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04-2988
O LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540.6833 Attorney ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, AN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. e - j 98e :CIVIL ACTION - LAW JN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. Ifyou wish to defend against the claims set forth in the following pages, youmust take prompt action. You are warned that ifyou fail to do so, the casemay proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any claim ofreliefrequested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the divorce is indignities orirretrievable breakdownofthemarriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 E. Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attomey ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. :CIVIL ACTION - LAW :IN DIVORCE NOTICIA Le handemandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) diasde plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentaruna apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones alas demandas en contr de su persona. Sea avisado que si usted no se defiende, ]a torte tomara medidas y puede entrar una order contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONAO LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION DE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service 2 E. Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attorney ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 04(, aZ9.?y :CIVIL ACTION - LAW JN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR SECTION 3301 (D) OR SECTION 3301(a)(6) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Warren Scott Cornelius, by and through his attorney, William T. Tully, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Warren Scott Cornelius, is an adult individual who resides at 411 Brian Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Tina Marie Cornelius, is an adult individual who resides atl900 State Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6) months immediatelyprior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1992 in Franklin County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America. LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 7171540.6833 Attorney ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. :CIVIL ACTION - LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. Ifyou wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that ifyou fail to do so, the case may proceed without you and a decree of divorce or annulment maybe entered against you by the court. A judgment may also be entered against you for any claim ofreliefrequested in thesepapers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation ofyour children. When the grounds for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 E. Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attorney ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. :CIVIL ACTION - LAW :IN DIVORCE NOTICIA Le han demandado a usted en la eorte. Si usted quiere defenderse de estasdemandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo alpartir de la fecha de la demanda y la notificacion. Usted debepresentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus obj eciones alas demandas en contr de su persona. Sea avisado que si usted nose defiende, la corte tomara medidas ypuede entraruna orden contra usted sinprevio aviso onotificacionyporcualquierquejaoalivioqueespedidoenlapeticiondedemanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO ALA OFICINA CUYA DIRECCION DE ENCUENTRA ESCRITA ABAJOPARA AVERIGUARDONDE SEPUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service 2 E. Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite H Harrisburg, PA 17109 717/540-6833 Attomey ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. p'?/_ 6s oV :CIVIL ACTION - LAW :IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR SECTION 3301 (D) OR SECTION 3301 (a)(6) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Warren Scott Cornelius, by and through his attorney, William T. Tully, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Warren Scott Cornelius, is an adult individual who resides at 411 Brian Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Tina Marie Cornelius, is an adult individual who resides atl900 State Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania and have resided therein foraperiodin excess ofsix (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1992 in Franklin County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America. LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attomey ID #36410 6. Plaintiffavers, that the ground upon which this action is based is that the marriage is irretrievably broken. 7. In the alternative, Plaintiff avers that the ground upon which this action is based is that the Defendant offered such indignities as to render the Plaintiff's condition intolerable and life burdensome. 8. There has been no prior action of divorce between the parties in this or any otherjuri sdiction. 9. Neither the Plaintiffrior the Defendant are not members of the Armed Services of the United States of America. 10. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the right to request that the court require the parties to participate in counseling. 11. There are three children bornofthismarriage, namely Jessica Lynn Cornelius, born March 8, 1995; Sara Elizabeth Cornelius, born July 1, 1998; and David Scott Cornelius, bom April 19, 2000. WHEREFORE, the Plaintiffrequests this Honorable Court to enter aDecree in Divorce from the bonds of matrimony. 