc. cc. Corey E. King w/ enc. 0 13 . ?= w - iii f it cp a T? i?. SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 MAILING ADDBESS: P. O. BOX 168 LEMOYNE, PA 17043-0168 LEMOYNE. PENNSYLVANIA 17043 TELEPHONE (717) 761-5361 E-MAIL: LawAndesOaol.com Frank Sluzis, Esquire Scaringi & Scaringi 27 North Front Street Harrisburg, PA 17108 9 March 2011 RE: Corey & Barbara King Dear Frank: PAX (717) 761-1435 By now you have a letter from me raising subjects about settlement. At this point I do not have a precise settlement offer to submit to you. My client recently lost her job and is without income sufficient to pay the mortgage on the house in New Cumberland, let alone the other property. Until her employment situation is known, it is difficult for me to make a settlement proposal. Hopefully that will change in the near future and I will be able to respond in more detail. In the meantime, of course, you are free to ask the court to appoint the Master but I think that may prove to be unnecessary and a waste of time. . I have the information you sent me about the two Corvettes. You note that he is no longer in possession of them. I would like to know if he has sold them or otherwise disposed of them and, if he has, what he received for them in that process. If he has not disposed of them, I would like to know where they are so that we can make arrangements to have them inspected and appraised if my client elects to do that. Please get back to me with the details of the disposition or present location of those two vehicles as soon as possible. Sincerely, Samuel %Ldes amh cc: Ms. Barbara D. King xP1151T THE ATTORNEYS 4 I ct L MARC A. SC.AR11VG1 MELANIE WALZ SCARING[ FRANK C. SLUZIS E 6 Kr[TIf E. KENDALL -? = CC_ MARY K. LEINI ION NICHOLE A. COLUNIS F: Full Ser-?--,ice 1 avv F -? Fil 2000 Linglestmvn Road, Suite 106 Harrisburg, Pennsylvania 17110 717-657-7770 717-657-7797 (f) March 11, 2011 Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 Re: King v. King Dear Sam: THE AMNIT\ISI'RATIVE STAFF MARY BETH LATCE FIr,1,I ADi ITNISTRATOR Domimc M.FuRL ASSISTANT FIRM ADMrNISTRATOR MARY L. SNYDE-R LAW CLERK DESTREE A. BROUGHER LA\a' CLERK I IARV.A 0. BAUGHI IAN PARALEGAL NF.wPoRI' OFFICE 14 S. 2"D STREET NEVTORT. PA 17071 Receipt is hereby acknowledged of your letters of March 8 and 9. I will discuss the contents therein with my client and will advise you accordingly. Despite your feelings that moving for a Master is a waste of resources, I will continue on that track. This matter has sat far too long. Even though certain information is lacking from your client despite formal discovery requests, I have enough information to pursue this matter to hearing. I applaud your attitude regarding settlement. Rest assured we will work to that end. Thank you for your kind attention to this matter, and I will be contact you in the near future. Very tidy ours, ^= r ?' Frank;-C. Sluzis f cc. Corey E. King ?xH?a?T L THE ATTORNEYS f ° • THE ADMINISTRATIVE STAFF caringi MARC A. SCARINGI MARY BETH LAKE MELANIE WALZ SCARINGI FIRM ADMINISTRATOR FRANK C. SLUZIS KEITH E. KENDALL??? DOMINIC M. FURE MARY K. LEMMON v P.C. ASSISTANT FIRM ADMINISTRATOR ERK SNYDER NICHOLE A. COLLINS q g Full Service Law E 1L irin MARY L. A. LAW CLERK L 2000. Lmglestown Road, Suite 106 DESIREE A. BROUGHER Harrisburg, Pennsylvania 17110 LAW CLERK 717-657-7770 HARVA O. BAUGHMAN 717-657-7797 (f) PARALEGAL May 18, 201 1 NEWPORT OFFICE 14 S. 2ND STREET Samuel L. Andes, Esquire NEWPORT, PA 17074 P.O. Bok 168 Lemoyne, PA 17043-0168 Re: King v. King Dear Sam: Receipt is hereby acknowledged of your letter of May 11, 2011.