HomeMy WebLinkAbout10-1763FILED-{;F; !C;E
l)F ? is PrT ?GNQTARY
Paul J. Esposito, Esquire 2019 MAR I I PM 3: 2 It
I.D. #25454
GOLDBERG KATZMAN, P.C. Cu Imr _ ."'UNTY
320 Market Street V 1 1
P. O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161; (717) 234-6808 (facsimile)
Counsel for Plaintiff
JULIA WADDINGTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. In - 17(y3 Civil Term
THOMAS WADDINGTON, CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE TO DEFEND
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 with twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the claims set forth against you.
You are warned that if you fail to do so, the case may proceed without you and a judgment may
also be entered against you by the Court without further notice for any money claimed in the
Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 Court Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166 0,70.50 PA Airl
M V 91739
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Paul J. Esposito,, Esguir;
I.D. /!25454'
GOLDBERG KATZMAN, P.C.
320 Market Street
P O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161; (717) 234-6808 (facsimile)
Counsel for Plaintiff
JULIA WADDINGTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. w " 116 3 Civil Term
THOMAS WADDINGTON. CTVIT. ACTION .- LAW
_ Defendant _ IN DIVORCE
WAIVER OF COUNSELING
JULIA WADDINGTON, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require my spouse and I to participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Office of
the Prothonotary, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I verify that the statements made in this l»aiver are tme and co_Tect. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
PADDINGTON
Paul J. Esposito, Esquire
I.D. #25454
GOLDBERG KATZMAN, P.C.
320 Market Street
P. O. Box 1268
Harrisburg, PA 17108-1268
(717) 234.4161; (717) 234-4161 (facsimile)
_ Counsel for Plaintiff
JULIA WADDINGTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 763 Civil Term
THOMAS WADDINGTON, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
Plaintiff, JULIA WADDINGTON, is an adult individual, who currently resides at
1540 McCormick Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant, THOMAS WADDINGTON, is an adult individual, who currently
resides at 2904 Chesterbrook Court, Apartment 406, Camp Hill, Cumberland County,
Pennsylvania 17011.
Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
a period of at least six (6) months immediately preceding the filing of this Complaint.
4. The parties were married on September 30, 1989, in Paxtang, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military service of the United States or its
allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
6. There have been no prior actions of divorce or annulment filed by either of the
parties hereto.
7. Plaintiff has been advised of the availability of counseling and that Plaintiff has
the right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the court to enter a decree of divorce.
COUNTI
9. The averments of Paragraphs 1 through 8 herein are hereby incorporated by
reference thereto.
10. The marriage is irretrievably broken.
COUNT II
11. The averments of Paragraphs 1 through 10 herein are hereby incorporated by
reference thereto.
12. Plaintiff and Defendant have acquired property, during their marriage until the
date of their separation, which property is marital.
13. Plaintiff requests this Court to preserve her right to have all marital property of
the parties equitably distributed.
COUNT III
14. The averments of paragraphs 1 through 13 herein are hereby incorporated by
reference thereto.
15. Plaintiff lacks sufficient property to provide for her reasonable means and is
unable to adequately support herself through appropriate employment.
16. Plaintiff requires reasonable support to adequately maintain herself.
17. Plaintiff requests this Court to preserve her right to seek an award of reasonable
temporary alimony and additional sums as may become necessary from time to time hereafter
until final hearing and permanent alimony thereafter.
2
COUNT IV
18. The averments of paragraphs 1 through 17 herein are hereby incorporated by
reference thereto.
19. Plaintiff has employed the firm of Goldberg Katzman, P.C., as counsel but is
unable to pay the necessary and reasonable attorney's fees for said counsel.
20. Plaintiff requests the Court to allow her reasonable counsel fees, costs and
expenses.
WHEREFORE, Plaintiff prays Your Honorable Court to:
a. Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of
matrimony heretofore existing between Plaintiff and Defendant; and
b. Order equitable distribution of marital property; and
c. Order payment of alimony as the Court deems just and reasonable; and
d. Order payment of alimony pendente lite, counsel fees, costs and other
expenses as the Court deems just and reasonable; and
e. Order such other relief as the Court deems just and reasonable.
Date:
GOLDBERG MAN, P C.
Paul J. E osit , Esquire
Attorney I.D. #25454
320 Market Street
P.O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
(717) 234-6808 (facsimile)
Attorney for Plaintiff
3
VERIFICATION
I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are
true and correct to the best of my knowledge, information and belief. I understand that false
statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
Date: ?ol
'
A WADDING ON
r.
JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-1763 f = -'
THOMAS WADDINGTON Diu,
: CIVIL ACTION - LAW CD
,
Defendant : IN DIVORCE `
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ORDER APPOINTING MASTER
// , 2012, E. Robert Elicker, III, Esquire is appointed
AND NOW, Stb
Master with respect to the following claims: divorce, equitable distribution, alimony, alimony
pendente lite, counsel fees, costs and expenses.
By the Court:
Distribution:
Samuel L. Andes, Esquire, P.O. Box 168, Lemoyne, PA 17043
(717) 761-5361 (phone); (717) 761-1435 (fax); lawandes(a aol.com (e-mail); Attorney for Plaintiff C? John J. Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033, i0'll 1??
(717) 533-3280 (phone); (717) 533-7771 (fax); iic(a)isdc.com (e-mail); Attorney for Defendant
E. Robert Elicker, III, Esquire, Cumberland County Divorce Master, 9 North Hanover Street, -+n bin
Carlisle, PA 17013; (717) 240-6535 (phone); (717) 240-7890 (fax)
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1I1.[E WADDINGTON,
Plaintiff
vs.
THOMAS WADDINGTON,
Defendant
IN THE COURT` OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2010-1763
IN DIVORCE
PRAECIPE
"I`t~ ~a,HE PROTHONOTARY:
Please enter my appearance for the Plaintiff Julie Waddington in the above captioned
mattar.
~,~~
t 7 ~_)ctober 2012 r~Q
Samuel I,. Andes
Attorney for
Supreme Court ID # 17225
525 North 12t'' Street
P.O. BOX 168
Lemoyne, PA 17043
(717) 761-5361
_ 0 F!
John J.Connelly,Jr.,Esquire ;
Attorney I.D.No. 15615
James Smith Dietterick&Connelly,LLP 2 0 f 3 A M'' 12
P.O.Box 650
Hershey,PA 17033 vU �Q�RL; FO CC ufrt i'i'
Attorneys for Defendant PENNSYLVANIA
JULIA WADDINGTON, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 10-1763
THOMAS WADDINGTON CIVIL ACTION-LAW
Defendant IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Date of Marriage: September 30, 1989
Date of Separation: November 14,2009
Divorce Complaint filing date: March 11,2010
1. ASSETS
A. Marital Property
See attached spreadsheet marked Exhibit"A".
B. Non-marital Property of Husband
(1) Husband's Merrill Lynch Personal Checking and Investments(3)Accounts—
inherited funds.
(2) Husband's Interest in Merrill Lynch Trust Accounts with his brother and
sister—inherited funds.
(3) 529 Accounts with Merrill Lynch—established for each of the parties'minor
children.
(4) Husband's current residence located at 31 Indiana Circle, Lemoyne,
Pennsylvania—acquired post-separation.
C. Non-marital Property of Wife
To be provided by Wife.
2. EXPERT WITNESSES
Husband knows of no expert witnesses at this time. However,Husband reserves the
right to supplement this answer should such become available and necessary.
Specifically,Husband may call upon Jonathan D.Cramer,F.S.A.,of Conrad Siegel
Actuaries for purposes of testifying regarding the marital portion of Husband's
pension through his employer,Gannett Fleming,Inc. Husband may also call upon
David M. Eskin,PA State Certified Residential Real Estate Appraiser regarding the
value of marital residence located at 1540 McCormick Drive,Mechanicsburg,
Pennsylvania 17055.
3. NON-EXPERT WITNESSES
Husband knows of no non-expert witnesses at this time with the exception of the
parties.However,Husband reserves the right to supplement this answer should such
become available and necessary.
4. EXHIBITS
Specific exhibits to be exchanged prior to trial to the extent necessary after
stipulation. Notwithstanding same,Husband intends to offer the following as
exhibits,if necessary:
(1) All documentation to support the values identified in the asset chart attached
hereto as Exhibit"A".
(2) Husband's 2012 Tax Return(to be provided at Pre-trial Conference).
(3) Husband's 2012. W-2 form(attached).
(4) Husband's most recent paystub (attached).
(5) Husband's Income Statement and Expense Statement, filed October 9,2012.
(6) Pension Valuation Report of Jonathan D. Cramer,F.S.A.,of Conrad Siegel
Actuaries dated December 6,2010(attached).
(7) Appraisal Report of the marital residence located at 1540 McCormick Drive,
Mechanicsburg,Pennsylvania 17055 dated March 30,2011,by David M.
Eskin,PA State Certified Residential Real Estate Appraiser(attached).
5. INCOME
A. Plaintiff/Wife—Wife is employed at Laboratory,Analytical and Biologic.
As reflected on Wife's 2012 W-2 form,Wife earned a gross annual income
of$42,949.82. Wife receives spousal support in the monthly amount of
$839.00 pursuant to the Support Order of February 11,2013.
B. Defendant(Husband—Husband is employed as a consulting geologist for
Gannett Fleming,Inc. As reflected on Husband's 2012 W-2 form,Husband
earned a gross annual income of$107,482.33. Husband's most recent
paystub reflects a bi-weekly gross salary of$4,048.00. After all deductions,
including$615.69 bi-weekly for child support and$387.23 bi-weekly for
spousal support,Husband's bi-weekly net pay is$1,390.22. Husband also
receives dividends and interest income from his Merrill Lynch Trust
Accounts,which appear on his 2012 tax return.
6. EXPENSES
Plaintiff/Wife has filed a claim for alimony,alimony pendente lite,counsel fees and
expenses. Wife's Income Statement and Expense Statement have not been filed
with the Court.
7. PENSIONS/RETIREMENT BENEFITS
i
A. Plaintitl7Wife.
(1) Wife maintains a Janus IRA,which had a value of$14,192.87 as of
November 2011,which must be updated.
B. dant/Husband:
(1) Husband maintains a pension dmugh his employer,Gannett
Fleming,Inc.,which was frozen under the plan as of December 31,
2005(no benefits were earned after that date). According to the
pension valuation report by Jonathan D. Cramer, F.S.A.,of Conrad
Siegel Actuaries,the marital portion of Husband's pension is
$65,090.00.
(2) Husband maintains a 401(k)Plan through his employer,Gannett
Fleming,Inc.,which had a value of$213,275.00 as of November 30,
2009(date of separation value). Currently,the account has a value of
$384,128.84 as of March 31,2013,which includes post-separation
contributions and increase in value on the marital portion.
8. COUNSEL FEES
Wife has made a claim for counsel fees and expenses.
9. PERSONAL PROPERTY DISPUTE
Husband believes that the parties can divide all personal property by agreement,
having already divided some of the personal property when Husband secured his
current residence. Some of the personal property remaining in the marital residence
needs to be addressed..
10. DEBTS
(1) At the time of separation in November 2009,the mortgage encumbering the
marital residence had a balance of$62,400.00. Since separation,Husband
has paid all mortgage payments, and there is no longer a mortgage
encumbering the property.
(2) At the time of separation in November 2009,there was an outstanding VISA
credit card balance of$3,125.00,which Husband paid in full post-separation.
(3) Husband paid the sum of$5,750 after separation from his separate funds for
improvements on the marital residence in order to place the property in a
saleable condition. -
11. PROPOSED RESOLUTION
Husband proposes a 50/50%distribution of marital assets,with$600 per month in alimony
payable to Wife until the parties'youngest child graduates from high school(approximately
four(4)years).
12. ESTIMATED LENGTH OF TRIAL
One day.
Respectfully submitted,
JAMES,SMITH,DIETTERICK
&CONNELLY,LLP
Dated: April 11,2013 By:
J hn o lly,Jr.
#15615
P.O. Box 650
Hershey,PA 17033-0650
(717) 533-3280
Attorneys for Defendant
EXHIBIT "A"
Exhibit"A"
Julia Waddington v.Thomas V.Waddington
Date of Marriage: September 30, 1989
Date of Separation: November 14,2009
Divorce Complaint Filing Date: March 11,2010
ASSET TITLE VALUE
$425,000.00(per appraisal dated March 30,2011)Husband and
Wife acquired from Husband's parents the marital residence for a
purchase price of$300,000.00 in November of 2004. For the initial
purchase,the parents gifted$30,000.00 which represented the
downpayment on the purchase. Husband's parents took back a
Note in the amount of$270,000.00. Both parents died in 2007
within two months of each other, and Husband and his two siblings
inherited the right to receive the balance on the Note. One-third of
the balance of the Note was forgiven as Husband's share of the
inheritance,and two-thirds of the Note was paid to Husband's
brother and sister for their share of the Note. Therefore, Husband
1540 McCormick Drive, made significant contributions to the acquisition of this residence
.Mechanicsburg, Pennsylvania Joint which is now valued as set forth above.