2 Respectfully submitted, Dated: By: c%cct _ William T. Tully, Esquire Supreme Court I.D. #36410 3964 Lexington Street, Suite A Harrisburg, PA 17109 (717) 651-9100 Attorney for plaintiff VERIFICATION I verify that the statements made m the foregoing document are true and correct. Iunderstand that false statements herein are made subject to the penalties of 1 S Pa.C.S.A. §4904, relating to unswom falsification to authorities. Date: C A'7 ? X ' ,,I4,? J60:O- [fir LAW OFFICE OF WILLIAM T. TULLY William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 717/540-6833 Attomey ID #36410 WARREN SCOTT CORNELIUS, PLAINTIFF V. TINA MARIE CORNELIUS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. :CIVIL ACTION - LAW AN DIVORCE CERTIFICATE OF SERVICE AND NOW, thi day ofj ?k-a w 2004, I, Tammy L. Kelly, of the Law Office of William T. Tully, hereby certify that a true and correct copy of the foregoing Complaint in Divorce will be served by the undersigned by United States first class certified mail, return receipt requested, postage prepaid, addressed as follows: RETURN RECEIPT REQUESTED 7003 1680 0004 61014526 Karen Koenigsberg, Esquire Dissinger & Dissinger 28 North 32 ad Street Camp Hill, PA 17011 A G)--? a? Tammy Kelly ? ?. ? o ? v. ? ?. - , _, ? ? ?. ?? _ . ?, w` ? ? ? Y :; ? ? ?? ?, o „?, = - ? -. _. !1 iWARREN SCOTT CORNELIUS, Plaintiff VS. TINA MARIE CORNELIUS, Defendant N O T I C E : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-2988 : IN DIVORCE T O D E F E N D You have been sued in court. If you wish to defend gainst the claims set forth in the following pages, you must ake prompt action. You are warned that if you fail to do so, he case may proceed without you and a decree of divorce or nnulment may be entered against you by the court. A judgment ay also be entered against you for any other claim or relief equested in these papers by the Plaintiff. You may lose money r property or other rights important to you, including custody r visitation of your children. When the ground for the divorce is indignities or rretrievable breakdown of the marriage, you may request arriage counseling. A list of marriage counselors is vailable in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF RTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IIS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE CE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 (WARREN SCOTT CORNELIUS, Plaintiff VS. TINA MARIE CORNELIUS, Defendant IN TH13 COURT OF COMMON PLEAS OF C04BERLAND COUNTY PENNSYLVANIA CIVIL ACTION NO. 04-2988 IN DIVORCE ANSWER AND NOW COMES the Defendant, Tina M. Cornelious, by her attorney, Karen L. Koenigsberg, Esquire, and files the following Answer and in support thereof avers as follows: I1. Admitted in part and denied in part. It is admitted that the Plaintiff is Warren Scott Cornelious, an adult individual. lIt is denied that Plaintiff resides at 411 Brian Court, chanicsburg, Cumberland County, Pennsylvania, 17050. By way further answer, it is believed that Plaintiff currently sides with his mother near Willow Hill, Pennsylvania. Admitted in part and denied in part. It is admitted that Defendant is Tina Marie Cornelious, an adult individual. lIt is denied that Defendant lives at 1900 State Street, Lemoyne, Cumberland County, Pennsylvania, 17043. By way of further answer, Defendant resides at 1902 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. Admitted. Denied. It is specifically denied that Plaintiff and endant were married on October 2, 1992, in Franklin County, nnsylvania. By way of further answer, Plaintiff and fendant were married on October 3, 1992. 15. Admitted. 16. No answer is required. 7. No answer is required, however, it is specifically denied that Defendant offered such indignities as to render the Plaintiff's condition intolerable and life burdensome. 18. Admitted. 19. Admitted. 10. Defendant is without sufficient knowledge to either admit or deny the averments in paragraph tern (10). 11. Admitted in part, however, the correct spelling of the parties' daughter's name is "Sarah Elizabeth Cornelious." COUNTERCLAIM AND NOW COMES the Defendant, Tina M. Cornelious, by her attorney, Karen L. Koenigsberg, Esquire, and files the following Counterclaim and in support thereof avers as follows: COUNT I Request for Equitable Distribution of Marital Property Under 3104 and 3502(a) of the Divorce Code 12. The prior paragraphs of this Answer are incorporated herein by reference thereto. 13. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of said marriage until the date of their separation. 14. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Defendant requests the court to equitably distribute the property. COUNT II Request for Alimony Pe,ndente Lite and Alimony under 3104, 3701, 3702 and 3704 of the Divorce Code 115. The prior paragraphs of this Answer are incorporated herein by reference thereto. I16. Defendant is unable to sustain herself during the course of litigation. 7. Defendant lacks sufficient property to provide for her easonable needs and is unable to sustain herself through ppropriate employment. WHEREFORE, Defendant requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor, pursuant to 3104, 3701, 3702 and 3704 of the Divorce Code. COUNT III Request for Counsel Fees, Costs and Expenses Under 3104 and 3502(a) of the. Divorce Code 18. The prior paragraphs of this Answer are incorporated herein ov reference thereto. L9. Defendant has employed Karen L. Koenigsberg, Esquire, of the Law firm of Dissinger and Dissinger to represent her in this natrimonial cause. 20. Defendant is unable to pay the necessary counsel fees, costs, and expenses and Plaintiff is more than able to pay them. WHEREFORE, reserving the right to apply to the court for temporary counsel fees, costs and expenses, prior to final hearing, Defendant requests that, after final hearing, the Court order Plaintiff to pay Defendant's reasonable counsel fees, costs and expenses. Respectfully Submitted: DISSINGER AND DI By: C?n e JM C %LYY MA Attdrney for Defendant" Supreme Court ID # 85556 28 N. 32d Street Camp Hill, PA 17011 717-975-2840 VERIFICATION' I, Tina M. Cornelious, verify that, the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. , lam/ n/r Tina M. Cornelious WARREN SCOTT CORNELIUS, Plaintiff Vs. TINA MARIE CORNELIUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION NO. 04-2988 IN DIVORCE CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, do hereby certify that a copy of the foregoing document has been duly served upon William T. Tully, Esquire, attorney for Plaintiff, by depositing same in the United States Mail, postage prepaid, addressed as follows: William T. Tully, Esquire 3964 Lexington Street Suite B Harrisburg, PA 17109 te. Oren L. Koenig berg Attorney for Defendar. ? O ?