- I am a bit miffed at your response concerning the "Blue Book" values 'of the vehicles. See item no. 10 of the Connelly letter to you dated June 21, 2010. In any event, should we proceed to a Master's Hearing, I will be submitting the low to average valuations as evidence. Concerning the proposal that our respective clients simply retain one of the vehicles, I am not a fan of piece-meal settlements. I believe that they hamper the efforts to resolve all the issues by way of global settlement. However, I will discuss your proposal with Mr. King and advise you accordingly. Please advise me 'of the status of the appraisal of the household items. Quite frankly I do not see these items of much value.. We are prepared to have Mr. King testify at the Master's Hearing as to the contents and values. If the appraisal-is not completed by May 26, 2011,1 will contact the Master and advise him that discovery is completed. Once- again you ask me for a settlement proposal, and again I must reiterate that Mr. King's prior counsel, Mr. Nealon, forwarded you a settlement proposal by letter dated April 23, 2010. I simply will not compete against myself. Should you wish to respond with a counter-offer, I will most definit v it serious conside do y t 1 yours, Fr C. Sluzis cc. Corey E. King THE ATTORNEYS tf. ® THE ADMINISTRATIVE STAFF caring'i MARC A. SCARINGI MARY BETH LAKE MELANIE WALZ SCARINGI J FIRM ADMINISTRATOR FRANK C. SLUZIS KEITH E. KENDALL + m v DOMINIC M. FURS MARY K. LEMMON ASSISTANT FIRM ADMINISTRATOR NICHOLE A. COLLINS _ MARY L. SNYDER JUDITH T. WALZ * ? Fuff Service Law Firm LAW CLERK *01 Coumv,1 2000. Linglestown Road, Suite 106 DESIREE A. BROUGHER Harrisburg, Pennsylvania 17110 LAW CLERK 717-657-7770 HARVA 0. BAUGHMAN 717-657-7797 (f) PARALEGAL June 27, 2011 NEWPORT OFFICE 14 S. 2ND STREET Samuel L. Andes, Esquire NEWPORT, PA 17074 P.O. Box 168 . Lemoyne, PA 17043-01.68 Re King y. King Dear Sam: In an effort to amicably resolve the economic issues associated with the case, kindly consider this correspondence as Mr. King's best and final offer to settle the case without the necessity of hearing. The Army National Guard Pension will be equally shared and distributed at time of Mr. King's retirement by way of QDRO. Mr. King will transfer his interest in the New Cumberland property by way of special warranty. deed. Mrs. King will refinance the mortgage on the property within ninety.(90) days of the execution of a Marital Settlement Agreement. Mrs. King will retain sole ownership of the 2007 Saturn Vue. The loan agreement for the vehicle currently in the sole name of Mr. King will be refinanced by Mrs. King. Mr. King will retain ownership of the North Carolina property and will be solely responsible for the mortgage secured by the real estate. The parties will retain as his/her sole property the current asset and/or debt currently in the name or possession ofthe respective party with the exception of the following items of personalty, which will become the sole possession of Mr. King: 1. All firearms including the firearms safe; 2. Wooden hand carved gun cleaning kit; 3. Collection of pint beer glasses; 4. Coca-Cola clock;` 5. Kenwood stereo and speakers; 6. All military property - these items are the property of the United States government; 7. Personal books, e.g., school books, school yearbooks, etc. I .. 14 (5 -T IV 8. Personal photographs from Mr. King's parents; 9. All personal documents, e.g., military awards, decorations, plaques; financial documents, etc.; 10. Keys and all related parts associated with the 1982 Corvette; 11. Dart board; .12. Carved wooden beer sign; 13. Military trunk containing army memorabilia; 14. Palm tree lamp; 15. 