Loading...
HomeMy WebLinkAbout04-1998MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant NOTICE T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. `?y 9 CIVIL TERM IN DIVORCE O 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 will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O `y- 1 9 9,P CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Melissa M. Leggett, an adult individual currently residing at 150 East Lauer Lane, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Donald B. Leggett, an adult individual currently residing at 1500 Fox Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 7, 1984, in New Cumberland, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT If EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, riffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: MELISSA M. LEGGETT, Plain r FJ /? ?l CJ l./ L 4 ? u h w e n MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1998 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this day of May, 2004, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Melissa M. Leggett, and states that a true and attested copy of a Complaint in Divorce was sent to Defendant, Donald B. Leggett, at 1500 Fox Hollow Road, Mechanicsburg, PA 17055, by certified mail, restricted delivery, return receipt requested, A copy of said receipt is attached hereto indicating that service was made on May 11, 2004. Sworn and subscribed to before me this _JL?? day o`. 2004 IY ? IC M K fk.!W 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 7 A rv m C3 Cl Certified Fee O Rehm Reclept Fee )Fndorsemem Requked) CJ Resmcted CelWery Fee A (Eedoreemem PeW red) O r A Total Postage & Fees ? Co(7 Z,>?o $ g•1 J m M1 8bse(. . Na; aPO6ox Na -- -- . 11 , iwS .r ?? i? !:1 L_ - _ 'tiT -1 i%i"! -_ :(: - . t? - - ? ?l ._ _ GJ ? )? .. f',;. . - = ! i - , -:;_ r" - y ?,, - , 4 MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 04-1998 CIVIL TERM IN DIVORCE DEFENDANT'S MOTION TO COMPEL TO COMPLIANCE WITH DISCOVERY AND NOW, comes Petitioner, Melissa M. Leggett, by and through her counsel, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Melissa M. Leggett, an adult individual currently residing at 150 East Lauer Lane, Camp Hill, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Defendent, Donald B. Leggett, an adult individual currently represented in these proceedings by Donald T. Kissinger, Esquire, 30 Walnut Street, Harrisburg, 17108, Pennsylvania. 3. By correspondence of January 24, 2006 forwarded to Defendant's Counsel by Plaintiff's counsel, an original and two copies of the first set of Interrogatories to Defendant were propounded upon the Defendant. 4. Pursuant to the Pennsylvania Rules of Civil Procedure, Answers were to have been filed to those Discovery requests by February 23, 2006. 5. Plaintiff's counsel has made numerous overtures to Defendant's counsel requesting that the Answers be appropriately completed and filed, which have 4 I resulted in various promises of compliance of Defendant through Defendant's counsel. 6. The time for filing the Answers to Interrogatories has been exceeded by more then 75 days and the Defendant is not in compliance with the Pennsylvania Rules of Civil Procedure. 7. Despite Plaintiff's counsel's numerous requests, Answers have not been filed or served upon Plaintiff or Plaintiffs counsel and Defendant is in violation of Pennsylvania Rules of Civil Procedure. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to answer the Discovery requests within a set and designated period of time, or in the alternative, to schedule a hearing to address this matter. Respectfully submitted, Date S 1 L b ( r W. G ffie, Esquire o y f)Defendant/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 i ' 1 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. / tz?? DATE: ?? Ly e b d` ` '? T?EKISSA M. LEGGETT, PLAINTIFF MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DONALD B. LEGGETT, NO. 04-1998 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certify that I did, the ?fkday of 2006, cause a copy of Plaintiff's Motion to Compel Answers to Request for Interrogatories to be served upon Defendent's attorney by first class mail, postage prepaid at the following addresses: Donald T. Kissinger, Esquire P.O. Box 810 Harrisburg, PA 17108 DATE: - ?-L LI 6 16 6 7 Griff , Esquire At ey for P aintiff FFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ra C3 ?' C= `c 0 -n r? =a MAY 1 8 2006 ` MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DONALD B. LEGGETT, NO. 04-1998 CIVIL TERM Defendant IN DIVORCE ORDER OF COURT th AND NOW, this I °1 day of 4v 2006, upon presentation and consideration of the within Motion to Compel, it is hereby ordered and directed that the Defendant, Donald B. Leggett, shall file Answers to Plaintiff's First Set of Interrogatories, Propounded Upon Defendant within 30 days of service of the within Order and Petition by first class mail, postage prepaid upon counsel of record for Defendant. If Answers are not filed accordingly, the Court will entertain a Motion for Sanctions. BY THE COURT, oh. 'p- cZ :9 WV ZZ IV14 9991 DRS # MELISSA M. LEGGETT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DONALD B. LEGGETT, :NO. 04-1998 CIVIL TERM Defendant : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE. AND NOW comes Petitioner, Melissa M. Leggett, by and through her counsel of record, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates, and petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Melissa M. Leggett, an adult individual currently residing at 150 East Lauer Lane, Camp Hill, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Defendant, Donald B. Leggett, and an adult individual currently residing at 1500 Fox Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Petitioner's date of birth is October 10, 1957, and her social security number is 178- 50-3614. 4. Respondent's date of birth is September 3, 1954, and his social security number is 184-38-0418. 5. Petitioner initiated the above captioned divorce action by the filing of a Complaint in Divorce on or about May 4, 2004. 6. Petitioner has employed counsel and will incur costs and expenses pursuant to the aforementioned divorce action, but is without sufficient assets or income to support herself, pay her attorney's fees, and/or pay the costs and expenses associated with this action. 7. Respondent has sufficient income or earning capacity, as well as the assets to assist in supporting the Petitioner and providing maintenance for her as well as to pay alimony pendente lite to Petitioner and assist in her counsel fees, costs and expenses. WHEREFORE, Petitioner requests your Honorable Court to enter a Order referring Petitioner's request for Alimony Pendente Lite to the Franklin County Domestic Relations Office for further proceedings. Respectfully submitted, riff , Esquire ttorney for Plaintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. r _ DATE: 61066 MELISSA M. LEGGETT MELISSA M. LEGGETT, Plaintiff V. DRS # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW DONALD B. LEGGETT, :NO. 04-1998 CIVIL TERM Defendant : IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Melissa M. Leggett ADDRESS 150 East Lauer Lane Cam Hill, PA BIRTH DATE October 10, 1957 SOCIAL SECURITY NUMBER 178-50-3614 HOMEPHONE 909-4703 WORK PHONE 579-9269 EMPLOYER NAME Self-employed EMPLOYER ADDRESS 4075 Market St. Camp Hill, PA 17011 JOB TITLE/POSITION Realtor DATE EMPLOYMENT COMMENCED January 2002 GROSS PAY $1,500.00 per month NET PAY OTHER INCOME ATTORNEY'S NAME Bradley L. Griffie, Esquire ATTORNEY'S ADDRESS 200 North Hanover Street Carlisle, PA ATTORNEY'S PHONE NUMBER 243-5551 RESPONDENT NAME Donald B. Leggett ADDRESS 1115 Country Club Rd. Camp Hill, PA 17011 BIRTH DATE September 3, 1954 SOCIAL SECURITY NUMBER 184-38-0418 HOME PHONE WORK PHONE 717-737-7777 EMPLOYER NAME Spanky's Auto Sales EMPLOYER ADDRESS 200 North Walnut St. Mechanichsburg, PA 17055 JOB TITLE/POSITION Owner/Manager DATE EMPLOYMENT COMMENCED GROSS PAY NET PAY OTHER INCOME ATTORNEY'S NAME Donald T. Kissinger, Esquire ATTORNEY'S ADDRESS 210 Grandview Ave. Camp Hill, PA 17011 ATTORNEY'S PHONE NUMBER 717-234-5402 MARRIAGE INFORMATION DATE OF MARRIAGE April 7, 1984 PLACE OF MARRIAGE New Cumberland, PA DATE OF SEPARATION ADDRESS OF LAST MARITAL HOME 150 East Lauer Lane, Camp Hill, PA 17011 DESCRIPTION OF DOCUMENT RAISING APL CLAIM Divorce Complaint DATE APL DOCUMENT FILED May 4, 2004 s _71 C1 _ _ CTr "? rv? y r 70 MELISSA M. LEGGETT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1998 CIVIL TERM DONALD B. LEGGETT, IN DIVORCE Defendant/Respondent PACSES CASE NO: 237108363 ORDER OF COURT AND NOW, this 19th day of June, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Friday. July 21, 2006 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 (1) 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© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed on June 19, 2006 to: Petitioner Respondent Bradley L. Griffie, Esq. Donald T. Kissinger, Esq. Date of Order: June 19, 2006 114 +( L Sh day, onference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND /N"'' REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 f? P+? ?J ? v ?i k t_ _ I qT ? 1 ?7?1 n? r?, ? . • G7 ? '? .- ?. Wit} -? -, {; t,a ?? _G° ,? °%? ..? MELISSA M. LEGGETT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1998 CIVIL TERM DONALD B. LEGGETT, IN DIVORCE Defendant/Respondent PACSES CASE NO: 237108363 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 19th day of July, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Friday. Aueust 18.1006 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: (1) 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© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed on July 19, 2006 to: Petitioner Respondent Bradley L. Griffie, Esq. Donald T. Kissinger, Esq. Date of Order: July 19, 2006 RN. Sh day, 06nfi-rence Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND ' REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 MELISSA M. LEGGETT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO, 04-1998 CIVIL TERM DONALD B. LEGGETT, IN DIVORCE Defendant/Respondent . PACSES CASE NO: 237108363 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 19th day of July, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on Thursday, Aurust 17.2006 at 10:30 AM. 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 (1) 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 1910.11C (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed on July 19, 2006 to: Petitioner BY THE COURT, Edgar B. Bayley, President Judge Respondent Bradley L. Griffie, Esq. Donald T. Kissinger, Esq. .. Date of Order: July 19, 2006 R. J. S, dday, Aonferce Officer / YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 EN' FJ -? ?) f.. _ Jl ! _? _? . _• ?,? ' - I?j ?? =(i, _ Cl t MELISSA M. LEGGETT, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 04-1998 CIVIL TERM DONALD B. LEGGETT, IN DIVORCE Defendant/Respondent PACSES CASE NO: 237108363 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 19th day of October, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on November 29, 2006 at 9:00 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. This date replaces the prior conference date of August 17, 2006. YOU are further ordered to bring to the conference: (1) 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© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you (6) IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Date of Order: October 19, 2006 Copies mailed to: Petitioner Respondent Bradley L. Griffie, Esq. Donald T. Kissinger, Esq. . Sha ay, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 N ?R In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION MELISSA M. LEGGETT ) Docket Number 04-1998 CIVIL Plaintiff ) vs. ) PACSES Case Number 237108363 DONALD B. LEGGETT ) Defendant ) Other State ID Number CONSENT ORDER AND NOW, to wit on this 22ND DAY OF FEBRUARY, 2007 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other PETITION FOR APL filed on JUNE 16, 2006 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF'S REQUEST TO WITHDRAW HER PETITION. O The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. Consented: Date Date DRO: R.J. Shadday Service Type M Plaintiff Signature Defendant Signature BY THE COURT: M.L. Ebert, Jr., JUDGE Form OE-505 Worker ID 21205 t') 0 Fin 3 33 IN-THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELISSA M. LEGGETT, Plaintiff ) NO. 04-1998 CIVIL TERM V. ) DONALD B. LEGGETT, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 30, 2004. 