2008 Lexus 3r150 n
Husband KBB Trade-in Value:$27,875.00(November 2009)
2006 Nissan Murano Wife K B B Trade-in Value: $15,960.00(November 2009).
Janus Account#3710 and The Janus and American Century Investments were divided
American Century Investments between the parties with Wife receiving$19,170.97 and Husband
Account Joint receiving$12,119.20.
119.20.
Northwestern Mutual Policy
#6531 Husband Cash Value:$2,641.93(as of November 9, 2010)
Wife's Insurance Policy Wife Cash Value:$4,663.53(as of March 2011)
Pagel Exhibit A-Asset Chart 041113.xis
Julia Waddington v.Thomas V.Waddington
Date of Marriage: September 30, 1989
Date of Separation: November 14,2009
Divorce Complaint Filing Date: March 11,2010
ASSET TITLE VALUE
Gannett Fleming, Inc. Pension _ Husband $65,090.00(marital portion per valuation report)
Gannett Fleming, Inc.401(k) $213,275.00(as of November 30, 2009)(current value$384,128.84
Plan Husband as of March 31, 2013)(includes post-separation contributions)
Wife $14,192.87(as of November 2011)(to be updated)
Janus IRA WOMEN"
$62,400.00(as of November 2009)(paid in full by Husband post-
Mortgage on marital residence Joint separation)
$3,125.00(as of November 2009)(paid in full by Husband post-
VISA Credit Card Joint separation)
Husband's Merrill Lynch
Personal Checking and
Investments(3)Accounts
(inherited funds) Husband
Husband's Interest in Merrill
Lynch Trust Accounts with his
brother and sister(inherited
funds) Husband
529 Accounts with Merrill Lynch
for the parties'children Husband
Husband's current residence
located at 31 Indiana Circle,
Lemoyne, Pennsylvania
(acquired post-separation) Husband
Page 2 Exhibit A-Asset Chart 041113.xis
Exhibit No. 3
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W-2 AND WAGE SUMMARY ®CERIDIAN
Exhibit No. 4
Pav c°"'- Page 1 of 1
CHECK NO: A430158
GANNETT FLEMING,INC. CHECK DATE: 4/12/2013
207 SENATE AVENUE
HILL,PA 17011 PERIOD ENDING: 41512013
CAMP
(717}763-7211 PAY FREQUENCY: BI-WEEKLY
PAY PERIOD: 03/23/2013-04/05/2013
WADDINGTON,THOMAS V ID NUMBER:04EO506691 STATUS EXEMPT TAX ADJUSTMENTS: STATE AND LOCAL CODES
31 INDIANA CIRCLE BASE RATE:50.6000 FED:SINGLE 1 FED: ST1: PRI: PA LOCI:GG LOC3:
LEMOYNE,PA 17043 SSN: STI: 0 DI/UC: 0 SEC: LOC2: LOCO:
ST2: LOCAL:%1.45 ST2: 0 L005:ZM
IMPORTANT MESSAGE
HOURS AND EARNINGS TAXES AND DEDUCTIONS SPECIAL INFORMATION
CURRENT Y-T-D CURRENT Y-T-D
DESCRIPTION RATE HOURS/UNITS EARNINGS HOURS/UNITS EARNINGS DESCRIPTION AMOUNT AMOUNT
REGULAR 50.6000 80.00 4,046.00 547.00 27,600.20 SO SEC TAX 236.89 1,904.36 PTO BALANCE 96.84
HOLIDAY .00 A0 16.00 797.60 MEDICARE 55.41 445.38 PTO EARNED 7.69
PTO .00 .00 77.00 3,866.20 TAX
FED INC TAX 667.81 3,814.08 GROIP LIFE 5.31
TOTAL HIE 80.00 4,048.00 640.00 32,264.00 PRI-STATE 117.14 941.66
TA
PRI-LOCAL 55.33 444.77
TAX
5-LOCAL TAX 2.00 16.00
SDIIUC TAX 2.83 22.56
TOTAL TAXES 1,137.41 7,588.81
PRE-TAX ITEMS AFTER-TAX ITEMS CURRENT NET PAY
DENTAL INS WW -20.82 -113.01 ACCIDENT DISTRIBUTION
MEDICAL INS W1H -210.49 -1,468.68
INSURANCE 1.65 11.55 )OOOCXXXXXXXXX07281,390.22
VISION INSURANCE -1.13 .9,23 CHILD SUPPORT 1 615.69 1,847.07 CHECKAMOUNT .00
401K PRE TAX W/H -283.36 -3,466.88 SUPPORT 387.23 1,161.69
TOTAL PRE-TAX -515.80 -5,057.80
TOTAL 80.00 3,532.20 640.00 27,206.20 1 TOTAL PER DED 1,004.57 3,020.31
GROSS PRE-TAX FIT TAXABLE LESS TAXES LESS REDS EQ NET PAY
CURRENT 4,048.00 -515.80 3,532.20 1,137.41 1,004.57 1,390.22 TOTAL CURRENT NET
Y-T-D 32,264.00 -5,057.80 27,206.20 7,588.81 3,020.31 16,597.08 PAY 1,390.22
88 2012 Ceddian Corporation.All rights reserved.
https://sourceselfservice2.ceridian.corn/en-us/empowerment.asp?FonnlD=FrmPayStabOut... 4/11/2013
Exhibit No. 6
` Coma Siegel 501 Corporate Circle•P.O.Box 5964= Harrisburg,PA 17110-0900
Conrad A C T U A R I E S Phone(717)652-5633
U
Fax(717)540.9106
The Employee Benefits Company www.conradslegel.com
Conrad M.Siegel,F.S.A.
Harry M.Leister,Jr.,F.S.A. December 6,2010
Clyde E.Gingrich,F.S.A.
Robert J.Dolan,A.S.A.
John J. Connelly,Jr.,Esq.
David F.Stifling,as A James Smith Dietterick&Connelly LLP
Robert J.Mrazik,F.S.A. P.O. Box 650
Hershey,PA 17033
David H.Killick,F.S.A.
Jeffrey S.Myers,F.S.A. Re: Thomas V.Waddington
Thomas L Zimmerman,F.S.A. Dear Mr.Connelly:
Glenn A.Hafer,F.S.A.
You requested that I prepare a pension valuation report regarding the defined benefit
Kevin A Erb,RSA pension earned by Thomas V.Waddington,through his employer,Gannett Fleming,
Frank S.Rhodes,F.S.A.,A.C.A.s. Inc. The purpose of this report is to provide an assessment of the value of the pension
Holly a Ross,F.s.A, for purposes of inclusion in the marital estate. This report is based upon the
following information provided to me:
Janes M.Leymeister,CEBS
1. Mr.Waddington was born on January 26, 1960. He is currently age 51 on an
Mark,k Bornsaii,F.S.A. 1.
nearest basis.
John W.Jeffrey,F.S.A.
Denise M.Pdin,F.S.A. 2. Mr.Waddington was hired by Gannett Fleming,Inc.on April 18, 1983.
Thomas W.Reese,A.S.A. 3. The parties were married on September 30, 1989,and they separated on
Jonathan D.Cramer,F.S.A. November 15,2009.
John D.Vargo,F.S.A. 4. Information concerning his benefits earned under the Gannett Fleming,Inc.
Robert M.Me,F.S.A.
Pension Plan as follows:
Bruce A.Senff,CEBS,CFP a. Mr.Waddington's benefits were frozen under the plan as of December 31,
Laura Y.Hess,F.Q.A. 2005. This means no benefits were being earned after that date.
Vicki L Deliigo b. Mr.Waddington is entitled to a single life annuity payable at a normal
J.Scott age of 65 in the amount of$1,117 per month. This pension
ett German,CEBS benefit was based on 21 years of credited service.
William J.Shipley,F.S.A.
The Gannett Fleming,Inc. Pension Plan is a defined benefit pension plan. The figure
Joshua R.Mayhue,A.S.A. which 1S marital r0
p perty for divorce purposes is the present value of the pension
Charles A Ebedin,E.A. earned during the marriage. A coverture fraction is applied to the total present value
Abigail S.Fortino,A.S.A. to exclude the effects of premarital service on the present value.
Jonathan A.Sapochak,A.S.A. The coverture fraction has a numerator of 16.25 years,which is the years of service
from the date of marriage until December 31,2005. The denominator of the coverture
Andrew S.Greenawalt,A.S.A. from
is 21.00 years,which is the total years of credited service as of December 31,
Trevor S.Bare,A.S.A. 2005. Hence,the coverture fraction is 0.774(16.25 divided by 21.00).
Conrad Siegel
A C T U A R I E S
John J. Connelly,Jr.,Esq.
December 6, 2010
Page 2
The following table displays the pension benefit being valued,the present value thereof,the
coverture fraction and the marital portion of the present value:
Retirement Monthly Present Value Coverture Marital Portion
Age Pension of Pension Fraction of Present Value
65 $1,117 $84,096 0.774 $65,090
This valuation does not take into account any early retirement subsidies which may be payable for a
benefit commencement age prior to 65.
The present value has been calculated based upon the annuity valuation assumptions published by
the Pension Benefit Guaranty Corporation in the fourth quarter of 2010. The interest rate is 4.48%
for the first 25 years and 4.51%per year thereafter. The mortality rates are in accordance with the
sex-distinct 1994 Group Annuity Basic Mortality table with mortality improvement projected until
2020 using Scale AA.
In my opinion,the assumptions set forth by the Pension Benefit Guaranty Corporation are
appropriate for purposes of determining the present value. I am a member of the American
Academy of Actuaries, a Fellow of the Society of Actuaries,and an Enrolled Actuary under the Joint
Board for the Enrollment of Actuaries, and I have satisfied the Qualification Standards necessary to
render the actuarial opinion contained herein.
If you have any questions regarding this report,please contact me.
With best regards,
Yours sincerely,
Jonathan D. Cramer,F.S.A.
Consulting Actuary
JDC:kad
Exhibit No. 7
APPRAISAL OF
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LOCATED AT:
1540 Mccormick Drive
Mechanicsburg, PA 17055
CLIENT:
James, Smith, Dietterick&Connelly
134 Sipe Avenue
Hummelstown, PA 17036
AS OF:
March 30, 2011
BY: i
David Eskin, PA State Certified Residential Real Estate Appraiser
'r
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James, Smith, Dietterick&Connelly
134 Sipe Avenue
"! Hummelstown, PA 17036
File Number: s11-0428
In accordance with your request, I have appraised the real property at:
1540 Mccormick Drive
Mechanicsburg, PA 17055
The purpose of this appraisal is to develop an opinion of the defined value of the subject property,as improved.
The property rights appraised are the fee simple interest in the site and improvements.
In my opinion, the defined value of the property as of March 30,2011 is:
$425,000
Four Hundred Twenty-Five Thousand Dollars
The attached report contains the description, analysis and supportive data-for the conclusions,
final opinion of value, descriptive photographs, assignment conditions and appropriate certifications.
David Eskin, PA State Certified Residential Real Estat(
i
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I
Property Address 1540 Mccormick Drive City Mechanicsburg State PA Zip 17055
Owner of PGblic Record Thomas V and Julia A.Waddington County Cumberland
Legal Description Deed Book 266 Page 1791
Assessor's Parcel# 13-31-2136082 Tax Year 2010 R.E.Taxes S 6,209.70
Neighborhood Name Lower Allen Township Map Reference ADC's 30-C4 Census Tract 3240-111
Property Ri hts Appraised [XI Fee Simple Ll Leasehold D Other describe
M research X did LJ did not reveal any prior sales or transfers of the subject property for the three years prior to the effective date of this appraisal.
Prior Sale/Transfer: Date N/A Price N/A Sources N/A
Analysis of prior sale or transfer history of the subject property(and comparable sales,if applicable) The subject has not tranfered in the past 36 months. All
com arables had not tranfered in the past 12 months except as noted as recent sales data. Comparable#1 did transfer on 6/12/2008
for$1.00, being a family transfer.
Offerings,options and contracts as of the effective date of the appraisal The subject has not been offered for sale in the past 12 months.The subject is not
under contract as of the date of this report.
Neighborhood Characteristics One-UnitHousingTrends One-unit Housing Present Land Use%
Location Urban X Suburban Rural Pro ert Values Increasinq Stable D.clininq PRICE AGE One-Unit 67 %
Built-U Over 75% X 25-75% Under 25% Demand/Supply Shortage X In Balance Over Supply $(000) s 2-4 Unit %
Growth I Ra id 1XIStable I 1clow Marketi Time Under 3 mths X 3 6 mths Over 6mths 100 Low New Multi-Family %
Neighborhood Boundaries See Attached Addendum 500+ H"In 100+ Commercial 3%
180+ Pred. 35+1 Other Vacant 30%
Neighborhood Description The subject is located in a residential area among properties of similar style and market appeal. Homes in the area
are maintained and occupied.All conveniences are easily accessible to the subject. No adverse factors were noted.The subject is
located 3 and 2/3 miles from US-15 for easy access to employment opportunities in the City of Harrisburg,the State Capitol, 7 miles
from the subject. Local shopping is available in Camp Hill 5 miles from the subject.