62 inch Mitsubishi television and television table (item no. 25 contained in property appraisal); 16. Grandfather clock (item no. 13 contained in property appraisal); 17. Prints (item no. 4. contained in property appraisal); 18. Print (item no. 10 contained in property appraisal); 19. Stereo (item no. 42 contained in property appraisal); 20. Work table (item no. 53 contained in property appraisal); 21. Tools (item no. 54 contained in property appraisal). The above outlined proposal is more than fair for your client. I have enclosed herewith an asset analysis spreadsheet. As contained therein, even with the 50150 distribution of the Army National Guard Pension, Mrs. King would still be in possession of over $32,000 of the marital assets with a 50150 distribution schedule. Of course, we will seek this amount should this matter proceed to a hearing. Thank you for your kind attention 7el and I await your reply. yours, luzis Enclosure cc. Corey E King w.enc. 0 0 00 ?9 9 -? O CD CO V O Cn .A Co N -? O fD 00 V O Cn P W N i z z 0 Z D ? D . -n m z z z z z z cn n " n 0 cD CD 3 3 0 coo v a a 0 C? C? 0 0 0 - N N T1 ?l CD N « ?< V N CIi m m m m T n 0 0 (D D ? r CO M 0 0 0 0 0 0 D W c c n = ? ? ? ? ? v .@ c c c c c c , CD O y C D D C o T N ( O CD O n T n O : .n. n ? ni ? D- O : x ? 2) 3 0 -p c p c c * O * O A *k w *k co < 4 3 CD - - c N v > 0 O 0 O D ) D n cn N cn N ? A A ) rn C0 rn co CD R :2 ;2 cn C71 O CA W W Cn D x cn O ? 0 rn ' -o D (?j C D CD rt It CO * CO cn cn cn cn cn cn N z CD m C D p -,., , CD CD CD 3 =r 3 S =r S Pp N = co N N C/) 0) N N II1 N D N D ID N D < 0 0 C4 co OD CD C ( CD C r- 3 Z7 0 4 cc ? O ` D p (D Z - • 0 0 v ? m ID 5 ? m 3 CD l< O O 0 . = 0 :3 = C_ C. C. G C = = G = = C. 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N \ \ N N \ (j \ N \ N \ N (] j O j \ \ \ \ \ \ CO N N O 0 N 0 O O O i ? 0 0 N N N N N N O :A. 0 0 0 0 i i 0 0 0 0 0 0 -? 0 i CO co i CO i O T OD 00 CO OD O CO CO CO w N O 0 (D 0 CL Q«7 m 0 O N N -f CD Q. r m N .? m D. 0 FILED-OFF-ICE O THE PROTHONOTARY 2012 JAN 12 AM 9: 08 COREY EDWARD KII BERLAND COUNTY IN THE COURT OF COMMON PLEAS PLAIN MYLVANIA : OF CUMBERLAND COUNTY, : PENNSYLVANIA VS. NO. 2009-2001 CIVIL TERM BARBARA DAWN KING, CIVIL ACTION -LAW DEFENDANT ACTION FOR DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff, COREY EDWARD KING. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO Dated: January 4, 2012 (717) 724-2278 COREY EDWARD KING, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA c ro3 N -a VS. NO. 2009-2001 CIVIL TERM r BARBARA DAWN KING, : CIVIL ACTION -LAW DEFENDANT c : ACTION FOR DIVORCE _ X RULE AND NOW, this /0? day of , 2012, upon consideration of the within Petition for Bifurcation, a Rule is hereby entered against Defendant, BARBARA DAWN KING, to show cause why the relief requested should not be granted. RULE is issued upon the Defendant to show cause why the Plaintiff, COREY EDWARD KING is not entitled to the relief requested. The Defendant shall file an answer to the petition within Z O days of this date. at RULE RETURNABLE with hearing thereon the /74 day of , 2012, ` R 30 o'clock A M. in Courtroom Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. BY THE COURT: 0/1 ?e J. COREY E. KING, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 09-2001 CIVIL BARBARA D. KING, Defendant IN RE: PETITION FOR BIFURCATION ORDER AND NOW, this / 2' day of July, 2012, hearing in the above-captioned matter set for August 17, 2012, is continued to Wednesday, September 5, 2012, at 2:30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Susan Candiello, Esquire For the Plaintiff t/ Samuel Andes, Esquire For the Defendant :rlm eep tes sta, leW Ae BY THE COURT, Kevin 'Hess, P. J. c / -G.3 , -a (n r- ?n 0 y £'? co :.. 4 ...1 ? `12 JUL 26 AM 10: 02 PENNSYLVANIX COREY EDWARD KING, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW BARBARA DAWN KING, ) NO. 2009-2001 CIVIL TERM Defendant ) IN DIVORCE DEFENDANT'S MOTION FOR ALIMONY PENDENTE AND NOW comes the above-named Defendant and moves the court to award her alimony pendente lite in the above matter. i 06 Sam L. An es Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 1 COREY EDWARD KING, Plaintiff vs. BARBARA DAWN KING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2001 CIVIL TERM IN DIVORCE DEFENDANT'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT II ALIMONY 2. