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HomeMy WebLinkAbout10-1573 Divorce Complaint Prepared By: MM Diane G. Radcliff, Esquire 3448 Trindie Road, Camp Hilt, PA 17011 Su reme Court ID # 32112 ' co (a p Phone: 717-737-0100 Fax: 717-975-0697 • Email: dianeradctiff @comcast.net ' ,? cLL Attorney for Plaintiff c>' ' - G o r17 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN IA JOHN D. MOORE, Plaintiff NO. Ip - 15'13 l??v? l??-?'?" V. TAMIE L. MOORE, NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumbelrand County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. : CIVIL ACTION - LAW : DIVORCE Defendant Cumberland County Bar Association $-Za •oo 00 ATT-Y 32 South Bedford Street W-0 400 Carlisle, PA 17013 Rfi? a 3853(c Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, V. TAMIE L. MOORE, Plaintiff NO. : CIVIL ACTION - LAW : DIVORCE Defendant AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de Las quejas expuestas en Las paginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidadas o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff NO. 6 - 157 3 V. CIVIL ACTION - LAW TAMIE L. MOORE, DIVORCE Defendant COMPLAINT Plaintiff, JOHN D. MOORE, by his attorney, Diane G. Radcliff, Esquire, and files this Complaint in Divorce of which the following is a statement: COUNT I DIVORCE 1. The Plaintiff is John D. Moore, an adult individual residing at 117 4th Street, New Cumberland, Cumberland County, Pennsylvania since March 2009. 2. The Defendant is Tamie L. Moore, an adult individual whose mailing address is 90 Hilldale Road, Etters, PA 17319. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 22, 1999 at Winchester, Virginia. 5. Plaintiff avers that there are no children under the age of eighteen (18) years born of the marriage. 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. -1- s 8. Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. Plaintiff avers that the grounds on which the action is based are: A. Section 3301(c) Mutual Consent No-Fault: The marriage is irretrievably broken; B. Section 3301(d) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, . RADCLIFF, ESQ I rindle Road Camp Hill, PA 1701 1 Phone: (717) 737-0100 Supreme Court ID # 32112 Attorney for Plaintiff -2- . . A VERIFICATION JOHN D. MOORE verifies that the statements made in this Complaint are true and correct. JOHN D. MOORE understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ? --j -1o -3- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff N0. 10-1573 v• CIVIL ACTION -LAW TAMIE L. MOORE, DIVORCE Defendant AFFIDAVIT OF SERVICE I, Diane G. Radcliff, Esquire, being duty sworn according to law, depose and say that on March 11, 2010, I served a true and correct copy of the Complaint in Divorce upon Tamie L. Moore, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Tamie L. Moore 90 Hillside Road Etters, PA 17319 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. D NE G. RA CLIFF, ESQUIRE 3 e Road Camp Hill, PA 17011 Supreme Court I.D. No. 32112 Attorney for Plaintiff Sworn to and subscribed before me a Notary Public in and for Cumberland County, Pennsylvania this day of;~;YIQ~~i , 20/(~. c N o ~ ~~~~~C-mil Q~~ ~ - _- ~ ~, NOTARY PUBLIC _ ,` ~ ,~ ~ My commission expires: COMMONWEALTH OF PENNSYLVANIA , ~_~~ ""' ~ ` Notarial Seal Debor2dt L DoNey, Notary Public ?- r:? •~ Camp HMI Boro, Ctanberlartd County t.ti My Comrrtissiort E~ires Sept 23, 201 l Member, Pennsylvania Association of Notaries ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~ ~{~llSide, ~c~a~ A. I ~ ~ed~ (P ~ntedeName) /((~t~ of D D. Is delivery address d'rfferent 17 If YES, enter delivery address O -7 q 3.`~Serv~ice Type ~~S ~ ~~- ~ / 3 ~ / 1~.Certined Mail ^ Express Mail /^ Registered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ~Yeq 2. Article Number 7~p9 1410 ~D00 119^ 5523 (Tnynsler /rom aerrfcs Asber) PS Form 3811,. February 2004 Domestic Retum Receipt to2ess-o2-ei_tsao EXHIBIT "A" RETURN RECEIPT CARD I ILEVOFFICE Or HE PROTHONOTARY 2011 DEC 30 PM 12*- 40 CU PENNSYLVANUATY Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff(aD-comcast.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff : NO. 10-1573 V. TAMIE L. MOORE, Defendant CIVIL ACTION - LAW DIVORCE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 25, 2009 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the-peryalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to auth ies. Date: JUMOORE, Plaintiff 7 f t,, l 1 ?T' , 20E?A 25 PM "'UMBER S?YLi?A ??, itc Ir. IN THE COURT OF COMMON PLEAS OF 9th JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE Plaintiff, V. TAMIE 1. MOORE Defendant No. 10-1573 Civil Action - Divorce COUNTER-AFFIDAVIT UNDER SECTION 3301(4) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (1), (ii) or both): ? (1) The parties to this action have not lived separate and apart 1-or a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I lose rights concerning alimony. division of property, lawyer's fees or expenses if f I do not claim them before the divorce is granted. (b) 1 wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If 1 fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ECONOMIC CLAIMS: Equitable Distribution of Real and Personal Property Equitable Division of Pension and Retirement Funds Alimony F iLED-t r`i iC jF i HE Pf OTHONdWl 2012 JAN 26 PM 2: 14 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff NO. 10-1573 V. : CIVIL ACTION - LAW TAMIE L. MOORE, DIVORCE Defendant AFFIDAVIT OF SERVICE 1, the undersigned, being duly sworn/affirmed according to law, deposes and says: 1. I am over 18 years of age and am not related to either party to this action. 2. 1 served a true and correct copy of the Affidavit Under Section 3301(d) of the Divorce Code, upon the Defendant, Tamie L. Moore, on / by hVding a copy to Defendant at ZS? :? f 4 5 ,y t?: t ?L &4C' 1?? ? , . ?. (Sig atur a •1 / (Printed name) Sworn to and subscribed before me a Notary Public in and for Cumb r and County, Pennsylvania this day of ?lk?NT, 2012-. COMMONWEALTH t!r ^?pyNSYL,VAtW?q NOTARIAL S&d, NOTARY PUBLIC CHARLES A. HARB0LD;?,!r±ary,=ublr, Camp Hill Boro., t rr ? ?9 rd Ccunrj i My commission expires: MyCommissi fl Expir-t_D:°xlaber.;() 2wa IN THE COURT OF COMMON PLEAS OF THE 9th JUDI PENNSYLVANIA m DISTRICT CUMBERLAND COUNTY , -<n ' N L1 _ JOHN D. MOORS r-7 > Plaintiff , No. 10-1573 Civil Term ° ° V. TAMIE L. MOORE Civil Action - Divorce Defendant AND NOW, Comes Defendant, Tamie L. Moore, by and through counsel, Lee E. Oesterling, Esquire and in support of this Petition avers as follows: 1. Defendant filed a counter - affidavit on January 25, 2012 2. Defendant listed on the Affidavit Claims which she anticpated raising and as required by Section (b) of the 3301(d) counteraffidavit. These claims include equitable distribution of marital property, both real and personal, equitable distribution of pension and or retirement benefits and alimony. 3. The counter-affidavit was served on counsel for the Plaintiff. 4. Defendant wishes to raise these claims by this pleading as PlaintiWs Counsel has suggested that Defendant has not properly done so on her counter-affidavit. 5. Defendant therefore raises and lists the following claims in accordance with the duly filed counteraffidavit: (1) Equitable Division of Marital Property Real and Personal (2) Equitable Division of Retirement Funds (3) Alimony 6. Counsel is presently out of state so is filing this Petition on Defedant's behalf by facsimile with a copy to follow by ordinary mail. RESPECTFULLY SUBMITTED, l Lee E. 06sterlin ; ?re` Supreme Court ID No. 71320 503 Bridge Street, Suite 212 New Cumberland, PA 17070 Attorney for Defendant VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in the foregoing Petition are true §and correct. k se statements in are made subject to the penalties of 18 Pa.C.S. 4904, relating unswom falsi cation to ties. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff v. TAMIE L MOORE, Defendant _a NO. 10-1573 -~;,~ ~ --+ CIVIL ACTION -LAW `~ cn ~' -~~f~`~ :: ~ ,._ , , . r-~ -tom DIVORCE ~~: ~ ~- ~ ~_~° - ~ c~~ ~ _ ~-. x, c- :~. ~ -- ~~: MOTION FOR APPOINTMENT OF MASTER --~' ~ Y' Plaintiff, John D. Moore, moves the Court to appoint a Master with respect to the following claims: [X] Divorce [ ] Annulment [X] Distribution of Property [ ] Support [ ] Alimony Pendente Lite [X] Alimony [ ] Counsel Fees [ ] Costs and Expenses In support of the Motion the Defendant states: 1. Discovery is complete with respect to the claims for which the appointment of the Master is requested. 2. The non-moving party has appeared in the action by her attorney, Lee E. Oesterling, Esquire. 3. The statutory ground for the divorce are: Section 3301 (c) and Section 3301(d) No- Fault. 4. The action is contested with respect to the following claims: All claims. 5. The action does not involve complex issues of law or fact.. 6. The hearing is expected to take one (1) day. 7. Additional information, if any, relevant to the Motion: None ~---_. .+~` Date: November 2, 2012 `' _._ ` ~°---------- " ~-BtA1'~tE G. ADCLIFF, ESQUIRE 1 or Plaintiff CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows: Lee E. Oesterling, Esquire 503 Bridge Street, Suite 212 New Cumberland, PA 17070 (Counsel for Defendant) ~~-. .