Market Conditions(including support for the above conclusions) See Attached Addendum
Dimensions See Deed Descri tion Attached Area 1.2 acres Shape Appx. Rectangular view Creek View/Good
Specific Zoning Classification R1 Zoning Description Single Family Established Residential
Zonin Com liance Le al Legal Nonconforming Grandfathered Use No Zonin III I describe
Is the highest and best use of the subject property as improved(or as proposed per plans and specifications)the present use? X Yes No If No,describe.
Utilities Public Other describe Public her(describe) Off-site Improvements—Type Public Private
Electrici X LJ 200&125&100 Water Well Street Asphalt X
Gas LJ . LXJ Propane Available Sanitary sewer X U Alley None
Site Comments The subject has a very desirable site being local along a creek known as the Yellow Breeches. Part of the subject site is
located in FEMA Flood Zone A but improvements appear to be located in the FEMA Zone C. No adverse site factors noted. The subject
has two fuel oil tanks in the basement with no si ns of leaking.
GENERAL DESCRIPTION FOUNDATION EXTERIOR DESCRIPTION materials" INTERIOR materials
Units X One Onew/Acc.un Elconcretesiab X Crawl S ace Foundation Walls Block/Average Floors HD&C t&Vin/Av
#of Stories 1 LJ Full Basement LXJ Partial Basement Exterior Walls Brick&Frame/Ave Walls D all/Ave
T e X Det. Att. S-Det./End Unit Basement Area 3069 sq.ft. Roof Surface Composition/Ave Trim/Finish Painted/Ave
X Existi Pro sed .J Under Const. Basement Finish 30% Gutters&Downspouts Yes/Ave Bath Floor Ceramic&Vin/Av
Desi n(Style) Ranch Outside Ent /Exit X sump Pump window Type Casement/Ave Bath Wainscot Ceramic/Ave
Year Built 1970 Storm Sash/Insulated Thermo anes/Ave Car Stora a None
Effective A e Yrs 15 Screens Yes/Avera-qe &Driveway #of Cars 10+
Attic None Heatinq NJ FWA IFJ HW I U Radiant Amenities WoodStove s # Driveway Surface Asphalt
Drop Stair Stairs Other I Fuel Gas X Fire laces #2 W Fence X Gara e #of Cars 2
Floor LXJ Scuttle Cooling X Central Air Conditionin I[X]Patio/Deck X Porch LJcarport #of Cars
Finished Heated Individual Other X Pool 18 x 44 X Other Att. Det. Built-in
Appliances X Refri erator LXJ Ra e/Oven X Dishwasher lyinisposai X Microwave Washer/D er LJ Other describe
Finished area above grade contains: 9 Rooms 4 Bedrooms 3 Baths 3,494-Square Feet of Gross Living Area Above Grade
.Additional Features 2 AC units, ceramic foyer, 1 modern bath, hardwood in bedroom partly updated kitchen with Corian counter tops and
ceramics lash backs and school decks, security system,central vac., partl finished basement with rec. room, 18 x 44 in round pool
,and 10 x 12 pool shed.
Camments on the Improvements The subject is in overall average condition on both the interior and exterior.The subject has a standard floor
Ian and amenities. No evidence of functional or economic obsolescence was observed.The subject is an older home but most)
�..-.:�1..:�..J [��...... �:.-..-J�C....i:.... .-�:�L�....L.............-.. �..t.:J :.-�I..J:..... ...J-��-...:..J�...��..J 4:� TL.. ....L:..-L Lam.- ..�....-. ....J..1�..
Da*a Source(s) _ns ec`ior NP-SISTEB Reports MLS/STEB Reports I VLS/S-EB Reports i-
Verification Source(s) Public -Re(,ords IO iblic Records_ Public Records Pjblic Records
,VALUE AUJUSTMENTS C DES-RIPTION -� DESCRIPTION +(•)sAd"stmern DESCRIFTION - �(-)$Adustnw DESCRIPTION � +{-)$Ad nwi
Sale or Financing N/A Conventional Conventional Convectional
Concessions N/A _ None Known None Known None Known
Date of Sale/Time NIA 4/15/2009 SD 9/22/2009 SD 2/25/2011 SD
Location Suburban Suburban Suburban Suburban
Leasehold/Fee Simple Fee Simple Fee Simple Fee Sim le Fee Simple
Site 1.2 acres .70 acre .58 acre 4.72 acres -30,000
View Creek Front Creek Front Creek Front Creek Front
Design(Style) Ranch Ranch 2 Story Ranch
Quality of Construction Brick&Frame/Ave Brick/Average Brick&Vin I/Ave Brick&Frame/Av
Actual Age 41 50 35 61 10,000
Condition Average Average e Good -301000 Average
Above Grade Taal Bcirms Baths Total 1, Baths Taai Bdrms. Baths �1500 Total Bdrms Baths
Room Count 9 4 3 9 4 2.5 1,500 9 4 2.5 1 1 4 3.5 -1,000
Gross ' Area30.00 3,494 .ft. 3,543 .ft. 2,956 .ft. 16,100 3,307 ft. 5 600
Basement&Finished Part Basement Full Basement -1,500 Full Basement -1,500 Full Basement -1,500
Rooms Below Grade 30% Finished 60% Finished -3,000 30%Finished 30% Finished
Functional Utility Average Average Average Average
Heat7n /Coolin FA/CA FA/CA FA/CA BBHW/CA
Energy Efficient Items Thermo panes Similar Similar Similar
Garage/Carport 2 Car Garage 2 Car Garage 2 Car Garage 3 Car Garage -5,000
PorcntPatiolDeck Patio Deck Porch Porch, Patio Deck Patio Deck, Patio
.Fireplaces,Pool 2 FPs in g. Pool 2 FPs In g. Pool 3 FPs In g. Pool -2,000 1 FP Pool,Tennis -3,000
MLS#s Not Listed 10171026 10182235 10197857
DOM NIA 156 days 46 day 103 days
Net Adjustment otal + X - $ 3,000 X $ 15,900 X $ 24,900
Adjusted Sale Price Net Adj. -0.7% Net Adj. -3.0% Net Adj. -5.5%
of Com arables Gross Ad'. 1.4% S 422,0 0 Gross Ad'. 9.7% $ 511,600 Gross Ad. 12.5% $ 425,100
Summary of Sales Comparison Approach See Attached Addendum
s
Cfl51 OAC l Olrikt LtE ''>t
Site Value Comments The cost approach is not considered applicable due to the age of the subject.
ESTIMATED OREPRODUCTIONOR [Z REPLACEMENT COST NEW OPINION OF SITE VALUE........................................= $ 120,000
Source of cost data Marshall and Swifts Cost Handbook Dwelling 3,494 Sq.Ft.@$ 74.01............= $ 258,591
Quality rating from cost service Average Effective date of cost data 12/2009 Bsmt: 3069 S .Ft. Sq,Ft.@$ 22.32...........= $ 68,500
Comments on Cast Approach Cgross living area calculations,depreciation,etc. Built-ins Porch,Deck Patio Pool Fireplaces, Fence 39,900
The age-life method was used for de reciation.Five lot sales were Garage/Carport Garage/Carport 575 S .Ft.c$ 30.23............_ $ 17,382
reviewed with sale prices from$99,900 to$275,000 and lot sizes Total Estimate of Cost-New = $ 384,373
JE rom .41 acre to 5.27 acres including one creek front lot on the Less Physical Functional Extemal
.Wme creek as the subject. Depreciation 30% _ $ 115,312
Depreciated Cost of Improvements................................ = $ 269,061
"As-is°Valueof Site improvements.lncludes.well.............. = $ 7,500
INDICATED VALUE BY COST APPROACH...................... = $ 396 6 0
NCOME APPROACH TO VALUE
stimated Monthl Market Rent$ N/A X Gross Rent Multiplier N/A =$ N/A Indicated Value b Income Approach
umma ry of Income Approach(including support for market rent and GRM) The income a roach is not considered a licable to this a of roe since
he typical buyer would be more interested in the amenities as an owner occupied propeq than the income the property may roduce.
lndicated Value by: Sales Comparison A roach s425,000 Cost Approach(ifdeveloped)9 396,600 Income Approach(ifdeveloped)s N/A
The sales approach is the best approach for this type of property.The cost approach is not applicable due to the age of the subject.
rThisappraisal me approach was not considered since the typical buyer of this a of roe is for owner occupancy and not an investor
.
is made IR"as is," 0 subject to completion per plans and specifications on the basis of a hypothetical condition that the improvements have been completed,
`)a*z Scurcers)
!ns e—for U LSISTEB Reports
VenficaticnSource(s)_ —Public Records Public Records_
-VALUE ADJUSTMENTS D1',-)'_'PIPTIQN Y DESCRIPTION S Adiustnol DESCRIPTION— $rma rrvnt DESCRIPTION $AdWniertt
Sale or Financing N/A Conventional
Concessions NIA None Known
Date of Sale/Time N/A 6/22/2010 SD
Location Suburban Suburban
Leasehold/Fee Simple Fee Simple Fee Simple
Site 1.2 acres 5.35 acres -40,00-0
View Creek Front Residential 20,000
Design(Style) Ranch Ranch
Quality of Construction Brick&Frame/Ave Brick/Ave
-Actual Age 41 27 -20,000
Condition Averaqe Good -30,000
Above Grade Total I 8drMs I Baths Total Bdfmsi Baths - - T� ms. Baths a] Bums Baths
Room Count 9 1 4 3 8 4 3
Gross LMnq Area 30.00 3,494 sq.ft. 3,440 sq.k so.ft. sq.k
,Basement&Finished Part Basement Part Basement
Rooms Below Grade 30% Finished 30% Finished
Functional Utility Average Average
Heatinq/Coolinq FA/CA HP/CA
Energy Efficient Items Thermo panes Similar
Garage/Carport 2 Car Garage 2 Car Garage
Pprchi'Patio/Deck Patio,Deck,Porch Patio 2 000
fireplaces, Pool 2 FPs, In g.Pool 1 FP,Tennis Ot 2,000
MLS#s - Not Listed 10191386
DOM N/A 44 days
Net Ad'ustment(Total) 0 1 66,000 $ 0 $ 0
Adjusted Sale Price Net Adj. -12.5% Net Adj. 0.0% Net Adj. 0.0%
of Comparables GrossAdi. 21.5% $ 464,000 Gr=Ad&. 0.0% $ 0 Gross Adj. 0.0% 0
Summary of Sales Comparison Approach
iri!ended use o°*.he repor*. Tyis report was prepared for the sole and exclusive use of the client and other identified intended users for the identified
intended use and its use by any other parties is prohibited. The appraiser is not responsible for unauthorized use of the report.
The appraiser's certification appearing in this appraisal report is subjectto the following conditions and to such other specific conditions as are
set forth by the appraiser in the report. All extraordinary assumptions and hypothetical conditions are stated in the report and might have affected the
assignment results.
1. The appraiser zssumes no responsibility for matters of a legal nature affecting the property appraised or title thereto,nor does the appraiser render any opinion as to the title,which is
assumed to be good and marketabie The property is appraised as though under responsible ownership.
2. Any sketch in this repon may show approximate dimensions and is included only to assist the reader in visualizing the property. The appraiser has made no survey of the property.
3. The appraiser is not required to give testimony or appear in court because of having made the appraisal with reference to the property in question,unless arrangements have been
previously made thereto.
4. Neither all,nor any part of the content of this report,copy or other media thereof(including conclusions as to the property value,the identity of the appraiser,professional designations,
or the firm with which the appraiser is connected),shall be used for any purposes by anyone but the client and other intended users as identified in this report,nor shall it be conveyed by
anyone to the public through advertising,public relations,news,sales,or other media,without the written consent of the appraiser.
5. The appraiser will not disclose the contents of this appraisal report unless required by applicable law or as specified in the Uniform Standards of Professional Appraisal Practice.
6. Information,estimates,and opinions furnished to the appraiser,and contained in the report,were obtained from sources considered reliable and believed to be true and correct.
However,no responsibility for accuracy of such items furnished to the appraiser is assumed by the appraiser.
7. The appraiser assumes that there are no hidden or unapparent conditions of the property,subsoil,or structures,which would render it more or less valuable. The appraiser assumes
no responsibility for such conditions,or for engineering or testing,which might be required to discover such factors. This appraisal is not an environmental assessment of the property and
should not be considered as such.