-? N ? i r ! ? 1 ? 1 ( ? /-T ?Il?_{ ' ,m C7 W ? ??J ?? ??i ? i <, i _ i 4: ?. WARREN SCOTT CORNELIUS, Plaintiff VS. TINA MARIE CORNELIUS, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA : CIVIL ACTION : NO. 04-2988 : IN DIVORCE PETITION TO WITHDRAW APPEARANCE AND NOW COMES, Mary A. Etter Dissinger, counsel for Tina Marie Cornelius, and requests permission to withdraw as counsel and in support thereof avers as follows: 1. Petitioner is Mary A. Etter Dissinger, an attorney associated with Dissinger and Dissinger. 2. Respondent is Tina Marie Cornelius, Defendant in the within action. 3. Karen L. Koenigsberg, an attorney associated with Dissinger and Dissinger, entered her appearance on behalf of Tina Marie Cornelius on July 21, 2004, by filing an Answer to the Complaint in Divorce. 4. On November 30, 2004, Respondent left a telephone message at the office of Dissinger and Dissinger stating she no longer wished their representation of her. 5. On December 6, 2004, Tina M. Cornelius indicated in writing to Dissinger and Dissinger that she no longer wishes to utilize our services. (copy of said letter is attached hereto as exhibit "A") WHEREFORE, Petitioner requests that a Rule be issued upon Defendant and Plaintiff's counsel herein to show cause why the relief requested should not be granted. Respectfully Submitted, DISSINGER & DISSINGER Mary A. Etter Dissinger? Esquire Petitioner Supreme Court ID# 27736 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Mary A. Etter Dissinger, verify that the foregoing facts are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Mary Etter Dissinge I, Tina Marie Cornelius, no longer wish to use the services provided to me by Dissinger and Dissinger. /n y-.max Date Tina Marie Cornelius EXHIBIT A WARREN SCOTT CORNELIUS, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA VS. : CIVIL ACTION TINA MARIE CORNELIUS, : NO. 04-2988 Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Tina Marie Cornelius, Defendant, and William T. Tully, Esquire, attorney for Plaintiff, by depositing same in the United States Mail, postage prepaid, addressed as follows: Tina Marie Cornelius 1902 Princeton Avenue Camp Hill, PA 17011 William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 Date: / Mary A. Etter Dissinger0 CJ ., C l Johnson, Duffle, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 VICKIE D. BORGOLINI and HIRAM BORGOLINI, Plaintiffs V. SHEETZ, INC., OPW ENGINEERED SYSTEMS, OPW FUELING COMPONENTS, RICHARDS, AN OPW COMPANY and KEYSTONE PETROLEUM, Defendants NO. 04-3001 CIVIL ACTION - LAW JURY TRIAL DEMANDED KEYSTONE PETROLEUM'S REPLY TO NEW MATTER AND NOW, this -19& of December, 2004, comes Defendant Keystone Petroleum, through its undersigned attorneys, and replies to the new matter of Defendant: Sheetz, Inc. as follows: NEW MATTER 31.-34. Denied. These averments are deemed denied as ones to which no responsive pleading on the part of Defendant Keystone Petroleum is required. WHEREFORE, Defendant Keystone Petroleum demands judgment in its favor. NEW MATTER PURSUANT TO PA.R.C.P. 2252(d) Attorneys Tor Keystone Petroleum IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 35.-36. Denied. WHEREFORE, Defendant Keystone Petroleum demands judgment in its favor. JOHNSON, DUFFIE, STEWART & WEIDNER By: Z-2. ?,'.W.ofWei&ner, Jr. :240673 22740-1794 VERIFICATION The undersigned says that the facts set forth in the foregoing are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. KEYSTONE PE1W5M By: FN 'Christopher Weikert Date: CERTIFICATE OF SERWCE AND NOW, this /5)= day of December, 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Paul F. D'Emilio, Esquire Puleo & D'Emilio, LLC 660 Sentry Parkway Blue Bell, PA 19422 Stephanie E. Chertok, Esquire 61 West Louther Street Carlisle, PA 17013 Kevin C. McNamara, Esquire Thomas, Thomas & Hafer, LIP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 David F. White, Esquire Marshall, Dennehey, Warner Coleman & Goggin 620 West Germantown Pike, Suite 350 Plymouth Meeting, PA 19462 JOHNSON, DUFFIE, STEWART & W NER By: EJizdbeth L. Ziegler L-/U :240673 22740-1794 ' c '' `i? - ' _- ? 1 - i _- T."? i _ i , _. _ L, Johnson, Duffle, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 VICKIE D. BORGOLINI and HIRAM BORGOLINI, Plaintiffs V. SHEETZ, INC., OPW ENGINEERED SYSTEMS, OPW FUELING COMPONENTS, RICHARDS, AN OPW COMPANY and KEYSTONE PETROLEUM, Defendants NO. 04-3001 CIVIL ACTION - LAW JURY TRIAL DEMANDED KEYSTONE PETROLEUM'S REPLY TO NEW MATTER AND NOW, this 4tpy of December, 2004, comes Defendant Keystone Petroleum, through its undersigned attorneys, and replies to the new matter of Defendant Sheetz, Inc. as follows: NEW MATTER 34.-37. Denied. These averments are deemed denied as ones to which no responsive pleading on the part of Defendant Keystone Petroleum is required. WHEREFORE, Defendant Keystone Petroleum demands judgment in its favor. NEW MATTER PURSUANT TO PA.R.C.P. 2252(d) Attorneys for Keystone Petroleum IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 38.-39. Denied. WHEREFORE, Defendant Keystone Petroleum demands judgment in its favor. JOHNSON, DUFFIE, STEWART & WEIDNER B - Y . Roy Weidner, Jr. :240669 22740-1794 VERIFICATION The undersigned says that the facts set forth in the foregoing are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unswom falsifications to authorities. KEYSTONE P ?MUM By: F. Christoph eikerit Date: ?•??/?Dy CERTIFICATE OF SERVICE AND NOW, this /5 1day of December, 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Paul F. D'Emilio, Esquire: Puleo & D'Emilio, LLC 660 Sentry Parkway Blue Bell, PA 19422 Stephanie E. Chertok, Esquire 61 West Louther Street Carlisle, PA 17013 Kevin C. McNamara, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 David F. White, Esquire Marshall, Dennehey, Warner Coleman & Goggin 620 West Germantown Pike, Suite 350 Plymouth Meeting, PA 194632 JOHNSON, DUFFIE, STEWART & By: L. :240669 22740-1794 ' r?? ? ( • -_a t - ; r:._ r ,-? -- t -r C; ? - ? 