------ ._z ~ , -- _ r, ~~ Date: November 2, 2012 ~ ~ Ql~fd~~- R DCLIFF, ESQUIRE Attorney or Plaintiff c-~ n.~ ,~~ - ~~ ~_~_ ~ h -'~ .2-~ .t ' rrt ~_ a r._.. _ ~; ~,,? ~ I ~' .:9 --< y. N --~ t-_ ; _._. ., i ~ 1_.~J ,~-__ s Y,-> .. ~ 5 .._, --i C *1 -,`, :~~ _~ ._ ." IN THE COURT OF COMMON PLEAS FOR THE NINTH DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY, PA JOHN D. MOORE, v. TAMIE L. MOORE, Plaintiff NO. 10-1573 Defendant CIVIL ACTION -LAW DIVORCE PLAINTIFF'S INVENTORY Submitted by John D Moore PREVIOUSLY ASSIGNED JUDGE None DIVORCE MASTER E. Robert Elicker, II, Esquire 9 North Hanover Street, Carlisle, PA 17013 Telephone: (717) 240-6535 Email: belicker ccpa.net APPEARANCE FOR PLAINTIFF Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Telephone: (717) 737-0100 Facsimile: P,717) 975-0697 Email: dianeradclifft_c'~r comcast.net APPEARANCE FOR DEFENDANT Lee E. Oesterling, Esquire 503 Bridge Street, Suite 212 New Cumberland, Pennsylvania 17070 Telephone: (717) 635-9641 Facsimile: None Known Email: pennsylvanialaw(a~msn.com Diane G. Radcliff, Esquire Supreme Court ID #32112 3348 Trindle Road, Camp Hill, PA 17011 Telephone: 717-'737-0100 • Facsimile: 717-975-0697 Email: dianeradcliffta'~.comcast.net Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR THE NINTH DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY, PA JOHN D. MOORE, v. TAMIE L. MOORE, Plaintiff NO. 10-1573 CIVIL ACTION -LAW DIVORCE Defendant INVENTORY OF PLAINTIFF, JOHN D. MOORE Plaintiff files the following Inventory of all property owned or possessed by either party at the time this action was commenced anti all propertytransferred within the preceding three years. Plaintiff verifies that the statements made in this Inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ' `_ Dated: /~~ - ~ /~ ~ // ...-- - - ~ --?" JOHN D ~ ~,/ Dated: } i ~... ~ "t._._ ~ 4 -- ,, ~~ ORE, PLAINTIFF . RADO~FF, ESQUIRE -2- ASSETS AND LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets and debts on the following pages. (,~) 01. Real Property and Real Estate Mortgages (,~) 02. Motor Vehicles and Vehicle Liens () 03. Stocks, Bonds, Securities and Options () 04. Certificates of Deposit (f) 05. Checking Accounts, Cash (,~) 06. Savings Accounts, Money Market and Savings Certificates ( ) 07. Contents of Safe Deposit Boxes ( ) 08. Trusts ( ) 09. Life Insurance Policies ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, Copyrights, Inventions, Royalties ( ) 14. Personal Property Outside the Home ( ) 15. Business ( ) 16. Employment Termination Benefits-Severance Pay, Worker's Compensation ( ) 17. Profit Sharing Plans (,~) 18. Pension Plans (indicate employee contribution and date plan vests) (d) 19. Retirement Plans, Individual Retirement Accounts ( ) 20. Disability Payments ( ) 21. Litigation Claims (matured and unmatured) ( ) 22. MilitaryN.A. Benefits ( ) 23. Education Benefits ( ) 24. Debts Due, including loans, mortgages held (d) 25. Household Furnishings and Personalty ( ) 26. Other Assets (,~) 27. Loans, Credit Cards .and Other Debts -3- INFORMATIONAL NOTES 1. The values used in the various Tables herein may be based on estimated values. Those estimated values are subject to adjustment upon appraisal or otherwise. 2. Any adjustment figure(s) that may appear in the various Tables herein have been inserted for illustration purposes only, and is not to be deemed a representation that an adjustment should be made or that the amount of the adjustment, is appropriate. ABBREVIATIONS A .......................... Appraisal ACT .......................... Account B .......................... Business C .......................... Child or Children CD .......................... Certificate of Deposit D .......................... Debt Est .......................... Estimate G .......................... Gift H .......................... Husband HG .......................... Household Goods INH .......................... Inheritance INS .......................... Insurance INV .......................... Investment KBB .......................... Kelley Blue Book Value NADA .......................... NADA Value NM .......................... Non-Marital Property PEN .......................... Pension Plan PM .......................... Pre-Marital PPV .......................... Private Party Value PS .......................... Post-Separation PSP .......................... Profit Sharing Plan RE .......................... Real Estate RET .......................... Retirement Plan S .......................... Stipulation TIV .......................... Trade in Value V .......................... Vehicle W .......................... Wife -4- SECTION I. BACKGROUND INFORMATION The following Table #1 sets forth the background information relevant to this case: TABLE #1-A PARTIES DESCRIPTION HUSBAND WIFE Name John D. Moore Tamie L. Moore Address 117 4`h Street New Cumberland, PA 17070 20 Sam Snead Circle Etters, PA 17329 Year of Birth 1971 1958 ? Age 41 54 ? Health Status Had prior work injury and unable to work 12/08-12/11 Good ? Educational Background HS graduate; 5 yrs app NJATC HS Graduate Names and Relationship of Persons Living with Party Michael Moore, son Nephew, Bobby Date Moved to Home March 13, 2009 Unknown Date PA Residency Began Birth more than 5 months Current Military Service N/A N/A Employer Brenner Motors Flight Systems, Inc. Occupation (Job Position) Commercial Sales Unknown Date Employment Began August 2012 Unknown Income Average of $1,937.50 over 16 month period + commissions ~.Jnknown Other: unable to work 12/08-12/11 prior 2012 job made total of $800 +/- 5 TABLE #1-B MARRIAGE INFORMATION Date of Marriage Place of Marriage Winchester, VA Husband's Number of Marriages 2 Wife's Number of Marriages 4 Date of Separation December 25, 2009 (Physical) Grounds for Divorce Non-Consent - No Fault -Section 3301(d) Prior Divorce Actions Between Parties None TABLE #1-C CHILDREN OF THIS MARRIAGE Name Age Birth Year School Grade Custodian Emancipation None N/A N/A N/A N/A N/A TABLE #1-D CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES Parent Name of Ghild Est. Age Emancipation Husband Michael Moore 21 ,C Wife Louis Kane 28 ,~ Wife Tanya Kane 24 d -6- SECTION II. SUPPORT The following Tables #2-A and #2-B sets forth the support information relevant to this case: TABLE #2-A SUPPORT FOR THIS MARRIAGE Name of Party Paying Support None Beneficiaries of Support N/A Amount of Support and Allocation N/A Date of Agreement or Order N/A Effective Date of Agreement or Order N/A Docket Number of Support Order N/A Comments Wife has filed a support action; Conference is scheduled for November 15, 2012 TABLE #2-B SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP Name of Party Paying Support N/A Beneficiaries of Support N/A Amount of Support and Allocation N/A Date of Agreement or Order N/A Effective Date of Agreement or Order N/A Docket Number of Support Order N/A Comments N/A -7- SECTION III. PLEADINGS The following Tables #3-A - #3-E sets forth information regarding the pleadings filed in this case. TABLE #3-A PLAINTIFF'S DIVORCE PLEADINGS Date of Filing of Divorce Complaint March 8, 2010 Date of Service of Divorce Complaint March 11, 2010 Manner of Service of Divorce Complaint Certified Mail, Restricted Delivery Divorce Claims Raised in Divorce Complaint No Fault -Sections 3301(c) and (d) Economic Claims Raised in Divorce Complaint None TABLE #3-B DEFENDANT'S DIVORCE PLEADINGS Description of Pleading Petition Supplementing Counteraffidavit to List Economic Claims Which Are Unresolved Date of Filing of Petition March 22, 2012 Divorce Claims Raised in Petition None Economic Claims Raised in Petition Equitable Distribution and Alimony TABLE #3-C 3301(C) PLEADINGS Plaintiffs 3301(c) Pleadings Description of Pleading Pleading Date Filing Date Service Date Plaintiff's 3301(c) Affidavit N/A N/A N/A Plaintiff's 3301(c) Waiver of Notice N/A N/A N/A Defendant's 3301(c) Pleadings Description of Pleading Pleading Date Filing Date Service Date Defendant's 3301(c) Affidavit N/A N/A N/A Defendant's 3301 (c) Waiver of Notice N/A N/A N/A -8- TABLE #3-D 3301(D) PLEADINGS Date of Separation December 25, 2009 Plaintiffs 3301(d) Pleadings Description of Pleading Date of Pleading Filing Date Service Date Plaintiff's 3301(d) Affidavit 12/29/2011 12/30/2011 01/18/2012 Plaintiff's 3301(d) Notice of Intention Plaintiff's 3301(d) Counter-Affidavit N/A N/A N/A Defendant's 3301 (d) Pleadings Description of Pleading Pleading Date Filing Date Service Date Defendant's 3301(d) Affidavit N/A N/A N/A Defendant's 3301(d) Notice of Intention N/A N/A N/A Defendant's 3301(d) Counter-Affidavit Undated 01/25/2012 Not Served Comments: Defendant did not object to divorce. She only asked to raise economic claims TABLE #3-E FINANCIAL PLEADINGS 1NCOME AND' EXPENSE STATEMENTS Plaintiff's I&E Statement Filing Date Concurrent Defendant's I&E Statement Filing Date None Filed INVENTORIES Plaintiff's Inventory Filing Date This filing Defendant's Inventory Filing Date None filed -9- SECTION IV. MARITAL ASSETS AND DEBTS The following Table #4 sets forth a listing and information regarding the marital