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 in divorce after service of notice of intention to request entry of the decree. WAIV ER OF NO TICE OF I NTENTI ON TO R EQUEST E NTRY OF A DIVOR CE DECR EE UND ER X3301& ) OF THE D IVORC E CODE 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: 1,5 Q onald B. , e en t e? rn MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1998 CIVIL TERM IN DIVORCE PRAECIPE Please withdraw Count number II previously filed in the Divorce Complaint on behalf of the Plaintiff in the above captioned matter. Respectfully submitted, Date:- Of/ ? ? "for , Esquire rntiff 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 rte" C:r =' .r?G N c.n G e: ca 3 .P- MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 04-1998 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on May 4, 2004 and served on May 11, 2004, as indicated in Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: LZI16 ti MELISSA M. LEGGETT t"`a Q 7v .?+ MELISSA M. LEGGETT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DONALD B. LEGGETT, : NO. 04-1998 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 13301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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. 410 -hl DATE: MELISSA M. LEGGETT a ?G N ? ?. co N MELISSA M. LEGGETT, Plaintiff V. DONALD B. LEGGETT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1998 CI M TERM IN DIVORCE TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on May 12, 2004. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: 9/14/07 by Defendant: 9/13/07 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 14, 2007 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 18, 2007 Esquire & SOCIATES r Plaintiff U _? co J ? e.n IN THE COURT OF COMMON PLEAS MELISSA M. LEGGETT Plaintiff VERSUS DONALD B. LEGGETT Defendant NO. 04-1998 DECREE IN DIVORCE AND NOW, _S P-!?kt ^ Ote l%C IT IS ORDERED AND DECREED THAT Melissa M. Leggett , PLAINTIFF, AND Donald B. Leggett , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None BY THE COURT: ?% -? ATTEST: J. (?&44 00"a PROTHONOTARY OF CUMBERLAND COUNTY STATE OF PENNA. . try. tooo? i 601, MAY 1 2 20081 Melissa M. Leggett _ IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW - IN DIVORCE Donald B. Leggett NO. 04-1998 Defendant QUALIFIED DOMESTIC RELATIONS ORDER 1. This Order relates to the provision of marital property rights to the Alternate Payee. 2. This Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of the Participant's benefits payable under an employer sponsored defined contribution plan which is intended to be qualified under Internal Revenue Code of 1986 ("Code") §401(a). The Court intends this order to be a Qualified Domestic Relations Order ("QDRO") within the meaning of Code §414(p) and §206(d) of the Employee Retirement Income Security Act of 1974 as amended ("ERISA"). The Court enters this QDRO pursuant to its authority under the 23 P.C.S.A. §3502. 3. This QDRO applies to the Spankeys Auto Sales, Inc. 401(k) Retirement Plan ("Plan"). Further, this Order shall apply to any successor plan to the Plan or any other plan(s) to which liability for provision of the Participant's benefits described below is incurred. Any benefits accrued by the Participant under a predecessor plan of the employer or any other defined contribution plan sponsored by the Participant's employer, whereby liability for benefits accrued under such predecessor plan or other defined contribution plan has been transferred to the Plan, shall also be subject to the terms of this Order. Any changes in Plan Administrator, Plan sponsor, or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order. 4. Donald B. Leggett ("Participant") is a participant in the Plan. Melissa M. Leggett ("Alternate Payee"), the former spouse of the Participant, is the alternate payee for purposes of this QDRO. 5. The Participant's name, mailing address, Social Security number and date of birth are: Donald B. Leggett 1115 Country Club Road Camp Hill, PA 17011 Social Security #: XXX-XX-0418* Date of Birth: September 3, 1954 6. The Alternate Payee's name, mailing address, Social Security number and date of birth are Melissa M. Leggett 150 East Lauer Lane Camp Hill, PA 17011 Social Security* XXX-XX-3614* Date of Birth: October 10, 1957 QDRO Page 2 The Alternate Payee shall have the duty to notify the Plan Administrator in writing of any changes in this mailing address subsequent to the entry of this Order. 7. The portion of the Participant's plan benefits payable to the Alternate Payee under this QDRO is $67,661.52 of the Participant's vested account balance accumulated under the Plan as of September 5, 2007. The Alternate Payee's share of the benefits shall be allocated on a "pro-rata" basis among all of the accounts and/or investment funds maintained on behalf of the Participant under the Plan. The Alternate Payee's share of the benefits shall be credited with any investment income or losses attributable thereto from September 5, 2007, until the date of distribution. 8. This QDRO does not require the Plan to provide any type or form of benefit the Plan does not otherwise provide. 9. This QDRO does not require the Plan to provide increased benefits. 10. This QDRO does not require the Plan to pay any benefits which another order previously determined to be a qualified domestic relations order requires the Plan to pay to another alternate payee. 11. The Plan shall distribute to the Alternate Payee her benefits (as designated in Paragraph 7 of this Order), as soon as administratively feasible following the Plan Administrator's approval of this Order. 12. The distribution pursuant to an election by the Alternate Payee shall be a lump sum payment to her or a direct rollover to an Individual Retirement Account or a direct rollover to another eligible retirement plan. 13. On and after the date that this order is deemed to be a QDRO, but before the Alternate Payee receives her distribution under the Plan, the Alternate Payee shall be entitled to all of the rights and election privileges that are afforded to Plan beneficiaries, including, but not limited to, the right to name a beneficiary, to the extent permitted under the Plan. 14. All payments made pursuant to this order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties. 15. It is the intention of the parties that this QDRO continue to qualify as a QDRO under Code §414(p), as it may be amended from time to time, and that the Plan Administrator shall reserve the right to reconfirm the qualified status of the order at the time benefits become payable hereunder. 16. In the event that the Plan inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this order, the Participant shall immediately reimburse the Alternate Payee to the extent that he has received such benefit payments and shall forthwith pay such amount so received directly to the Alternate Payee within ten (10) days of receipt. J QDRO Page 3 In the event that the Plan inadvertently pays to the Alternate Payee any benefits that are assigned to the Participant pursuant to the terms of this order, the Alternate Payee shall immediately reimburse the Participant to the extent that she has received such benefit payments and shall forthwith pay such amount so received directly to the Participant within ten (10) day of receipt. 17. After payment of the amount required by this QDRO, the Alternate Payee shall have no further claim against the Participant's interest in the Plan. 18. The Alternate Payee assumes sole responsibility for the tax consequences of the distribution under this QDRO. 19. The Alternate Payee's right to the amount assigned to her under this QDRO shall not be affected by the Participant's death (whether before or after benefit payments to the Alternate Payee have commenced). In the event of the Alternate Payee's death prior to the commencement of benefit payments to the Alternate Payee pursuant to this QDRO, the Plan shall pay the remaining benefits under this QDRO as soon as practicable to any beneficiary designated by the Alternate Payee and recorded with the Plan Administrator under the terms of the Plan. If no designated beneficiary survives the Alternate Payee, benefits shall be paid to the Alternate Payee's estate. 20. The Plan shall treat this QDRO in accordance with Code §414(p)(7). As soon as administratively practicable after receipt of the proposed QDRO, while the Plan is determining whether this order is a qualified domestic relations order, the Plan Administrator shall separately account for the amounts which would have been payable to the Alternate Payee. 21. The Plan Administrator promptly shall notify the Participant and the Alternate Payee of the receipt of this QDRO and shall notify the Participant and the Alternate Payee of the Plan's procedures for determining the qualified status of this QDRO. The Plan Administrator shall determine the qualified status of the QDRO and shall notify the Participant and the Alternate Payee of the determination within a reasonable period of time after receipt of this QDRO. 22. In the case of a conflict between the terms of this QDRO, and the terms of the Plan, the terms of the Plan shall prevail. QDRO Page 4 23. The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. Accepted and ordered this -L4 !day of BY THE COURT CONSENT TO ORDER: 4 ?, ?Imi? Judge Plaintiff/Alternate Payee Date eDate tt ntiff/ Date e ayee Q22 /z? Attorney or Defen t/ ate Participant *The original Order being filed of record has had the parties' Social Security Number redacted for confidentiality purposes. , 4 r, rr ?h, 17'i 'a'1t1 rl J;4fi Ad "I -E Wd h f IVW BBQZ ]Ns J0 Please let me know which Judge has been involved in this case Page 1 of 1 Mitchell, Jamie From: Brad Griffie [BGriffie@griffielaw.com] Sent: Monday, May 12, 2008 4:58 PM To: Mitchell, Jamie Subject: RE: c ilure to Comply with Local Rule Sorry, Jami .Judge Ebert s' ned the Divorce Decree. Thanks, Brad Griffie From: Mitchell, Jamie [mailto:jmitchell@ccpa.net] Sent: Monday, May 12, 2008 4:31 PM To: Brad Griffie Subject: Notice of Failure to Comply with Local Rule 2004-1998 Leggett v. Leggett Stipulation for the Entry of "Domestic Relations Order' Please let me know which Judge has been involved in this case. Just for future reference, Judge Bayley has indicated that Rule 208.3(a) will not apply to Stipulations and QuaDRO's. However, he would still like some indication of which judge signed the divorce decree and/or had prior involvement. Either by indicating the name of the Judge on the signature line, an attached letter or simply a post it on the front of the Stipulation/QuaDRO. If after two notices no information has been provided, your stipulation/QuaDRO will be sent back to the Prothonotary's office and placed in the file and no further action will be taken. Jamie A. Mitchell Court Administrator's Office. (717) 240-6200 The information in this message may be privileged and confidential and protected from disclosure. If the reader of this message is neither the intended recipient, nor an employee or agent responsible for delivering this message to the intended recipient, then