'i' r,,? . ,. , cr-? - . WARREN SCOTT CORNELIUS, Plaintiff VS. TINA MARIE CORNELIUS, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION NO. 04-2988 IN DIVORCE MOTION TO MAKE RULE ABSOLUTE The Petition respectfully represents: 1. Petitioner is Mary A. Etter Dissinger, an attorney with the firm of Dissinger and Dissinger, with a place of business at 28 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania. 2. Respondent is Tina Marie Cornelius, residing at 1902 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. On December 10, 2004, Petitioner, Dissinger and Dissinger, counsel for Defendant, filed a Petition to Withdraw Appearance due to Defendant's request that we no longer provide services to her. 4. On December 15, 2004, this Honorable Court issued a Rule on Defendant and Plaintiff's counsel to show cause why the requested relief should not be granted. 5. The Rule to Show Cause of December 15, 2004, was served upon Tina Marie Cornelius on or about December 17, 2004 (See copy of letter to Ms. Cornelius attached as Exhibit "A"). 6. A copy of the Rule to Show Cause was served on William T. Tully, Esquire, counsel for Warren Scott Cornelius, on or about December 17, 2004 (See copy of letter to Attorney Tully attached as Exhibit "B"). 7. As of January 7, 2005, neither Defendant nor Plaintiff's counsel have filed an Answer to the Petition or Rule to Show Cause. WHEREFORE, Petitioner, Dissinger and Dissinger, requests this Honorable Court to make the Rule Absolute and order Dissinger and Dissinger withdrawn as counsel for Defendant. Respectfully submitted, DISSINGER AND DISSINGER Mary A. Etter Dissinger Petitioner Supreme Court ID #27736 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Mary A. Etter Dissinger, verify that the foregoing facts are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Mary A. Etter Dissinger Dk:)SINGER t,, DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices: 717.957.3474/voice • 717.957.2316/fax December 17, 2004 Tina M. Cornelious 1902 Princeton Avenue Camp Hill, PA 17011 Dear Ms. Cornelious: Enclosed, please find a Rule To Show Cause regarding our withdrawal from your case. You have ten (10) days within which to respond, if you choose to do so. Very truly yours, Mary A. Etter Dissinger Attorney at.Law 11 MAED:las encl: 2 .'iie 2-U4-544 EXHIBIT A Attorneys at Law 28 North Thirty-Second Street • Camp Hill, PA 17011 400 South State Road • Marysville, R 17053 DiSSINGER E'DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices: 717.957.3474/voice • 717.957.2316/fax December 17, 2004 William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 Re: Cornelious v. Cornelious Dear Mr. Tully: Enclosed, please find a Rule To Show Cause dated December 15, 2004. You have ten (10) days within which to respond, if you choose to do so. Very truly yours, Karen L. Koenigsberg Attorney at Law KLK:las encl : 1 - cc : - `T'ina M. Cornelious File 2-04-544 Attorneys at Law 28 North Thirty-Second Street • Camp Hill, PA 17011 400 South State Road • Marysville, PA 17053 r WARREN SCOTT CORNELIUS, Plaintiff VS. TINA MARIE CORNELIUS, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION NO. 04-2988 IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Tina Marie Cornelius and William T. Tully, Esquire, attorney for Plaintiff, by depositing same in the United States Mail, postage prepaid, addressed as follows: Tina Marie Cornelius 1902 Princeton Avenue Camp Hill, PA 17011 William T. Tully, Esquire 3964 Lexington Street, Suite B Harrisburg, PA 17109 Date: C--j a ? Mary A. Etter Dissinger '"' G --? _- ? ? ..- - . ., ?? :?? ? ? .', ? _ "i t? ' ?' _- rr `?:? ? --• i JAN 1 3 2005 N SCOTT CORNELIUS, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY : PENNSYLVANIA Vs. CIVIL ACTION MARIE CORNELIUS, NO. 04-2988 Defendant IN DIVORCE ORDER ?-y AND NOW this I ~ , day of lJ 2005, the appearance Dissinger and Dissinger for efendant, Tina Marie Cornelius, is ebv withdrawn from the record. E J. S c , WARREN SCOTT CORNELIUS vs Case No.() 4- 2 Q 8.q TINA MARIE CORNELIUS Statement of Intention to Proceed To the Court: Warren Scott Cornelius intends to proceed with the above captioned matter. Print Name W i 1 ] i a m T rt 7 7 zv , _Fg,f}gn Name z-- • ! % _? %r Date: Attorneyfor Plaintiff, Warren Scot Explanatory Comment Cornelius The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. C; --s'? ?? c? .? _ ,°? ? i ?.? ...J _. "' ..? a t_} .. fit,..... +?- `? bs r ? WARREN SCOTT CORNELIOUS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSY I VANIA . ;7 C3 -n V. NO. 04-2988 -0:t - - - M `-j TINA MARIE CORNELIOUS, CIVIL ACTION - LAW = r. © DEFENDANT IN DIVORCE 4C) MATRIMONIAL SETTLEMENT AGREEMENT ?b THIS AGREEMENT, made this day of-Wevember, 2010, by and between Wa rren Scott Cornelious, of 58 Montebello Road, Duncannon, Pennsylvania, 17020 ("Husband") and Tina Marie Cornelious, of06 S. Main Street, Marysville, Pennsylvania 17053 ("Wife"). NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows: PROPERTY SETTLEMENT A. Husband agrees to return the personal property as described in the attached list, and demanded by Wife. B. Husband agrees to pay to Wife an amount equal to $4,000.00. C. Wife agrees, that upon the return of the personal property as described in the attachment to this Agreement and the payment of $4,000.00, as follows: 1. Wife agrees to waive any and all rights to any other property that was, is now, or maybe in the possession of Husband, and any and all other property that was, is now, or maybe considered marital property. 