assets and debts. John D. Moore vs. Tamie L."Moore DOM: 1122199 • DOS: 12125109 .Dated: July 18, 2012 A B C D E F G Binder 0 Description Date of Distribution Distribution Distribution Value Value to Husband to Wife REAL ESTATE AND REAL ESTATE MORTGAGES RE-1 H 117 4'h Street, New Cumberland 12.25.09 HNM Gift HNM Gift RE-1 JT Evelyn Stetler Mtg DOA 3.09 12,000.00 12,000,00 RE-1 JT Evelyn Stetler Mtg DOS 12.25.09 (9,818.77) (9,818.77) RE-1 > Property inherited by H's father and aunt. On 3109 the father and aunt transferred the property to Husband as a gift. The only thing they asked was for him to reimburse the Aunt for the $12,000 she borrowed on her line of credit to pay inheritance taxes, real estate taxes deed preparation etc. The agreement was that Husband would that credit line with 2.5% per annum in monthly installments of $ 300. At separation the balance was $9,400. >Husband submits that the real estate did not increase in value from 3.09 DOA and 12/09 DOS . >the mortgage was paid down during marriage from the $12,000 - $ 9,818.77 = 2,181.23 . MOTOR VEHICLES AND VEHICLE LIENS V-1 H 1994 Fortl Escort No Value No Value V-2 W 1992 Geo Metro No Value No Value CASH, CHECKING ACCOUNTS AND SAVINGS ACCOUNTS A-1 H Member's 1S' # 7403 Checking 12.24.09 231.67 231.67 A-1 H Member's 1 S' # 7403Savings 12.24.09 25.28 25.28 -10- A B Binder 0 John D. Moore vs. Tamie L. Moore DOM: 1122199 • DOS: 12125109 Dated: July 18,2012 C D E Description Date of Distribution Value Value A-2 W NCFCU # 3089 Checking 12.24.09 5.00 A-2 W NCFCU # 3089 Savings 12.24.09 143.66 A-3 H NCFCU # Savings 5.00 F Distribution to Husband 5.00 HOUSEHOLD GOODS AND OTHER TANGIBLE PERSONAL PROPERTY HG-1 JT Household Goods and PP Est 10,000.00 2,000.00 HG-1 See Tables # 5-A and #5-B for listing RETIREMENT PLANS RET-1 H Local 143 Fund 12.31.09 15,324.88 15,324.88 RET-2 H Local 143 Pension RET-2 Payable @ 748Imo at age 65 ASSET TOTALS TBD TBD G Distribution to Wife 5.00 143.66 8,000,00 TBD Totals for Assets wlo Pension Value Included 27,916.72 19,768.06 8,148.66 LOANS, CREDIT CARDS AND OTHER DEBTS D-1 H Citi Financial # (13,364.00) (13,364.00) D-1 *Husband to provide account statement showing balance owing as of 12.25.09 (Consolidation Loan) D-2 H H's Capital One # (1,200.00) (1,200.00) D-2 *Husband to provide account statement showing balance owing as,of 12.25.09 Ddebt incurred by Wife) D-3 H H's Fashion One# (1,000.00) (1,000.00) D-3 *Husband to provide account statement showing balance owing as of 12.25.09 DEBT TOTALS Total of Debts (15,564.00) (15,564.00) 0.00 -11- John D. Moore vs. Tamie L. Moore DOM; 1122199 • D4S: 12/25109 Dated;.July 18, 2012 A B C D E F G Binder 0 Description Date of Distribution Distribution Distribution Value Value to Husband to Wife SUMMARY Descri tp ion Total Above H Above W Above Asset Total 27,916.72 19,768.06 8,148.66 Debt Total 15 5( 64.00 15 564.00. 0.00 Net Estate Totals 12,352.72 4,204.06 8,148.66 -12- SECTION V. HOUSEHOLD GOODS AND PERSONAL PROPERTY The following Table #5-A and Table #5-B sets forth a listing of and information regarding the household goods and contents and other personal property in the possession of Husband and /or Wife unless otherwise noted that the prior division is not in dispute.. FN#' TABLE #5-A HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM LIVING ROOM 1 50" Sony Bravia LCD TV H & W 2 TV Stand H & W 3 VCR!DVD Player H & W 4 Couch Pillows H & W 5 Home Interior Piece H & W 6 Dragon Collection H & W REMOVED FROM DINING ROOM 7 All DVDs H & W 8 Computer Software CDs H & W 9 Canon Digital Camera H & W 10 Elvis Collection H & W 11 Packet of Photo Paper H & W FN#1 Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. The increase in value during the marriage of non-marital property is marital property. -13- TABLE #5-A No. 12 13 14 15 16 17 18 19 20 21 21 22 23 24 25 26 27 HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM LAUNDRY ROOM Dog (Toots) H & W Dog Kennel H & W Dog Food Container H & W Dog Dishes H & W Coleman Air Mattress H & W Freezer Contents (20 Ibs of H & W chicken; 20 Ibs of hamburger; E~ Ibs shrimp; 6-8 Ham steaks; bags of veggies; frozen pizza; waffles) Freezer Contents Stove to Cutting Boards Spices and Pantry Contents Frying Pans Oven Dishes Tupperware All Gleaning Supplies Swifter Sweeper Steam Shark Blow Dryer Contents of Downstairs Vanity REMOVED FROM KITCHEN H&W H&W H&W H&W H&W H&W H&W H&W H&W H&W H&W -14- TABLE #5-A No 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM UPSTAIRS 3 Comforters from Michael's Bed H GifE from H's Mother Pillows from Michael's Bed H Serving Platter H & W Contents of Upstairs Vanity H & W Including Extra Shampoo, 3 Bottles Rubbing Alcohol; 3 Bottles Hydrogen [Peroxide: 3 Tubes Toothpaste; Box of Disposable Razors Bassinette H & W H Purchased for GD Baby Swing H & W H Purchased for GD High Chair H & W N Purchased for GD Cedar Chest H & W All Towels and Wash Rags H & W All Sheets and Pillow Cases H & W Pellett Gun H & W Sony Digital Camera H & W Sony Boom Box H & W Bathroom Rug H & W All Clothing Baskets H & W Taurus .357 5 shot CIA W 5.25.12 270 Hammerless -15- TABLE #5-B HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital LIVING ROOM 1 XBox360 H&W 2 2 end tables H & W 3 Coffee table H & W 4 2 lamps H & W 5 Couch and chair 6+ yrs old H & W DINING ROOM 6 Table & chairs - H's GM's H N/A N/A Inheritance or Gift from H's GM 7 China Cabinet - H's GM's H N/A N/A Inheritance or Gift from H's GM 8 China H & W 9 Computer 7+ yrs old H & W 10 HP Printer H & W 11 Computer Desk H & W LAUNDRY ROOM 12 Washer and dryer - H's GM's H N/A N/A Inheritance or Gift from H's GM 13 Freezer - H's GM's H N/A N/A Inheritance or Gift from H's GM 14 Vacuum Cleaner H & W 15 Shop Vac H & W 16 18 Qt Roaster H & W 17 2 Small Crock Pots H & W 18 Foocl Processor H & W -16- TABLE #5-B HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital 19 Misc Cleaning Supplies H & W 20 Misc Hand Tools; H & W KITCHEN 21 Phone Stand H & W 22 Refrigerator - H's GM's H N/A N/A Inheritance or Gift from H's GM 23 Microwave with Stand H & W 24 Dishes, Bowls and Cups H & W 25 Toaster H & W 26 Toaster Oven H N/A N/A Gift from H's Mother 27 Misc Pots H & W 28 Flatware H & W 29 Broom and Dust Pan H & W MASTER BEDROOM 30 Bed H & W 31 Dresser and Chest of Drawers - H N/A N/A Inheritance or Gift H's GM's from H's GM 32 Sitting Chair H N/A N/A Gift from H's Mother BEDROOM # 2 33 2 Gun Cases H 34 Bed - H's GM's H N/A N/A Inheritance or Gift from H's GM 35 Dresser and Chest of Drawers H N/A N/A Gift from H's Mother -17- TABLE #5-B HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital OUTSIDE 36 Gas Grill H & W 37 Table and Chairs H & W 38 Hose H & W 39 Garden Tools H & W 40 Cooler H & W GUNS 41 Taurus 444 Raging Bull 44 mag H 5.25.12 320 42 Savage 93R17 '17 caliper rifle H 5.25.12 75 43 Remington 760 35 caliper rifle H 5.25.12 275 44 Hi Standard Marshall 22 cal rpistol H N/A N/A 45 Ruger Security Six 357 Mag Rev. H N/A N/A 46 Savage 99F 308 caliber rifle H N/A N/A 47 Mossberg 500c 20 gauge shotgun H N/A N/A 48 Marlin 80 22 caliber rifle H N/A N/A 49 Marlin 81 22 caliper'rifle H N/A NIA 50 Winchester 70 7mm mag rifle H N/A N/A 51 Charles Daly MM12 12 gauge H N/A N/A Shotgun 52 Remington 7600 243 caliper rifle H N/A N/A Gift From Wife F~urchased during marriage Gift from H's Father Gift from H's GF Gift from H's GF Gift from H's GF Belongs to H's son Belongs to H's brother Belongs to H's son Belongs to H's son Belongs to H's brother -18- SECTION VI. NON-MARITAL ASSETS AND DEBTS The following Table #6 contains a listing of and information regarding the parties' non-marital assets and debts. FN# z,3 TABLE #6 NON-MARITAL PROPERTY AND DEBTS Description Marital Non-Marital Total Value Basis for Method of Value Value Exclusion Valuation & Supporting Documents H's 117 4`h Street, New Cumberland $2,183.23 $47,816.77 $50,000 - G Deed, to $70,000 PS Mortgage 67,816.77 Statements Various items of Personal TBD TBD TBD NM N/A Property specified in Tables G or INH or #5-A and #5-B owned b y 3`d party ABBREVIATIONS FOR TABLE #6 H =Husband C =Children PM =Property Acquired Before Marriage G =Property Acquired by 3`d Party Gift W =Wife NM =Non Marital Property PS =Property Acquired Post Separation INH =Property Acquired by Inheritance FN #2 Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. FN #3The value of each item has been estimated unless otherwise noted. -19- SECTION VII. PROPERTY TRANSFERRED The following Table #7 contains a listing of and information regarding all property which was transferred within 3 years of the date of the commencement of this action or was transferred since the date of separation: TABLE #7 PROPERTY TRANSFERRED Description of Property Transfer Date Consideration Transferor Transferee None Known -20- CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on this date I am serving a copy of the foregoing pleading upon the following person by mailing same by first class mail, postage prepaid, addressed as follows: Lee E. Oesterling, Esquire 503 Bridge Street, Suite 212 New Cumberland, Pennsylvania 17070 (Attorney for Defendant) /9 Dated: ~ ~ ~ ~ ~ ' IANE G RADCLIFF, SQUIRE e Court ID #32112 3448 