HomeMy WebLinkAbout02-0188PAMELA Y. HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COM]VION PLEAS
: CUMBERI,AND COUNTY, PENNSYLVANIA
: CIVIl, ACTION - LAW
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the office of the
Prothonotary, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNUL~ 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 WI-IER~ YOU CAN GET L]~GAL I-I~LP~
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
NOTICIA
Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apadencia escrita o en persona o por abogado
y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden
comra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion
do demanda. Usted puede perder dinero o sus propiedades o otros derechos importanates para usted.
LI~F~VE ESTA DEMANDA A LIN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
I~N PI~P, SONA O LLAM~ POR TI~LFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
PAMELA Y. HALL,
Plaintiff
Ve
GALEN G. HALL,
Defendant
: IN TliE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:No. Or-
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
AND NOW comes the above Plaintiff, Pamela Y. Hall, by his attorney, Cara A. Boyanowski,
Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds
hereinafter sot forth:
1. The Plaintiff, Pamela Y. Hall, is an adult individual who resides at 5145 E. Trindle
Road, Apartment J, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. The Defendant, Galen G. Hall, is an adult individual who resides at 1751 Mountain
Road, York Springs, Adams County, Pennsylvania 17372.
3. The Plaintiffhas been a bona fide resident of the Commonwealth of Pennsylvania for
at least six (6) months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 22, 1988, in Carlisle,
Cumberland County, Pennsylvania.
5. The Plaintiff and Defendant are both citizens of the United States of America.
6. There have been no prior actions in divorce between the parties.
7. Plaintiff avers that there are no children bom of the marriage.
8. The Plaintiff and Defendont are not members of the Asmed Services of the United
States or any of its allies.
9. Plaintiff has been advised of the availability of counseling and that she may have the
right to request that the Court require the parties to participate in counseling.
10. The causes of action and sections of I)ivorce Code under which Plaintiffis proceeding
are~
Section 3301(c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an Affidavit.
B. Section 3301(d). The marriage of the parties is irretrievably broken.
The Plaintiff and Defendant separated in July, 1999.
WHEREFORE, the Plaintiffprays your Honorable Court to enter a Decree in Divorce from
the bonds of matrimony.
I verify that the statements made in this Complaint 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 unswom
falsification to authorities:
Date:
~ara A. Boyanowsl~, Esquire
Attorney No. 68736
1029 Scenery Drive
Harrisbur~ PA 17109
(717) 657-4795
Attorney for Plaintiff
PAMELA Y. HAIJ.
Plaintiff
Ve
GAI.EN G. HALL,
Defendant
: IN TWE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-188 ~ TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be emered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the office of the
Prothonotary, Cumberland County Courthouse, High and Hanover Streets, 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 YOUDO NOT
HAVE A LAWYF, R OR CANNOT AFFORD ONE, GO TO OR TFJ.EPHONE THE OFFICE SET
FORTH B~.LOW TO FIND OUT VVrIERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Car{is{e, PA 17013
(717) 249-3166
NOTICIA.
Le hah demandado a usted en la cone. Si usted quiere defenderse de estas demandas
expuestas en las paginas si~fientes, usted tiene viente (20) dias de plazo al parfir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado
y archivar en la corte en
forma escrita sus defensas o sus objeciones a ~ demandas en contra de su persona. Sea avisado que
si usted no se defiende, la corte tomara mediates y puede entrar una orden contra usted sin previo
aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda Usted
puede perder dinero o sus propiedades o otros derechos importanates para usted.
LL~.VE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOOADO O SI NO TIENE l~. DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE
ENC~ ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCiA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3155
PAMELA Y. HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
AMENDED COMPLAINT IN DIVORCE UNDER
SECTIONS 3301(c) AND 3301(d)
OF ~ DIVORCE CODE
AND NOW, comes the Plaintiff, Pamela Y. Hall, by and through her attorney, Cara A.
Boyanowski, Esquire, and files this Amended Complaint in divorce seeking to obtain a decree in
divorce from the above-referenced Defendant purs~_~_ont to Sections 3301(c) and 3301(d) of the
Divorce Code and sets forth the following:
COUNT I
DIVORCE
1. Paragraphs One (1) through Ten (10) of the original complaint in divorce filed on
January 14, 2002, are incorporated herein by reference thereto.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT H
EQUITABLE DISTI~mUTION
Paragraph One of this Complaint is incorporated herein by reference as though set
Plaintiff and Defendant have acquired property, both real and personal during their
marriage from the date of their marriage, October 22, 1988, until the date of their separation,
July, 1999.