8. The appraiser specializes in the valuation of real property and is not a home inspector,building contractor,structural engineer,or similar expert,unless otherwise noted. The appraiser
did,not conduct the intensive type of field observations of the kind intended to seek and discover property defects. The viewing of the property and any improvements is for purposes of
deeloping an opinion of the defined value of the property,given the intended use of this assignment. Statements regarding condition are based on surface observations only. The
appraiser claims no special expertise regarding issues including,but not limited to:foundation settlement,basement moisture problems,wood destroying(or other)insects,pest infestation,
radon gas,lead based paint,mold or environmental issues. Unless otherwise indicated,mechanical systems were not activated or tested.
This appraisal report should not be used to disclose the condition of the property as it relates to the presence/absence of defects. The client is invited and encouraged to employ qualified
experts to inspect and address areas of concern. If negative conditions are discovered,the opinion of value may be affected.
Unless otherwise noted,the appraiser assumes the components that constitute the subject property improvements)are fundamentally sound and in
working order.
Any viewing of the property by the appraiser was limited to readily observable areas. Unless otherwise noted,attics and crawl space areas were not accessed. The appraiser did not move
furniture,floor coverings or other items that may restrict the viewing of the property.
9. Appraisals involving hypothetical conditions related to completion of new construction,repairs or alteration are based on the assumption that such completion,alteration or repairs will
be competently performed.
10. Unless the intended use of this appraisal specifically includes issues of property insurance coverage,this appraisal should not be used for such purposes. Reproduction or
Replacement cost figures used in the cost approach are for valuation purposes only,given the intended use of the assignment. The Definition of Value used in this assignment is unlikely
to be consistent with the definition of Insurable Value for property insurance coverage/use.
11.The ACI General Purpose Appraisal Report(GPAR'"')is not intended for use in transactions that require a Fannie Mae 1004/Freddie Mac 70 form,
also known as the Uniform Residential Appraisal Report(URAR).
Additional Comments Related To Scope Of Work,Assumptions and Limiting Conditions
3. Wess n'henN;se s+a'nr+ 'he a._ apse,tins no Drese^,or prosPeclive in?e'es.in"e property tti r. s hA s S..,ir—o ti s ro po r+a^. �zs no persona efes m �respe�,,o the parties
f
involved,
i
4. The appraiser has no bias with respect to the property that is the subject of nis report or to the parties involved with this assignment.
5. The appraiser's engagement in this assignment was not contingent upon developing or reporting predetermined results.
6. The appraiser's compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of
the client,the amount of the value opinion,the attainment of a stipulated result,or the occurrence of a subsequent event directly related to the intended use of this appraisal.
7. The appraiser's analyses,opinions,and conclusions were developed,and this report has been prepared,in conformity with the Uniform Standards of Professional Appraisal Practice.
8. Unless otherwise noted,the appraiser has made a personal inspection of the property that is the subject of this report.
9. Unless noted below,no one provided significant real property appraisal assistance to the appraiser signing this certification. Significant real property appraisal assistance provided by:
Additional Certifications:
Definition of Value: ®Market Value ❑Other Value:
Source of Definition: National Residential Appraisers Institute
The most probable price which a property should being in a competive and open market under all conditions requisite to a fair sale,
the buyer and seller,each acting prudently, knowledgeeably and assuming the price is not effected by undue stimulus. Implicit in this
definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditions whereby:
(1)buyer and seller are typically motivated, (2)both parties are well informed or well advised, and each acting in what he or she
considers his or own best interest, (3)a reasonable time is allowed oft exposure in the open market, (4), payment is made in terms of
cash in U.S.dollars or in terms of financial arrangements comparable thereto,and(5)the price represents the normal consideration
for the property sold unaffected by special or creative financing or sales concessions granted by onyone associated with the sale.
ADDRESS OF THE PROPERTY APPRAISED:
1540 Mccormick Drive
Mechanicsburg, PA 17055
EFFECTIVE DATE OF THE APPRAISAL: 03/30/2011
APPRAISED VALUE OF THE SUBJECT PROPERTY $425,000
APPRAISER SUPERVISORY APPRAISER
Signature: Signature:
Name: David Eskin,PA State Certified Residential Real Estate Appraiser Name:
State Certification# RL003174L State Certification#
or License# or License#
or Other(describe): State#: State:
State: Pennsylvania Expiration Date of Certification or License:
, t ttG J VIGVt IJ VVUIIVGU VVI\V4lG VV 1,Z Q114 J/'Y 1111Ica IIVI II I,1V1VV1 GJ IVIVVI?tall I I'VQV, 1 Q114 LIV IIIIIGJ Gf6J., I.rl CV11114'1llall '
Drive, 1/4 mile south and Arcona Road, 1 and 1/3 miles west.
Neighborhood Market Conditions
Marketing conditions are considered average. Homes in the upper price range,$300,000 to$500,000,like the subject,are in
balance with demand and market prices are stable. Per the local MILS data service over the past 12 months the average list
price was$397,094 and average sold price was$380,119 with an average"days on the market. In the prior 12 months the
{ average list price was$366,728 and average sold price was$360,110 with an average of 90 days on the market.Although
the raw stats indicate an increasing market it was noted in the prior 12 months several additional lower range sales,skewing
the stafs and overall the market is stable as reported. Properties of this style and area sell well with seller concessions, if
any,typically limited to 1-3 discount points.There is no known prevalence of unusual seller financing concessions/buydowns
that impact this market. Marketing time is typically 3-6 months when listed within 5%of the final selling price. I have
considered relevant competitive listings and/or contract offering in the performance of this appraisal and in the trending
information reported in this section. If a trend is indicated, I have attached an addendum providing relevant competitive
listing/contract offering data. Markting time is stable for the subject neighborhood.
Comments on Sales Comparison
All sales are closed transactions.All sales are considered average indicators of value. In the final reconciliation most weight
is given to comparables#1 and#3,being most similar in design,age and condition.The guidelines for sales sold with in six
months and one mile were exceeded due to low turn-over of similar sales in the subjects neighborhood.All comparables are
older larger dwellings with comparables#1,#2 and#3,being creek front homes and all comparables share the same
employment centers and good indicators of value.The subject is located along the Yellow Breeches Creek, like comparable
#3,comparables#1 and#2 are located along the Condoguinet Creek with similar views and similar marketability.
Comparbale#4 is not a creek front property and was selected being a larger one story dwelling and was adjusted for view.
The subject is an older dated home like comparables#1 and#3 and comparables#2 and#4 were adjusted for condition.
The subject has an inground pool,like comparables#1,#2 and#3.Comparable#3 also has a tennis count and was
adjusted and comparable#4 also has a tennis court and considered similar in value to the pool and was not adjusted.
Comparable#3 is under renovations and MILS photo is included on separate photo page.Comparable#4 is back a private
driveway and not visable from the public street and MILS photo is included on separate photo page.
FRONTVIEWOF
~' t SUBJECT PROPERTY
Appraised Date:March 30, 2011
Fyn, ,r Appraised Value: $425,000
I
REAR VIEW OF
SUBJECT PROPERTY
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COMPARABLE SALE#1
,u
25 Eastgate Drive
Camp Hill, PA 17011
Sale Date: 4/15/2009 SD
n s Sale Price: $ 425,000
I
COMPARABLE SALE#2
2.55 E. Lauer Lane
Camp Hill, PA 17011
Sale Date: 9/22/2009 SD
Sale Price: $ 527,500
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900 Mccormick Road
Mechanicsburg, PA 17055
Sale Date: 2/25/2011 SD
Sale Price: $ 450,000
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COMPARABLE SALE#4
1040 Brookwood Drive
Mechanicsburg, PA 17055
Sale Date: 6/22/2010 SD
Sale Price: $ 530,000
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COMPARABLE SALE#5
Sale Date:
Sale Price: $
COMPARABLE SALE#6
Sale Date:
Sale Price: $
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Comp#4, MLS Photo
900 Mccormick Road
Mechanicsburg, PA 17055
Comp#3, MLS Photo
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22' 10'
_ 21'
in I Enclosed
�* 14'-� Deck v
Porch - Bedroom
82' Deck
Laundry Bath
i�
Bedroom Kitchen Family Den
Bath
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25' ID
Bath Bedroom
"' Dining Living Room Foyer
N Garage
6'
44' 2
Patio Bedroom
25' L.
14'
21'
Ske[ch by Apex MedinaTM
Comments: - -
AREA CALCULATIONS SUMMARY LIVING AREA BREAKDOWN
Code Description Net Size Net Totals Breakdown
Subtotals
GAR First Floor 3494.0 3494.0 First Floor
GAR Garage 575.0 575.0 14.0 x 21.0
P/P Screened Porch 319.0 294.0
Wood Deck 224.0 14.0 x 21.0 294.0
2.5 x 28.0 70.0
Patio 155.0 698.0 2.5 x 44.0
110.0
12.5 x 78.0 975.0
17.0 x 103.0 1751.0
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p Purcell#: 13-31-2136-482.
This indenture,made the day ofNavcrrtber,in the year two thousand four
(2004),
Between
i Harold T. Waddington and Anne W. Waddington, Trustees, or their
successors in true under the Harold T. Waddington Living Trust dated
November 20, 2000, and any amatdments thereto, and Anne W.
Waddington and Harold T. Waddington, Trustees, or their successors in
trust, under the Anne W. Waddington Living Trust dated November 20,
2000,and any ame timgnts thereto,as Tenants in Common,Grantors
And
Thomas V. Waddington and Julia A. Waddington, husband and wife, of
York County,Pennsylvania,Grantees
Witnesseth, that the Grantors, for and in consideration of the sum of Two
Hundred Seventy Thousand and No/100 ($270,000.00) Dollars, lawful money of the
3 United States of America,unto them well and truly paid by the Grantees at or before the
sealing and delivery hereof the receipt whereof is hereby acknowledged,have granted,
bargained and sold,released and confirmed,and by these presents do grant,bargain and
sell, release and confirm unto the Grantees, their heirs„ personal representatives and
assigns.
j ALL THOSE CERTAIN tracts or lots of ground situate in the Township of Lower
Allen, County of Cumberland, and Commonwealth of Pennsylvania, bounded and
described as follows,to wit:
TRAM NO,1: BEGII�WING at a point on the south side of a 50 foot street
known as McCormick Drive at the corner of Lot No, 6 as shown in the hereinafter
mentioned Plan of Lots; thence along said Lot No.6, South 18 degrees 24 minutes East
! 303.6 feet to a point in the middle of the Yellow Breeches Creek;thence on a tine in said
Creek,South 76 degrees,30 minutes West 100.33 feet to a point at the comer of Lot No.
8,as shown in the hereinafter mentioned Plan of Lots;thence along said Lot No.8,North
18 degrees 24 minutes West 295.03 feet to a paint on the south side of McCormick Drive
aforesaid; thence along the south side of McCormick Drive,North 71 degrees 36 minutes
East 100 feet to a point at the corner of Lot No.6 aforesaid,the place of BEGINNING.
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BEING Lot No. 7 in the Plan of Section"C" of Lisburn Estates, as recorded in
Plan Book 14, Page 38, in the Office of ft Recorder of Deeds in and for Cumberland j
County.
'EAM XO.2_ BEGINNING at a point on the south side of a 50 foot street
own as McCormick Drive at the corner of Lot No, 7, as shown on the hereinafter
entianed Plan of Lots;thence along said Lot Na. 7, South 18 degrees 24 minutes East
95.03 feet to a point in the middle of the Yellow Breeches Creek;thence along a line of
aid Creek,South 76 degrees 30 minutes West 49.86 feet to a point;thence continuing on
Lline in said creek South 56 degrees West 52.51 feet to a point at the comer of Lot No. 9,
orth 18 degrees 24 minutes West 304.81 feet to a point on the south side of McCormick
Drive; thence along the south side of McCormick Drive, North 71 degrees 36 minutes
fast 100 feet to a point at the corner of Lot No.7 aforesaid;the place of BEGINNING.
BEING Lot No. 8 in time Plan of Section"C"of Lisburn Estates,'as recorded in
Ian Book 14, Page 38 in the Office of the Recorder of Deeds in and for Cumberland
aunty. E
RAVING THEREON ERECTED a dwelling known and numbered as 1540
�Xormick Drive,Mechanicsburg,Pennsylvania.
( BEING the same premises which Harold T. Waddington and Anne W.
Waddington, husband and wife, by Deed dated November 20, 2000, and recorded
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Waddington,
27, 2000, in Record Boole 234, Page 875, in the Office of the Recorder of
iDeeds in and for Cumberland County,Pennsylvania, granted and conveyed unto Harold
F. Waddington and Anne W. Waddington,Trustees of the Harold T.Waddington Living
t?rust dated November 20,2000, and Anne W.Waddington and Harold T. Waddington,
'Trustees of the Anne W. Waddington Living Trust dated November 20, 2000, the
Grantors herein.
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I NOTE: This Is a transfer between Trusters and Bieedt elaries of their Living Trusts
to their son and his wife and Is,therefore,exempt from Pennsylvania Realty
Transfer Tax.