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff -21- PELED-O~~iC ~.tP TNI~ PRO~NO"~O~ARY 2012 NOV 13 PM 1 ~ 26 CU PENN YLUYANI~N TY IN THE COURT OF COMMON PLEAS FOR THE NINTH DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY, PA JOHN D. MOORE, Plaintiff : NO. 10-1573 v. CIVIL ACTION -LAW TAMIE L. MOORE, DIVORCE Defendant PLAINTIFF 'S INCOME AND EXPENSE STATEMENT Submitted by Plaintiff, John D. Moore PREVIOUSLY ASSIGNED JUDGE None APPEARANCE FOR PLAINTIFF: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Telephone: (717) 737-0100 Facsimile: (717) 975-0697 Email: dianeradcliff(c~comcast.net APPEARANCE FOR DEFENDANT: Lee E. Oesterling, Esquire 503 Bridge Street, Suite 212 New Cumberland, Pennsylvania 17070 Telephone: (717) 635-9641 Facsimile: None Known Email: pennsylvanialawCa~msn com -1- PART I. INCOME A. EMPLOYMENT INFORMATION: Employer: Brenner Position: Commercial Sales Pay Period: Biweekly B. EMPLOYMENT INCOME -Salary: Plaintiff is paid on a salary + commission basis through 12/31/13. The salary is on a reducing basis as indicated below. DESCRIPTION PAY PERIOD MONTH YEAR 9.1.12 - 2.28.13 Salary $1,384.62 $3,000.00 $36,000.00 3.1.13 - 8.31.13 Salary $692.30 $1,500.00 $18,000.00 9.1.13 - 12.31.13 $461.50 $1, 000.00 $12, 000.00 1.1.14 and forward All commissions B. EMPLOYMENT INCOME -Commissions: Employment started on 8/28/12 so there has not been sufficient time to predict average commissions. Nonetheless the commissions earned today are listed as follows:. PAY PERIOD BIWEEKLY AMOUNT MONTHLY AMOUNT ANNUALIZED AMOUNT 8.29.12 to 9.11.12 0.00 9.12.12 to 9.25.12 450.00 9.26.12 to 10.9.12 482.46 10.10.12 to 10.23.12 1,172.08 Total $2,104.54 # of pay Periods 4 Average Total $526.14 $1,139.96 $13,679.54 -2- D. OTHER INCOME ©ESCRIPTION MONTHLY YEARLY Interest $0.00 Dividends $0.00 Pensions $0.00 Annuities $0.00 Social Security $0.00 Rents $0.00 Royalties $0.00 Expense Account $0.00 Gifts $0.00 Unemployment Compensation $0.00 Workman's Compensation $0.00 Income Tax Refunds $0.00 Tips $0.00 Support or Alimony $0.00 Other (Specify): $0.00 TOTAL OTHER INCOME $O.OD $0.00 -3- PART II. EXPENSES DE3CR~PTiON Mt~ITHLY AMOUNT COI~I~TS HOME EXPENSES: Primary Mortgage Paid off Post Separation Homeowners Insurance $78.50 $943/yr Real Estate Taxes (C, M & S) $112.30 $1, 348/yr Maintenance and Repairs $500.00 New roof and flashing Electric $250.00 Water $46.00 Sewer & Trash $150.90 Cell Phone $170.00 Pay TV and Internet $210.00 INSURANCE: Automobile Insurance $91.60 Health-Medical Insurance Do not have insurance Dental Insurance Do not have insurance Vision Insurance Do not have insurance TAXES: Per Capita Taxes $1.00 AUTOMOBILE EXPENSES: Payments Fuel $400.00 Maintenance and Repair $100.00 License and Registration $6.00 -4- DESCRIPTION MONTHLY AMOUNT COMMENTS MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $25.00 Optical Dental $25.00 Orthodontic Hospital Medicine $25.00 PERSONAL AND MISCELLANEOUS EXPENSES: Clothing $100.00 Food $450.00 Barber and Hair Dresser $20.00 Memberships $41.60 Union Dues Newspapers/Magazines $10.00 Entertainment $100.00 Vacations $166.60 Gifts $50.00 Charitable Contributions $75.00 Legal Fees $200.00 TOTAL EXPENSES '..$3,404'.50 -5- PART III. PROPERTY OWNED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VAt_UE H W JT Checking Members 1St 501.00 X Savings Members 1St 1,472.00 X Stocks/bonds Real Estate 117 4T" St. New Cumberland, PA 70,000.00 X Other Various 900.00 X TOTAL 72,873.00 PART IV. INSURANCE INSURANCE INFORMATION COVERAGE TYPE COMPANY POLICY NO. H W C Hospital N/A Medical N/A Health Accident N/A Disability Income N/A Dental N/A Vision N/A Other-Specify N/A *H=Husband; W=Wife; J=Joint; C=Child -6- PART V. SUPPLEMENTAL INCOME STATEMENT [ d ]CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ]attached (2) The most recent Profit and Loss Statement. [ ]attached (c) Name of Business: Business Address: Business Telephone: (d) Nature o1 [] 1. [] 2. [] 3. [] 4. [] 5. [ l s. Business (check one) Sole Proprietorship Partnership Joint Venture Professional Corporation Other (e) Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that on this date I am serving a copy of the foregoing document, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail, Postage Prepaid and Addressed as Follows: Lee E. Oesterling, Esquire 503 Bridge Street, Suite 212 New Cumberland, Pennsylvania 17070 (Attorney for Defendant) Dated: November 13. 2012 D DCLI~'~QUIRE ~ I ourt ID #32 2 3448 Trindle Road Camp Hill, PA 17011 Phone: (717) 737-0100 Attorney for Plaintiff, John D. Moore -9- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE, Plaintiff NO. 10-1573 v. TAMIE L. MOORE, Defendant CIVIL ACTION -LAW DIVORCE 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 falsific Date: //~.~ ~/off t t 1 �'f; d1JTlii10 1t; 's ZGI3 JUN _7 PH 1: 30 CUMBERLAND PENNSYLVANIA RTY IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA JOHN D. MOORE, • Plaintiff : NO. 10-1573 v. : CIVIL ACTION - LAW TAMIE L. MOORE, : DIVORCE Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 8, 2012. 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 in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. (� 7 /3 Dated: ...; _ . y • ORE i 11 ?i'.41 5IHHOU 1 Akk fl13 JUN --7 PM 1: 30 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA JOHN D. MOORE, • Plaintiff • NO. 10-1573 • v. • CIVIL ACTION - LAW TAMIE L. MOORE, • DIVORCE Defendant • PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 this Waiver 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. Dated: /4/L : 'N D. MOO',- IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA JOHN D. MOORE, ; Plaintiff NO. 10-1573 w V. CIVIL ACTION - LAW --cam CD <CD -- � > TAMIE L. MOORE, DIVORCEC,� y' Defendant - : DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 8, 2010. 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. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: q-0? o TAMIE L. MOO E IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA JOHN D. MOORE, Plaintiff NO. 10-1573 C: V. CIVIL ACTION - LAW w -� to N) r TAMIE L. MOORE, DIVORCE Defendant , WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. verify that the statements made in this Waiver 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. C Dated: 11AIAE L. MOORE r IN THE COURT OF COMMON PLEAS OF THE 91h JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE Plaintiff, No. 10-1573 Civil Term V. TAMIE L. MOOD Civil Action - Divorce Defendant DEFENDANT'S INVENTORY AND STIPULATIONS C= GO PREVIOUSLY ASSIGNED JUDGE rr, None 7 DIVORCE MASTER .c- ca �? E. Robert Elicker, 11, Esquire 9 North Hanover Street,Carlisle,PA 17013 - Telephone: (717)240-6535 e-mail: belicker @cepa.riet APPEARANCE FOR PLAINTIFF APPEARANCE FOR DEFENDANT Diane G. Radcliff, Esquire Lee E. Oesterling,Esquire 3448 Trindle Road 503 Bridge Street, Suite 2:12 Camp Hill, PA 17011 New Cumberland, PA 17070 Voice: (717) 737-0100 Voice: (717)884-2065 Fax: (717)975-0697 Fax: (717)370-5567 a IN THE COURT OF COMMON PLEAS OF THE 9"' JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE Plaintiff, No. 10-1573 Civil Term vi. TAMIE L. MOORE Civil Action - Divorce Defendant INVENTORY OF DEFENDANT TAMIE L. MOORE Defendant files the following inventory of all property owned and possessed by the either party at time of the above captioned action and all property transferred within the past three years. Defendant incorporates by reference thereto,Plaintiff s Inventory and stipulated to it's accuracy to the extent that Defendant otherwise offers clarification herein. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements made herein are subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: C1 -A / Tamie L. Moore, Defe dart ti SECTION 1. BACKGROUND INFORMATION Defendant Stipulates to the accuracy of Plaintiff's Background information in Table 1-A which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with the following exceptions: I. Defendant's year of birth is 1957 2. Defendant is 55 years old 3. Since November 9 2012 Defendant lives at 3404 Timber Trail SE, Minot ND 58701. Defendant lives with her son, daughter-in-law and 2 grandchildren. 4. Although Defendant's health is generally good she suffers from high blood pressure. 5. Defendant has been employed by SHatz Truck Stop since the first week of July 2013 as a cashier. 4. Defendant's income is approximately $1,600 per month at present. Defendant Stipulates to the accuracy of Plaintiff's Background information in Table 1- B, I-C and 1-D which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with no exceptions: SECTION II. SUPPORT Defendant Stipulates to the accuracy of Plaintiff's Support information in Table 2-A and 2-13 1-B, I-C and 1-D which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with no exceptions: SECTION III. PLEADINGS Defendant Stipulates to the accuracy of Plaintiff's Pleading information in Table 3-A and 3-B, 3-C, 3-D and 3-E which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with the following exceptions: 1. Defendant has filed this inventory, her income statement and affidavit of consent and waiver. SECTION IV. MARITAL ASSETS AND DEBTS Defendant Stipulates to the accuracy of Plaintiff's information.in Table IV which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with the following exceptions and additions: 1. REAL PROPERTY: Defendant does not agree that the Marital Residence at 117 4"' Street,New Cumberland, PA was solely a gift to Husband and further denies the accuracy of the valuation. Defendant maintains that the property was gifted to the parties as Husband and Wife and that she provided valuable consideration in the amount of $8,000.00 from the sale of her personal residence which she purchased prior to the marriage. Defendant maintains that the total equity in the home is subject to equitable distribution. 