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Defendant is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Plaintiff is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Defendant and to pay her alimony in accordance with the Divorce Code of Pennsylvania. aR -• WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which she has become accustomed during the marriage. COUNT III - ALIMONY PENDENTE LITE 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her reasonable alimony pendente lite during the pendency of this action. COUNT IV -COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. -4S4 - - ---------- S 1 L. Andes Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 that falsification to authorities). (unsworn Date: r?, !?5 4 B A kA*A K 161 E OF TARY 2017 JUL 27 PM 1:21 CUMBE,R?AND COUNTY COREY EDWARD KING, ) IN THE COURT OF COMM Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNS'YLVANL VS. ) CIVIL ACTION - LAW BARBARA DAWN KING, NO. 2009-2001 ) Defendant ) IN DIVORCE TO PLAINTIFF NAMED HEREIN; YOU ARE HEREBY NOTIFIED TO RESPOND TO THE ENCLOSED NEW WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT MAY BE ENTERED AGAINST YOU. Sami`Ye1 L`4nd+es Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. BOX 168 Lemoyne, PA 17043 (717) 761-5361 TTER rr . COREY EDWARD KING, ) IN TIDE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW NO. 2009-2001 BARBARA DAWN KING, ) Defendant ) IN DIVORCE AM NOW comes the above-named Defendant by her attorney Samuel L. Andes, and makes the following Answer to the Plaintiff's Petitio: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. The parties have engaged in extensive discovery and Defendant has repeatedly provided information to Plaintiff and his attorneys in response to his discovery demands. The conclusion of the matter has been delayed because of Plaintiffs changing attorneys three separate times and because of a recent illness of his attorney, which resulte in the postponement of a proceeding before the Master. Defendant has not dragged out the atte 5. Denied. The Master has scheduled conferences and Plaintiff has attended two of them for the purposes of discussing settlement. Defendant actively engaged and participat d in those meetings and made serious and bone fide offers and efforts to settle the case. The p 'e; were not able to reach an agreement and that is no more than Defendant's fault than Plaint ff s fault. 6. Defendant is aware that Plaintiff has a girlfriend but is not aware of his formal engagement to her because that information is within the control of Plaintiff so Defendant enie this averment and demands proof thereof at a trial. 7. Denied as stated. It is admitted that the parties have exchanged settlement pro but denied that Plaintiff has made one as described in this paragraph. Moreover, the settle proposals made by Plaintiff have largely been unacceptable to Defendant because they do leave her sufficient funds to live, pay her debts, and realize her fair 8. share of the marital 8. Denied as stated. The parties have reached agreement on several occasions to assets for sale, exchange assets, or otherwise move toward settlement. They halve also asl Master to schedule hearings and the Master has done so. Unfortunately, the parties have been able to reach agreement on the agreement or the resolution of the economic issues ar the matter will have to go to the Master for that decision. WI FORE, Defendant prays this court to deny Plaintiffs Petition for Bifurca By way of further answer to Plaintiff's Petition, Defendant sets forth the following Matter: the so 9. This matter is currently before the Master. The Divorce Master has scheduled hearing in the matter for 20 September 2012 at 9:00 a.m. 10. Bifurcating the divorce action now, without resolution of the economic issues, will work substantial hardship on Defendant. That hardship includes the risk that she will loos the right to participate in a sizeable retirement benefit earned by Plaintiff during the marriage blot is a significant marital asset. 