UNDER AND SUBJECT to all restrictions,easements,covenants,conditions and
agreements of record.
I TOGETHER with all and singular the bui,Iings and improvements,ways,streets,
alleys, passages, waters, water-courses, rights, liberties, privileges, hereditaments and
appurtenances, whatsoever unto the hereby granted premises belonging, or in any wise
appertaining,and the reversions and remainders,rants, issues mid prolits-thereof; and all
the estate, right, title interest, Property, claim and demand whatsoever of them, the
Grantors,as well at law as in equity,of,in and to the same.
TO HAVE AND TO HOLD the said lot or piece of ground above described,with
I the messuage or tenement thereon erected,hereditaments and premises hereby granted,o r
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JULIA WADDINGTON, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 10-1763
THOMAS WADDINGTON CIVIL ACTION-LAW
Defendant IN DIVORCE I
CERTIFICATE OF SERVICE
L John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP, attorney
for the Defendant, Thomas Waddington, hereby certify that I have served a copy of Defendant's
Pre-trial Statement on the following on the date and in the manner indicated below:
U.S.MAIL,FIRST CLASS,PRE-PAID
E. Robert Elicker, 11, Esquire Samuel L. Andes,Esquire
Cumberland County Divorce Master P.O. Box 168
9 North Hanover Street Lemoyne, PA 17043.
Carlisle,PA 17013
JAMES,SMITH,DIETTERICK
& CONNELLY,LLP
Dated: April 2013 By:
hn o Jr.
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5 Jr.
ey .9. 1;6
P.O.Box 650
Hershey,PA 17033-0650
(717)533-3280
Attorneys for Defendant
JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYOK
V. :NO. 10-1763 z
THOMAS WADDINGTON, : CIVIL ACTION—LAW C) .� ;
Defendant : IN DIVORCE .`
D-TI
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 11,2010.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of Notice of Intention
to request entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER 43301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 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.A. §4904, relating to unworn
falsification to authorities.
Date: 7,q
"Waddi-
i ngton,.Plaintiff
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JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS r
Plaintiff : CUMBERLAND COUNTY,PENNSYI-kA19.
�n
V. :NO. 10-1763 ,
THOMAS WADDINGTON, : CIVIL ACTION—LAW ' '
Defendant
IN DIVORCE
o C
AFFIDAVIT OF CONSENT —a
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 11,2010.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the 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.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER-0301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 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. F understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn
falsification to authorities.
Date:
J omas Waddington dant
JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : NO. 10-1763
THOMAS WADDINGTON, : CIVIL ACTION—LAW
Defendant : IN DIVORCE
ORDER
AND NOW,this 6Z day of , 2013,the appointment of
E. Robert Elicker,III, Esquire, as Master in the above-captioned proceeding is hereby revoked.
BY THE COURT:
J
Distribution:
,13'amuel L. Andes, Esquire, P.O. Box 168, Lemoyne, PA 17043-0168
john J. Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033 ��"" � �
E. Robert Elicker, III, Esquire, 9 North Hanover Street, Carlisle, PA 17013 _a&c�i 4)4i�
ova 2a•,. � +.;;
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JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. :NO. 10-1763
THOMAS WADDINGTON, : CIVIL ACTION—LAW
Defendant : IN DIVORCE
PETITION TO REVOKE
APPOINTMENT OF MASTER
1. On October 11,2012, E.Robert Elicker, III, Esquire, was appointed Master in the
above-captioned matter to consider the issues raised in the proceedings.
2. The parties have resolved all issues pursuant to a Marital Settlement Agreement.
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3. The undersigned therefore requests that the appointment of E. Robert Elicker, III,
Esquire be revoked.
Respectfully submitted,
JSDC Law Offices
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Dated: August�Z7,2013 By:
6 J Co Ily,Jr.
A rney #1561
P.O. Box 650
Hershey,PA 17033-0650
(717) 533-3280
Attorneys for Defendant
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JULIE WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : NO. 10-1763
THOMAS WADDINGTON, : CIVIL ACTION—LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
I; John J. Connelly, Jr.,Esquire,of JSDC Law Offices, , attorney for the Defendant, Thomas
Waddington,hereby certify that I have served a copy of the foregoing Petition to Revoke
Appointment of Master on the following on the date and in the manner indicated below:
U.S.MAIL,FIRST CLASS-,PRE-PAID
Samuel L. Andes, Esquire
P.O. Box 168
Lemoyne, PA 17043
E. Robert Elicker, III, Esquire
Cumberland County.Divorce Master
9 North Hanover Street
Carlisle, PA 17013
JSDC Law Offices
Dated: August " 2013 By:
o J.to lly, Jr.
me #15615
P.O. Box 650
Hershey, PA. 17033-0650
(717) 533-3280
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MARITAL SETTLEMENT AGREEMENT
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C_— _
BY AND BETWEEN '
C> C ' r
THOMAS V.WADDINGTON
AND
JULIA WADDINGTON
John J. Connelly,Jr.,Esquire Samuel L.Andes,Esquire
JSDC Law Offices P.O.Box 168
P.O.Box 650 Lemoyne,PA 17043-0168
Hershey,PA 17033
Telephone: (717)533-3280 Telephone: (717)761-5361
Counsel for Thomas V. Waddington Counsel for Julia Waddington
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of 2013, by
and between THOMAS V.WADDINGTON and JULIA WADD GTON.
WITNESSETH:
WHEREAS,Thomas V.Waddington(hereinafter called"Husband")currently resides at 31
Indiana Circle,Lemoyne,Pennsylvania 17043;
WHEREAS, Julia Waddington (hereinafter called "Wife") currently resides at 137
Blacksmith Road, Camp Hill,Pennsylvania 17011;
WHEREAS, the parties hereto are husband and wife, having been lawfully married on
September 30, 1989;
WHEREAS, the parties have lived separate and apart since on or about November 14,
2009;
WHEREAS, two (2) children were born of the marriage between the parties, namely,
Hannah N. Waddington,born March 6, 1997; and Ryan T. Waddington,born June 6, 1999;
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, including, without limitation,
the settling of all matters between them relating to the ownership of real and personal property, the
support and maintenance of one another and, in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW THEREFORE, in consideration of these premises, and of the mutual promises,
covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the
receipt and sufficiency of which is hereby acknowledged by each of the parties hereto,Husband and
Wife,each intending to be legally bound hereby,covenant and agree as follows:
1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live
separate and apart. Each shall be free from all control,restraint, interference and authority,direct or
indirect, by the other. Each may reside at such place or places as he or she may select. Each may,
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for his or her separate use or benefit, conduct, carry on or engage in any business, occupation,
profession or employment which to him or her may seem advisable. Husband and Wife shall not
molest, harass, disturb or malign each other, nor compel or attempt to compel the other to cohabit
or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere
with the use, ownership, enjoyment or disposition of any property now owned by or hereafter
acquired by the other.
2. ADVICE OF COUNSEL. Each party acknowledges that he or she has had the
opportunity to receive independent legal advice from counsel of his or her selection. Husband has
secured legal advice from John J. Connelly, Jr., Esquire, his counsel, and Wife has secured legal
advice from Samuel L. Andes, Esquire, her counsel. Each party fully understands the facts and his
or her legal rights and obligations,and each party acknowledges and accepts that this Agreement is,
in the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, and
that the execution of this Agreement is not the result of any duress or undue influence,and that it is
not the result of any improper or illegal agreement or agreements. In addition, each party
understands the impact of the Pennsylvania Divorce Code,whereby the court has the right and duty
to determine all marital rights of the parties including divorce, alimony, alimony pendente lite,
equitable distribution of all marital property or property owned or possessed individually by the
other,counsel fees and costs of litigation and,fully knowing the same,each party hereto still desires
to execute this Agreement acknowledging that the terms and conditions set forth herein are fair,just
and equitable to each of the parties, and waives his and her respective right to have the Court of
Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any
determination or order affecting the respective parties' rights to alimony, alimony pendente lite,
support and maintenance,equitable distribution,counsel fees and costs of litigation.
3. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or
she is aware of his or her right to seek discovery including, but not limited to, written
interrogatories, motions for production of documents, the taking of oral depositions, the filing of
inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the
Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or she has
2
had the opportunity to discuss with counsel the concept of marital property under Pennsylvania law
and each is aware of his or her right to have the real and/or personal property, estate and assets,
earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any
other court of competent jurisdiction. The parties do hereby acknowledge that there has been full
and fair disclosure to the other of his or her respective income, assets and liabilities, whether such
are held jointly, in the name of one party alone or in the name of one of the parties and another
individual or individuals. Each party agrees that any right to further disclosure,valuation, appraisal
or enumeration or statement thereof in this Agreement is hereby specifically waived,and the parties
do not wish to make or append hereto any further enumeration or statement. Specifically, each
party waives the need for copies of bank statements, insurance policies, retirement plan statements
or any other documentation. Each party warrants that he or she is not aware of any marital asset
that is not identified in this Agreement. The parties hereby acknowledge and agree that the division
of assets as set forth in this Agreement is fair,reasonable and equitable, and is satisfactory to them.
Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs,
executors, administrators or assigns, that he or she will never at any time hereafter sue the other
party or his or her heirs, executors, administrators or assigns in any action of contention, direct or
indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was
any fraud, duress, undue influence or that there was a failure to have available full, proper and
independent representation by legal counsel.
4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the
parties agree,that by this Agreement they have resolved all ancillary economic issues related to the
dissolution of their marriage and thus any divorce action with respect to these parties shall be
limited to a claim for divorce only. Wife acknowledges that she has filed a Divorce Complaint in
the Court of Common Pleas Cumberland County, Pennsylvania indexed to Docket No. 10-1763.
The parties agree that, at the time of execution of this Agreement, they will each execute an
Affidavit of Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree in order
that counsel for Wife may finalize the divorce action promptly. Upon completion of the divorce
action,counsel for Wife shall supply counsel for Husband with a copy of the Decree.
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5. EQUITABLE DISTRIBUTION.
A. Real Estate.
(1) The parties are the owners of real estate located at 1540 McCormick
Drive, Mechanicsburg, Pennsylvania. The real estate is in the process of being listed for sale
with Ken Diltz, a realtor the parties have been working with to date. The listing with Mr. Diltz
shall occur as soon as the work is completed on the residence to place it in a saleable condition.
There is no mortgage against this property.
(2) Wife has acquired another residence in her name individually which will
be her sole and separate property. The residence is located at 137 Blacksmith Road, Camp Hill,
Pennsylvania. Husband has advanced $63,000.00 to Wife to acquire her residence. Reference to
Husband's loan to Wife is more particularly set forth herein.
The parties agree that upon the sale of the marital residence, the net proceeds shall
be assigned 50% to Wife and 50% to Husband. Net proceeds shall be defined as the gross sale
price less any ordinary adjustments on the settlement sheet including but not limited to real estate
taxes, commission and transfer taxes as well as any other costs. In the event either of the parties
have advanced funds in order to repair, replace or upgrade items to place the residence in a
saleable condition, those monies shall be repaid to each of the parties from the proceeds before
division. In the event Husband borrows funds from Merrill Lynch using his brokerage account as
collateral in order to pay for agreed upon repairs, he shall be reimbursed not only the amount of
the agreed upon repair but also any interest accrued on funds borrowed for that purpose. To date
Husband and Wife have expended certain funds subject to reimbursement more particularly set
forth herein as well as on Exhibit"A" attached hereto and made a part hereof. The expenditures
listed include interest accrued through August 14, 2013.
The parties have agreed that Shadel Roofing will replace the roof on the residence
based on the estimate attached hereto marked Exhibit `B". The parties further agree that Echo
will act as a general contractor providing other repairs in the estimated amount of$7,049.00 and
Aaron Martin will perform additional landscaping work based on an estimate of$525.00. The
above estimates are also listed on Exhibit `B" hereof. All of the above expenses shall be
4
advanced by Husband through his Merrill Lynch Account and shall be reimbursed to him plus
interest at closing except the Aaron Martin bill will not generate interest. The interest rate
charged through Husband's borrowing on his Merrill Lynch Account is approximate 4%;
however, the rate varies. The parties have been provided a copy of the Merrill Lynch Contract
regarding the interest cost and recognize the approximate amount being charged for interest on
monies advanced by Husband. Any additional work to be done on the house not referenced
herein must be agreed upon by the parties prior to undertaking said work. In the event the parties
cannot agree,the Court retains jurisdiction over this issue.
Husband shall be financially responsible for maintaining the property during the
pendency of the sale (utilities, taxes, insurance, ordinary maintenance, etc.). This maintenance
shall include grass cutting and landscaping. Husband will also secure an exterminator at a cost of
$150.00 to treat the house at the appropriate time. Husband shall also be reimbursed for those
expenses from the proceeds and interest charged. Wife shall assume responsibility for hiring a
contractor to completely clean and close the pool by September 15, 2013. Husband will pay the
expense to clean and close the pool and will be reimbursed for those expenses plus interest from
the sale proceeds.