2. Wife agrees to sign any and all documents necessary to finalize the divorce. INCOME TAX TREATMENT OF CHILDREN A. The parties have three children: Jessica, David, and Sarah. The parties agree to the following schedule representing the number of children each may claim on their individual federal income taxes for the years 2010-2012. Year Husband ,, G sg' 2010 34e6ii- J d,V d 2011 Jessica 2012 Jessica and David Wife 7'pgC J E 55 ( Ca' Ou Band Sarah David and Sarah Sarah B. The parties agree that, beginning in the year 2013, each will claim one child on their federal tax return. Beginning in the year 2013, Husband will claim David and Wife will claim Sara. It is assumed that their daughter Jessica will not be eligible to be claimed for federal income tax purposes after the year 2012. However, if Jessica is eligible to be claimed, the Husband will claim Jessica for all years after 2012. After Sarah reaches the age at which she will not be eligible to be claimed for federal income tax purposes, the parties will alternate claiming David for federal income tax purposes until he is no longer eligible to be claimed. CUSTODY AND CHILD SUPPORT A. The parties agree that they cannot agree on the terms of custody and child support. Therefore, all matters of custody and child support are not the subject of this agreement, and all issues regarding custody and child support are to be decided by the appropriate Administrative Agency and/or Court. The parties reserve all rights regarding custody and support. MUTUAL RELEASE A. Mutual Release. Except as otherwise provided herein and so long as this Agreement is not canceled by subsequent agreement, the parties hereby release and discharge, absolutely and forever, each other from any and all rights, claims and demands, past, present and future, resulting from the marriage relationship, specifically from the following: alimony pendente lite; alimony; spousal support; division of property; claims or right to pension or deferred compensation, claims or rights of dower and right to live in the House; right to act as executor or administrator in the other's estate; rights as devisee or legatee in the Last Will and Testament of the other; any claim or right as beneficiary in any life insurance policy of the other unless specifically named otherwise or as required herein; and any claim or right in the distributive share or intestate share of the other party's estate, all unless specified to the contrary herein or in a subsequent writing signed by the parties hereto. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first above written: WITNESS: HUSBAND: Warren Scott Cornelious Q IA- ,X-11z17 Qyjvl?," WITNESS: WIFE: l?z.•?L Lco u.o Tina Marie Cornelious STATE OF PENNSYLVANIA SS. COUNTY OF On this, the '?3O day of , 2010, before me, the undersigned personally appeared Tina Marie Cornelious, known to me (or satisfactorily proven) to be the persons whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. rW BORAW IA"A N, Nw" Pt.W Notary ,a n. A AD ,? Oreburg t':.M., ,d'Cou?yr y G?olrmk*w E Nov 8, 209 S STATE OF PENNSYLVANIA SS. COUNTY OF On zzann d of 2Q10, before me, the undersigned personally appeared & , o ?b'me (or satisfactorily proven) to be the persons whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. TH' Notary N? SEAL DEHORA'*-- : H hota+y b4ic Sppp?buB r.V'8?% +?+•Coe^ Nov. 8.201!4? DPW$ LIST OF PERSONAL PROPERTY TO BE RETURNED TO WIFE SG? -??=,is7? roorYs °?- h??? choir r ?q,?i rparr? l enl S??' r1' r49 E:?oo,f lP/G?r'e.J` 4? ?i ds f ?D / o.14 O. eziee5e,10',lr? O desk l GSUB/ e .- A:A741-r -r S IOP? y ? e .use a c.fi?v?i s??c .9 ors r f-rt?S ?Q? ? s' 9/nv? h4?yrny 4? CA cane c ciG C - 1?7 . 4,1- ' ' ZZ-e-' tZ- I'A /J'u//O OESORA? ?. KWYAD Nov. 8, 201S u/OU Vp 474 /.vc?S s ,bad y S?Hyr/ -j O jo Lowl, Wa? ot? GENERAL POWER OF ATTORNEY i, WARREN SCOTT CORNELIOUS, of Wheatfield Township, Perry County, Pennsylvania, hereby appoint my mother, BONNIE E. CORNELIOUS [hereinafter referred to as "my attorney"] my attorney for me and in my name and stead to transact all my business and to manage all my business and to manage all my property and affairs as completely as I myself might do if personally present, including but not limited to, exercising the following powers: 1. Execution of Contracts: To enter into, perform, modify, extend, cancel, compromise, enforce, or otherwise act with respect to any contract of any sort whatsoever -- including but not limited to, leases and mortgages--and to pay any money or transfer title and possession to any real or personal property that may be required to be paid or transferred by any contract or in the performance of any obligation entered into or incurred by me or on my behalf. 2. Investments: To invest in all forms of real and personal property without any restriction whatsoever as to the kind of investment, including but not limited to, United States Treasury Bonds which are redeemable at par in payment of federal estate taxes. 3. Registration of Property: To hold property unregistered or in the name of a nominee. 4. Personal Property: To buy or sell at public or private sale for cash or credit or partly for each, exchange, pledge, lease, give or acquire options for sales or exchanges or leases, or by any other means whatsoever to acquire, dispose of, repair, alter or manage tangible or intangible personal property or any interest therein; and, without limitation, with respect to any securities, to comply with any securities laws or regulations, to execute indemnity agreements, to purchase insurance and to pay commissions or discounts required by any underwriting. 5. Real Propert y: To buy or sell at public sale for cash or credit or partly for each, exchange, mortgage, encumber, lease for any period of time, give or acquire options for sale, purchases, exchanges or leases, dedicate, or by any other means whatsoever to acquire or dispose of real property or any interest therein; to partition and subdivide real property; to manage real property; to repair alter, erect or tear down any structure or part thereof; and to file such plans, applications, or other documents in connection therewith and do such other acts as may be requested by any government or other authority having or purporting to have jurisdiction. 6. Securities: To vote in person or by proxy at any meeting or to join in any merger, reorganization, voting-trust plan or other concerted action of security holders, to make payments in connection therewith, and in general to exercise all rights of a security holder. Further, my attorney is specifically authorized to sell or redeem United States treasury securities or any other securities of agencies, instrumentalities or establishments of the United States of America. 