11. Granting a bifurcation now will further prejudice Defendant in that it will trig Dead Mans Rule, which would prevent Defendant from testifying at her own hearing, as other Procedural matters that would operate to Defendant's prejudice. 12. The equities in this matter do not justify a bifurcation but, rather, require that action be heard before the Master in the normal course of events so that the rights of both can be properly protected. 13. Plaintiff has not averred or supplied information in support of his claim adequ satisfy the requirements for bifurcation under the Pennsylvania Divorce Code. the as to WHEREFORE, Defendant prays this court to dismiss Plaintiffs Petition for and allow this matter to be determined by the normal Divorce Master proceedings. Safi L. Ands Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the Penalties of 18 Pa. C.S. 4904 (un orn falsification to authorities). Date: !? _? r? I hereby certify that 1 served an original of the foregoing document upon counsel for the Plaintiff herein by regular mail, postage prepaid, addressed as follows: Susan Kay Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 Date: (- ab-/ a Amy for Samuel L. Andes 0 COREY EDWARD KING, PLAINTIFF VS. BARBARA DAWN KING, DEFENDANT IN THE COURT OF COMMON P OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2001 CIVIL TERM c? : CIVIL ACTION -LAW M W : ACTION FOR DIVORCE rT1 PLAINTIFF, COREY EDWARD KING'S ANSWER TO THE NEW MATTER IN THE PETITION FOR BIFURCATION n• c t 1. Plaintiff, Corey Edward King, is represented by Susan Kay Candiello, whose office is located at 4010 Glenfinnan Place, Mechanicsburg, Pennsylvania, 17055. 2. Defendant, Barbara Dawn King, lives in the couple's marital home located at 1825 Bridge Street, New Cumberland, Pennsylvania 17070. 3. Plaintiff filed for a divorce in March 30, 2009. 4. Defendant has engaged in dragging out the discovery for well into three years plus. 5. Plaintiff has engaged in three (3) Master's hearings. 6. Plaintiff has been engaged to Erin McAvaney since June, 2010. 7. Plaintiff has offered a 60/40 split of assets to Defendant, Defendant refused. 8. Plaintiff had everything prepared to be able to get a divorce and get married this summer Paragraphs 1 through 8. of this Complaint are incorporated herein by reference thereto. 9. Denied. This matter is currently before the Master who has scheduled it for November 15, 2012. 10. Denied in part and Admitted in part, numerous settlements the Plaintiff has offered included 1/2 of the retirement benefit. 11. Denied. Plaintiff would be happy to waive the Dead Man's Rule. 12. Denied. 13. Denied. By way of further explanation; Plaintiff has waited for almost two 1 /2 years get married. He has made offers that are never good enough for Defendant or are increased when he meets the offer. He does not want to lose this woman whom he lo, Dated: August _t_, 2012 j Gv, I Susan Kay Candiell , Esquire Counsel for Plai PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 ?s VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: C O EDWARD K 114G COREY E. KING, Plaintiff/Respondent VS. BARBARA D. KING, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI CIVIL ACTION - DIVORCE NO. 09-2001 CIVIL TERM IN DIVORCE PACSES CASE: 988111625 c w? > C` N aa• c N ORDER OF COURT AND NOW, this 2nd day of August, 2012, upon consideration of the Petition for 3 cv Alimony Pendente Lite and/or counsel fees, it is hereby ordered that the parties and their respective counsel appear before R. J. Shadday on August 29. 