2. VEHICLES: Defendant accepts the valuation of the vehicles; however, further acknowledges that the 1992 Geo Metro is no longer in her possession and was sold to her brother for $500.00 after it developed transmission problems that Defendant could not afford to repair. 3. RETIRMENT PLANS: Defendant has no retirement or pension plans. SECTION V. HOUSEHOLD GOODS AND PERSONAL PROPERTY Defendant Stipulates to the accuracy of Plaintiff's listing of household goods and marital property in Tables 5-A and 5B which is attached hereto collectively as part of Exhibit "A" and incorporated by reference with the following exceptions: 1. Defendant maintains the right to identify the marital or non marital nature of the parties assets at the time of trial as well as their present location if known., SECTION VI. NON-MARITAL ASSETS AND DEBTS INCOME AND EXPENSE Defendant maintains that the property at 117 4t" Street,New Cumberland, PA was acquired in furtherance of the marriage, was gifted to both parties regardless of the instrument of title, and further states that she gave good and valuable consideration towards the purchase of the hone in the form of$8,000.00 derived from the sale of her mobile home which was solely titled in her name. Defendant therefore denies that the property is non-marital and further asserts that the total equity value of the property is subject to distribution as marital property. Defendant believes this value to be approximately $73,000.00 less any liens acquired pre-separation. Defendant currently works for Schatz Crossroads as a cashier. Since approximately the second week of July when she started work, the Defendant has earned approximately $3,457.00 or the equivalent of approximately $1600.00 gross per month. Defendant pays rent to her son in the amount of$600.00 and buys her own food at a cost of$200.00 per month SECTION I. BACKGROUND INFORMATION The following Table #1 sets forth the background information relevant to this case: TABLE#1-A PAR7tE5,. pECRIPTtON: HUSF3AND WIFE Name John D. Moore Tamie L. Moore Address 1174 1h Street 20 Sam Snead Circle New Cumberland, PA 17070 Etters, PA 17329 Year of Birth 1971 1958 ? Age 41 54 ? Health Status Had prior work injury and unable to Good ? work 12/08-12111 Educational Background HS graduate; 5 yrs app NJATC HS Graduate Names and Relationship of Michael Moore, son Nephew, Bobby Persons Living with Party Date Moved to Home March 13, 2009 Unknown Date PA Residency Began Birth more than 6 months Current Military Service N/A N/A Employer Brenner Motors Flight Systems, Inc. Occupation (Job Position) Commercial Sales Unknown Date Employment Began August 2012 Unknown Income Average of$1,937.50 over 16 month Unknown period + commissions Other: unable to work 92/08-12/11 prior 2012 job made total of $800 +/- -5- TABLE' #1`-B >MARRME.:INPORMAT- 10N. Date of Marriage Place of Marriage Winchester, VA Husband's Number of Marriages 2 Wife's Number of Marriages 4 Date of Separation December 25, 2009 (Physical) Grounds for Divorce Non-Consent- No Fault -Section 3301(d) Prior Divorce Actions Between Parties None TABLE#:1 C CHILDREN OF,THIS MARRIAGE A1am� Ag Bich Year Schoo! Grady _: Custodian Emancipa#"ron None N/A N/A N/A NIA NIA TABI+E #1 d CHILDRE t OF OTHER RELATIONSHIPS/MARRLAGES Parent tamp of�Chcld Est Age Emanc.�paion Husband Michael Moore 21 Wife Louis Kane 28 Wife Tanya Kane 24 -6- SECTION II, SUPPORT The following Tables #2-A and #2-13 sets forth the support information relevant to this case: TABLE#2-A ::::_ SUPPURT FOR THlS MARRIAGE Name of Party Paying Support None Beneficiaries of Support N/A Amount of Support and Allocation NIA Date of Agreement or Order NIA Effective Date of Agreement or Order NIA Docket Number of Support Order NIA Comments Wife has filed a support action; Conference is scheduled for November 15, 2012 TABLE#2.B 5tlPPQRTIALIIIr p FQR PRIOR MARRIAGES/RELATIC)NSHIP Name of Party Paying Support NIA Beneficiaries of Support NIA Amount of Support and Allocation N/A Date of Agreement or Order N/A Effective Date of Agreement or Order NIA Docket Number of Support Order NIA Comments NIA -7- SECTION III. PLEADINGS The following Tables #3-A -#3-E sets forth information regarding the pleadings filed in this case. TAB.LE:, #3=A PLAiN7FF`S.DIVORCEPLEADINGS Date of Filing of Divorce Complaint March 8, 2010 Date of Service of Divorce Complaint March 11, 2010 Manner of Service of Divorce Complaint Certified Mail, Restricted Delivery Divorce Claims Raised in Divorce Complaint No Fault - Sections 3301(c) and (d) Economic Claims Raised in Divorce Complaint None TABLE#3-B DEFENDANT'$ DIVORCE PLEADINGS Description of Pleading Petition Supplementing Counteraffidavit to List Economic Claims Which Are Unresolved Date of Filing of Petition March 22, 2012 Divorce Claims Raised in Petition None Economic Claims Raised in Petition Equitable Distribution and Alimony TABLE .3-C '33Q1°(C). PLEADINGS Pramti€#`s�330 e =Plead�n s 9 Description of Pleading Pleading Date Filing Date Service Date Plaintiff's 3301(c) Affidavit N/A N/A N/A Plaintiffs 3301(c) Waiver of Notice N/A NIA N/A ' Defendant's--330T c Pleadings; _-: Description of Pleading Pleading Date Filing Date Service Date Defendant's 3301(c) Affidavit N/A NIA N/A Defendant's 3301(c) Waiver of Notice NIA N/A N/A -8- a TABLE#3-D. 330''f(D) PLEADINGS Date of Separation December 25, 2009 Pla�ntiiffs 330'1 d)-,Phm ings. Description of Pleading Date of Filing Date Service Date Pleading Plaintiffs 3301(d) Affidavit 12129/20/1 12/30/2011 01118/2012 Plaintiffs 3301(d) Notice of Intention Plaintiffs 3301(d) Counter-Affidavit N/A N/A NIA = Denant`s 330" (d) Pleadings Description of Pleading Pleading Date Filing Date Service Date Defendant's 3301(d) Affidavit NIA N/A NIA Defendant's 3301(d) Notice of Intention N/A N/A N/A Defendant's 3301(d) Counter-Affidavit Undated 01/25/2012 Not Served Comments: Defendant did not object to divorce. She only asked to raise economic claims TABLE #3=E . FtNAN IAL LE'AUiNGS [NCO�E AND EXPENSE S`t`A7EMEN7S= Plaintiffs I&E Statement Filing Date Concurrent Defendant's ME Statement Filing Date None Filed .,.INVENT4RIES Plaintiff's Inventory Filing Date This filing Defendant's Inventory Filing Date None filed -9- SECTION IV. MARITAL ASSETS AND DEBTS The following Table #4 sets forth a listing and information regarding the marital assets and debts. �Ja e Binder 0 Description Date of distribution Distribution Distribution Value Value to Husband to Wife ��._�_u�—:s'7�.. z-�-.'.'3�...,�.=-1�r_......._...._.Yk,.;_x=:a,�''-'=-a__s__•ww�+ ,;.._.. :rte-rYY u ' �:l," �[ -... -S'T0 0-. _�- w 0 , .a.r RE-1 H 117 41h Street, New Cumberland 12.25.09 HNM Gift HNM Gift RE-1 JT Evelyn Stetler Mfg DOA 3.49 12,000.00 12,000.00 RE-1 JT Evelyn Stetler Mig DOS 12.25.09 (9,818.77) (9,818.77) RE-1 ) Property inherited by H's father and aunt, On 3/09 the father and aunt transferred the property to Husband as a gift. The only thing they asked was for him to reimburse the Aunt for the $12,000 she borrowed on her line of credit to pay inheritance taxes, real estate taxes deed preparation etc. The agreement was that Husband would that credit line with 2.5% per annum in monthly installments of$300. At separation the balance was$9,400. >Husband submits that the real estate did not increase in value from 3.09 DOA and 12109 DOS . *the mortgage was paid down during marriage from the$12,000-$9,818.77 = 2,181.23 . �r �� � ' ' f FK _ ,_���-�� ►£I �t���A�y��ilf�l��tE :�.�:�x.�-=�._-=:_:�._�.-�;__.... _ _ .. V-1 H 1994 Ford Escort No Value No Value V-2 W 1992 Geo Metro No Value No Value � g _ *.�- � -_: Wit.,, tt.- -r_ -..:--rte- -- - - _ - _. r b 9 �..NT A-1 Member's 1 #7403 Checking 12.24.09 231.87 231.67 A-1 H Member's 1 S`#7403Savings 12.24.09 25.28 25.28 -10- - =-�� 4Da#'ed�Jiri $,2092 Binder 0 Description Date of Distribution Distribution Distribution Value Value to Husband to Wife A-2 W NCFCU#3089 Checking 12.24.09 5.00 5.00 A-2 W NCFCU#3089 Savings 12.24.09 143.66 143.66 A-3 H NCFCU # Savings 5.00 5.00 .._-____ _,gin -�=...w,,._.----•-r-�=.T---�:--•�.-��.��_ - .- r�-,: .. =:,;ALL-�= -_ - -=._.�=-:� _ z-- -- -_ _ HG-1 JT Household Goods and PP Est 10,000.00 2,000.00 8,000.00 HG-1 See Tables#5-A and#5-B for listing _ �S:•�3..��:r,+N..:'^-i+:.l^xi:4Y;.'.i.',:i�."i�'!�T�4:N.��,,�=,J�r��li-:f SL- '�.-'�,{Lys._�-_,�s:..:� ..r,�t.+g�w�,;ys�.]�'I;:i/�l'�T(`�+, t �.��c_;rx ",�Si�T.L',.�.JI, _T',r. . ��.r S-t„�:-'ia-, ��e.��-�,��-��� =+'1s„'��''r'a=',.:...�7.,�7�?-H�47Ti71��M`Il�}717i1x1�_f--Y'►I7�7��"�._�.c.,;-_�-_�=�.�' 7 �y-e-,-'- ._a .. ....- ;tR.sue-Sx.'