7. Insurance: To procure, alter, extend or cancel insurance against any and all risks affecting property and persons, and against liability, damage or claim of any sort. 8. Loans: To borrow money in such amounts for such periods and upon such terms as my attorney shall deem proper and to secure any loan by the mortgage or pledge of any property, and I specifically authorize my attorney to borrow money and to pledge property as collateral for the purpose of purchasing United States Treasury Bonds which are redeemable at par in payment of federal estate taxes. 9. Bank Accounts: To sign checks, drafts and other instruments or otherwise make withdrawals from any checking, savings, transaction or other deposit account in my name, and to endorse checks payable to me and receive the proceeds thereof in cash or otherwise; to open and close checking, savings, transaction or other deposit accounts in my name; to purchase and redeem savings certificates, certificates of deposit or similar instruments in my name; to execute and to deliver receipts for any funds withdrawn or certificates redeemed; and to do all acts regarding any checking account, savings account, savings certificate, certificate of deposit or similar instrument which I now have or may hereafter acquire, the same as I could do if personally present. Any financial institution may continue to rely on this power of attorney until it receives written notice from me that this power of attorney is revoked or actual notice of my death and shall be indemnified and held harmless by me and my estate, personal representatives and heirs against any liability or loss, including lawyers fees, costs of suit, and claims of third parties, which it might incur by relying on this power after termination or revocation but before it receives such notice, or at any time because of wrongful acts, omissions or representations of my attorney with respect to transactions covered by this power of attorney. My attorney shall be subject to whatever bank rules and regulations I would be subject to. 10. Safe Deposit Boxes: To have access to and control over the contents of any safe deposit box rented by me, to rent safe deposit boxes in my name, to close out and execute and deliver receipts for safe deposit boxes in my name, and to do all acts regarding any safe deposit box which I now have or may hereafter acquire, the same as I could do if personally present; provided that my attorney shall not deposit or keep in any such safe deposit box any property in which my attorney has a personal interest. Any financial institution may continue to rely on this power of attorney until it receives written notice from me that this power of attorney is revoked or actual notice of my death and shall be indemnified and held harmless by me and my estate, personal representatives and heirs against any liability or loss, including lawyers fees, costs of suits and claims of third parties, which it might incur by relying on this power after termination or revocation but before it receives such notice, or at any time because of wrongful acts, omissions or representations of my attorney with respect to transactions covered by this power of attorney. My attorney shall be subject to whatever bank rules and regulations I would be subject to. .11. Receipts and Approval of Accounts: To receive a payment of any kind, including a bequest, devise, gift or other transfer of real or personal property to me in my own right or as a fiduciary for another, and to give full receipt and acquittance therefor, or a refunding bond therefor, to approve accounts of any business, estate, trust, partnership or other transaction whatsoever in which I may have any interest of any nature whatsoever, and to enter into any compromise and release in regard thereto. 12. Compromise and Arbitration of Claims: To compromise or arbitrate any claim in which I may be in any manner interested, and for that purpose to enter into agreements to compromise or arbitrate, and either through counsel or otherwise to carry on such compromise or arbitration and perform or enforce any award entered in arbitration. 13. Institution and Defense of Claims: To institute, prosecute, defend, compromise, or otherwise dispose of, and to appear for me in, any proceedings at law or in equity or otherwise before any tribunal for the enforcement or for the defense of any claim, either alone or in conjunction with other persons, relating to me or to any property of mine or any other person, and to retain, discharge and substitute counsel and authorize appearance of such counsel to be entered for me in any such action or proceeding. 14. Taxes: To prepare, execute and file in my name and on my behalf any return, report, protest, application for correction of assessed valuation of real or other property, appeal, brief, claim for refund or petition, including petition to the United States Tax Court, in connection with any tax imposed or purported to be imposed by any government, authority or agency, or claimed, levied or assessed by any government, authority or agency and to pay any such tax and to obtain any extension of time for any of the foregoing; to execute waivers of restrictions on the assessment and collection of deficiency in any tax; to execute closing agreements and all other documents, instruments and papers relating to any tax liability of mine of any sort; to institute and carry on either through counsel or otherwise any proceeding in connection with contesting any such tax or to recover any tax paid, or to resist any claim for additional tax or to recover any tax paid, or to resist any claim for additional tax or any proposed assessment or levy thereof, and to enter into any agreements or stipulations for compromise or other adjustment or disposition of any tax. 15. Disclaimer: To execute, deliver and file for record disclaimers of any part or all of any property, power or interest passing to or for me under any will, deed of trust or otherwise; and to direct my spouse's executor to elect to qualify or to elect not to qualify for the marital deduction any portion or all of a marital deduction trust created for me by my spouse. 