Both parties agree to cooperate to 1)cancel the house telephone, cable, and refuse
services, 2) change and forward power, water, sewer, tax, insurance, and existing contractor bills
to the Husbands name and current address, and 3) to identify and/or secure new contractors, as
necessary, to remove unwanted items from the property and to maintain the house utilities and
property grounds (such as, the heating and air conditioning system, swimming pool, hot tub spa,
gardens, and lawn). Wife shall forward any real estate tax bills to Husband as soon as they are
received.
After all of the deductions from the proceeds referenced above, each party shall be
allocated 50% of the proceeds as their separate property. However, Wife will receive all of the
net proceeds. Husband's 50% will be applied to the balance due Wife in equitable distribution
more particularly set forth in paragraph 5(G) hereof. For example, if the net proceeds after the
costs of sale, repairs and reimbursements (50%) are $300,000.00, Wife will receive $150,000.00
5
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as her distribution from which she will repay Husband $63,000.00 plus interest referenced below
and she will also receive Husband's $150,000.00 distribution which will be applied to the
equitable distribution balance due Wife as set forth in paragraph 5(G)hereof($207,940.00).
In order to facilitate Wife's purchase of her new residence as referenced in
paragraph 5(A)(2) hereof, Husband has provided Wife with a $63,000.00 loan through his
Merrill Lynch Account which as referenced above will be repaid from Wife's share of the
proceeds plus any interest accrued. As of August 14, 2013, Husband is owed $63,000.00 plus
$406.37 interest which will continue to accrue until paid in full.
B. Furnishings and Personalty. The parties agree that they have divided by
agreement between themselves all furnishings and personalty located in the Marital Residence,
including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and
equipment. Accordingly, Husband shall retain sole and exclusive ownership of all furnishings
and personalty currently in his possession, free and clear of any right, title, claim and/or interest
of Wife and Wife shall retain all items of furnishings and personal property currently in her
possession as her sole and separate property free and clear of any right,title, claim and/or interest
of Husband.
C. Motor Vehicles.
(1) Husband shall retain as his sole and separate property the 2008 Lexus
ES350 with a value of$27,875.00.
(2) Wife shall retain as her sole and separate property the 2006 Nissan
Murano with a value of$15,950.00.
(3) The parties agree that they have already cooperated in effectuating the
transfer of titles and insurance to accomplish the purposes of this subparagraph.
D. Life Insurance.
(1) Husband shall retain his ownership in his Northwest Mutual Life
Insurance Policy with a value of$2,642.00.
(2) Wife shall retain her ownership in her Madison National Life Insurance
Policy with a value of$4,488.00.
6
E. Pension and Retirement Benefits.
(1) Wife shall retain her ownership of her Janus IRA with a balance of
approximately$16,965.00.
(2) Except as provided in paragraph 5G below, Husband shall retain sole
ownership of his Gannett Fleming, Inc. Tax-Deferred 401(k) Savings Plan having a marital value
of$316,635.00 and his pension which is currently frozen through Gannett Fleming with a marital
value of$65,090.00.
F. Financial Accounts. The parties have previously divided to their mutual
satisfaction their bank accounts with PSECU as well as their Janus and American Century
Mutual Funds. The PSECU accounts were used for the purpose of marital obligations and the
mutual funds referenced above in the amount of$31,290.15 were distributed $19,171.00 to Wife
and $12,119.00 to Husband.
G. Equitable Distribution Payment. The parties have determined that their
marital property with the exception of their house has a value of $480,935.00. Wife shall be
entitled to receive 55% of that figure or $264,514.00. Based on the value of the assets being
retained by Wife, she has received a total to date of$56,574.00 leaving a balance due to her in
equitable distribution the amount of$207,940.00. Husband's 50% proceeds from the sale of the
marital residence referenced in paragraph 5(A) hereof, will be applied to this amount and
whatever balance is left, will be rolled over pursuant to a Qualified Domestic Relations Order
from Husband's Gannett Fleming, Inc. Tax-Deferred 401(k) Savings Plan into an IRA designated
by Wife. The Qualified Domestic Relations Order shall be prepared by Jonathan D. Cramer,
A.S.A., of Conrad Siegel Actuaries, and the parties will share equally the cost of the preparation.
For example, if Husband's proceeds from the sale of the house are $150,000.00, this amount
would be applied to the balance due to Wife of $207,940.00 with a balance to be rolled over
pursuant to a Qualified Domestic Relations Order from Husband's Gannett Fleming, Inc. Tax-
Deferred 401(k) Savings Plan of$57,940.00.
H. Miscellaneous Property. As of the execution date of this Agreement, any
and all property not specifically addressed herein shall be owned by the party to whom the
7
property is titled; and if untitled, the party in possession. This Agreement shall constitute a
sufficient bill of sale to evidence the transfer of any and all rights in such property from each to
the other.
I. Property to Wife. The parties agree that Wife shall own, possess, and
enjoy, free from any claim of Husband, the property awarded to her by the terms of this
Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and
waives and relinquishes any and all rights thereto, together with any insurance policies covering
that property, and any escrow accounts relating to that property. This Agreement shall constitute
a sufficient bill of sale to evidence the transfer of any and all rights in such property from
Husband to Wife.
J. Property to Husband. The parties agree that Husband shall own,
possess, and enjoy, free from any claim of Wife,the property awarded to him by the terms of this
Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property, and
waives and relinquishes any and all rights thereto, together with any insurance policies covering
that property, and any escrow accounts relating to that property. This Agreement shall constitute
a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to
Husband.
6. DEBTS.
A. Marital Debt. The parties have no marital debt with the exception of
continuing accruing obligations at the marital residence.
B. Liability not Listed. Each party represents and warrants to the other that
he or she has not incurred any debt, obligation or other liability, other than those described in this
Agreement, for which the other party is or may be liable. A liability not disclosed in this
Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it,
and such party agrees to pay it as the same shall become due,and to indemnify and hold the other
party and his or her property harmless from any and all debts,obligations and liabilities.
C. Indemnification of Wife. If any claim, action or proceeding is hereafter
initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this
8
Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or
proceeding, whether or not well-founded, and indemnify her and her property against any
damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Wife in connection therewith.
D. Indemnification of Husband. If any claim, action or proceeding is
hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife
under this Agreement, Wife will, at her sole expense, defend Husband against any such claim,
action or proceeding, whether or not well-founded, and indemnify him and his property against
any damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Husband in connection therewith.
E. Warranty as to Future Obligations. Husband and Wife each represents
and warrants to the other that he or she will not at any time in the future incur or contract any
debt, charge or liability for which the other, the other's legal representatives, property or estate
may be responsible. From the date of execution of this Agreement, each party shall use only
those credit cards and accounts for which that party is individually liable and the parties agree to
cooperate in closing any remaining accounts which provide for joint liability. Each party hereby
agrees to indemnify, save and hold the other and his or her property harmless from any liability,
loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach
hereof.
7. INCOME TAX. The parties have heretofore filed joint federal and state tax
returns. Both parties agree that, in the event any deficiency in federal, state or local income tax is
proposed or any assessment of any such tax is made against either of them, each will indemnify
and hold harmless the other from and against any loss or liability for any such tax deficiency or
assessment or any interest, penalty or other expense incurred in connection therewith which has
been caused by the indemnifying party's failure to disclose income, improperly claim deductions,
or otherwise provide inaccurate information used in the preparation of the returns which result in
such additional charges. Any additional tax, interest, penalty, or expense shall be paid solely and
entirely by the individual who is finally determined to be responsible for the inaccurate,
9
i
incomplete, or false information used to prepare the returns which resulted in such additional
expenses.
8. SUPPORT.
A. ALIMONY,ALIMONY PENDENTE LITE, SPOUSAL SUPPORT.
Husband agrees to pay to Wife the sum of $700.00 per month as alimony commencing on
September 1, 2013 for a period of 72 months ending in the month of August 30, 2019. The said
alimony payments shall be non-modifiable as to duration or amount and shall terminate upon the
first to occur of the following: (1) the expiration of the alimony term; (2) death of Husband; (3)
death of Wife; or(4)Wife's remarriage or cohabitation.
Upon execution of this Agreement,counsel for Wife shall immediately contact the
Cumberland County Domestic Relations Office and terminate the current spousal support Order
consistent with the terms of this Agreement. The amount of spousal support may be replaced
with the alimony payment ($700.00) effective September 1, 2013. Both parties will execute any
documents necessary to enter an alimony Order.
All such payments by Husband to Wife shall be deemed alimony, as defined in
Section 71 (b)(1)(A)of the Internal Revenue Code as amended,and as said Section is amplified by
the provisions of the Tax Reform Act of 1984 and Tax Reform Act of 1986,and any future laws or
regulations related thereto. Payments from Husband,when received by Wife, shall be deductible in
the year of payment by Husband pursuant to Section 215 of the Internal Revenue Code, as
amended, or any similar future laws or regulations thereto, and shall be includable in the year of
receipt in the gross income of Wife pursuant to Section 71 (b)(1)(A)of the Internal Revenue Code,
as amended or any similar future laws or regulations thereto.
B. CHILD SUPPORT. There is currently an Order of child support indexed
to PACSES Case No. 213113751 in the Court of Common Pleas Cumberland County,
Pennsylvania in the amount of$1,334.00. The parties agree that if there is any modification of
child support prior to the parties' oldest daughter's termination of support upon her graduation in
June of 2015, the payment of alimony to Wife shall not be included in Wife's income nor
deductible from Husband's income. Beginning with any modification of child support based on
10
the parties' daughter's graduation from high school and thereafter,the income from alimony shall
be included in Wife's income and deducted from Husband's income in calculating any new child
support order.
9. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each
waive all rights of inheritance in the estate of the other, any right to elect to take against the will
or any trust of the other or in which the other has an interest, and each of the parties waives any
additional rights which said party has or may have by reason of their marriage, except the rights
saved or created by the terms of this Agreement. This waiver shall be construed generally and
shall include, but not be limited to,a waiver of all rights provided under the laws of Pennsylvania
or any other jurisdiction.
10. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically
set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights
and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a
beneficiary designation which belongs to the other parry under the terms of this Agreement,
including, but not limited to, pensions and retirement plans of any sort or nature, deferred
compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay
checks or any other post-death distribution scheme, and each party expressly states that it is his
and her intention to revoke by the terms of this Agreement any beneficiary designations naming
the other which are in effect as of the date of execution of this Agreement. If and in the event the
other party continues to be named as beneficiary and no alternate beneficiary is otherwise
designated,the beneficiary shall be deemed to be the estate of the deceased party.
11. RELEASE OF CLAIMS.
A. Wife and Husband acknowledge and agree that the property dispositions
provided for herein constitute an equitable distribution of their assets and liabilities pursuant to
§3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their
property except as provided for in this Agreement. Furthermore, except as otherwise provided
for in this Agreement, each of the parties hereby specifically waives, releases, renounces and
II
forever abandons any claim, right, title or interest whatsoever he or she may have in property
transferred to the other party pursuant to this Agreement or identified in this Agreement as
belonging to the other party, and each party agrees never to assert any claim to said property or
proceeds thereof in the future. The parties have divided between them to their mutual satisfaction,
personal effects, household goods and furnishings and all other articles of personal property which
have heretofore been used in common by them, and neither party will make any claim to any such
items which are now in the possession or under the control of the other. Should it become
necessary, each party agrees to sign any title or documents necessary to give effect to this
paragraph, upon request. However, neither party is released or discharged from any obligation
under this Agreement or any instrument or document executed pursuant to this Agreement.
Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other,
all items of personal property, tangible or intangible, acquired by him or her from the execution
date of this Agreement, with full power in him or her to dispose of the same fully and effectively
for all purposes.
B. Except as specifically provided herein, each party hereby absolutely and
unconditionally releases and forever discharges the other and the estate of the other for all
purposes from any and all rights and obligations which either party may have or at any time
hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony,
equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic
or otherwise, whether arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well
as under any other law of any other jurisdiction, except and only except all rights and obligations
arising under this Agreement or for the breach of any of its provisions. Neither party shall have
any obligation to the other not expressly set forth herein.
C. Except as otherwise set forth in this Agreement, each party hereby
absolutely and unconditionally releases and forever discharges the other and his or her heirs,
executors, administrators, assigns, property and estate from any and all rights, claims, demands
or obligations arising out of or by virtue of the marital relationship of the parties whether now
12
existing or hereafter arising. The above release shall be effective regardless of whether such
claims arise out of any former or future acts, contracts, engagements or liabilities of the other or
by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance,
or under the intestate laws or the right to take against the spouse's will, or the right to treat a
lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any
state, commonwealth or territory of the United States, or any other country.
D. Except for the obligations of the parties contained in this Agreement and
such rights as are expressly reserved herein, each party gives to the other by the execution of this
Agreement an absolute and unconditional release and discharge from all causes of action, claims,
rights or demands whatsoever in law or in equity, which either party ever had or now has against
the other.