`,.,.k«'.:-7_'--'�i' RET-1 H Local 143 Fund 12.31.09 15,324.88 15,324.88 RET-2 H Local 143 Pension TBD TBD TBD RET-2 Payable @ 748/mo at age 65 ASSE TOTALS Totals for Assets w/o Pension Value Included _ 27,916.72 19,768.06 8,148.66 �' �-,��''tea,..` �': -�--�� a` a ---arx:�r,.�<«•�.-:::.e.r�_-,:.�it-`���_���„�.-_�____._-^ ---,_� �` .. D-1 H Citi Financial# (13,364.00) (13,364.00) D-1 (Consolidation Loan) D-2 H H's Capital One# (1,200.00) (1,200.00) D-2 A—:08 Ddebt incurred by Wife) D-3 H H's Fashion One# (1,000.00) (1,000.00) D-3 *MOM"M �e� ta �fafem�� �ti� �a[ane�ovvfrzg�so��22509 DEBT T{3TALS Total of Debts (15,564.00) (15,564.00) 0.00 -11- t ,_.:c:i--a:::._.-iT.:. ,-.r ..._...._T. n -.s'...�... _�.-. _ �.._ .7�•� ,,,,,�,_'�..�a,�'C�.'?G°.:: _ .__.:Lana::r."-•::.-Y._.�..._ - 'Y�Y.r-�_ •___'=._:.:':.:c. .L.::r_.-..�-i:_r_�:L.C•y�z•=C�:���.^.S1'�C-� •t_�-r^"�'F�-�s-�.-_..0 �� �......_ _.mac._ _ _ _ __ _ _ :r--_..a ,..''...�.-.3- 3--i..�. .'.xF - _ --•G=-x-=-='^__r._....-:cE_-L.�_;-:�-'�•::C_.T.�=_'--atr.'='--�=�-E, .-;.:sf3?:*:_z__:_�;L_� a_.; �:_—`i._x��-�G. ._.r.-,-:=�.j�"'.�- =:-::�3'r-�.�.�'tu;.r"T�.T�,,t r'=•� ,� �'t-�-r�Y-�•,T=, _•�-�--�'-s.��ce:,jam.i_.-x--.=s..__::��_:.__;=�=;r�=�r='�-��_.�_, _ _�-�.��,r�`u-= -:��. =t�- .,��"'z - -�<Q 7]r:��,Q.O��.V.S-.��I�I�;:l1flU.or$r.�..•�'T�-� •x� - --_==.«�—_._ i r.--._�-...-x:--''2-_'..�,v::' .;a:��=_, y;��{��.,-•/!�!�� ry-�--� �+yiT y ryC�/ ._..c_c;:rtE:.r..:r.-c.�:?.__:-r._-:r__"......__",.:::..._>;Yi.:.E:__c _;._�.-=-;.._:.— _���:_r,�•—�--__:_�-•�- 3:Jt11;-7XY1�.'7�,w��IJ.��7.s�.�L.V1.��_--�_��.'=?=`'���=�5_s:t--`'.t ".='- y::c't-: :::._�---_� _.;�-_ �-_ Wes-- .. ___.�__.__-_�_ I: _ .8:�01'Z•� . -- -- -= - -- �����-. .�,.--.....:,-•�--'r'-_�.-s-..:..��_'_x•.•� ..•-�.-r�;_.:a._.--`'.�._��:.-=�:'S:p_��-_°,.c. � .r...._-:-.-,._...M....�...........::�..'�....... :_r..rc-{:: ^w':_:.=u.Ir::;-�.- A B C D E F G Binder 0 Description Date of Distribution Distribution Distribution _ Value Value to Husband to Wife ..._t 7L�i�=- i---' �- �- __--�^���•-. "'..�„��_'� .V L'-�=r:T_.�.:��-. :�-�::-rte-:. . ��" �3w- �----it"- i ..�`�S"i� �'�'��.c-r_.'-3.`�,='-L�.t.'a%--:.rte�L��T.t':.:v;.-�+:2".•ez'r:_s-..-��:'[s"_.._s=cr'F�. •�:,. _�=�'_=.�. ...._:_:_._ ____....-. Description Total Above H Above W Above Asset Total 27,916.72 19,768.06 8,148.66 Debt Total 15 564.00 15� ,564.00) 0.00 Net Estate Totals 12.352.72 4,204.06 8,148.66 -12- SECTION V. HOUSEHOLD GOODS AND PERSONAL PROPERTY The following Table #5-.A and Table #5-13 sets forth a listing of and information regarding the household goods and contents and other personal property in the possession of Husband and /or Wife unless otherwise noted that the prior division is not in dispute. FN#' TABLE#5-A HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM LIVING ROOM 1 50" Sony Bravia LCD TV H & W 2 TV Stand H &W 3 VCR/DVD Player H &W 4 Couch Pillows H & W 5 Home Interior Piece H &W 6 Dragon Collection H &W REMOVED FROM DINING ROOM 7 All DVDs H &W 8 Computer Software CDs H &W 9 Canon Digital Camera H &W 10 Elvis Collection H & W 11 Packet of Photo Paper H &W 1 FN#1 Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. The increase in value during the marriage of non-marital property is marital property, -13- TABLE#5-A HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM LAUNDRY ROOM 12 Dog (Toots) H &W 13 Dog Kennel H & W 14 Dog Food Container H & W 15 Dog Dishes H &W 16 Coleman Air Mattress H &W 17 Freezer Contents (20 lbs of H & W chicken; 20 lbs of hamburger; 6 lbs shrimp; 6-8 Ham steaks; bags of veggies; frozen pizza; waffles) REMOVED FROM KITCHEN 18 Freezer Contents H &W 19 Stove to Cutting Boards H & W 20 Spices and Pantry Contents H & W 21 Frying Pans H &W 21 Oven Dishes H &W 22 Tupperware H &W 23 All Cleaning Supplies H &W 24 Swifter Sweeper H &W 25 Steam Shark H & W 26 Blow Dryer H &W 27 Contents of Downstairs Vanity H &W -14- si TABLE #f5-A HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital REMOVED FROM UPSTAIRS 28 3 Comforters from Michael's Bed H Gift from H's Mother 29 Pillows from Michael's Bed H 30 Serving Platter H &W 31 Contents of Upstairs Vanity H &W Including Extra Shampoo, 3 Bottles Rubbing Alcohol; 3 Bottles Hydrogen [Peroxide; 3 Tubes Toothpaste; 'Box of Disposable Razors 32 Bassinette H &W H Purchased for GD 33 Baby Swing H & W H Purchased for GD 34 High Chair H &W H Purchased for GD 35 Cedar Chest H &W 36 All Towels and Wash Rags H &W 37 All Sheets and Pillow Cases H & W 38 Pellett Gun H &W 39 Sony Digital Camera H &W 40 Sony Boom Box H &W 41 Bathroom Rug H & W 42 All Clothing Baskets H &W 43 Taurus .357 5 shot CIA W 5.25.12 270 Hammerless -15- TABLE#5-B HOUSEHOLD GOODS AND OTHER PERSONAL'PROPERTY IN HUSBAND'S POSSESSION No. Description Owner Value Est. Basis for Exclusions Date Value If Non- Marital LIVING ROOM 1 X Box 360 H &W 2 2 end tables H & W 3 Coffee table H &W 4 2 lamps H &W 5 Couch and chair 6+ yrs old H &W DINING ROOM r en anee:or°:Gif N fro_rn HSGM v . [ �siG`N1 N NIA 11A Ir f eritan-wbt-'; 7 Ctnaan,_. :..ti_.._._.._...s from=H's':GM 8 China H &W 9 Computer 7+ yrs old H & W 10 HP Printer H &W 11 Computer Desk H &W LAUNDRY ROOM -Y NlA IVfI ln_tef ta ce 12 Hill or;Gift 13r' e r �r N M IP► NSA lriteritace zr Gift s,GN($ frolri 1 .�.s;:G 14 Vacuum Cleaner H &W 15 Shop Vac H & W 16 18 Qt Roaster H &W 17 2 Small Crock Pots H &W 18 Food Processor H & W -16- s TABLE#5-B HOUSEHOLD GOODS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION Description Owner Value Est. Basis for Exclusion No. Date Value If Non- Marital. 19 Misc Cleaning Supplies H &W 20 Misc Hand Tools H &W KITCHEN 21 Phone Stand H &W 22 lerigerafo FIsM_s; Pram;F i's.GI1ll 23 Microwave with Stand H &W 24 Dishes, Bowls and Cups H &W 25 Toaster H &W N1p; Gift from;'N's{�llather. 26 Tostere 27 Misc Pots H &W 28 Flatware H &W 29 Broom and Dust'Pan H &W MASTER BEDROOM 30 Bed H &W = H N1 #�11? Inher►tance aY Gift 31 Dresse acid Gl esf ofDraw .r firom N's GM o wl�lrn� �� NIf1 rift,#�Qi:m H's Mather 32 Sittig Chair BEDROOM #2 33 2 Gun Cases H 34 Biu _sIl1s N N1A N_/A lnhe��fartae or G.f# from..H s GM 35 C�3r�ssand�C .� hes���br�%�ersH NSA NlA Gtft�firom H's 1Vlother -17- • TABLE#5-B HOUSEHOLD GOODS AND OTHER PERSONAL. PROPERTY IN HUSBAND'S POSSESSION No. Description Owner Value Est. Basis for Exclusion Date Value If Non- Marital OUTSIDE 36 Gas Grill H & W'd 37 Table and Chairs H & I!'til 38 Hose H & W 39 Garden Tools H &W 40 Cooler H &W GUNS 41 Taurus 444 Raging Bull 44 mag H 5.25.12 320 Gift From Wife 42 Savage 93817 17 caliper rifle H 5.25.12 75 43 Remington 760 35 caliper rifle H 5.25.12 275 Purchased during marriage # Iarxdarla .f?all � caf psfoi I N./A-" tJIAitrvm H' Father 4$ H NIA NIA Gift,rh H's GF 6 e03�ealirnfl H NIA NIA Gift from FI$ GF .47 #i7losfC? ^ a i ;shafgtl H NIA AA Giftfr'om::H'sGF 8 tladmB:Ql I't N/A WA H`elgra' °s tio`Fi's°sdn 49 il� 16" 8 . . !?' fi NIA Belongs-to H's_brnttaec 0 c�ahesfe �rnrafi N N%A lsori � � - _ - - ! y 61 iC�aTT�P�� .�1 T� ugh H N7A .. to_-'H—.:8 `° NIA Se oil "s. Sfio�ur 5 ..emrngto T£,UD 4 a li°er-r�ff.e H !V'7A NIA Belortigs'%to'K*t brother -18- v e SECTION VI. NON-MARITAL ASSETS AND DEBTS The following Table#6 contains a listing of and information regarding the parties' non-marital assets and debts, FN#2,3 TABLE #6 NON'MAR"ITAL PROPERTY AND DEBTS Description Marital Non-Marital Total Value Basis for Method of Value Value Exclusion Valuation & Supporting Documents H's 1174a'Street, New Cumberland $2,183.23 $47,816.77 $50,000 - G Deed, to $70,000 PS Mortgage 67,816.77 Statements Various items of Personal TBD TBD TBD NM NIA Property specified in Tables G or INH or #5-A and#5-B owned b y 3`d party ABBREVIATIONS FOR TABLE #6 H = Husband W = Wife C = Children NM = Non Marital Property PM =Property Acquired Before Marriage PS = Property Acquired Post Separation G = Property Acquired by 3`d Party Gift INH = Property Acquired by Inheritance 2 FN#2 Exclusions from marital property include property acquired before marriage, property acquired after separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and inheritance also specify the source person. 3 FN Whe value of each item has been estimated unless otherwise noted. -�g_ JOHN D. MOORE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 10 - ±J793 CIVIL TAMIE L. MOORE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this _011-4 day of 2013, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on September 26, 2013, the date set for a Master' s hearing, the agreement and stipulation having been transcribed and signed by the parties, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent and waivers of the parties so that a final decree in divorce can be entered. BY THE COURT, 1 "'0' 1 F A4 Kevi Hess, P.J. CC: ✓Diane G. Radcliff. Attorney for Plaintiff ry . Lee E. Oesterling t✓) -r; Attorney for Defendant - n w JOHN D. MOORE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA �S`73 c-a 1-Z _' v s. NO. 10 --jqq-3�IVIL �W cn �-x-- r r°T F TAMIE L. MOORE, . to N ' Defendant IN DIVORCE ..,� �(D e Q-� f"? 