2012 at 10.30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. You are further ordered to bring to the conference: (l) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11 c (a) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. CC361 rTr_? -C3 r - If you fail to appear for the conference or to bring the required documents, the court issue a warrant for your arrest and/or enter an interim order. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the action. BY THE COURT, Date of Order: August 2 2012 ?.. y Edward E:`Guid%-°-# Judge YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 32 S. BEDFORD ST. CARLISLE, PENNSYLVANIA 17013 (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at:. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. .HC1._~3 i. j itry.- -T Yttt~~Ck~~~f~GT~~~';'z ~, ~ ~',,C ~ ~ P~ ~ ; 20 COREY EDWARD KING, PLAINTIFF vs. BARBARA DAWN KING, DEFENDANT ^:E.;i ~cRL YND CQUNTY ~ E~h1~i '~~~~URT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2001 CIVIL TERM CIVIL ACTION -LAW ACTION FOR DIVORCE MOTION TO WITHDRAWL PETITION BOR BIFURCATION AND NOW, comes the Plaintiff, COREY EDWARD KING, by and through his counsel, Susan Kay Candiello, Esquire and files this Motion to Withdrawal his Petition for Bifurcation and in support thereof, respectfully represents the following: 1. The Plaintiff is CODY EDWARD KING who currently resides at 2406 Magnolia Terrace, Harrisburg, Pennsylvania, 17110. 2. The Defendant is, BARBARA DAWN KING whose currently resides at 1825 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff had filed a Divorce Complaint in Cumberland County, at Docket Number 2009-2001. 4. Plaintiff now wishes to withdrawal the Petition for Bifurcation. WHEREFORE, Plaintiff, COREY EDWARD KING, requests this Petition for Bifurcation be withdrawn. Respectfully Submitted, LA FIRM OF S KAY N LO Dated: August 14, 2012 u Kay Candie to Esquire Counsel for Plaints PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: ~ ~ `?i /~ ~` , ` COR Y EDWARD ING ME PROTHONOTAR"T 2W AUG 22 Ply 1: 56 COREY EDWARD KIN WMBERLAND COU * YIN THE COURT OF COMMON PLEAS PLAINRI?jIRg YLVA N I A OF CUMBERLAND COUNTY, : PENNSYLVANIA VS. BARBARA DAWN KING, DEFENDANT : NO. 2009-2001 CIVIL TERM : CIVIL ACTION -LAW : ACTION FOR DIVORCE PRAECIPE TO WITHDRAWL DIVORCE COMPLAINT AND NOW, comes the Plaintiff, COREY EDWARD KING, by and through his counsel, Susan Kay Candiello, Esquire and files this Praecipe to Withdrawal his Complaint for Divorce and in support thereof, respectfully represents the following: The Plaintiff is CODY EDWARD KING who currently resides at 2406 Magnolia Terrace, Harrisburg, Pennsylvania, 17110. 2. The Defendant is, BARBARA DAWN KING whose currently resides at 1825 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff had filed a Divorce Complaint in Cumberland County, at Docket Number 2009-200.1. 4. Plaintiff now wishes to withdrawal the Complaint for Divorce. WHEREFORE, Plaintiff, COREY EDWARD KING, requests this Divorce Complaint be withdrawn. Respectfully Submitted, LAW FIRM OF SUSAN rY CA Dated: August 20, 2012 C? Susan Kay Candiel o, E quire Counsel for Plainti PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 L _U 1 r jGTHOHOTAR 2012 AUG-2jN RfI> :( URT OF COMMON PLEAS COREY EDWARD KING, AND COUNTY, V PLAINTIFF CJ rl WER L IA ?'ENN? ANR? VS. BARBARA DAWN KING, DEFENDANT NO. 2009-2001 CIVIL TERM : CIVIL ACTION -LAW : ACTION FOR DIVORCE W PETITION NOW, comes the Plaintiff, COREY EDWARD KING, by and through his counsel, Susan Kay Candiello, Esquire and files this Preacipe to Withdrawal his Petition for Bifurcation and in support thereof, respectfully represents the following: I . The Plaintiff is CODY EDWARD KING who currently resides at 2406 Magnolia 'Terrace, Harrisburg, Pennsylvania, 17110. 