12. PRESERVATION OF RECORDS. Each party will keep and preserve for a
period of four(4) years from the date of their Divorce Decree all financial records relating to the
marital estate, and each party will allow the other party access to those records in the event of tax
audits.
13. MODIFICATION. No modification, rescission, or amendment to this
Agreement shall be effective unless in writing signed by each of the parties hereto.
14. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable,the remaining provisions hereof shall
nevertheless survive and continue in full force and effect without being impaired or invalidated
in any way.
15. BREACH. If either party hereto breaches any provision hereof, the other party
shall have the right, at his-or her election,to sue for damages for such breach, or seek such other
remedies or relief as may be available to him or her. The non-breaching party shall be entitled to
recover from the breaching party all costs, expenses and legal fees actually incurred in the
enforcement of the rights of the non-breaching party.
13
16. WAIVER OF BREACH. The waiver by one party of any breach of this
Agreement by the other party will not be deemed a waiver of any other breach or any provision of
this Agreement.
17. NOTICE. Any notice to be given under this Agreement by either party to the
other shall be in writing and may be accomplished by registered or certified mail, return receipt
requested. Notice to Husband will be sufficient if made or addressed to the following:
Thomas V. Waddington
31 Indiana Circle
Lemoyne,PA 17043
and to Wife, if made or addressed to the following:
Julia Waddington
137 Blacksmith Road
Camp Hill,PA 1.7011
Notice shall be deemed to have occurred upon the date received by the recipient. Each party may
change the address for notice to him or her by giving notice of that change in accordance with the
provisions of this paragraph.
18. APPLICABLE LAW. All acts contemplated by this Agreement shall be
construed and enforced under the substantive laws of the Commonwealth of Pennsylvania
(without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of
execution of this Agreement.
19. DATE OF EXECUTION. The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which the parties signed the Agreement if they
do so on the same date, or if not on the same date, then the date on which the Agreement was
signed by the last party to execute this Agreement.
20. EFFECTIVE DATE. This Agreement shall become effective and binding upon
both parties on the execution date.
21. EFFECT OF RECONCILIATION, COHABITATION OR DIVORCE. This
Agreement shall remain in full force and effect and shall not be abrogated even if the parties
effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This
14
Agreement also shall continue in full force and effect in the event of the parties' divorce. There
shall be no modification or waiver of any of the terms hereof unless the parties in writing execute
a statement declaring this Agreement or any term of this Agreement to be null and void.
22. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text
of the several paragraphs and subparagraphs hereof are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor shall they affect its meaning,
construction or effect.
23. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall
bind the parties hereto and their respective heirs, executors, administrators, legal representatives,
assigns, and successors in any interest of the parties hereto.
24. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully
read this Agreement; that he or she has discussed its provisions with an attorney of his or her
own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that
this instrument expresses the entire agreement between the parties concerning the subjects it
purports to cover and supersedes any and all prior agreements between the parties. This
Agreement should be interpreted fairly and simply, and not strictly for or against either of the
parties.
25. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver
to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations,
tax returns, and other documents, and shall do or cause to be done every other act or thing that
may be necessary or desirable, to effectuate the provisions and purposes of this Agreement. If
either party unreasonably fails on demand to comply with these provisions,that party shall pay to
the other party all attorney's fees, costs, and other expenses actually incurred as a result of such
failure.
26. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated
into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into
said decree. The parties shall have the right to enforce this Agreement under the Divorce Code
of 1980, as amended, and, in addition, shall retain any remedies in law or in equity under this
15
Agreement as an independent contract. Such remedies in law or equity are specifically not
waived or released.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the
date hereinabove set forth.
a /
(T�
i F,PGi'4
ES Thomas V. Waddington
SS
'JuakWaddington
16
EXHIBIT"A"
Expended by Husband:
Park Custom Homes- $5,750.00 (August 7, 2013)
Interest through August 14,2013 - $247.26
Aaron Martin- $575.00 (July 19, 2013)
Buchannan &Erb Repair Water Softener- $200.00 (June 13, 2013)
Expended by Wife:
Garbage Disposal - $106.00
Pool Pump and Installation - $474.94
Sewer&Refuse bill paid through September 30, 2013 - $105.93
EXHIBIT`B"
Shadel Roofing Proposal - $17,250.00
Echo Proposal - $7,049.00(General Construction)
Aaron Martin Proposal -$525.00 (Landscaping)
ar r a
PROPOSALSUBMRTEDTO PHONE DATE
Tom Waddington 433-1846 7/5/13
STET JOB NAME
1540 McCormick Drive
CfM-STATE AND ZIP CODE JOB LOCATION
Mech. , Pa. 17055 same
AACHR'ECT DATE OF PLANS JOB PHONE
e h mltspec affone and tas
$17250.00 Li f etime.warranty TIMBERLINE architectural shingle on roof. (I1
0 MPH)
Labor and materials to remove and haul away existing roofing. Check condition of wood.
Install tar felt paper with cap nails. Install class A fiberglass shingles with nails.
Install new heavy gage F5 aluminum drip metal along all outside edges.
Install new rubber and galvanized vent collar boots around all pipes (high quality).
Install new custom formed aluminum base and cap flashings around chimney.
Install aluminum ridgevent along all the roof peaks. Paint and reuse exhaust fan.
Included -- Install snow and ice shield along bottom edges 3' wide under shingles.
InstaW snow and ice shield in the valleys and conceal them with shingles.
Customer will obtain building permit if needed.
All debris will be thrown from roof onto truck and not in yard. Tarps are used elsewhere.
Wood replacement will be extra at $1.50 plywood and $3.00 for boards per square foot.
Written warranty will be issued by the manufacturer on materials. Contractor warrants labor
against defects. We are manufacturer certified and HIC registered ) A19206.
We P OpOW hereby to tudsh material and labor-complete in a000rdano_s with above apes loa8ons,for Ow sum of:
see page 2 donan<�
rayrnenr ro Ae made as touoae:
AM material is aaarardeed 10 be as aPICMed• Jul WOO to be aorMS"d In a 1011",l4i worlanalk0 Authorized
manes woordo9 to ep am*bmlgd Per$1006W Pia Any abnellon or deoietlon Yom
six"s"1 alts IINONYg adA a0ek aal to executed ody upon soNton orders,and wi beowns Swrattua
an ema ormp over and ebwe ftu sslin e.Map*--ft OoMiaperd q-atdk1%aeddatda Or
l aihar mk�aatr,ov+aker fie: us It
we
My covered WoriuwnCaepsution I � days.
Acceptance of Propose/ -The above prices,
speei6oations and conditions are satisfactory and are hereby accepted.
You are authorized to do the work as specified. Payment wilt be made
as outlined above. Signature
Date of Acooptance: sure
PFOPi SAL SUBMMW TO PHONE DATE
Tom Waddington 715/13
STREET JOB NAME
CITY,STATE AND ZIP CODE JOB LOCATION
AACW MCT DATE OF PLANS JOB PHONE
We carry $1,000,000 property damage and $100,000 workmans insurance. Start date and
completion date will be given upon acceptance. You may cancel within 3 days after signing.
We PrOPOSe hereby to famish material and labor-complete In accordanoe wNh&bows spw t WoM,for Die sum or.
seventeen thousand two hundred fifty $17250.00
Parraw to be made as fonts:
25% non-refundable deposit due upon acceptance. Full payment received within 10 days after
completion of job. Overdue accounts are subject to a 20% interest rate and lawyer fees.
Ad ari M k gmQaisaed io iM o gratihd.M wank In be WMWW in a eubdw"W*&—ft AWm rindl
MWOtd
mennw saaardlig ba eperaiotlloiie VA w wndud pnasae,.AM as,rasan or drAmbn tam
abow,peoiioetlaiwt YfuolYeg r�laead,wtA ba eowougd arty uptln rd>sen Orden,V W w/i 6aoonN
an rare dwp ewer end sbwe the edlm%W M ap vMM upon dare a or wMxkuwn
dslarsyb o worm o to me�mdo ana other naawy inertia.our workrs NOM:This by us tt noder be MMNn 30 days
Acceptance of Proposal -The above
apeefteticris and condltkma are satisfactory WO are hereby accepted.
You an authorized to do the work as epeexled. Payment VAN be made
as oudwod a . Sign
bove sriee
Dam of Acceptsttce:
Echo Estimate
320 S.York Street - a- 08/09/2013 1
Mechanicsburg, PA 17055
Fc 1012
(7j7)443-1944 Fx> £?ale
info @GoEcho.net — -
'1�ttr:;5s
Tom Waddington
1540 McCormick drive
Mechanicsburg,pa 17055
i _
08/09/2013 iremove wall oven/microwave combo and replace with double wall oven(or remove and 1,249.00
;replace wall oven microwave combo$2549) ($1,059 allowance on double wall oven)
08/09/2013:remove and replace garbage disposal 199.00
08/09/2013 remove and replace black dish washer ($249 allowance on dishwasher) 435.00
08/09/2013 ipressure wash and paint pressure treated stairs, replace two flag stones and level rest of 535.00
!stain;.replace 3 posts with pressure treated 44's and install new railing
08/09/2013;sand and paint back door 85.00
08109/2013'remove and replace carpet in den,study, master,and hall. 1015 sgft(price does not 2,030.00
,include pad)
08/09/2013:steam clean all other carpet 1,128sgft 699.00
08/09/2013:whole house cleaning- includes vacuuming,wiping all walls,inside of closets,ceilings in 495.00
:each room,all wood doors,baseboard, and trim,cleaning interior side of all glass
'windows(13)and sliding glass doors(4),complete cleaning of full bathrooms(3),
Cleaning the kitchen counters, cabinets, sinks,and inside of the kitchen
refrigerator/freezer,and vacuuming and mopping,as appropriate,all floors in the house
08/09/2013;fix ceilings in bath, master bath,3rd bed,and kitchen prime and paint(spot paint and 350.00
,blend in kitchen)
08/09/2013130 yard dumpster rental(21 day)additional weight and time charges may apply 600.00
08/09/2013 remove two freezers from basement 100.00
08/09/2013 clean basement and garage 125.00
08109/2013?replace trim in basement and paint wall 92.00
08/09/2013,porch-dust,and remove cobwebs on the screen and frame.vacuum, hose and mop file 55.00
ifloor
08/09/2013 price per hour to assist with removing trash($18.75) 0.00
i
Total $7jO49.00
Accepted By Accepted Date
www.GoEcho.net 320 S.York Street,Mechanicsburg, PA 17055 717-443-1944
w KEYSTONE PROPOSAL AND
ACCEPTANCE
MAINTENANCE Phone: 717-7742086
717.562.4182
Toll Free:1-666-836-7422
PROPOSALISUBMITT15D TO WORK TO BE PERFORMED AT:
to t , t
STREET -#� (� ADDRESS
CITY,STATE and ZIP CODE CITY,STATE.
PHONE NO. DATE OF PLANS DATE OF PLANE J08 PHONE
We here by propose to furnish the materials and perform the labor necessary for the completion of
,a0
6. o�
Alt material is guaranteed to be as specified,and the above work to be performed in accordance with the drawings and specirications submitted for above
work and completed In a substantial workmanlike manner for the sumo of:
Payment to be made as follows: Willem$
Any alternations or deviation from above speciricallons involving extra costs
will be executed only upon written order,and will become an extra charge over Authorized
and above the estimate.All agreements contingent upon strikes,accidents, Signature
or delays beyond our control. Note:This proposal may be
withdrawn by us if not accepted withll days.
Acceptance of Proposal-The above prices,specifications and conditions
are sa9sWory and are hereby accepted. You are authorized to do the wank as spselfird. Signattxe
Peymaa will be made as c.rtlined above.
Date of Aooeptance �a
_ 1" L 0-0FF"ICE:
Samuel L. Andes,Esquire X11" THE PRO TH�3NQ TA,R y
Attorney I.D.No. 17225
525 North Twelfth Street 2013 AUG 30 PM 2: 06
P.Q.Box 168
Lemoyne,PA 17043 CUMBERLAND COUNTY
Attorneys for Plaintiff PENNSYLVANIA
JU'lA WADDINGTON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. :NO. 10-1763
THOMAS WADDINGTON, : CIVIL ACTION—LAW
Defendant : IN DIVORCE
PRAECIPE TO WITHDRAW CLAIMS
TO THE PROTHONOTARY:
Please withdraw the claims for equitable distribution, alimony,alimony pendente lite,
counsel fees, costs and expenses filed on behalf of Plaintiff in the above-captioned divorce action.
Date: u!
ie ��, Qu
Attorney I.D. #17225
P.O. Box 168
Lemoyne, PA 17043-0168
(717) 761-5361 (phone)
(717) 761-1435 (fax)
Attorneys for Plaintiff
;1 PRt3Tl� 1TAR`
2 13 AUG 30 P t y 1
JULIA WADDTNGTON ciiMBERLAN
, OURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 10-1763
THOMAS WADDINGTON CIVIL ACTION-LAW
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record,together with the following information,to the Court for entry of a
Divorce Decree:
1. Ground for divorce:irretrievable breakdown under Section(x}3301(c) { }
3301(d)of the Divorce Code.