you are hereby notified that any dissemination, distribution, unauthorized use, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to this message and deleting it from your computer. Thank you, Cumberland County, PA. 5/13/2008 Please let me know which Judge has been involved in this case Mitchell, Jamie From: Mitchell, Jamie Sent: Monday, May 12, 2008 4:43 PM To: Bradley L. Griffie (BGriffie@griffielaw.com) Subject: Notice of Failure to Comply with Local Rule 2004-1998 Leggett v. Leggett Stipulation for the Entry of "Domestic Relations Order' Please let me know which Judge has been involved in this case. Page 1 of 1 Just for future reference, Judge Bayley has indicated that Rule 208.3(a) will not apply to Stipulations and QuaDRO's. However, he would still like some indication of which judge signed the divorce decree and/or had prior involvement. Either by indicating the name of the Judge on the signature line, an attached letter or simply a post it on the front of the Stipulation/QuaDRO. If after two notices no information has been provided, your stipulation/QuaDRO will be sent back to the Prothonotary's office and placed in the file and no further action will be taken. Jamie A. Mitchell Court Administrator's Office (717) 240-6200 5/12/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW Melissa M. Leggett 0?1- qa$ Plaintiff FILE NU04*t99 9 NO. VS. IN DIVORCE Donald B. Leggett Defendant NOTICE TO RESUME PRIOR SURNAME 2+i* Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 26th d,,y of September hereby elects to resume the prior surname of Melissa M. McCord and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: e. &A.e- Signature Sigma of name being resumed COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND On the IJI* day of SIMe , 20_U_, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained.. In Witness Whereof. I have hereunto set m)- hand and official seal. N - Pu li Mp Co??a On ? N??? of i?. X011 Y k m j ?I f?i ._ MIBEkL,? iiLl AS! PENNSYLVANIA c,"k $ 11. ou Pd F Cash V- W- CQ LP s I Le 404 Juii 18 r k+ 7i?k? frry ,,.t i tir astt 3: s' ; ~~a~~a7 •g pi~uoQ `~u~pua~aQ zoo iasuno~ 9 i 9Z-~£Z (L I L) :auoudaja~ 80I L T Vd `~zngsizznH Oi8XOg Od ~aaz~S ~nui~rn 0 £ i •J'd `,LS'IOH ?8 2I~rJNISSI~I `.I..L~~Y10H zmbsg `za~uissi}I •Z pi~uoQ ZI ~~ 'a~eQ •no~ ~sut~~~ paza~ua aq .~nuz luauz~pnf ~ zo ~oazau aainzas uzoz~ seep (OZ) ~i~uann~ utu~im uzieia-za~uno~ pug zap}eye ~aN `LOOZ `bI zaquza~daS pa~~p ~uauzaaz~~ ~uauzai~~aS i~~iz~y~~o ~uauiaazo~u~ zoo uoi~i~ad o~ asuodsa~ s~~u~pua~aQ pasoiaua ar~I o~ asuodsaz ua~~izn~ n aii~ o~ pat~i~ou .~gazau az~ noA OLOLT Vd `pueizaqu.mJ maN Iaaz~S a~pizg 6~S azmbs~ `uentiinS-aiduznS ~zegzeg o/o ~3i~uieid `~a~~aZ •y~ essiiay~ ~OZ Q~d'Id OZ d~I.LO1~I ~~2IOAIQ III rn~7 - NOLLO~' 'IIAI~ ~unpua3aQ `.L.L~1J1J~7 •S QZVNOQ n 866T-~0 •ON ~31~uinid `.L.L~JrJ37 'I~i ~'SSI'I~I^i ~I.~d11'I~SItN~d `~.LNIlO~ QN~"I2I~gY~iI1~ d0 S~'~'Id NOY~iI~IO~ d0 .L2I~10~ 3H.L III jv' j `;` I !I i f , ~, y~,, w? ; ~, , ti_ . :f,.. . 9i9Z-b£Z ~LIL) :auoudalaZ SOILl dd `°-rngsi.u~H OI8 aog •O•d / 1aa.uS inui~tlcl 0£i •~~d '.LSZOH ~8 2I3 J,'~ISShI `.L.L3MOH L~6Lb 'obi •Q•1 nauzouy azmbs3 `la~uissr}I •1 pleuoQ •paiuap .~IieagTaads si uot~~~azdza~ur s,.~.~~~o.a t1a~ pug ,S~titq~ri cans `zapzo ~uauz~pnf un~~ap pigs nq pausiiq~~sa nnouauzos s~nn ~znoa a~~~s auk ut pa~~i~tut za~~i aq o~ za~~~uz ~uauzaazo~ua nun ut s~soa pug saa~ i~~ai ~o ~uaua~~d zoo n~tiiq~ti ~~u~ ~zass~ o~ ~duza~~~ L ud~z~~z~d~o s~uauzzan.~ auk ~~u~ ~ua~xa auk oZ •~a~dnzxueq ui aiq~a~z~uasip-uou aq o~ ~uau~aaz~~ ~uauzai~as ie~iz~y~ au1 zapun suzi~ia s~zauoi~i~ad paz~iaap ~iduzis p~a~sui ~nq zauoi~t~ad o~ ~uapuodsa~ ~q o~ aiq~~~d pug anp sums pa~~pmbii usligz~sa you pip zapzp pt~s `zanoazoy~ •pazmbaz st asuodsaz ou azo~azau~ pug ~ias~i zoo sx~ads 0 i OZ `~Z zaquza~das pa~~p zapz0 aus •L .pa~~t~pF~ .9 'Pa~~?spy 'c pa~~iuzp~ •p pa~~tuzPH • ~ •pa~~?~P`~ 'Z •pal~T~p~ • i LOOZ ~t 2I~gY~i~,LddS Q~.LdQ .I.1~I~I~Idd2I0~ .LUdI~Id~I.L.LdS 'I~',LI2i~I~I 30 .LI~idI^i~~2iO31~I~ ?IO3 I~IOI.LI.I.~d OZ ~SI~?OdSd2I :~utnnoiio~ aul u~TO3 spas ~iin~~aadsaz ~Sgazau Dunn `•~•d `~sioH :~ za~uissiX `~~annoH `iasunoa siu u~nozu~ pug ~q `~~a~~a~ •g pieuoQ `au~pua~aQ sauzoa `MO!~ QI~~' L~iI~"I~-2I~,L1~I~~1O~ QI~~' 2I~.L.I,~I~I Mdu LOOZ bi 2I~gL1Id,Ld~S Q~,L~'Q Z!~~Y~~~Od .LI~I~W~'I,L.LdS Z~.LRI~I~I 30 .LI~IdL~Id~2IO31~I~ 2IOd I~IOI.LI.L~d OZ dSI~OdS~2I S~.LI~I~'Q!~Id3dQ ~~2IOt~IQ ICI ~ ~u~pua~aQ !Y1~'7 - NOLL~F~ 'IIAI~ ~ `.L.L~iJrJ~'I •S Q'IF~NOQ •~ 866I-p0 'ON ( 3.h~ureid ~ `.L.L~iJIJ3'I •~ ~'SSI"I3I~I dIl'~dn7_~SR~3d `:I.L!~I:'10~ QI~iFr~I2I3gY~il'1~ 30 S~'~'Id NOI~Y~TO~ 30 .L2IIlO:~ HH.L ICI C pine ~q pa~eatunuzuzoo pue pazn~is senn ~uapuodsa~i u}inn ~a~z~uoa ueoi ski nnauaz o~ asn~az ~u~tuz ~Nd za~i~au:nn nano uzaauoa ~~u~ ~ua~xa a~i~ o~ «suzreio i~uot~ippn„ pa~n~t~suoa suzieia s~}iu~g ~Nd ~~u~ `zanannou `paruap st ~1 •aouaprsaz ie~iznuz auk ~o ains auk uo ~uauzai~as ~o auzi~ auk ~n spaaoozd ut tiZ'LSL`S9I$ pantaaaz pug pa~naaxa dreg ~Nd l~u~ pa~~tuzpn st ~I 'SZ azn~n~ auk ui auzi~ .~u~ ~n paonpaz ~ii~ueagiu~is aq pinoa nno~ us~a ~iu~uouz zau ~nu1 uot~noaxa ~o auzt~ auk ~~ aat~ou uo s~nn zauot~t~ad •papniaut azam suoisinozd uot~~inoi~aaz~zor~~T~o~auaz `~uauzaaz~~ ~uauiai~~as ie~izny~ auk o~ui ~t~ua o~ ~uapaoazd uot~ipuoo ~ se azo~aza~i~ pug `suot~e~tigo ~uauz~~d ~iiu~uouz i~n~anz~uoo auk q~inn njduzoa o~ ~~titgeur si~i u1 ~insaz ~~uz ~utaueut3 ssautsnq s~~uapuodsa~ ~o aznitn~ ~ ~~u~ ~~TiTgissod i~az auk pa~~iduza~uoa sal~znd u~oq ~~ul pazzane sr ~T `zanoazoy~ •~uauzaaz~~ luauzai~~as je~TZ~y~ aq~ ~o uot~naaxa ~o auzt~ a~j~ ~~ pa~edtat~ueun ~uapuodsa~ ~q uoi}a~ .~u~ ~o ~insaz ~ s~ s}soa ~utnou~ pazznaui zauot~i~ad ~~u~ patuap si ~i •pa~e~s s~ patuaQ •bZ •suoi~~t~o~au ~uauzai~~as ~o asodznd a~i~ zo3 .~zadozd a~i~ o~ pa~nciiz~~~ anion a~i~ spaaaxa zed ~iai~im `00.000`Ot~S$ s~nn aauapisaz pt~s uo aaizd sales ssoz~ aq~ `zanoazoy~ •papu~uzap st3oaza~i~~oozd agtaads pun `aauapisaz ie~izeuz a~i~~o ales a~i~ uo «ssoi i~t~ue~sgns,, ~u~ paza~~ns zauot~t~ad ~~~ patuap ~ii~at.~taads s1 ~I •paruaQ •~Z anoq~uTazati iZ ~idnz~ez~d o~ asuodsaz st~i utaza~i sa~ezodzoaut ~uapuodsa~i •papu~uzap sr ~oaza~i~ ~oozd agtaads pine `ZZ ~idez~~zed ut pauteluoa s~uauzzan~ a~i~ ~o ,4~isi~~ zo ~i~nz~ auk o~ se~atiaq n uzzo~ o~ s~ uot~~uuo~ui ~uaiai~~ns ~nou~inn st ~uapuodsa~ 'ZZ za~i o~ s~uauz~ed~o zapua~ s,~uapuodsa~ uodn pauoi~Tpuoa you s~:~n suo.~~~iigo a~i~ o~ s~uauz:~~ed a~i~ a~uz oz ~ltitciTSUOdsaz s,zauoi~i~ad `zanoazolnl •papu~uzap st~oaza~~~oozd aT~loads pug `TZ udez~eznd ut paut~~uoa suoi~~~aiie auk ~o n~isi~~ zo u~nz~ a~i~ oz se.IaTiaQ ~ uzzol o~ uot~~uuo~ui ~uaiat~~ns ~nou~inn st ~uapuodsa~i • 1 Z 9 •uoi~n~i~sui ~~u~~o suoi~a~ auk ~q pauoisnaao uot~~~s~nap l~taueug ssauTSncl puz leuoszad auk prom o~ s~ os szapual zau~o aldi~lnuz tl~inn ~lueg JNd o~ suoi~~~ilgo sTu aau~ugaz o~ pug ~g ~Nd ~q uoi~a~ cans ~zane o~ ~duza~~~ o~ potzad papua~xa ue zano algissod s~zo~~a ll~ apeuz ~uapuodsa~l ~~u~ pazzan~ st ~i `zanoazoy~ •ssaupa~gapui ~ui~lzapun auk uzoz~ ssaluzz~u zauot~t~ad plow pug ~tuutaput o~ ~uapuodsaZl ~o zed auk uo ~~tltq~ul u~ ut pa~lnsaz zauol~i~ad ~sui~~~ ~uauz~pnf~o tiz~ua s~xuzg ~Nd ~~u~ pad}iuzp~ si ~I •t'£ •pa~~i~p~ •£~ •nllnzaua~ sdi~lszal~ap zea pasn zo3 suot}ipuoa ~uipual aszanp~ pug `saa~olduza s;~uapuodsaZl `s~a~ l~uiuztza `off pa~tuzil you ~nq `~uipnlaui `zo~a~~~o p~iz~uz ~ uzoz~ pa~lnsaz u~ol ssauisnq a~l~ uo ~In~~ap atl~ `asuodsaz za~l~zn~~o ~zm ~g •pa~~iuzpy •~c sanlasuaa~l~ zoo s~l~ads ~lat~ln~ ~a~z~uoa a~l~ ~o suzza~ auk pa~e~saz ~la~~znaae s~~l zauot~i~ad • I sanlasuza~l~ zoo s~nads uaTu~ ~a~z~uoa a~~o suzza~ a~~ pa~~~saz ~la~~znaa~ sou zauoi~t~ad •0~ •pazmbaz sT asuodsaz ou azo~azau~ pug sanlasuza~l~ zoo suds ~uauzaaz~~ ~uauzal~as l~~iz~y~ a~~o (Z)(ui)S pun (Z)(u)S tld~z~~zed •6Z zacluznu pug u~za~ 1~u~ o~ ~uapuodsaZl pue zauot~t~ad ~sut~p~ passa~uoa senn ~uauz~pnf `zanoazoy~ •pa~~tuzp~ •8Z pa~~tuzpb' •LZ •pa~~luzp~ •9Z spaaaazd ~utureuzaz arl~ uodn uoi~naaxa zoo sis~q a~l~ uzzo~ ~lueg ;~!~id~o zone uT su~ol a~l~ Io saa~u~znn~ l~uoszad sat~z~d a~l~ puu `luauzaaz~~ ~uauzal~as l~~iz~li~ au~~o uot~naaxa o~ zotzd sa~und u~oq uaan~~aq L zapuai auk o~ pauzn~az sen~ ~T auzt~ auk ~~ aiatuan au~3o anion pa~etaazdap auk u~u~ azouz ou o~ pa~tuzti aq pinous a~~urep zoo uzi~ia s,zauoi~t~ad ~~u~ pazzan~ pea~sut st ~i pug `s~uauz~~d a~~uz o~ anut~uoa o~ aznii~~ s;~uapuodsa~~o ~insaz ~ s~ zauoi~t~ad ~q paza~~ns a~~ua~p i~T~ua~od ~u~ ~o uol~~inai~a auk pug papz~~azsip ~iazt~ua aq ~~uz sz~a~ on~~~o ssaaxa ur potzad ~ zo3 aiaiuan p1~s~o ~uauz,~ofua pu~~o asn s.zauoi~i~ad ~~u~ patuap st ~I •aialuan pres uo s~uauz~i~d a~uz o~ anui~uoa o~ ~tiiq~ut siu ut pa~insaz saau~~suznazia atuzouoaa aiq~zon~~un s.~uapuodsa~ ~~u~ pa~~tuzp~ si ~i •pa~e~s s~ patuaQ •z~ •zapuai auk o~ aiaiuan auk pauzn~az ,~ii~n~uana zauot~t~ad ~~ul pa~painnou~a~ st }t pug `os op o~ ai9n ~ii~?au~ut~ za~uoi ou s~nn au uagn~ aiatuan au~ uo s~uauz~~d ~ui~~uz paseaa ~uapuodsa~ ~~u~ pa~~TUZpe st ~I •aiaiuan au~~o ~uauz~ofua pug asn ~umut~uoa s,zauoi~i~ad uo zanaos~~un~ ~a~duzt Sue p~u ~unouz~ izn~a~z~uoa auk uroz~ anion ui aauaza~~ip auk ,~dn-a~~uz„ o~ ~,aznit~~„ s~~uapuodsa~ ~~u~ patuap st ~I •pa~~~s s~ patuaQ • i~ •pa~tuzpV '0~ •Pa~~t~pF~ •6£ •pa~~T~pd • 8 ~ •Pa~~t~Pb' •L£ •pazmbaz st asuodsaz ou azo~azau~ pug saniasuzau~ zoo x~ads ~uauzaaz~d ~uauzai~~as ie~iz~y~ au~~o (£)(o)s ud~z~ezed ~o suoisrnozd auZ •9c 2I~1~i0I.LI.Ldd 210,3 d'I~IH~A aauapTSaz i~~rz~uz auk ~o airs aq}~o spaaaozd uodn ,Snai ~ul~insaz auk pug ~_'~d o~ uoi~~~iigo auk uo ~in~~ap pions o~ pinoa au i~u1 suotla~ aigtssod III ~oo~ au ~~u~ szan~ ~uapuodsa~ `zanoazoy~ •pazrnbaz sr asuodsaz ou uatum o~ ~atiaz zoo ~sanbaz ~ a~n~i~suoa c ~ ud~z~ez~d ~o s~uauzzan~ auZ • 8 ~uauzai~~as Ie~izey~ au~~o (q)S r~dez~ez~d o~ ~u~nsznd ~~zadozd s~urzds uanas ar~~~o zaun~o anrsnjaxa pug alos auk auzoaaq o~ paj~t~ua senn zauor~i~ad ~~~~ pa~~tuzpy '£S •pa~~i~p~' •ZS •pa~~t~P~' ' t S •pa~~tuzpy 'OS •pa~~T~p~' •6~ rI.LIZIgVI'I Q2I~~ ,I,IQ~2i~ •urazar~~ s~saza~ut ~~radozd due sure~az za~uo1 ou ark pue a~r;~sa ~a~dnzxtrnq str~ ~o ~rnd auzeaaq s~uauz~sanut ~ur~izapun ar~~ pue ~uauzaaz~~ ar~~ ~o uor~naaxa za~~ suot1ngiz~sip vans ou paniaaaz ark ~~u~ szan~ ~uapuodsa~ `pazmbaz sr asuodsaz ou r~atr~nn o~~aijaz zoo uzreja ~ a~n~i~suoa g~ ud~z~ezed3o s~uauzzane ar~~ u~no~~i~ •Str •suoi~ngiz~sip cans ~u~ panraaaz you seu osle ~uapuodsa~ ~~q~ pazzan~ sr ~i pine ~uauzaaz~~ ar~~ ~o uot~naaxa aaurs suor~ngrz~srp ~u~ panraaaz you s~~ zauor~i~ad ~~u~ pa~~tuzp~ st ~1 •~}, •pazmbaz sr asuodsaz ou azo~azar~~ pug sanjasuzaq~ zoo sxeads ~uauzaaz~y ~uauzal~~aS I~~i~Y~I au~~o (~)(z)S udezpez~d~o suoisinozd auZ •9p S~I.LI.LI~I~ SS~I~ISIlg I~IO2I3 SI~IOI,LRSI2I.LSIQ •a~~zanoo aa~~ ui 000`000` t $ r{~tnn ~atlod aau~znsur a~ii ar~~ urr;~ureuz pug a~n~t~sui o~ pazmbaz suznruzazd ar~~ fed o~ uztr~ ~ruzzad you op saau~~suznazra i~tau~ur~ ~uazzna pine a}i~au s;~uapuodsa~ 1~u~ pazzane sr ~r `zanoazoy~ •pa~~tuzp~ •S~ •pa~uuzp~ •t~b •pa~~iuzp~ '£p ~~ Rf'2I11S!~I ~3I'I 6 •uot~et~o~auaz zoo ~.sanbaz zad 00'000`S$ 3o d~a ~ o~ do pazznaui ~Ilen~ae saa~ je~al zoo ajgisuodsaz aq ~~uz ~uapuodsa~ `~uauzaaz~~ ~uau~al~~as I~~izey~ au~~o (s)S gd~ez~ez~d o~ ~unnsznd suua~ luauz~nd aipotzad au~~o uot~er~o~auaz zoo ~sanbaz s;~uapuodsa~ uodn ~~u1 pa~~tuzp~ st ~I •pa~e~s se paiuaQ ' i9 •pazmbaz st asuodsaz ou azo~azau~ pue ~Ias~i zoo sxeads ~uauzaaz~~ ~uauzal~~as I~~ize~ au~ ~o S I ud~z~ezed •09 •~zno7 siu~ you pine ~znoa ~a~dnzxueq auk u~nozu~ pa~aalioa aq ~snuz aznoa ~a~dnz~q auk tl~nozu~ papz~.~e saa~ ~u~ •~zno~ aiq~zouoH stuff pine aznoa 1a~dnzxueq ar~~ r~~oq u~nozu~ suo~~a ~uauzaozo~ua atu~s auk o~ pa~~Iaz s~soa pug saa~ Iasunoa ani~ealldnp papz~nne aq you ~euz zauot~i~ad ~~ui pazzan~ st ~r `zanoazoy~ •pazmbaz asuodsaz o;~I '6S •uoi~ae siu~ uT ~znoa ~a~dnz}Iueq auk u~nozu~ zau o~ papz~nn~ saa~ ~oalloa ~ouuno zauoi~i~ad •~uauzaaz~~ ~~u1 ~o suua~ auk u~in~ suoi~~t~o~auaz ~urpze~az Iasunoa~~uapuodsa~ pauaeozdde anew pinoa `pea~sui ~nq ~uauzaaz~~ ~uauzal~as I~~izey~ auk aazo~ua o~ Iasunoa aztu o~ pazmbaz ou senn zauot~i~ad •paiuaQ •gS ~pazmbaz asuodsaz oN 'LS .L~I~I~i~~2IO.