4. Plaintiff and Defendant have b~n unable to agree as to an equitable division of said
property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
COUNT IH
COUNSEL FEES, COSTS AND EXPENSES
Paragraph One of this Complaint is incorporated herein by reference as though set
forth in full.
6.
Defendant's annual gross income is unknown and Defendant has assets which have not
yet been ascertained.
7. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable
attorney's fees for said counsel.
8. Plaintiff is unable to sustain herself during the course of this litigation.
WHEREFORE, Plaintiff requests your Honorable Court to enter an award for counsel fees
and costs and expenses, as deemed appropriate.
I verify that the statements made in this Amended Complaint are tree and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A~ {}4904
relating to unswom falsification to authorities.
~a~da Y. Hall, Plainti~ '
DALEY LAW OFFICES
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
Attorney for Plaintiff
PAMELA Yo HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBEI~!.AND COUNTY, PENNSYLVANIA
: NO. 02-188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
INVENTORY
UNDER RULE 1920.33
Plaintiff~ Pamela Y. Hall, files the fo~owing inventory of all property owned or possessed
by either party at the time this action was commenced and all property transferred within the
preceding three years.
She verifies that the statements made in this amended inventory are true and correct. She
understands that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904
relating to unswom falsification to authorities.
Date:
ASSETS Ol~ 1,ARTn~S
PAMF. LAY. HAI.L MARKS ON THE LIST Bl~l.OW THOSE ITEMS APPLICAB!,F.
TO THE CASE AT BAR AND ITElV~ZF, S THE ASSETS ON THE FOLLOWING PAGES.
(X) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of Deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit box(s)
( ) 8. Trusts
CA') 9. Life insurance policies (indicate face value, cash surrender value and current
( ) 10. Annuities
( ) ll. Gii~s
( ) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Businesses (list aH owners, including percentage of ownership, and officer/director
positions held by a party with company)
(X) 16. Employment temdrmtion benefits - severance pay, worker's compensation
claim/award
(X) 17. Profit sharing plans
(X) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. Military/V.A. benefits
( ) 23. Education benefits
(X) 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (include as a total category and aRaeh
itemized list if distribution of such assets is in dispute)
( ) 26. Other
HALL v. H~LL
Date of Marriage - October 22, 1988
Date of Separation - July, 1999
MARITAL ASSETS
Assets Wife's Husband's Difference Notes
Value Value in Value
Real Estate
Marital Residence: $130,000.00 Pre-Marital Property.
1751 Mounemin Road (Appraisal) Property appraised in January,
York Springs, Pennsylvania $54,000.00 2002.
(Marital Husband purch~._o~d property in
Portion) 1986 fo~ $76,000.00.
Marital property consists of
increase in value of real
property since 1988.
No mortgage exists on the
property.
lt~,tirmnent Aceouuts
EBI $44,968.15
Retiremem Account
(vctte)
TIAA-CREF (Borough Retirement) $5,394.04
Retirement Account
(Wa'e)
AHOLD USA, Inc. $0.00 Pre-Marital Property.
401(k) Savings Plan Wife's participation in account
Giant Foods began after date of separation.
(Yea'e) ,,
Appleton Papers Unknown Information in sole possession
Retirement Account of Husband.
(Husband)
MARITAL ASSETS
Appleton Papers Severance Pay $16,312.47 Husband received severance
(Husband) pay on June 1, 2001.
Husband deposited severance
into joint checking account no.
514045-7216.
Morrett Plumbing Unknown Information in sole possession
(Husband) of Husband.
Automobiles
1996 Ford Taurus Estimated at: In possession of Wife.
(Wife) $5,000.00 No lien exists on this vehicle.
1986 Ford Bronco Estimated at: In possession of Husband.
(Husband) $2,000.00 No lien exists on this vehicle.
Life ln~aranee Policy
Hartford Life and Annuity Insurance Face Value: Value of policy as of
Company $120,000.00 November 28, 2001.