3C - �C-� e' C --- t* THE MASTER: Today is Thursday, Sepeei' -per 26,ti _ 2013 . This is the date set for a Master' s hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, John D. Moore, and his counsel Diane G. Radcliff, and the Defendant, Tamie L. Moore, and her counsel Lee E. Oesterling. This Action was commenced by the filing of a complaint in divorce on March 8, 2010 raising grounds for divorce or irretrievable breakdown of the marriage. With respect to the grounds for divorce, counsel have given the Master affidavits of consent and waivers of notice of intention to request entry of divorce decree. Husband' s affidavit and waiver were signed on June 4, 2013 , and filed on June 7, 2013 . Wife' s affidavit and waiver were signed on September 26 , 2013, and filed the same date with the Prothonotary. No economic claims were raised in the complaint. However, on March 22 , 2012, wife filed a petition supplementing a counter-affidavit that was filed in 1 w response to the 3301 (d) affidavit raising claims of equitable distribution and alimony. No claims have been raised by either party for counsel fees and costs . After discussion this morning, the parties and counsel have reached an agreement with respect to the outstanding economic claims . The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be considered the substantive agreement of the parties not subject to any changes or modification except for correction of typographical errors, which may be made during the transcription. Consequently, upon the statement of the agreement on the record and when the parties leave the hearing room today, they are bound by the settlement even though there is no consequent signing of the agreement . However, the Master has been advised that counsel and the parties will return later this morning to review the agreement for typographical errors, make corrections, if any, and affix their signatures affirming the terms of settlement as stated on the record. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court. The parties were married on January 22, 1999, 2 R and separated on December 25, 2009 . There were no children born of this marriage. Ms . Radcliff . MS. RADCLIFF: 1. The parties agree that their marriage is irretrievably broken and they will conclude and secure the entry of a divorce decree under Section 3301 (c) of the Divorce Code . Within a reasonable time after the revocation of the Master' s appointment. Husband' s attorney will file all necessary documents to secure the entry of that divorce decree under Section 3301 (c) . 2 . The parties agree to a division of their marital assets in accordance with the proposed distribution schedule set forth on Joint Exhibit No. 1 which will include the following: a) The parties acknowledge that the real estate located at 117 4th Street, New Cumberland, Pennsylvania, was gifted to husband in March of 2009 and there has been no increase in value of that non-marital asset during the marriage. Wife waives, releases, and renounces any right, title, interest, and claims that she may have in that real estate and that real estate shall remain the non-marital property of husband. b) Husband shall receive the following marital assets : The 1994 Ford Escort; the Member' s 1st account, No. 7403; any household goods and personal property in his possession with the exception of wife ' s items that are in the shed located on the New Cumberland property; and husband' s Local 143 pension. Husband has also previously paid the Citi Financial, No. 0057 credit card account; the Capital One, No. 5270 credit card account; and the Fashion Bug, No. 5416 credit card account. His payment thereof has been taken into consideration in the agreed upon distribution and there shall be no further adjustment or monies owed by wife to husband as a result of these payments . 3 . Wife shall receive the following marital assets: Her NCFCU, No. 3089 bank account; any household goods and personal property in her possession; her personal items located in the shed at the New Cumberland property; and 100% of the value of husband' s Local 143 annuity. 3 r 4 . With respect to the household goods and property located in the shed at the New Cumberland property, the parties shall coordinate an agreeable time for wife ' s retrievable of those items, which is anticipated will occur on Sunday, September 29, 2013 . S . With respect to the Local 143 annuity fund, the transfer shall be made to wife by way of a tax free roll over of retirement benefits pursuant to a QDRO. The QDRO shall be prepared by wife ' s attorney, approved by the parties, and then submitted to the Court for entry. Husband shall provide wife with appropriate contact information regarding the plan administrator so that all plan requirements can be met with regard to the preparation of the QDRO. Wife ' s benefits under that plan may be paid to her in any manner or option as authorized by that plan, including, if authorized, a roll over of such benefits into another qualified plan or a withdrawal of the benefits from the plan. Any taxes associated with any withdrawals or roll overs, if any, shall be paid by wife. 6 . The parties waive any and all claims arising out of their marital relationship or as provided in the Divorce Code including but not limited to any claims for equitable distribution, spousal support, spousal maintenance, alimony, counsel fees and costs . 7 . Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow' s allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other' s estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MS. RADCLIFF: Mr. Moore, you are the Plaintiff in this case; is that correct? MR. MOORE: Yes, ma'am. 4 a r. MS. RADCLIFF: And you heard me state the terms and conditions of the agreement that was reached today with your spouse? MR. MOORE: Yes, ma' am. MS. RADCLIFF: Did you understand those terms? MR. MOORE: Yes, ma'am. MS. RADCLIFF: Do you agree that that represents your entire agreement that you have reached today with your spouse? MR. MOORE: Yes, ma'am. MS. RADCLIFF: Are you under the influence of any drugs or alcohol which would prevent you from reaching this agreement and entering into this agreement? MR. MOORE: No, ma'am. MS. RADCLIFF: And is this agreement being entered into by you on a voluntary and knowledgeable basis? MR. MOORE: Yes, ma'am. MR. OESTERLING: Mrs. Moore, you heard the recitation by attorney Radcliff in regard to the settlement proposal, do you agree that that settlement proposal represents the entire agreement between yourself and Mr. Moore, your spouse? MS. MOORE: Yes, sir, MR. OESTERLING: And do you knowingly and 5 voluntarily into that agreement? MS. MOORE: Yes, sir. MR. OESTERLING: And is there anything affecting your capacity to make that agreement? MS. MOORE: No, sir. MR. OESTERLING: You are not under the influence of any drugs or alcohol? MS. MOORE: No, sir. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: . Radcliff ohn Moore ey o laint ' ff Lee E. - es ng a Moore Attorney for Defendant 6 A ►� � EXHIBIT Page 1 John D. Moore vs. Tamie L. Moore DOM: 1/22/99 • DOS: 12/25/09 0. 1 PLAINTIFF'S MARITAL ESTATE ANALYSIS AND PROPOSED DISTRIBUTION SCHEDULE ASSETS 0 Description Date Value Net Value To Husband To Wife H 117 4" Street, New Cumberland DOS Value 12.25.09 HNM Gift J Evelyn Stetler Mtg DOA 3.09 12,000.00 J Evelyn Stetler Mtg DOS 12.25.09 L9,818,77) Marital Increase 12.25.09 2,181.23 2,181.23 2,181.23 H 1994 Ford Escort No Value No Value No Value W 1992 Geo Metro No Value No Value No Value H Members 1S'#7403 Checking 12.24.09 231.67 Savings 12.24.09 25.28 Total 12.24.09 256.95 256.95 256.95 W NCFCU #3089 Checking 12.24.09 5.00 Savings 12.24.09 143.66 Total 148.66 148.66 148.66 1 -4 tNrw'---' v\ J Household Goods and PP Est 1$,@898 46 99A-00 27@� 89690 H Local 143 Fund CO3VV\(,)J 12.31.09 15,324.88 15,324.88 15,324.88 cz:� H Local 143 Pension @ 748/mo at age 65 To H To H To H Totals for Assets w/o Pension Value Included .-4;438.10 DEBTS H Citi Financial#0057 10.18.10 (6,000.00) (6,000.00) (6,000.00) H Capital One#5270 Incurred by W 12.9.10 (650.00) (650.00) (650.00) H Fashion Bug#5416 7.21.10 (925.34) (925.34) (925.34) Total Debts (7,575.34) (7,_575.34) 0.00 Summary ,—Description Total bt�"A ove�. W Above Asset Total 11.72 4,438.18 23,473.54 Debt Total -�""`�� 7575. .34 0.00 Net Estate Tot 20.336.38 3137.16 4 3.54 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION � y Plaintiff File No. l n-- V "Sr) L)\ l vs. • IN DIVORCE CYlC,O Defendant • NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, (select one by marking"X"). Xprior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of CK ks-c__ I'�P ��� ;�t�[�rand gives this written notice avowing his/her intention pursuant to the provisions of 54 P.S. §704. Date: JO -3% ur- Signatur- of na :"•ei� : resu ed COMMONWEALTH OF PENNSYLVANIA COUNTY OF a."10eri/a.„A On the 3 d day of QG�v , 024(3 , before me, the Prothonotary or 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 my hand and official seal. (� 2 Xe40...AA- J . 