~~I~ 2I03 5~~3'I~SI~110~ ,30 Q2I~'~Y1~' •pazinbaz asuodsaz oN '9S •~uiz~au ~~ papu~uzap si ~oazau~ ~oozd agtaads pug `~qap pzea ~ipaza aaiouaizau.~ aq~ o~ uoius~e~ ~u~ ut pa~elaz s~.M ~~u~ ~~zadozd s~utzds uanas au~~o ales auk uo ~ihq~tl x~~ sut~~ Ie~id~ea pazznaur zauotzt~ad 1~u~ paiuaQ •cS pay?~Tp~' 'i~S ~u~i~azau~ pa~~iaoss~ ~ipaza ~o sauTl zo sunol _n~mba auzou `sa~n~~zouz ~fue zoo alq~rl ~Ialos aq o~ n~iltgisuodsaz zau o~ 1aaCgns ~uauzaaz~~ OT ~ ure~ui~ur o~ alge ~utaq pu>;gsnH uodn pauo~~ipuoa si `ura.zarT .zoo paii~a sn s~uauz~~d arporzad~o Ianal arT~ axnur o~ ~jiiiq>? sirT ~ir>;Inar~red `s~uauz~~d uor~ngt.z~srp aige~mba uodn paaa~e s;pungsnH a~palnnou~ae sat~z~d auZ ~uauzaaz~y ~uaural~~aS I~~u>?y~ atl~~o (s)S tld~z~za~d ur paui~~uoa a~~n~u~I ~uT<~noiio~ arT~ ut pa~Insaz suor~~i~o~au pies •L9 ~~iligisuodsaz uror~ aureu s;.zauor~i~ad anouzaa o~ paaueurda.z ~uiaq ~o alq~dna you a.zann suor~~~tlgo uatunl pug ~uauzal~~as ~i~zado.zd n o~ ~uaptoui panoura.r ~uraq~o alq~d~a aq you plnonn saazu~.znn~ Ir;uoszad rTalrTnn `a~~rr•reuz arl~ ~urrnp (~ueg ~Nd aa~ej) xrz~g a~~1S niu~ni~suuad ~q apeuz su~oi ute~taa ~o saa~ueren~ I~uos.rad ;sar~r>?d arT~ ,~q pasoduzr sar~.rltgisuodsa.z ir?~ai ~umui~uoo arT~~o a.renne Bann aaann iasunoo .rarT pug aauoi~t~ad •99 •uos>?aa ~u>? aoT pa~ara~sa.z auzoaaq .~euz ~uiau~ug ssauisnq sirT #~u~ Juana auk ut suua~ ~uauz~~d ~Tpour o~ urru ~tuz~ad plnonn ~nu~ a~~n~u~i ~o uorsnlaui auk uodn ~stsur plnonn ~uapuodsa~ }~q~ Iasunoo rT~no.rrT~ ~uapuodsa~ ~q pasTnp~ ~Il~o~ioads a.zann Iasunoa aau pine .rauoi~l~ad `~uauraaa~~ ~uauzal~~aS In~i~Y~i auk our pa~eaodzoaur ~Ia~euri~In suua~ ~uauzai~~as arT~ ~o uor~~r~o~au ~o aura arT~. ~~ • c9 •uia.rarT iin~ u~zo~ gas 3T sn anoq~uraaau ~9-I sr~d~.z~r?a~d~o sasuodsa.z arl~ sa~eaodaoaur ~gararT ~uapuodsa~ •b9 .LI~I~Y~?~~2i0~ .LI~?~L~i~Z.I,.L~S 'I~,LI2I~'L~I dH,I.30 S S Hd~2i0~'2I~'d OZ .L1~I~1ZS2I11d I~iOI.L~IZOO~I~I~2i ~L~I~'I~-2I~.L~I~10~ 2I~ZZ~I~4 Mau •utaaarT u~zo~ gas suos>?a.z arT~ ao~ ~uauzaa.ro~ua .zoo ~sanba.r s;.zauor~i~ad ~uap ~rno,~ alge.zouoH srrT~ ~nu1 s~sanba.z nlTrr~~aadsa.r ~uapuodsa~ `~2I0,~~2IdHAA pa~~tuzp~' • ~9 •pazmbaz asuodsa.z o~ •~9 •Iasunoa~o aainpn arl~ o~ ~unnsznd ~uauzaaz~~ ~uauzal~~aS In~izny~r arl~ ~ursiozaxa ~Iizn~union ~g suorsinozd pres o~ paaz~n zauor~t~ad •69 •ainparlas ~uauz~nd srrl~o not}ninoleaaz ~ur~Iaas snnn arI ~nrl~ pine paltn~ pnrl aaunuuo~zad s~~uapuodsa~ o~ ~uapaaazd uor~ipuoa age ~nu~ azn~n sn.~ pine ~o~dnz~Irzng Inuoszad arl~ ut zo~rpaza n sn aar~ou paptnozd snnn zauor~t~ad `na~dnz~Iueg ssauisng pine Inuoszad zoo ~utl~ ~uapuodsa~ uodn •saaun~suznazia Iniaunu~ ~uilsixa uarl~ uodn pasng ~ui~nd~o aigndna si ~uapuodsa~ ~nrl~ Ianal n uodn pasng s~uauz~fnd uor~ngiz~sip algn~mba~o uot~ninalna auk ~sanbaz o~ ~uapuodsa~ s~tuuad a~nn~uni pies ~89 •uor~ninalnaaz n s~Iaas pungsnH ~nu~ uolsnaoo liana zoo (00.000`S$) szniioQ punsnouZ anrd o~ pa~tuztl ag Ilnrls aim ~g pazznaui s~soa pine saa~ zo3 ~~iltgisuodsaz s~pungsnH `4uro~azo~ ar~~ ~urpun~sr~~in~~o~I •~utsoo~Ia zau3o aatnpn Inuorssa~ozd aznaas o~ algn ag Ilnrls a~irn •~~Tlrgrsuodsaz s,pungsnH ag onus `pzn~az srrl~ lit a3im ~g pain}issaoau saarnzas zarl~o ~iun sn IIa~ sn `suor~ninalna ~o marnaz pun `suoi~ninolna `suot~nt~o~au `suorssnasrp nun `~nu~ cans `ainpauas ~uaur.~ed uor~ngiz~stp algn~mba arl~~o uot~ninalnaaz n zoo ~sanbaz s,pungsnH o} ani~niaz aaun~srssn pine aainpn Inuoissa~ozd znltuzis pun `aainpn ~ur~unoaan `aarnpn In~al zoo a~irn ~g pazznaut s~soa pine saa3 algnuosnaz itn pine :tun zoo algisuodsaz ag Ilnus pungsnH `s~uaurnnd uor~ngiz~srp algn~mba s pueclsnl-~~o uoi~~inaleaaz~o suoissnasrp clans ~u~ sansznd puegsnl-~ Juana aq~ uI •~uauzaaz~~ srrl~ ~o a~np uot~naaxa arl~ ~o sn (00.000`008$) sznlloQ punsnorlZ pazpunH ~rl~rg~o anlnn ~uasazd n ~urnnr~ s~uauz~ind arpotzad~o ~unouzn Ilnzano un unrl~ ssal ou aniaaaz Ilnrls a~irn pun `~un~suoa urnuzaz Ilnus (00.000`008$ `a •i) ~uauzaaz~~ stuff ~o a~np uor~naaxa auk ~o sn ~uauzali~as uot~ngiz~sip algn~mba Iln.~ano s~a~ir~ ~o anlnn luasazd arl~ ~nrl~ aaz~n pun a~palnnou~Ian a3irn pun pungsnH `nuto~azo~ age Durpun~su~t.~~o~ •saaun~surnazra Inraunur~ ~ut~sixa uatl~ srrl uodn pasng :i~si~ns una pungsnH ~nrl~ Ianal n o~ pa~ninalnaaz ag Ilnrls ainparlas ~uauz.lnd uor~ngrz~sip algn~mba s,pungsnH aaz~n a~i,~ pine pungsnH `~uiaunui~ ~Iueg ~o Ianal siq asol pungsnH pinorls `azo~azarl~ •utazarl zoo pallna sn s~uaurnnd uor~ngiz~sip algn~mba arpoizad ~o Ianal arl~ a~Inur o~ Inu~t~,azaum Iniaunut~ age annu you Iltnn pungsnH a~paln~ou~an a~r~ pux~ pungsnH `sat~i~ua ssaursng snotznn srrl rl~nozrl~ snrl arI ~uiounui~ ~Iung ~o Ianal ~uasazd auk asol pungsnH pinouS •~uauraaz~~ siu~~o uorlnaaxa ~o a~np arl~ ~o sn snrl ag rlarrln~ inrl~ rlnnn ~ua~sisuoa nu~aunui~ xung ~c Ianal zI ~~a~~aZ •g pl~uoQ `~uepua~aQ zoo Iasuno~ 9I9Z-~£Z ~LiL) :auoudaiaZ 80 i L I add `~.zngst.u~H 0 T 8 xog 'O'd / ~aaa~S ~nul~tY10£ I '~•d `.LS'IOH ~' 2I3tJI~IISSI~I `.L.L~tY1OH £6Lp 'oI~I 'Q'I ~au.zo~~ a.zm s aa~utssix • pl~uoQ J -~ _.,._~ `pa~tuzgns ~Iln~~oadsa~ ~ ~ v~y ~ / .a~nQ suua~ ~uauz~~d pa~~Inainaaz auk o~ ~unnsand s~uauz~nd uoi~ngi.z~sip aiq~~mba aan~n~ o~ paildd~ aq o~ a~~.~ ~sa.za~ui pug s~uauz~~d aipot.~ad~o uot~nlnajnaaz .zoo ~ulpino.zd zau~n~ pug ~uauzaa.r~~ ~uauzal~~aS I~~t.zzy~ aq~ o~ ~unns.znd aauot~t~ad o~ ~uapuodsa~ ~Cq aige~fzd pug anp s~unouz~ asiaa~d auk ~o uot~~Inal~a auk .zoo ~utpinoad .zapzO un .~a~ua ~zno~ aigezouoH sru~ ~~tl~ s~sanba.z ~illn~~aadsaz ~uapuodsa~ `~2I03~2I~H~41 •saau~~suzna.zia auk aapun uot~~Inalnaaz cans ~o sasodand ao~ pailddn aq o~ a~nz ~sa.za~ui a~ni.zdo.zdde un ~o uoi~nlnal~aaa sxaas .zau~zn~ au pun `~uauzaaaDd ~uauzal~~aS ju~ixey~ o~ ~unnsand s~uauz,~~d ~o uotsuadsns srq ~o auzt~ auk o~ ant~anoa~az uot~~Inalnaaa cans s~aas ~uapuodsa~ • I L •uoi~a~ ~u~~sui auk palg aus uaum ZIOZ .zaquza~daS pun s~uau.~nd~o uotsuadsns s~~uapuodsa~~o auzt~ auk uaann~aq Iasunoa s,~uapuodsa~ u~no.n.I~ sums Ieuot~ippn ~o ~uauz~~d xaas o~ sda~ ou ~oo~ zauot~r~ad 'OL ~~a~~a~ •g pleuoQ `~u~pua~aQ zoo ~asuno~ 9I9Z-t~£Z ~L T L) :auoudalaZ 80 I L i dd `~zngs?zz~H Oi8 xog •O•d ~aaz~S ~nui~M 0 £ I •~•d `.LS'IOH ?8 2I~OI~IISSI~I `.L.L~.K~OH £6L~ 'ol~I •Q•I ~auzo~~~ ~ `za~u?ss?x •Z pl~uoQ ~Z 'a~~Q OLOL T add `p~izaquzn~ n~aN ~aaz~S alp?zg 6~S azmbsg `uen?IInS-aiduznS nz~gz~g smollo~ s~ passazpp~ `ZTOZ `9Z zaquzano,~ uo `ss~Ia ~szid `I?zuz sa~~~S pad?un auk ui cures ~u?~rsodap ~q `~~?~u?~Id `~~a~~a~ •y~ ass?Iay~ zoo Iasunoa `azmbs~ `urn?IInS-aiduznS ~z~gz~g uodn panzas s~nn LOOZ `~I zaquza~daS pa~~p ~uauzaaz~d ~uaural~~aS I~~?zey~ ~o ~uauzaazo~u3 zoo uoi~T~ad o~ asuodsa~ ~u?o~azo~ arl~ ~o ndoa ~aazzoa pue anz~ ~ ~~u~ ~?~zaa ~gazau `uo?~a~ pauo?~d~a -anogn auk u? ~unpua~aQ `~a~~a~ •g pl~uoQ zoo Tasunoa `azmbsg `za~utssix •Z pl~uoQ `I ~~IA2I~S .~O ~,L~~IdI.L2i~~ ~~2IOAIQ 1~LI ~ ~u~pua~aQ :1~d'I -1~OI.L~~ 'IIAIJ ~ `.L.L3rJrJ~'I •S Q'Ib'!~OQ ( •n 8661-t~0 •ON ( ~.I?~u?~Id ~ `.L.L3rJrJ~7 •I~ F~SSI'I~Y~I F'I!~dA71~S!~~Idd `~I.I.!~~lOJ Q_~~'72I3gi~?~1~ .30 S~d37d 1~i0Y~I~iO~ 30 L2I_'10~ 3H.L NI ~a~~a7 'S Pi~uo 3.L~Q •sat~t~oti~n~ o~ uot~eagisi~~ u.zornsun o~ ~ut~eiaz ~b06~§ 'S'~'~d 8I 30 sat}~t?uad at~ o~ ~aa fgns apt?uz a.re pug ~atiaq put? uot~~uuo~ut `a~paimou~ Buz ~o ~saq auk o~ ~aaztoa ~.sT~-.za uno0 pue .za~~eW MaN 'LOOZ '~iT .zacgua~daS Pa~~P ~uamaa.z~~ ~uau~aT~~aS pug anz~ att? . -yaw a o~ asuo ,sag s, ~u~pua~aQ ~uto~aao~ auk ut paut~~uoa s~a~~ ati~ ~~u~ uut~~t? put? .turns .~gaaau `~an~a-I •g pi~uoQ `i "~OI.L~'~I3RI~A Donald T. Kissinger, Esquire Attorney 1.D. No. 47937 HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 '' ~ - ~ ~ ~ _,,, ~~.iLDGE EBERT f.. f ' ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEI~,I~ISYLVANIA MELISSA M. LEGGETT, ) Plaintiff ) v. ) DO:~'ALD B. LEGGETT, ) Defendant } NO. 04-1998 CIVIL ACTION -LAW IN DIVORCE NOTICE TO PLEAD TO: Melissa M. Leggett, Plaintiff c/o Barbara Sumple-Sullivan, Esquire 549 Bridge Street New- Cumberland, PA 17070 You are hereby notified to file a written response to the enclosed Defendant's Response to Petition for Enforcement of Marital Settlement Agreement dated September 14, 2007, New Matter and Counter-claim within twenty (20) days from service hereof or a judgment may be entered against you. Date: ~~~ ~~ ~-- ~ Donald T. Kissinger, Esquir HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street P.O. BOX 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Donald B. Leggett IN THE COURT OF COMMON PLEAS OF C[.T_VIBERLAND COUNTY", PEN~iS~"LVANIA MELISSA M. LEGGETT, ) Plaintiff ) NO. 04-1998 v. ) DONALD B. LEGGETT, ~ CIVIL ACTION -LAW Defendant ) IN DIVORCE DEFENDANT'S RESPONSE TO PETITION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT DATED SEPTEMBER 14, 2007, NEW MATTER AND COUNTER-CLAIM AND NOW, comes Defendant, Donald B. Leggett, by and through his counsel, Howett, Kissinger & Holst, P.C., who hereby respectfully sets forth the following: RESPONSE TO PETITION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT DATED SEPTEMBER 14, 2007 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. The Order dated September 23, 2010 speaks for itself and therefore no response is required. Moreover, said Order did not establish liquidated sums due and payable to by Respondent to Petitioner but instead simply declared Petitioner's claims under the Marital Settlement Agreement to be non-dischargeable in bankruptcy. To the extent that the averments of paragraph 7 attempt to assert that liability for payment of legal fees and costs in any enforcement matter to be later initiated in the state court was somehow established by said default judgment order, such liability and Petit:o~l~~~r's interpretation is specifically denied. Admitted. EQUITABLE DISTRIBUTION PAYMENTS 9. Paragraph 5(s)(1) of the Marital Settlement Agreement speaks for itself and therefore no response is required. 10. Denied as stated. Paragraph 5(s) reads as follows: The parties acknowledge Husband's agreed upon equitable distribution payments, particularly his ability to make the level of periodic payments as called for herein, is conditioned upon Husband being able to maintain a level of bank financing consistent with that which he has as of the date of execution of this Agreement. Should Husband lose the present level of bank financing he has through his various business entities, Husband and Wife acknowledge Husband will not have the financial wherewithal to make the level of periodic equitable distribution payments as called for herein. Therefore, should Husband lose his level of bank financing, Husband and Wife agree Husband's equitable distribution payment schedule shall be recalculated to a level that Husband can satisfy based upon his then existing financial circumstances. Notwithstanding the foregoing, Husband and Wife acknowledge and agree that the present value of Wife's overall equitable distribution settlement as of the execution date of this Agreement (i. e., $800,000.00) shall remain constant, and Wife shall receive no less than an overall amount of periodic payments having a present value of Eight Hundred Thousand Dollars ($800,000.00) as of the execution date of this Agreement. In the event Husband pursues any such discussions of recalculation of Husband's equitable distribution payments, Husband shall be responsible for any and all reasonable fees and costs incurred by Wife for legal advice, accounting advice, and similar professional advice and assistance relative to Husband's request for a recalculation of the equitable distribution payment schedule, such that, any discussions, negotiations, calculations, and review of calculations, as well as any other services necessitated by Wife in this regard, shall be Husband's responsibility. V~'ife shall be able to secure professional advice of her choosing. Notwithstanding the foregoing, Husband's responsibility for fees and costs incurred by Wife shall be limited to Five Thousand Dollars ($5,000.00) for each occasion that Husband seeks a recalculation. 