2. The Defendant is, BARBARA DAWN KING whose currently resides at 1825 Bridge Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff had filed a Divorce Complaint in Cumberland County, at Docket Number 2009-2001. 4. Plaintiff now wishes to withdrawal the Petition for Bifurcation. WHEREFORE, Plaintiff, COREY EDWARD KING, requests this Petition for Bifurcation be withdrawn. Respectfully Submitted, L FIRM OF SAN _KAY C ND LO Dated: August 20, 2012 usan Kay Candi o Esquire Counsel for Plai PA I.D. # 64998 4010 Glenfinnan Place Mechanicsburg PA 17055 (717) 724-2278 COREY EDWARD KING, Plaintiff/Respondent VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 09-2001 CIVIL TERM - BARBARA DAWN KING, IN DIVORCE , ~ , . Defendant/Petitioner PACSES CASE: 988111625 ,,, ~ ,-~; ': a Order :~~ -~ ~~. -~-- `~" ~~ -. ~ ~ v~ .. AND NOW to wit, this 29~'' day of August, 2012 it is hereby Ordered that: the Peti~n~ ~, request for Alimony Pendente Lite is dismissed, without prejudice, pursuant to an effective order ~ f spousal support docketed at 313 S 2010. BY THE COURT: AUG 2 9 2012 DATE Edward E. uido, JUDGE COREY EDWARD KING, Plaintiff vs. BARBARA DAWN KING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~T CIVIL ACTION - LAS NO. 2009-2001 r~-~ ~ v IN DIVORCE ~ ":~' -,~ ,~- DEFENDANT'S PETITION FOR SPECIAL RELIEF ~ AND NOW comes the above-named Defendant, by her attorney Samuel L. Ande petitions the court for special relief based upon the following: 1. The Petitioner herein is the Defendant. The Respondent herein is the Plainti 2. Plaintiff and Defendant were married on 10 May 1986. They sepazated on 7 2009 when Plaintiff moved from the marital residence. 3. Plaintiff and Defendant aze the owners of a single family residence at 1825 ~;~ c' p-~- °m _~; and Street in New Cumberland, Cumberland County, Pennsylvania. Defendant has resided i that house since Plaintiff moved out of it in Mazch of 2009. 4. The parties also own property in Fayetteville, North Carolina which has been ~ rental property for several yeazs. 5. Since Plaintiff moved from the New Cumberland residence, Defendant has her funds, including the liquidation of most of her retirement funds, to maintain the prof pay the mortgage. She is no longer able to pay those expenses and maintain the house. 6. The parties, through counsel, have repeatedly discussed selling both the New Cumberland the Fayetteville property. Plaintiff, however, has refused to cooperate in li; properties for sale. and the Page 3 of 8 IT ~ _ T 7. In August of 2012, Plaintiff filed a Praecipe to withdraw his Divorce Compla nt in an apparent attempt to terminate the divorce litigation. The action has not been terminated because Defendant's counterclaims are still pending. COUNT I - REQUEST FOR SALE OF REAL ESTATE 8. The averments set forth in Paragraphs 1 through 7 above are incorporated her in by reference. 9. Defendant believes that neither of the parties can or will pay the costs to mai in the New Cumberland property and that, if it is not sold, the property will be lost at foreclos e. 10. Neither party has expressed a desire currently to retain either the New Cumb rland property or the Fayetteville property. Both parties have proposed that those properties b sold to .assist in the distribution of marital assets. 11. Defendant is willing and prepared to execute the documents and take such o er action as may be necessary to list and sell both the New Cumberland property and the Fayetteville property. 12. If the properties are not listed for sale promptly, Defendant fears that they w 11 be lost at foreclosure and the parties will not be able to effect a division of their assets. WHEREFORE, Defendant prays this court to enter an order directing the parties to list both the New Cumberland residence and the Fayetteville property for sale and to take all actions reasonably necessary, including cooperation with each other and others, to effect that sal as promptly as possible for a fair market price as promptly as possible. COUNT II -EXCLUSIVE POSSESSION OF RESIDENCE 13. The averments set forth in Paragraphs 1 through 7 above are incorporated he reference. 