16. Employment of Others: To employ accountants, attorneys at law, investment counsel, custodians, agents, servants, and others, to delegate to them, to remove them, and to remuneration as my attorney shall deem proper. 17. Execution of Documents: To execute, deliver, file for record, cancel, modify, endorse, acquire or dispose of any instrument, including but not limited to stock and bond powers, vehicle registrations, financing statements and related filing documents, reports of any sort to any government, authority or agency, as required or permitted by law, deeds with or without covenants or warranties, and any other document appropriate for carrying out any of the foregoing powers. 18. Revocable Trusts: To deliver any property of mine to and deposit any such property with the trustee or trustees of any revocable deed of trust for my benefit executed by me even though the trust may not be payable upon my death to my estate and to revoke in whole or in part any such trust. 19. General: To do all things which my attorney shall deem proper in order to carry out any of the foregoing enumerated powers, which shall be construed in the broadest possible manner. The descriptive headings of this general power of attorney are inserted for convenience only and shall not be deemed to affect the meaning or construction of any of the provisions hereof orto limit in any way the construction thereof in the broadest possi- ble manner. 20. Substitution: My attorney shall have full power of substitution and revocation, and such substitution or revocation may relate to, or be limited to, any one or more or all of the foregoing acts or powers, or be limited as to time or in such other respect as my attorney shall deem proper. 21. Ratification: I hereby ratify and confirm all that my attorney or the substitute or substitutes therefor shall lawfully do or cause to be done by virtue hereof. 22. Effect of My Disability: This power of attorney shall not be affected by my disability. 23. Gifts: To give property without consideration in any amount to anyone including my attorney, outright or in trust, so long as my attorney believes that after such gifts sufficient funds will remain to provide for my welfare. 24. Continuation of Gift Program: To continue any program of gifts that I may have begun by giving property without consideration to persons, including my attorney, outright or to trusts which I have previously created for their benefit. I give my attorney this power because it is my intention that my giving program can continue in the event of my disability. 25. Payment of Fees to My Attorney: My attorney shall be entitled to reasonable compensation for services rendered hereunder. 26. Placement in an Institution: To take charge of my person in case of illness or disability of any kind; to authorize my admission to a medical, nursing, residential or similar facility, and to enter into agreements for my care; and to remove and place me in such institutions or places as my attorney may deem best for my personal care, comfort, benefit and safety after giving consideration to any wishes I have previously expressed on this subject. 27. Medical Procedures: To authorize medical and surgical procedures upon me. By grant of this power of attorney, I authorize my Attorney-in-Fact to make decisions about my medical treatment if I become incompetent, incapacitated or in any way permanently unable by reason of a physical and or mental disability to participate in decisions regarding my medical care. These instructions reflect my firm and settled commitment to refuse medical treatment under the circumstances indicted below. I direct my attending physician to withhold or withdraw treatment that serves only to prolong the process of my dying, if I should be in an incurable or irreversible physical and or mental condition with no reasonable expectation of recovery. These instructions apply if I am (a) in a terminal condition, (b) permanently unconscious but have irreversible brain damage and will never regain the ability to make decisions and express my wishes. I direct that treatment be limited to measures to keep me comfortable and to relieve pain, including any pain that might occur by withholding or withdrawing treatment. I authorize my Attorney-in-Fact to do whatever may be legally necessary to carry out these, my stated wishes. 28. Guardian of the Person: For purposes of recording my wishes in a convenient place, I record here that if it is necessary to appoint a guardian of my person, it is my desire, but not my direction, that Bonnie E. Cornelious be appointed such guardian. 29. Creation of Trust: To execute any revocable deed of trust on my behalf under the terms of which (i) my attorney or any one or more other person or corporations with fiduciary powers selected by my attorney is named as the trustee or trustees, (ii) during my lifetime the entire net income and as much of the principal as I or my attorney direct or my trustee thinks desirable shall be paid to me or as I or my attorney direct or my trustee thinks desirable shall be paid to me or as I or my attorney direct, and (iii) upon my death the principal and any undistributed income shall be payable to the executor or administrator of my estate; and to transfer property to the trustee or trustees thereunder. 30. Renounce Fiduciary Positions: To renounce fiduciary positions to which I have been appointed or am serving. 31. Withdraw Trust Funds: To withdraw and receive the income or corpus of a trust over which I have a power of withdrawal. 32. Termination of appointment of My Attorney: My attorney's appointment hereunder shall terminate by operation of law or upon (i) delivery to me of my attorney's written resignation or (ii) delivery to my attorney of a written revocation of this power signed by me, and my attorney may request a written opinion of a licensed physician stating that in his or her opinion I am not "incompetent" as that word is defined in 20 Pa.C.S.