2 The above paragraph reflects that the parties clear'v contemplated that Respondent may have difficulty maintaining the level of financing that he enjoyed during the period of negotiation and at the time of execution of the Marital Settlement Agreement, and said provision therefore specifically provided for renegotiation of the amount of periodic payment to be made by Respondent if his level of bank financing was reduced. Petitioner has been fully aware of the personal and business bankruptcies imposed upon Respondent as a result of PNC Bank calling his primary loans, and Petitioner made no effort before the filing of the instant Petition in September, 2012 to require Respondent to make monthly payments in any amount inasmuch as she was aware that Respondent did not have the financial wherewithal to do so. Respondent still does not have the financial wherewithal to make the called for payments. 11. Denied as stated. While it is acknowledged that Respondent's outstanding obligation was to carry a four percent interest rate in the event that no modification to the payment terms was required, the condition precedent to renegotiation of said payment terms in fact occurred, and the most appropriate interpretation of the parties' intent was to provide for recalculation of payments to a level that Respondent would have the ability to satisfy based on then existing financial circumstances, including monthly payments and prevailing interest rates. 12. Denied as stated. The parties recognize at the time of execution. of the Marital Settlement Agreement that the terms of payment, including monthly payments of principal and. interest, would be subject to recalculation and renegotiation in the event of fulfillment of the condition precedent. provided in paragraph 5(s) of the Marital Settlement Agreement. Respondent specifically denies that recalculated payment terms would require the payment of $824,075.16 to Petitioner. 13. No response required. However, Respondent acknowledges that payments made by him totaled $186,829.83. 14. Denied. It is specifically denied that after recalculation of Respondent's payments pursuant to the terms of paragraph 5(s) of the Marital Settlement Agreement the remaining balance of monthly payments equals $76,447.44. The total amount owed cannot be determined until the appropriate recalculation occurs as called for in the contract. 15. Denied. As stated Respondent hereby denies and disputes the calculations of total sums due to Petitioner as well as future payments due to Petitioner pursuant to paragraph 15 of the Petition. The total amount owed cannot be determined until the appropriate recalculation occurs as called for in the contract. 16. The averments of paragraph 16 constitute a request for relief to which no response is required. 17. The averments of paragraph 17 constitute a request for relief to which no response is required. MARITAL RESIDENCE 18. The terms and provisions of paragraph 5(a) of the Marital Settlement Agreement speaks for themselves and therefore no response is required. 19. Admitted. 20. It is admitted that the home was encumbered by mortgages to G'~1AC and Americhoice as of the execution of the Marital Settlement Agreement. It is further averred that at the time the parties had previously personally guaranteed essentially all of Respondent's financing related to the operation of Spankey's Auto Sales, Inc., specifically including, but not limited to, the large floor plan loan in favor of PNC (previously Pennsylvania State Bank). 4 21. Respondent is without sufficient information to form a belief as to the truth or falsity of the allegations contained in paragraph 21. and specific proof thereof is demanded. Moreover, Petitioner's responsibility to make the payments to the obligations was not conditioned upon Respondent's tender of payments to her. 22. Respondent is without sufficient information as to form a belief as to the truth or falsity of the averments contained in paragraph 22, and specific proof thereof is demanded. Respondent incorporates herein his response to paragraph 2 ~ hereinabove. 23. Denied. It is specifically denied that Petitioner suffered any "substantial loss" on the sale of the marital residence, and specific proof thereof is demanded. Moreover, the gross sales price on said residence was $540,000.00, which far exceeds the value attributed to the property for the purpose of settlement negotiations. 24. Denied as stated. It is denied that Petitioner incurred moving costs as a result of any- action by Respondent unanticipated at the time of execution of the Marital Settlement Agreement. Moreover, it is averred that both parties contemplated the real possibility that a failure of Respondent's business financing may result in his inability to comply with the contractual monthly payment obligations, and therefore as a condition precedent to entry into the Marital Settlement Agreement, renegotiation/recalculation provisions were included. Petitioner was on notice at the time of execution that her monthly cash flow could be significantly reduced at anv time in the future. 25. It is admitted that PNC Bank executed and received $165,77.24 in proceeds at the time of settlement on the sale of the marital residence. It is denied, however, that PNC Bank's claims constituted "additional claims" to the extent that concern over whether PNC might refuse to renew its loan contract with Respondent was shared and communicated by and J between both parties prior to execution of the Marital Settlement Agreement, and the parties personal guarantees of the loans in favor of PNC Bank form the basis for execution upon the remaining proceeds. 26. Admitted. 27. Admitted. 28. Admitted. Moreover, judgment was confessed against Petitioner and Respondent to that term and number. 29. Paragraph 5(h)(2) and 5(m)(2) of the Marital Settlement Agreement speaks for themselves and therefore no response is required. 30. Petitioner has accurately restated the terms of the contract which speaks for themselves. 31. Petitioner has accurately restated the terms of the contract which speaks for themselves. 32. Admitted. By way of further response, the default on the business loan resulted from a myriad of factor, including, but not limited to, criminal acts, Respondent's employees, and adverse lending conditions for used car dealerships generally. 33. Admitted. 34. It is admitted that PNC Bank's entry of judgment against Petitioner resulted in an inability on the part of Respondent to indemnify and hold Petitioner harmless from the underlying indebtedness. Moreover, it is averred that Respondent made all efforts possible over an extended period to attempt to avert such action by PNC Bank and to refinance his obligations to PNC Bank with multiple other lenders so as to avoid the personal and business financial devastation occasioned by the actions of that institution. 6 3~. The averments of paragraph. 35 constitute a request for relief to which no response is required. vloreover, Respondent avers that he took all possible actions that he could to avoid default on the obligation to PNC and the resulting levy upon proceeds of the sale of the marital residence. VEHICLE FOR PETITIONER 36. The provisions of paragraph 5(0)(3) of the 'Marital Settlement Agreement speak for themselves and therefore no response is required. 37. Admitted. 3 8. Admitted. 39. Admitted. 40. Admitted. 41. Denied as stated. It is denied that Respondent's "failure" to "make-up" the difference in value from the contractual amount had any impact whatsoever on Petitioner's continuing use and enjoyment of the vehicle. It is admitted that Respondent ceased making payments on the vehicle when he was no longer financially able to do so, and it is acknowledged that Petitioner eventually returned the vehicle to the lender. 42. Denied as stated. It is admitted that Respondent's unfavorable economic circumstances resulted in his inability to continue to make payments on said vehicle. It is denied that Petitioner's use of and enjoyment of said vehicle for a period in excess of two years may be entirely disregarded and the calculation of any potential damage suffered by Petitioner as a result of Respondent's failure to continue to make payments, and it is instead averred that Petitioner's claim for damage should be limited to no more than the depreciated value of the vehicle at the time it was returned to the lender. 7 LIFE INSURANCE 43. Admitted. 44. Admitted. 4~. Admitted. Moreover, it is averred that Respondent's health and current financial circumstances do not permit him to pay the premiums required to institute and maintain the life insurance policy with $1,000,000 in face coverage. DISTRIBUTIONS FRONT BUSINESS ENTITIES 46. The provisions of paragraph 5(r)(4) of the Marital Settlement Agreement speaks for themselves and therefore no response is required. 47. It is admitted that Petitioner has not received any distributions since execution of the Agreement and it is averred that Respondent also has not received. any such distributions. 48. Although the averments of paragraph 48 constitute a claim for relief to which no response is required, Respondent avers that he received no such distributions after execution of the Agreement and the underlying investments became part of his bankruptcy estate and he no longer retains any property interests therein. CREDIT CARD LIABILITY 49. Admitted. 50. Admitted. 51. Admitted. _52. Admitted. 53. Admitted that Petitioner was entitled to become the sole and exclusive owner of the Seven Springs property pursuant to paragraph 5(b) of the Marital Settlement 8 Agreement subject to her responsibility to be solely liable for any mortgages, home equity loans or lines of credit associated therewith. 5~4. Admitted. 55. Denied that Petitioner incurred capital gains tax liability on the sale of the Seven Springs property that was related in any fashion to the Americhoice credit card debt, and specific proof thereof is demanded at hearing. 56. No response required. AWARD OF COtiNSEL FEES FOR ENFORCEMENT 57. No response required. 58. Denied. Petitioner was no required to hire counsel to enforce the Marital Settlement Agreement but instead, could have approached Respondent/counsel regarding renegotiations with the terms of that Agreement. Petitioner cannot collect fees awarded to her through the bankruptcy court in this action. 59. No response required. Moreover, it is averred that Petitioner may not be awarded duplicative counsel fees and costs related to the same enforcement efforts through both the bankruptcy court and this Honorable Court. Any fees awarded through the bankruptcy court must be collected through the bankruptcy court and not this Court. 60. Paragraph 15 of the Marital Settlement Agreement speaks for itself and therefore no response is required. 61. Denied as stated. It is admitted that upon Respondent's request for renegotiation of the periodic payment terms pursuant to paragraph 5(s) of the Marital Settlement Agreement, Respondent may be responsible for legal fees actually incurred up to a cap of $5,000.00 per request for renegotiation. 9 62. No response required. 6~. Admitted. WHEREFORE, Respondent respectfully requests that this Honorable Court deny Petitioner's request for enforcement for the reasons set forth herein. NEW MATTER COUNTER-CLAIM: RENEGOTIATION PURSUANT TO PARAGRAPH 5(S) OF THE MARITAL SETTLE'_VIENT AGREEMENT 64. Respondent hereby incorporates the responses of paragraphs 1-63 hereinabove as if set forth full herein. 