14. Plaintiff voluntarily moved from the marital residence in March of 2009 and resided at the residence since that time. by not Page 4 of 8 ___ i 15. Plaintiff has resided in the residence and, until her assets were exhausted, pa mortgage and other expenses necessary to maintain the property. Plaintiff made no dire. contribution to the payment of any of those expenses. 16. Plaintiff has threatened to move back into the house. 17. Defendant does not want Plaintiff to return to reside in the house for numero~ reasons, which include: a. She is physically afraid of Plaintiff and his anger; b. Plaintiff constantly harasses her by making unwanted communications to her; the c. Plaintiff verbally abuses Defendant by calling her names, insulting her, and belittling her; d. Defendant has exhausted her funds and financial assets and, if Plaintif moves into the house, Defendant has no where to live; e. Plaintiff has become involved with other women and, Plaintiff believe , has a steady girlfriend that he will want to invite into the residence; and f. Defendant believes that Plaintiffs plan to move back into the house, or his threats to do so, are merely a ploy to force Defendant into a financial settleme t to her disadvantage. 18. If Plaintiff moves back into the marital residence in New Cumberland, Defe dant will suffer serious and irrevocable emotional harm and fears that she will suffer physical harm as well. WHEREFORE, Defendant prays this court to grant her exclusive possession of a New Cumberland residence . 19. Prior matters in this case have been assigned to the Honorable Kevin A. President Judge. 20. Plaintiff does not concur in the relief requested int his Petition. Page 5 of 8 i ~ WHEREFORE, Defendant prays this court to grant her the relief requested in Petition. Sam`Q'el L. ArT~e,~' ~" Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 Page 6 of 8 I verify that the statements made in this document are true and correct. I any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 falsification to authorities). Date: ~.~~~ , D. KING that Page 7 of 8 CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document upon counsel Plaintiff herein by regular mail, postage prepaid,. addressed as follows: Susan K. Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 al3ha Amy Page 8 of 8 ~. Secretary for Samuel L. Andes the Frank C. Sluzis, Esquire ~-7 ~ r..; Attorney ID No. 43829 '~~ ~ :~.. -. SCARINGI & SCARINGI, P.C. z~''' ~ `ter- v 2000 Linglestown Road, Suite 106 ~~ z Harrisburg, PA 17110 ~ ~" `._..~,,~, (717) 657-7770 -telephone ~ ~- -a "-~ `rt' (717) 657-7797 -facsimile ~" ~'=` ~C ~ ~.,-~~- -~-~ ~~.nj frank@scaringilaw.com ~~ ~ ° ~;~ .: Attorney for Plaintiff ~ ~'"~ COREY E. KING, : iN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. BARBARA D. KING, Defendant No. 2009-2001 AFFIDAVIT OF CONSENT l . A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 30, 2009. 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: .1 ~! ~ / ~ a / ,Z Barb .King, Defend c~ r-..~ --:~ ~' ~ a "t7'f_r^ Frank C. Sluzis, Esquire Wit-- .... ~~' AttorneylDNo.43829 _C+,-', ~' --ate SCARINGI & SCARINGI, P.C. '" -~-~ 2000 Linglestown Road, Suite 106 ~' c`. ~ :.~- ~.-, Harrisburg, PA 17110 =" ~ '~ N ~~ ~~' (717) 657-777() -telephone ~; p _ (717) 657-7797 -facsimile ~' :. frank@scaringilaw.com Attorney for Plaintiff COREY E. KING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. BARBARA D. KING, Defendant No. 2009-2001 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. .. Date: ~ ~ / ~ 3 L~~ , Barbara D. King, Defendant ,