0 ed Prothono ary o No Public C cg611 . Po29,63CL-C—. My Commi�ciat,:F.xplrot Uw FiNuninitiotitay of Jai.aDtC A CF THE PROTHONO IAR', 2013 OCT -14. AM 11: 23 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • JOHN D. MOORE, Plaintiff : NO. 10-1573 • v. : CIVIL ACTION - LAW • TAMIE L. MOORE, : DIVORCE Defendant PRAECIPE OF TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: 03/08/2010 b. Manner of Service of Complaint: 03/11/2010 c. Date of Service of Complaint: Certified Mail Restricted Delivery 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C)OF THE DIVORCE CODE: a. Plaintiff: 06/04/2013 b. Defendant: 09/26/2013 4. RELATED CLAIMS PENDING: No issues are pending. All issues have been resolved pursuant to the parties' Agreement entered into before the Divorce Master dated September 26, 2013. 5. DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: 06/07/2013 b. Defendant's Waiver: 09/26/2013 • n A 'ADCLIFF IRE 3— . eRoad Camp Hill, PA 17011 Supreme Court ID# 32112 Phone: (717) 737-0100 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JOHN D. MOORE • V. • TAMIE L. MOORE : NO. 10-1573 DIVORCE DECREE AND NOW, 4 1 Oc016142.4"-, 2417‘3 , it is ordered and decreed that JOHN D. MOORE plaintiff, and TAMIE L. MOORE , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") No issues are pending. All issues have been resolved pursuant to the parties' Agreement entered into before the Divorce Master dated September 26, 2013. By the Curt, Attest: Common Pleas J••ge Prothonota Cle c pert Oopq rna i heel io oirty Rack liff Niche+Copy Alai led lo cley- Ma1.161 /01105 • FILED -OFFICE OF THE PROTHONOTARY 2014 OCT 31 PH 2:35 CUMBERLAND COUNTY PENNSYLVANIA' IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA JOHN D. MOORE, Plaintiff v. TAMIE L. MOORE, Defendant : NO. 10-1573 : CIVIL ACTION - LAW : DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER Re: IBEW Local No. 143 Annuity Fund AND NOW, this24- .71 • day of 5.-,472014, upon consideration of the within consent and Stipulation of the parties, IT IS HEREBY ORDERED AND DECREED as follows: 1. Plan Name. The name of the Plan to which this Order applies is the IBEW Local No. 143 Annuity Fund, (hereinafter referred to as "the Fund"). Any changes in Plan Administrator, Plan Sponsor, or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order. 2. Identification of the Plan Administrator/Account Trustee. The name and address of the Fund Administrator/Account Trustee are: PATH Administrators 4785 Linglestown Road, Suite 200 P. 0. Box 6480 Harrisburg, PA 17112-1005 3. Parties, Divorce Action, Jurisdiction, Marriage and Divorce: The parties hereto were husband and wife, and a divorce action is in this Court at the above number. This Court has personal jurisdiction over the parties. The parties were married on January 22, 1999 and divorced on October 11, 2013. 4. Identification of Participant: The Plan Participant's name is John D. Moore. A -1- separate Addendum containing the Participant's address, Social Security Number and date of birth is being provided to the Plan Administrator. 5. Identification of Alternate Payee. The Alternate Payee's name is Tamie L. Moore. A separate Addendum containing the Alternate Payee's address, Social Security Number and date of birth is being provided to the Plan Administrator. It is the responsibility of the Alternate Payee to keep a current mailing address on file with the Plan at all times. 6. Effect of this Order as a Qualified Domestic Relations Order: This Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of the Participant's vested benefits payable under an employer-sponsored defined contribution plan under Section 401(a) of the Internal Revenue Code of 1986, as amended, (the "Code"). The parties and the Court intend this Order to be a Qualified Domestic Relations Order ("QDRO") pursuant to Section 206(d)(3) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA") and 414(p) of the Code. 7. Pursuant to State Domestic Relations Law. This Order is entered pursuant to the authority granted in the applicable domestic relations laws of the Commonwealth of Pennsylvania. 8. Provisions of Marital Property Rights. This Order relates to the provisions of marital property rights between the Participant and the Alternate Payee. 9. Amount of Alternate Payee's Benefit. This Order assigns to the Alternate Payee 100% of Participant's vested interest in the Fund as of September 26, 2013, together with any investment gains or losses attributable to the assigned amount from September 26, 2013, (or nearest valuation date thereto) to the date the awarded amount is distributed to the Alternate Payee. The remaining balance of the Participant's vested account, if any, shall be the sole and separate property of the Participant. The Alternate Payee's portion of the benefits described above shall be allocated on a pro rata basis from all of the accounts and/or investment options maintained under the Plan on behalf of the Participant. Such benefits shall also be segregated and separately maintained in a nonforfeitable account(s) established on behalf of the Alternate Payee. This account(s) will initially be established in the same fund mix percentages as the Participant account. -2- 10. Commencement Date and Form of Payment to Alternate Payee. Payments will commence to the Alternate Payee as soon as possible following the qualification of this Order and the Alternate Payee's completion of any distribution election forms. Benefits will be payable to the Alternate Payee in a lump sum. The Alternate Payee will be responsible for paying any applicable withdrawal charges imposed under any investment account(s) with respect to her share under the Plan. 11. Alternate Payee's Rights and Privileges. On and after the date that this Order is deemed to be a QDRO, but before the Alternate Payee receives a total distribution under the Plan, the Alternate Payee shall be entitled to designate a beneficiary for death benefit purposes, pursuant to the terms of the Plan. 12. Death of Alternate Payee. In the event of the Alternate Payee's death prior to receiving the full amount of benefits assigned under this Order the unpaid benefits under the terms of this Order shall be paid to the Alternate Payee's estate or any other beneficiary designation by the Alternate Payee on a form acceptable to the Plan Administrator. 13. Death of Participant. Should the Participant predecease the Alternate Payee, such Participant's death shall in no way affect the Alternate Payee's right to the portion of the benefits as stipulated herein. 14. Savings Clause. This Order is not intended, and shall not be construed in such a manner as to require the Plan: (A) to provide any type or form of benefit or any option not otherwise provided under the Plan; (B) to provide increased benefits to the Alternate Payee; (C) to pay any benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a QDRO; or (D) to make any payment or take any action which is inconsistent with any Federal or state law, rule, regulation or applicable judicial decision. 15. Certification of Necessary Information. 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 -3- may reasonably require from such parties. 16. Continued Qualified Status of Order. It is the intention of the parties that this QDRO continues to qualify as a QDRO under section 414(p) of the Code, 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. 17. Tax Treatment of Distributions Made Under this Order. For purposes of sections 402(a)(1) and 72 of the Code, or any successor Code section, the Alternate Payee shall be treated as the distributee of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate income taxes on such distribution. 18. Parties Responsible in Event of Error. In the event that the Plan inadvertently pays the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall immediately reimburse the Plan to the extent that the Participant has received such benefit payments by paying such amounts directly to the Plan within ten (10) days of receipt. In the event that the Plan inadvertently pays the Alternate Payee any benefits that are to remain the sole property of the Participant pursuant to the terms of this Order, the Alternate Payee shall immediately reimburse the Plan to the extent that the Alternate Payee has received such benefit payments by paying such amounts directly to the Plan within ten (10) days of receipt. 19. Effect of Changes to Plan. Any changes in Plan Administrator, Plan Sponsor, or name of the Plan shall not affect Alternate Payee's rights as stipulated under this Order. 20. Effect of Plan Termination. In the event of a Plan termination, the Alternate Payee shall be entitled to receive her portion of the Participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries. 21. Continued Jurisdiction. The Court retains jurisdiction over this matter to amend this Order to establish or maintain its status as a domestic relations order under Code, as amended and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as a necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein. -4- Judge Thomas A Piney The foregoing QDRO is consented and agreed to bComm0f Pleas )edge Distribution of this QDRO to: Attorney for Participant: lane G. Radcliff Esquire 3448 Trindle Road Camp Hill, PA 17011 Attorney for Alternate Payee: None {QS /�`tiucl topoy ALTERNATE PAYEE: TAMIE L. MOORE Date: l� -/ - 2ci'l Participant: John D. Moore 117 4T" Street New Cumberland, PA 17070 Alternate Payee: L. ----ramie L. Moore 3404 Timber Trail SE Minot, ND 58701 -5-