65. At the time of negotiation of the settlement terms ultimately incorporated into the Marital Settlement Agreement, Petitioner and her counsel were specifically advised by Respondent through counsel that Respondent would insist upon the inclusion of language that would permit him to modify payment terms in the event that his business financing may become restricted for any reason. 66. Petitioner and her counsel were well aware of the continuing legal responsibilities imposed by the parties' personal guarantees of certain loans made by Pennsylvania State Bank (later PNC Bank) during the marriage, which personal guarantees would not be capable of being removed incident to a property settlement and which obligations were not capable of being refinanced to remove Petitioner's name from responsibility. 67. Said negotiations resulted in the following language contained in paragraph 5(s) of the Marital Settlement Agreement: The parties. acknowledge Husband's agreed upon equitable distribution payments, particularly his ability to make the level of periodic payments as called for herein, is conditioned upon Husband being able to maintain a 10 level of bank financin, consistent with that which he has as of the date of execution of this Agreement. Should Husband lose the present level of bank financing he has through his various business entities, Husband and Wife acknowledge Husband will not have the financial wherewithal to make the level of periodic equitable distribution payments as caIled for herein. Therefore, should Husband lose his level of bank financing, Husband and Wife agree Husband's equitable distribution payment schedule shall be recalculated to a level that Husband can satisfy based upon his then existing financial circumstances. Notwithstanding the foregoing, Husband anal Wife acknowledge and agree that the present value of Wife's overall equitable distribution settlement as of the execution date of this Agreement (i. e., $800,000.00) shall remain constant, and Wife shall receive no less than an overall amount of periodic payments having a present value of Eight Hundred Thousand Dollars ($800,000.00) as of the execution date of this Agreement. In the event Husband pursues any such discussions of recalculation of Husband's equitable distribution payments, Husband shall be responsible for any and all reasonable fees and costs incurred by Wife for legal advice, accounting advice, and similar professional advice and assistance relative to Husband's request for a recalculation of the equitable distribution payment schedule, such that, any discussions, negotiations, calculations, and review of calculations, as well as any other services necessitated by Wife in this regard, shall be Husband's responsibility. Wife shall be able to secure professional advice of her choosing. Notwithstanding the foregoing, Husband's responsibility for fees and costs incurred by Wife shall be limited to Five Thousand Dollars ($5,000.00) for each occasion that Husband seeks a recalculation. 68. Said language permits Respondent to request the calculation of equitable distribution payments based upon a level that Respondent is capable of paying based upon then existing financial circumstances. Upon Respondent filing for personal and business bankruptcy, Petitioner was provided notice as a creditor in the personal bankruptcy and was aware that the condition precedent to Respondent's performance had failed and that he was seeking recalculation of his payment schedule. 69. Petitioner agreed to said provisions by voluntarily exercising the Marital Settlement Agreement pursuant to the advice of counsel. 11 70. Petitioner took no steps to seek payment of additional sums through Respondent's counsel between the time of Respondent's suspension of payments and September 2012 when she filed the instant action. 71. Respondent seeks such recalculation retroactive to the time of his suspension of payments pursuant to Marital Settlement Agreement, and he further seeks recalculation of an appropriate interest rate to be applied for purposes of such recalculation under the circumstances. WHEREFORE, Respondent respectfully requests that this Honorable Court enter an Order providing for the calculation of the precise amounts due and payable by Respondent to Petitioner pursuant to the Marital Settlement Agreement and further providing for recalculation of periodic payments and interest rate to be applied to future equitable distribution payments pursuant to the recalculated payment terms. Date: l ~ -~~ ~ ~- Respectfully submitted, _-____ ~' Donald .Kissinger s uire Attorney I.D. No. 4793 HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Donald B. Leggett 12 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANL~ MELISSA M. LEGGETT, Plaintiff v. DONALD B. LEGGETT, Defendant NO. 04-1998 CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Donald B. Leggett, Defendant in the above- captioned action, hereby certify that a true and correct copy of the foregoing Response to Petition for Enforcement of Marital Settlement Agreement dated September 14, 2007 was served upon Barbara Sumple-Sullivan, Esquire, counsel for Melissa M. Leggett, Plaintiff, by depositing same in the United States mail, first class, on November 26, 2012, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Date: Z~ ~~_._ Donald T. Kissinger, E Attorney LD. No. 4793 HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Donald B. Leggett VERIFICATIOti I, Donald B. Leggett, hereby swear and affirm that the facts contained in the foregoing Defendant's Response to Pe ; ; on fnr Fnforcemer~t of Mari al __ are true and Settlement Agreement dated September 14, 200%, New Matter and. Coun er-Cla'm correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 11 ~~ ~ -i.. - _ DATE onald B. Leggett Barbara Sumple-Sullivan,Esquire Supreme Court#32317 549 Bridge.Street New Cumberland,PA 17070 (717)774-1445 MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1998 DONALD B. LEGGETT, CIVIL ACTION - LAW Defendant IN DIVORCE C nS C°.r tz MOTION FOR HEARING �M- T -0 �, �,..... 1. Petitioner is Plaintiff, Melissa M. Leggett. .. ZZ; a NJ orb? 2. Respondent is Defendant, Donald B. Leggett. 3. Petitioner filed a Petition for Enforcement of Marital Settlement Agreement on September 24, 2012 upon which a hearing was scheduled for December 10, 2012 before the Honorable Judge Ebert. 4. On December 7, 2012, the parties jointly requested a continuance of the hearing for issues arising out of the death of Respondent's mother. 5. On December 10, 2012, an Order Adopting a Stipulation of Parties was entered by the Honorable Judge Ebert whereupon the hearing in the matter was rescheduled for February 15, 2013. 1 6. On February 14, 2013, Counsel for Petitioner requested a continuance of the hearing due to the lack of current financial information for Respondent. 7. No success has been reached for resolution and formal discovery is now ongoing given the lack of receipt of said financial records. Petitioner requests a hearing date be scheduled at the Court's convenience on or after June 1, 2013. Wherefore, Petitioner requests a hearing be scheduled immediately in this matter. The hearing is expected to take one-half day. Respe- full itted, DATE: April 2013 O/L____ Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 2 Barbara Sumple-Sullivan,Esquire Supreme Court#32317 549 Bridge Street New Cumberland,PA 17070 (717)774-1445 MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1998 DONALD B. LEGGETT, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE 1, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Motion for Hearing in the above-captioned matter upon the following individual(s)by first class mail,postage prepaid, addressed as follows: Donald T. Kissinger, Esquire Howett, Kissinger& Holst, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 DATED:A 7j /Barbara Sumple-Sullivan,Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 Barbara Sumple-Sullivan,Esquire Supreme Court 932317 549 Bridge Street New Cumberland,PA 17070 (717)774-1445 MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 04-1998 DONALD B. LEGGETT, : CIVIL ACTION - LAW rn M -0 rM Defendant : IN DIVORCE - Win;, j --<D tp C5 r—Z: --r<n CD ORDER x r AND NOW, this of , 2013, upon consideration of Petitioner's Motion for Hearing, the Hearing in the above-captioned matter scheduled for the J day of 2013 at ),`f 5 /P.M. in Courtroom —of the Cumberland County Courthouse. BY THE COURT: UAA� MX Eb rt,Jr.,J. Distribution: ,,Aarbara Sumple-Sullivan, Esquire, 549 Bridge Street,New Cumberland, PA 17070 VDonald T. Kissinger, Esquire,130 Walnut Street, P.O. Box 810, Harrisburg, PA 17108 a'� i t FILED-OF F'1-1-i-1- F THE P Q N 't J O iAIR11# Barbara Sumple-Sullivan, Esquire 2813 JUN 17 AM 9: U Supreme Court#32317 549 Bridge Street W�R�Y COUNTY NY New Cumberland, PA 17070 (717) 774-1445 MELISSA M. LEGGETT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1998 DONALD B. LEGGETT, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER AND NOW, to wit, this 14th day of June, 2013, upon stipulation of the parties, it is hereby ordered and agreed as follows: 1. The terms of the parties' Addendum to the Marital Settlement Agreement dated September 14, 2007, which Addendum is executed on June 14, 2013, are hereby entered as an Order of this Court. In accordance with the requests of the parties, the terms of said Addendum shall be redacted from the public record. 2. Based on the stipulation of both parties, it is acknowledged and agreed that said terms require and support continued pendency of a lis pendens against real estate located at 701 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, which real estate is titled in the name of 701 East Locust Street Associates, LLC.. 1 3. The prior.Orders of this Court dated September 21, 2012 and December 10, 2012 are hereby vacated subject to Defendant's requirement to fulfill his obligations toward transfer of said assets as set forth in the Addendum to the Marital Settlement Agreement dated June 14, 2013. Defendant is directed to execute all documents necessary to effectuate the transfers. Simultaneously with the execution of this Order, a domestic relations order is being executed to effectuate transfer of ownership of Defendant's Metropolitan Life IRA Policy #700187438 to Plaintiff. 4. The hearing scheduled for June 14, 2013 is hereby cancelled. BY THE COURT, M. L. Ebert, Jr., Judge �tribution: ,,-"BaTtiara Sumple-Sullivan, Esquire,549 Bridge Street, New Cumberland,PA 17070 y,�onald T. Kissinger, Esquire, Howett, Kissinger &Holst, P.C., 130 Walnut Street, P.O. Box 810, Harrisburg, PA 17108 I-as (o 17//3 2 FILL -GFFI ;E Barbara Sumple-Sullivan,Esquire 04-- Th PRO TMW t.ARV Supreme Court#32317 549 Bridge Street 2013 JUN 17 AM 9: 16 New Cumberland,PA 17070 717)774-1445 MM ERLA ND COUNTY MELISSA M. LEGGETT, tWff Y)F COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-1998 DONALD B. LEGGETT, CIVIL ACTION - LAW Defendant IN DIVORCE DOMESTIC RELATIONS ORDER This Order is intended to be a Domestic Relations Order (hereinafter referred to as "DRO"). This DRO is granted in accordance with the Pennsylvania Divorce Code, 23 Pa. C.S.A. 3502, et. seq., which relate to marital property rights, child support, and/or spousal support between spouses and former spouses in matrimonial actions. SECTION 1. IDENTIFICATION OF POLICY This Order applies to benefits under Met Life Annuity Policy No. 7700187438 owned by Donald B. Leggett, Defendant. SECTION 2. IDENTIFICATION OF PARTICIPANT AND ALTERNATE PAYEE a. Defendant is hereinafter referred to as the "Participant." Information relating to Participant is as follows: Social Security Number: See attached addendum. Date of Birth: See attached addendum Address: See attached addendum. II b. Plaintiff is hereinafter referred to as the "Alternate Payee." Alternate Payee is the former spouse of the Participant. Information relating to the Alternate Payee is as follows: Social Security Number: See attached addendum Date of Birth: See attached addendum Address: See attached addendum. SECTION 3. AMOUNT OF ACCOUNT TO BE PAID TO ALTERNATE PAYEE As soon as administratively possible, Met Life shall transfer to the Alternate Payee One Hundred Percent (100%) ownership of Participant's Met Life Annuity Policy No. 7700187438 to Alternate Payee. Participant shall immediately execute all forms necessary to finalize this ownership transfer to Alternate Payee. SECTION 4. METHOD OF PAYMENT After submission of a certified copy of this Order and the ownership transfer forms, full ownership of said Policy shall be distributed to Alternate Payee. SECTION 5. DEATH OF PARTICIPANT Ownership change to Alternate Payee shall not be affected by the Participant's death. 