§5501. Upon termination my attorney shall return to my full control any property of mine in my attorney's possession within a reasonable time consistent with an orderly transfer thereof. My attorney shall have no further responsibility for funds so deposited. 33. Reliance by Others: This power of attorney shall continue in force and may be accepted and relied upon by anyone to whom it is presented despite my purported revocation of it, the issuance of a court decree declaring my incompetency or my death, until written notice of such event is received by such person. Executed May A0 2009 Zj9 (SEAL) Warren Scott Cornelious ACKNOWLEDGMENT STATE OF PENNSYLVANIA C(AV catt-*o ss. COUNTY OF On this, them).day of May, 2009 before me, the undersigned officer, personally appeared WARREN SCOTT CORNELIOUS known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. "?-[SEAL] ublic COMMONWEALTH vF 1-ENNSYLVANIA NOTARIAL SEAL DONNA K. HOPE, Notary Public Camp MR Borough, Cumberland Cov* My Commission Expires March 15, 2011 . POWER OF ATTORNEY OF WARREN SCOTT CORNELIOUS ACKNOWLEDGMENT BY AGENT I, the undersigned, have read the attached power of attorney and am the person identified as the agent for the principal. I hereby acknowledge that in the absence of a specific provision to the contrary in the power of attorney or in 20 Pa.C.S. when I act as agent: I shall exercise the powers for the benefit of the principal. I shall keep the assets of the principal separate from my assets. I shall exercise reasonable caution and prudence. I shall keep full and accurate record of all actions, receipts and disbursements on behalf of the principal. kro Bonnie E. Cornelious, Agen FLED-OFFICE .,F THE PROTHONOTARY 2011 MAR _Z AM 11: 30 CUMBERLAND COUNTY PENNSYLVANIA WARREN SCOTT CORNELIOUS AN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 04-2988 TINA MARIE CORNELIOUS, :CIVIL ACTION - LAW DEFENDANT AN DIVORCE AFFIDAVIT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within 20 days after this affidavit has been served on you or the statements will be admitted. 1. The parties to this action separated in September, 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 14904 relating to unsworn falsification to authorities. Dater/ Tina Marie Cornelious EiLED-Or 1' ICE ;tr Tj'JE PROTHONOTARY 2011 MAR -7 AM 11: 30 CUMBERLAND COUNTY PENNSYLVANIA WARREN SCOTT CORNELIOUS PLAINTIFF :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE CORNELIOUS, DEFENDANT :NO. 04-2988 :CIVIL ACTION - LAW :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OR 3301(d) OR 3301(a)(6) 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. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date:_? q//-i W I Tina Marie Cornelious '- LE OF F I C 'fur FCOTHONOTAR°Y' 2011 MIT -3 AN 11: 30 CUMBERLAND COUNTY PENNSYLVANIA WARREN SCOTT CORNELIOUS PLAINTIFF :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. TINA MARIE CORNELIOUS, DEFENDANT :NO. 04-2988 :CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within 20 days after this affidavit has been served on you or the statements will be admitted. 1. The parties to this action separated in September, 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:l Warren Scott Cornelious Ac OTHO AR" 201 t BAR -? ?? 11:29 ?;?MBER SY COON" ?ENNt_VANiA WARREN SCOTT CORNELIOUS :IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 04-2988 TINA MARIE CORNELIOUS, :CIVIL ACTION - LAW DEFENDANT :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OR 3301(d) OR 3301(a)(6) 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. 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: 3 Warren Scott Comelious WARREN SCOTT CORNELIOUS PLAINTIFF V. TINA MARIE CORNELIOUS, DEFENDANT .1 !• "1'?t1 ??R 1 ti A ta5 t L ?°t??tBER?A?D ?OUNT'? ?E??SYLVp,NI? AN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 04-2988 :CIVIL ACTION - LAW :IN DIVORCE CERTIFICATE OF SERVICE NMA4*Fb ¦ p?dwlt yoltfra go "0 Will, i 1NIr L and 2 a?lii+t>ipm In fjM owd 1. Afte /bdtlreeeed to k YEB, etaMr d" V Md" below. No 23 M. 32 Aft" p kulaN id 1r A E3 CXW. a. aeettit 0011101111 F*O 0 sere 2. M ole (ftwh 7023 1680 0004 6101 4526;.} , Arm 2= 00"dic Rearm Reoelpt w1bo PS Fom Ln (Domesti,- Mail only, No insurance Coverage Provided) For delivery information visit our website at www. usps.com ra `D Po ge $ ?a S M&U O Ceptifie Fee O Return Rgoiep ee Postmark Here (Endorsement Required) E3 Restricted Delivery Fee co (Endorsement Required) ..D r-q m 0 ?SenYo 0 t Jr WARREN SCOTT CORNELOUS, PLAINTIFF V. TINA MARIE CORNELIOU DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 04-2988 • zrn i if-. - T3 :CIVIL ACTION - LAW 2, M 77-1 :IN DIVORCE ° =C) PRACCIPE TO TRANSMIT RECORD ?z °• r`. ? crf TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under 3301(c) or 3301(d) of the Divorce Code. 2. Date and manner of s?rvice of the Complaint: United States First Class Certified Mail, Return Receipt Requested - dated June 28, 2004. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: 3/1/2011; by Defendant: 2/24/2011. 4. Date Plaintiff's Waiv?r of Notice in §3301(c) Divorce was filed with Prothonotary: Contemporaneously with this Date Defendant's Contemporaneously with this 5. Related claims of Notice in §3301(c) Divorce was filed with Prothonotary: pe. Matrimonial Settlement Agreement between the parties dated December 30, 2010, to be incorpprated by reference and merged into the Divorce Decree. Respectfully submitted, By: (/ L LZ / / / ,C_ -A154 William T. Tully, Esquire Supreme Court 1. D. #36410 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 717-540-6833 Dated: -'?)l A Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,.PENNSYLVANIA Warren Scott Cornelious V. Tina Marie Cornelious NO. 04-2988 DIVORCE DECREE AND NOW,. ;'01 , it is ordered and decreed that Warren Scott Cornelious plaintiff, and Tina Marie Cornelious , 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 Marriage Settlement Agreement dated December 30, 2010 is incorporated herein by reference and the parties shall comply with the terms thereof. By the rt, Attest: J. 4D Prothonotary Cgpy rna"W -b a-VAf -T'l!y NWee + Copy rrauw * de+