2. Date and manner of service of the Complaint:Upon counsel for Defendant on
March 25,2010 as evidenced by the Acceptance of Service on record.
3. Complete either paragraph(a)or(b).
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c)of the Divorce Code: by Plaintiff`.August 27,2013;by Defendant:
August 27, 2013.
(b) (1) Date of execution of the Plaintiff's Affidavit required by Section
3301(d)of the Divorce Code:
(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: All claims have been settled pursuant to a Marital
f
Settlement Agreement dated August 27,2013.
5. Date and manner of service of the notice of intention to file Praecipe to Transmit
Record,a copy of which is attached,if the decree is to be entered under Section 3301(d)of the
Divorce Code:
or,date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree
under Section 3301(c)of the Divorce Code: by Plaintiff: August 27,2013;by Defendant: August
27,2013.
and,date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce
Decree: by Plaintiff: August 27,2013;by Defendant: August 27,2013.
JSDC Law Offices
Dated: August 29,2013 By.
o J Cann ly,Jr.
ttpIn
V
11 . IjD. 15615
P.O. Box 650
Hershey,PA" 17033-0650
(717)533-3280
Attorneys for Defendant
INCOME WITHHOLDING FOR SUPPORT
0 ORIGINAL INCOME WITHHOLDING ORDER/NOTICE FOR SUPPORT(IWO) 2 -751 4q I I I +rz L�
(D AMENDED IWO
0 ONE-TIMEORDERINOTICE FOR LUMP SUM PAYMENT
0 TERMINATION OF IWO Date: 09104/13
❑ Child Support Enforcement(CSE)Agency Z Court ❑ Attorney 171 Private Individual/Entity(Check One)
NOTE:This IWO must be regular on its face.Under certain circumstances you must reject this IWO and return it to the sender(see IWO
instructions http://www.acf;hhaai /p"ti ciegAs/cse/newhire/empl:L)yer/publication/oublication.htm-forms).If you receive this document from
someone other than a State or Tribal CSE agency or a Court,a copy of the underlying order must be attached.
State/Tribe/Territory Commonwealth of Pennsylvania Remittance Identifier(include w/payment): 2480102656
City/County/Dist./Tribe CUMBERLAND Order Identifier: (See Addendum for orderldocket Informalton)
Private Individual/Entity CSE Agency Case Identifier: (See Addendum for case summary)
GANNETT FLEMING INC' RE: WADDINGTON,THOMAS V.
PO BOX 67100 Employee/Obligor's Name(Last,First,Middle)
HARRISBURG PA 17106-7100 164-58-4702
Employee/Obligor's Social Security Number
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Party/Obligee's Name(Last,First,
Middle)
Employer/income Withholder's FEIN 251613591 NOTE:This IWO must be regular on its face.
Under certain circumstances you must reject
Child(ren)'s Name(s)(Last,First,Middle) Child(ren)'s Birth Date(s) this IWO and return it to the sender(see IWO
instructions
http:llwww,acf.hhs.gov/programs/ose/newhire
employerlpublication/r)ublication.htm-formal.If
you receive this document from someone other
than a State or Tribal CSE agency or a Court,a
copy of the underlying order must be attached.
2516135910
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This document is based on the support or withholding order from CUMBERLAND County,
Commonwealth of Pennsylvania (State/Tribe). You are required by law to deduct these amounts from the employee/
obligor's income until further notice. C_
$ 1,334.00 per month in current child support
$ 0.00 per month in past-due child support- Arrears 12 weeks or greater? 0 y
$ 0.00 per month in current cash medical support =::o -0
wr-
$ 0.00 per month in past-due cash medical support _<)> Ct C:)
$ 700.00 per month in current spousal support r—=
$ 0.00 per month in past-due spousal support C:)-n
C5
$ 0.00 per month in other(must specify)
for a Total Amount to Withhold of$ 2,034.00 per month.
AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information.
If your pay cycle does not match the ordered payment cycle, withhold one of the following amount:
$ 469.3cl per weekly pay period. $ 1,0 17.00 per semimonthly pay period(twice a month)
$ 93q 37 per biweekly pay period(every two weeks) $ 2,034.00 per monthly pay period.
$ Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order.
REMITTANCE INFORMATION: If the employee/obligor's principal place of employment is within the Commonwealth
of Pennsylvania (State/Tribe), you must begin withholding no later than the first pay period that occurs ten (10)
working days after the date of this Order/Notice. Send payment within seven (7)working days of the pay date. If
you Cannot withhold the full amount of support for any or all orders for this employee/obligor, withhold up to 55% of
disposable income for all orders. If the employee/obligors principal place of employment is not within the
Commonwealth of Pennsylvania (State/Tribe), the employer can obtain withholding limitations, time requirements,
and any allowable employer fees at http://www.acf.hhs.-gov/programs/cse/newhire/employer/contacts/contact -map.
htm for the employee/obligor's principal place of employment.
Document Tracking Identifier
OMB No.:0970-0154 Form EN-028 06/12
Service Type M Worker ID$IATT
❑ Return to Sender[Completed by Employer/Income Withholder]. Payment must be directed to an SDU in
accordance with 42 USC§666(b)(5)and (b)(6)or Tribal Payee(see Payments to SDU below). If payment is not
directed to an SDU/Tribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to
the sender.
Signature of Judge/Issuing Official (if required by State or Tribal law):
Print Name of Judge/Issuing Official:
Title of Judge/Issuing Official:
Date of Signature:
If the employee/obligor works in a State or for a Tribe that is different from the State or Tribe that issued this order,a copy of this IWO
must be provided to the employee/obligor.
❑ If checked,the employer/income withholder must provide a copy of this form to the employee/obligor.
ADDITIONAL INFORMATION FOR EMPLOYERS/INCOME WITHHOLDERS
Pennsylvania law(23 PA C.S.§4374(b))requires remittance by an electronic payment method if an employer is ordered
to withhold income from more than one employee and employs 15 or more persons, or if an employer has a history of
two or more returned checks due to nonsufficient funds. Please call the Pennsylvania State Collections and
Disbursement Unit(PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 1D(shown above as
the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT
SEND CASH BY MAIL.
State-specific contact and withholding information can be found on the Federal Employer Services website located at:
http://www.acf.hhs.gov/programs/cse/newhire/employer/contacts/contact map.ht m
Priority: Withholding for support has priority over any other legal process under State law against the same income(USC 42
§666(b)(7)). If a Federal tax levy is in effect, please notify the sender.
Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from
more than one employee/obligor's income in a single payment. You must, however, separately identify each employee/
obligor's portion of the payment.
Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a
Tribal CSE agency. If this IWO instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial
party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent
by a Court,Attorney, or Private Individual/Entity and the initial order was entered before January 1, 1994 or the order was
issued by a Tribal CSE agency, you must follow the"Remit payment to" instructions on this form.
Reporting the Pay Date: You must report the pay date when sending the payment.The pay date is the date on which the
amount was withheld from the employee/obligor's wages. You must comply with the law of the State(or Tribal law if
applicable)of the employee/obligor's principal place of employment regarding time periods within which you must implement
the withholding and forward the support payments.
Multiple IWOs: If there is more than one IWO against this employee/obligor and you are unable to fully honor all IWOs due to
Federal, State, or Tribal withholding limits,you must honor all IWOs to the greatest extent possible, giving priority to current
support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee/obligor's principal
place of employment to determine the appropriate allocation method.
Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this
employee/obligor such as bonuses,commissions, or severance pay. Contact the sender to determine if you are required to
report and/or withhold lump sum payments.
Liability: If you have any doubts about the validity of this IWO, contact the sender. If you fail to withhold income from the
employee/obligor's income as the IWO directs,you are liable for both the accumulated amount you should have withheld and
any penalties set by State or Tribal law/procedure.
Anti-discrimination: You are subject to a fine determined under State or Tribal law for discharging an employee/obligor from
employment, refusing to employ, or taking disciplinary action against an employee/obligor because of this IWO.
OMB Expiration Date—05/31/2014.The OMB Expiration Date has no bearing on the termination date of the IWO;it identifies the version of the form currently in use.
Form EN-028 06/12
Service Type M Page 2 of 3 Worker ID$IATT
Employer's Name: GANNETT FLEMING INC* Employer FEIN: 251613591
Employee/Obligor's Name: WADDINGTON,THOMAS V. 2480102656
CSE Agency Case Identifier:(See Addendum for case summary) Order Identifier:(See Addendum for order/docket information
Withholding Limits:You may not withhold more than the lesser of: 1)the amounts allowed by the Federal Consumer Credit Protection
Act(CCPA)(15 U.S.C. 1673(b));or 2)the amounts allowed by the State or Tribe of the employee/obligor's principal place of
employment(see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such
as: State, Federal, local taxes;Social Security taxes;statutory pension contributions;and Medicare taxes.The Federal limit is 50%of
the disposable income if the obligor is supporting another family and 60%of the disposable income if the obligor is not supporting
another family.However,those limits increase 5%-to 55%and 65%-if the arrears are greater than 12 weeks. If permitted by the State
or Tribe, you may deduct a fee for administrative costs.The combined support amount and fee may not exceed the limit indicated in
this section.
For Tribal orders,you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employers/income
withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which
the employer/income withholder is located or the maximum amount permitted under section 303(d)of the CCPA(15 U.S.C. 1673(b)).
Depending upon applicable State or Tribal law,you may need to also consider the amounts paid for health care premiums in
determining disposable income and applying appropriate withholding limits.
Arrears greater than 12 weeks?If the Order Information does not indicate that the arrears are greater than 12 weeks,then the
Employer should calculate the CCPA limit using the lower percentage.
Additional Information:
NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employee/obligor never worked for you or you are
no longer withholding income for this employee/obligor,an employer must promptly notify the CSE agency and/or the sender by
returning this form to the address listed in the Contact Information below: 2516135910
Q This person has never worked for this employer nor received periodic income.
0 This person no longer works for this employer nor receives periodic income.
Please provide the following information for the employee/obligor:
Termination date: Last known phone number:
Last known address:
Final Payment Date To SDU/Tribal Payee: Final Payment Amount:
New Employer's Name:
New Employer's Address:
CONTACT INFORMATION:
To Employer/income Withholder: If you have any questions, contact WAGE ATTACHMENT UNIT(Issuer name)
by phone at(717)240-6225, by fax at(717)240-6248, by email or website at:www.childsupport.state.pa.us.
Send termination/income status notice and other correspondence to:DOMESTIC RELATIONS SECTION, 13 N. HANOVER ST.
P.O. BOX 320, CARLISLE, PA. 17013(Issuer address).
To Employee/Obligor: If the employee/obligor has questions, contact WAGE ATTACHMENT UNIT(Issuer name)
by phone at(717)240-6225, by fax at(717)240-6248, by email or website at www.childsupport.state.pa.us.
IMPORTANT:The person completing this form is advised that the information may be shared with the employee/obligor.
OMB No.:0970-0154 Form EN-028 06/12
Service Type M Page 3 of 3 Worker ID $IATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: WADDINGTON,THOMAS V.
PACSES Case Number 213113751 PACSES Case Number 491114184
Plaintiff Name Plaintiff Name
JULIA A.WADDINGTON JULIA A.WADDINGTON
Docket Attachment Amount D et Attachment Amount
00045S2013 $ 1,334.00 10-1763 CIVIL $ 700.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
HANNAH N.WADDINGTON
RYAN T.WADDINGTON 06/06/99
PACSES Case Number PACSES Case Number
Piaintiff Name Plaintiff Name
Docket Attachment Amount Docket Altachment Amours
$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s)* DOB
PACSES Case Number PACKS Case-Number
Plaintiff Name Plaintiff Nam
Docket Attachment Amount Docket Attachment Amount
$ 0.00 $ 0.00
Child(ren)'s Name(s): DOB Child(ren)'s Name(s): DOB
Addendum Form EN-028 06/12
Service Type M OMB No.:0970-0154 Worker 10$IATT
IN THE COURT OF COMMON PLEAS OF
JULIA WADDINGTON CUMBERLAND COUNTY, PENNSYLVANIA
V.
THOMAS WADDINGTON NO 10-1763
DIVORCE DECREE
AND NOW, /.1�,�1'r,..��r s` Za 3 , it is ordered and decreed that
JULIA WADDINGTON , plaintiff, and
THOMAS WADDINGTON , 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.")
The parties' Marital Settlement Agreement dated"August 27, 2013 is hereby
incorporated, but not merged, into this Decree in Divorce.
By the Court,
ts -
J.
rothonotary
CeA Copy r-Y6 ed 4o o-ttq Ades
Nemec + &Py 4o Connelly
M��e i3
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