2 SECTION 6. DEATH OF ALTERNATE PAYEE PRIOR TO DISTRIBUTION Upon the death of Alternate Payee prior to actual change, said policy shall be transferred directly to Alternate Payee's estate. SECTION 7. COMPLIANCE WITH APPLICABLE LAWS AND POLICY PROVISIONS The parties to this Order intend that it comply with the applicable provisions of all tax codes allowing for transfer to spouse incident to divorce as a tax free rollover. SECTION 8. RESERVATION OF JURISDICTION This Court reserves jurisdiction over the parties and the Policy until such time as the ownership of the Policy has been fully transferred and discharged. Further, this Court reserves jurisdiction to amend this Order to establish or maintain its status as a tax deferred rollover. Date: los BY THE COURT, "" M.L. Ebert, Jr. dge Approved as to form and substance: Melissa M. McCord Barbara Sumple-Sullivan, Esqui—re Attorney for Plaintiff Donald B. Leggett' D—on-�. Kissing-er, Flq—ul—re- Attorney for Defend 3 ADDENDUM TO DOMESTIC RELATIONS ORDER Due to the Federal Privacy Act, many state courts prohibit the inclusion of personal data in public records to prevent identity theft. Therefore, please forward the following information sheet to the Policy Administrator. This Addendum will not be filed with the court. Participant Information Alternate Payee Information Name: Donald B. Leggett Name: Melissa M. McCord Address: 1525 N. Front Street Address: 2727 S. Rosegarden Blvd. Harrisburg, PA 17102 Mechanicsburg, PA 17050 Social Security No.: 184-38-04.18 Social Security No.: 178-50-3614 Date of Birth: September 3, 1954 Date of Birth: October 10, 1957 Partici ant Attorney's Information Alternate Payee Attorney's Information onald T. Kissinger, Esquire arbara Sumple-Sullivan, Esquire Supreme Court# 47937 Supreme Court #32317 130 Walnut Street 549 Bridge Street P.O. Box 810 New Cumberland, PA 17070 Harrisburg, PA 17108 (717) 774-1445 (717) 234-2616 A .x ti P3 TMONo TAP`t Barbara Sumple-Sullivan,Esquire DEC Q P 3• Supreme Court#32317 � � 549 Bridge Street PEN SYLVANjgNTY New Cumberland,PA 17070 (717)774-1445 MELISSA M. LEGGETT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-1998 • DONALD B. LEGGETT', : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT,AS AMENDED ON JUNE 14,2013 1. Petitioner is Melissa M. McCord, an individual residing at 2727 S. Rosegarden Boulevard, Mechanicsburg, Pennsylvania 17055. 2. Respondent is Donald B. Leggett, an individual residing at 1525 N. Front Street, #101, Harrisburg, Pennsylvania 17012. 3. On or about June 14, 2013, the parties reached a resolution of certain issues related to their Marital Settlement Agreement dated September 14, 2007. A copy of said Amendment is attached hereto as Exhibit A and incorporated herein by reference. 4. Paragraph 2 requires that Respondent provide a life insurance policy to secure his obligations to Petitioner. This paragraph provides as follows: Husband shall maintain, at his cost, for the duration of his equitable distribution obligation as set forth herein, $350,000.00 in life insurance benefits on his life, in which Wife shall be named the irrevocable beneficiary to the extent of her equitable distribution interest as set forth herein, and the parties' children shall be equal secondary beneficiaries of any excess coverage. Husband shall be entitled to reduce the amount of said life insurance benefits due to Wife on an annual basis on the anniversary date of this Addendum during the course of his equitable distribution obligation to Wife to reflect the then current amount Husband owes on his equitable distribution obligation and designate the remainder of the face amount as payable to the parties' children. In no event shall the amount of benefits payable to Wife ever be less than the amount owed on said equitable distribution obligation. Once Husband satisfies his equitable distribution obligation in full, he shall have no further obligation to maintain the life insurance benefits for Wife's benefit. Husband warrants that he has made application for insurance and has provided Wife with a copy of such application. Wife shall receive a copy of the life insurance policy upon issuance, as well as a copy of the current beneficiary designation statement thereon, to ensure Husband's compliance. Husband shall obtain the appropriate life insurance protection as soon as possible after execution hereof. Husband further agrees to execute any and all documents necessary to allow Wife to obtain directly from the life insurance company any and all information concerning the policy, including,but not limited to, periodic premium notices and notices of default. The parties acknowledge Husband has made application for life insurance coverage consistent with the terms herein. Husband and Wife agree the provisions of paragraph 2 herein are subject to Husband's ability to obtain life insurance coverage; to the extent Husband is only able to obtain coverage at a lesser amount, Husband shall be required to obtain such coverage at any lesser amount subject to the terms and conditions herein. 5. Despite repeated requests and after giving the Respondent sufficient time to acquire the life insurance policy, Respondent has failed to secure a policy and provide proof of coverage. 6. Respondent's failure to comply with the provision of life insurance is a material breach of the parties' Marital Settlement Agreement, as amended. 7. Paragraph 7 provides: If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages of such breach or seek such other remedies as amy be available to him or her. The non-breaching party shall be entitled to recover from the breaching party the costs and expenses reasonably incurred in the enforcement of the rights of the non-breaching party, including, but not limited to, reasonable attorneys' fee. 8. Petitioner requests fees and costs incurred in the enforcement of the Agreement be awarded to her. WHEREFORE, Petitioner request an Order be entered: a) Directing that Respondent secure a life insurance policy in accordance with paragraph 2; and b) Requiring Respondent to pay all costs and expenses incurred by Petitioner in bringing this action for enforcement. Respectful y ubmitted DATE: December 9, 2013 / i ( Barbara Sumple-Sullivan, Esquire Attorney for Petitioner 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court#32317 549 Bridge Street New Cumberland,PA 17070 (717)774-1445 MELISSA M. LEGGETT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-1998 DONALD B. LEGGETT, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do certify that I have served a true and correct copy of the Motion for Enforcement of Marital Settlement Agreement, in the above captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: Donald T. Kissinger, Esquire Howett, Kissinger, Conley & Holst, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 f �DATE: December 9, 2013 i Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Petitioner MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DONALD B. LEGGETT, DEFENDANT NO. 04-1998 CIVIL IN RE: PLAINTIFF'S MOTION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT ORDER OF COURT AND NOW, this 19th day of December, 2013, upon consideration of the Melissa Leggett's Motion for Enforcement of Marital Settlement Agreement, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Donald Leggett to show cause why the relief requested by Plaintiff should not be granted; 2. The Defendant will file to the Motion an answer on or before January 10, 2014; 3. A hearing/argument on the Motion will be held on Friday, January 24, 2014, at 2:00 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, M. L. Ebert, Jr., J. fBarbara Sumple-Sullivan, Esquire , Attorney for Plaintiff r�, c r-n r t Zonald T. Kissinger, Esquire �[ �;C7 Attorney for Defendant r < ' bas • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. MELISSA M. LEGGETT, ) Plaintiff ) NO, 04-1998 CIVIL TERM V. ) ) c-- DONALD B. LEGGETT, ) CIVIL ACTION - LAW _ Defendant ) IN DIVORCE m ' --0 cn r...) 7-• RAECIPE FOR WITHDRAWAL OF APPEARANCE AND ENTRY OF APPEARANCE PRO SE •• 7-", TO THE OFFICE OF PROTHONOTARY: Pursuant to Rule 1930.8(c)(2)kindly withdraw the undersigned as counsel for Defendant, Donald B. Leggett, as Mr. Leggett is entering his appearance pro se. • Date: . 4111111- _ Donald T. Kissinger, Esquire! HOWETT,KISSINGER& . OLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717)234-2616 Pursuant to Rule 1930.8(c)(2)please enter my appearance pro se. As a pro se party, I understand I am under a continuing obligation to provide current contact information to the Court, to other self-represented parties, and to all attorneys of record. Date: I 1 17-1 3 10 Donald B. Leggett 1525 North Front Street Condo 101 Harrisburg, PA 17102 Telephone: (717) 737-7777 20 AI 3 } Melissa M Legget, `�` ., Court of Common Pleas of Plaintiff PE -Vr "W1: y Cumberland County, Pennsylvania A NIA V NO.04-1998 Donald B Leggett Civil Action-Law Defendant In Divorce RESPONSE This is the answer to the motion for enforcement of marital settlement agreement, between Melissa Leggett(plaintiff) 2727 S Rosegarden Boulevard, Mechanicsburg, PA 17055,and Donald Leggett (defendant) 1525 N. Front Street,#101, Harrisburg, PA 17055,docket NO.04-1998. Listed below is everything I have done to comply with your request. Exhibition 1 - Applied for the first insurance policy in or around the beginning of July 2013. Exhibition 2 - Took a physical at my office (Spankys Auto Group) in the middle of July 2013 Exhibition 3 - Received my test results back: For a life Insurance policy of$350,000.00 I received a quote of $7000.00/per year. Exhibition 4 - Contacted a new insurance after waiting several weeks and reapplied on or about mid August 2013. Exhibition 5 the insurance company, and awaited a reply. - Filled out more paper work forte p y, Exhibition 6 - Took another physical examine in my office (Spankys Auto Group) in late September 2013. Exhibition 7 - Received follow up paper work on 11/20/2013 that had to be filled out and sent back to the insurance company. Exhibition 8 - On December 4, 2013 I was assigned a case manager(Carol Richards)along with an accu quote. - Also in the letter(which is provided) it states the underwriting process can take 4-6 weeks) Exhibition 9 - January 2, 2014 was my last contact with the insurance company. I have amicably attempted to resolve this issue. This is a process though, not just a simple visit to the doctor's office.They were aware of my ft application for life insurance,which was a no go. I could not afford $7000.00 a year.So I told them I would reapply with a new insurance company which they were fully aware of. I left my attorney go about 5-6 weeks ago. I owe him about 10,000.00, and can no longer string him along. I emailed Barb's office (see attached email). However, I am doing all I can to comply. My current state of affairs are not affordable. I am currently 3 months behind on my mother's mortgage. My cable was 2 months behind,which they shut off.There are also$4500.00 unpaid taxes for 701 E. Locust Street Mechanicsburg,that I am responsible for.The economic conditions in the past year have made it a challenge. Especially the last two months,with holidays and the extreme weather conditions. However we are looking forward to the new year,and the economy rising. As you can see,there has been interactions through out this process the entire time,with myself and the insurance company to get the issue resolved.(All proof is attached) I have done everything I can along the way,filled out all paper work, and made all the appointments that were required, and followed through with each one.At this point I am stuck waiting on the insurance company to follow through, and process everything they need to on their end. Thank you for your time, 1 ) q Donald B Leggett (Defendant) Fwd: This is Carol Richards from AccuQuote - I'll be updating you on your... Page 1 of 1 From: Donald Leggett<dlegg84001 @aol.com> To: mikebangs<mikebangs @verizon.net>;dknisely<dknisely @hkhlaw.net> CZ Subject: Fwd:This is Carol Richards from AccuQuote-I'll be updating you on your app. Date:Wed,Jan 8,2014 11:13 am Here was my e-mail to them letting them know where I was in the process and I just got another one explaining where we are now !!! i'll pass it along... Original Message From: Donald Leggett<dlegg84001(a�aol.com> To:.Barbara-bssesg,<Barbara-bssesqRverizon.net> lentTue, Dec 10,2013 9:05 am ' Subject: F`d-Thisis-Carol'Richards f om AccuQuote- I'll be updating you on your app. ,--.. i a,'•:arbara, Here's.where we are with the life ins. application... As you know the first approach to life ins was un- ffordable at over 7000 a yr. which was far to expensive... We started this process with them 8/27 and had several phone call and a appointment for blood work and now we're just waiting on the results... This is all I know... I'm sure they'll get back to me in a few weeks... Don, Original Message From: Deborah Thomas<dthomasi accuquote.com> To: dlegg84001 <dlegg84001 cr.aol.com> Sent:Wed, Dec 4, 2013 10:05 am Subject:This is Carol Richards from AccuQuote- I'll be updating you on your app. Hello Don Leggett, I'm Carol Richards, introducing myself as your Case Manager from AccuQuote. I am going to be your contact person during your application's underwriting evaluation. Because the underwriting process generally takes 4 to 6 weeks to complete, I will be here every step of the way to make sure this process is simple and effortless on your part. I want to let you know we have received your life insurance application.While I keep you updated on the progress of your application, I will be using the preferred method you've indicated; phone, email or text messages. In order to help expedite the underwriting process, please respond promptly in regards to any additional information needed. If you signed the authorization to draft funds and provided your checking account information: Your premium may be drafted from your account, so please have the necessary funds available. If you have questions at any time during this process, please call me at 800-442-9899 Ext.217. File ID: 2580417 Best regards, • Carol Richards Case Manager CRichardst accuquote.com Phone:847.850.1608 Fax:847.850.1608 AccuQuote http://www.accuquote.com/ Saving Your Money for Life TM Get insurance tips and advice: Visit our blog at http://www.Accuquote.com/bloq Follow us on Twitter http://www.Twitter.com/Accuquote Visit us on Facebook http://www.Accuquote.com/facebook CONFIDENTIAL-This email contains private information intended solely for the recipient to whom it was sent. http://mail.aol.com/3 8252-111/aol-6/en-us/mail/PrintMessage.aspx 1/8/2014 Fwd: C630771 - Don Leggett life ins... Page 1 of 1 From: Donald Leggett<dlegg84001 @aol.com> ICD To: mikebangs<mikebangs @verizon.net>; dknisely<dknisely @hkhlaw.net> Subject: Fwd: C630771 -Don Leggett life ins... Date: Wed,Jan 8,2014 11:17 am here's the latest up date These things just take time.... Original Message From: Carol Richards <crichards(c�accuquote.com> • To: dlegg84001 <dlegg84001(a aol.com> Sent:Thu,_Jan 2, 2014 2:08 pm , _ Subject: C630771 - Don Leggett Hello Don, Dr Khan's office has not returned any messages left by EMS!, the vendor obtaining the records yet. I will keep you updated. Thanks, Carol Carol Richards Case Manager CRichards©accuquote.com Phone: 800.442.9899 x217 Fax: 847.850.1608 AccuQuote http://www.accuquote.com/ Saving Your Money for Life TM Get insurance tips and advice: Visit our blog at http://www.Accuquote.com/bloq Follow us on Twitter http://www.Twitter.com/Accuquote Visit us on Facebook http://www.Accuquote.com/facebook CONFIDENTIAL - This email contains private information intended solely for the recipient to whom it was sent. • http://mail.aol.com/3 8252-111/aol-6/en-us/mail/PrintMessage.aspx 1/8/2014 • AQacg o4E6 Saving You Money For Life 1400 South Wolf Road,Bldg 500.Wheeling,IL 60090 Fax 6.847.8504606 11/20/2013 Case ID: C630771 DON LEGGETT 701 E. LOCUST ST. MECHANICSBURG, PA 17055 Dear Don Leggett, Thank you for choosing AccuQuote to handle your life insurance needs! This is important and valuable coverage for both your family and yourself. Per our conversation, enclosed is your paperwork. I have indicated areas that require your attention or signature on each form. Please initial any alterations that you make to your worksheet, and date all forms with the same date. In addition, all forms must be signed by the policy owner and the person to be insured (if this is not the policy owner). To complete your request for insurance, follow these 2 easy steps: Complete ALL HIGHLIGHTED SECTIONS of these enclosed forms:1 (Do not use correction fluid on any of the enclosed forms)j • Application • Bank Draft Authorization • Disclosure (3) • Exam Results Request Form • HIPAA Form • HIV Form 2. Mail back your signed paperwork' • Postage-paid envelope enclosed. • Do not send money at this time. Don't forget to return your application immediately. Once received, the insurance company can begin evaluating your case. Again,thank you for choosing AccuQuote. Our goal is to make this easy for you and we will keep you up- to-date throughout the process. Please contact us anytime with`your questions or concerns at 800-442- 9899. Sincerely, Steven Guarini Account Manager Byron Udell and/or Byron Udell&Associates,Inc., d/b/a AccuQuote derives substantially all of its revenue through industry standard commissions and performance-based bonuses earned from the sale of life insurance and other related products. • i O -.P. l•." glC - ra ____......„ AccbQuot ovember 19, 2013 Pruco Life Insurance Company-A.M. Best Rating:AMB#08240 A+ XV(5-9-13)** Term Essential 10(<250K PruXpress ONLY) E , L u P • Prepared for Don Leggett -------° T` : —Pgge 1 of 1 Prepared by Byron Udell, JD, CLU, CFP, ChFC Pennsylvania Male Age Last Birthday:59 Non-smoker Plus(R+NS) Renewable to 95 Convertible to 65 Face Amount: 250,000 Annual Premium Premium Age Guaranteed Guaranteed Monthly 59 1,160.00 104.40 60 1,160.00 104.40 61 1,160.00 104.40 . 62 1,160.00 104.40 63 1,160.00 104.40 64 1,160.00 104.40 65 1,160.00 104.40 66 1,160.00 104.40 •\ • `,. 67 1,160.00 104.40 ' 68 1,160.00 104.40 69 16,495.00 1,484.55 70 18,090.00 1,628.10 71 20,027.50 1,802.48 72 22,292.50 2,006.33 73 24,680.00 2,221.20 '' 74 27,245.00 2,452.05 75 30,037.50 2,703.38 76 33,187.50 2,986.88 - 77 36,850.00 3,316.50 78 ....41.0.02.50 3,699.23 79 45,870.00 4,128.30 80 51,185.00 4,606.65 81 56,965.00 5,126.85 82 63,085.00 5,677.65 83 69,767.50 6,279.08 84 77,200.00 6,948.00 85 85,465.00 7,691.85 86 94,555.00 8,509.95 87 104,380.00 9,394.20 88 114,825.00 10,334.25 89 125,785.00 11,320.65 90 136,700.00 12,303.00 91 147,445.00 13,270.05 92 158,702.50 14,283.23 93 170,572.50 15,351.53 94 183,077.50 16,476.98 -The actual premium will be determined after underwriting. NOTE: Every effort has been made to assure the accuracy of this information but we cannot guarantee accuracy and are not liable for errors or omissions. Prudential *: Financial PENNSYLVANIA DISCLOSURE STATEMENT The Prudential Insurance Company of America Pruco Life Insurance Company both are Prudential companies This Disclosure Statement with all applicable blanks filled in is for your protection. It gives you basic information about the Cost and Coverage of the insurance being solicited. Read it carefully before signing any agreement to buy Life Insurance. This Disclosure Statement shall not be considered as an offer to contract or as altering or modifying any Policy or rider that may be issued. Name of Proposed Insured Don B. Leggett 'Age 59 'Sex Male Name of Agent preparing Disclosure Byron Udell Agent home or agency address 1400 S. Wolf Road Building 500 Telephone number of Agent 847-850-2000 Name of Insurer Prudential Home Office Address of Insurer(City and State) Wheeling, IL 60090 Direct all correspondence to Insurer: Customer Service Office 2101 Welsh Road Dresher, PA 19025-1406 Descriptive Title Face Amount of Coverage (1) Annual Premium of Coverage If not applicable, If not know, Description of Coverage Premium for Mode Quoted (2) Base Policy- Check one Term Essential 10 250000.00 1160.00 ❑ Includes ® Excludes Waiver of Premium n/a n/a n/a Rider(s) n/a n/a n/a n/a Supplemental Benefits(s) (1) The face amount of coverage of the base policy changes as follows: n/a The amount of coverage of the rider(s) changes as follows: (2) The premium for the base policy changes;the ultimate n/a premium will be n/a at policy year n/a If more than one premium change,representativen/a premium will ben/a andn/a at policy years n/a andn/a The premium for the base policy changes;the ultimate n/a premium will ben/a at policy yearn/a If more than one premium change,representativen/a premium will ben/a andn/a at policy years n/a and n/a Total lnitialn/a (mode)premium for the policy and rider(s)will ben/a COMB 96999 Ed.1/2005 Guaranteed Cash Value. If you continuously pay your premiums on this policy as they come due,you will have the following guaranteed cash value per face amount(or for each$1,000). You may borrow against this cash value at an annual loan interest charge. Number of Years Policy Has been in Force 5 10 20 Age 65 Total Accumulated Cash Value 4.64 4.64 4.64 4.64 Per Total Face Amount(or per$1,000) 4.64 4.64 4.64 4.64 Dividends. The following is a dividend illustration for your policy based on the current interest, mortality and expense experi- ence of the company as reflected in the dividends currently paid. However,the illustrations are not a guarantee of what future dividends will be. Number of Years Policy Has been in Force 10 20 Illustrated Dividend for that Individual 4.64 4.64 Year per Face Amount(or per$1,000) 4.64 4.64 A Surrender Comparison Index will be provided upon delivery of the policy or earlier if requested. This Index provides one means of comparing the relative costs of two or more similar policies. The prospective insured ❑ has ID has not requested an earlier delivery of the index. Upon request either the company or agent will furnish you with additional information about the insurance described. If inapplicable to insurance being offered,section may be deleted entirely or clearly marked Not Applicable". COMB 96999 Ed.1/2005 MELISSA M. LEGGETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. DONALD B. LEGGETT, DEFENDANT NO. 04-1998 CIVIL IN RE: PLAINTIFF'S MOTION FOR ENFORCEMENT OF MARITAL SETTLEMENT AGREEMENT ORDER OF COURT AND NOW, this 24'h day of January, 2014, upon consideration of Plaintiff's Motion for Enforcement of Marital Settlement Agreement and the Court being advised that the parties have reached an agreement on that matter, IT IS HEREBY ORDERED AND DIRECTED that the Hearing scheduled for this date is CANCELLED. Either party may request it be rescheduled if required. By the Court, ,t�-� Q V M. L. Ebert, Jr., J. arbara Sumple-Sullivan, Esquire Attorney for Plaintiff �nald B. Leggett c-3 Defendant 1525 North Front Street Condo 101 Harrisburg, PA 17102 c:) , bas ]acs Z Pa , /v(.dI LL