Policy No. 101-LU0935779 Cash
(Husband) Surrender
Value:
$3,340.89
Bank Accounts
Members First $3,949.64 Balance of account as of
Savings Account August, 1999.
No. 112581 Wife withdrew $3,851.49 from
(Joint) account on May 7, 2002.
PNC Bank $4,762.73 Balance of account as of July,
Checking Account 1999.
No. 51-4045-7216 Husband withdrew $2,292.99
(Joint) from account on July 2, 1999.
Wife withdrew $601.95 from
account on May 7, 2002.
MARITAL ASSETS
PNC Bank $8,815.54 Balance of account as of July,
Savings Account 1999.
No. 51-3039-2607 Husband withdrew $8,000.00
(Joint) from ac, count on July 2, 1999.
Wife withdrew remaining
balance of account in Febtaj~ry,
Z002.
Household Goods and Furnishings Estimated at: Husband in possession of
$30,000.00 items. Wife only removed
living room suite, valued at
approximately $3,000.00.
None
GRVST - 1
COPYRIGHT 1985 e BY ALL-ST ATE LEGAL SUPPLY CO.
ONE COMMERCE DRIVr, CRANFORO N.J. 07016
Nin~enhundredand eighty-six (].986)
~ztwzz~ GARY R. WEG~ZYNOWICZ and PATRICIA A. WEGRZYNOWiCZ
formerly Patricia A. Cassel), his wife, of York Springs, Adams
County, Pennsylvania
GRANTORS
, in the year
AND
GALEN G. HALL, single man, of Dillsburg, York County, Pennsylvania
GRANTEE
Wt~~, That in ~,;;iderat~?& of Seventy-six thousand and no/100
............................. $76,000.00 ........................ DolOrs,
in hand pa~, the receipt whe? . '!f ~ hereby ~know~dged, th~ sa~ ~ant~ s ~
~e~ ~nt a~ ~v~ ~ O~ s~ ~ant~e , his ~rs a~ ~,
ALL THAT CERTAIN piece or parcel of land, situate on the west side
of Mountain Road, L.R. 66001, ~in the ToWnship of Latimore~ County
of Adams, Co~onwealth of Pennsylvania, more particularly bounded
and'described according to a final plan of lots ~f Section 3-A of
Stone Head Estates prep~red by Jerry D. LaRue, Registered Surveyor,
dated April 21, 1978 as follows, to wit:
BEGINNING at an iron pin on the dedicated right-of-way 1Lne on the
East side of Mountain Road, L.R. 66001, at the common lo% line of
lots 23 and 24 of the a~oresaid plan; thence alon~ the co--on lot
line of Lots No. 23 cng 24, South fifty-five (55) degrees fifty-
eight (58) minutes forty-eight (48) seconds East two hundred ninety
and no hundredths (290.00) feet to an iron pin; thence along other
lands of Grantors South thirty-four (34) degrees one (1) minute
twelve (12) seconds West one hundred fifty and no hundredths (150.00)
feet to a concrete mo~ument on the dedicated right-of-way line of an
unnamed street; thence along said unnamed street North fifty-five
55) degrees fifty-eight (58) minutes forty-eight (48) seconds West
two hundred sixty and no hundredths (260.00) feet to a point; thence
on a curve to the right having a tangent of thirty (30) feet, an arc
of forty-seven and twelve hundredths (47.12) feet, and a radius of
thirty (30) feet along the right-of-way line of the aforesaid un-
named street and MountcLn Road'North ten (10) degrees fifty-eight
(58) minutes forty-eight (48) seconds West to a point on the eastern
right-of-way line of the said Mountain Road; thenc'e along the eastern
right-of-way line of said Mountain Road North thirty-four (34) degrees
one (1) minute twelve (12) seconds East one hundred twenty and no
hundredths (120.00) feet to an iron pin, the point and place of
BEGINNING.
BEING Lot No. 24 of the aforesaid final plan of Section 3-A of Stone
Head Estates recorded in Adams County Plan Book 21, Page 45.
:BOOK PAGE:
0431 0381
The aforesaid Mountain Road has been erroneously identified on the
said final plan of Section 3-A of Stone Head Estates as L.R. 01009.
BEING the same premises which Vernon E. Anderson, Inc., a Pennsyl-
vania Corporation, by Deed dated December 24, 1981, and recorded in
the Office of the Recorder of Deeds of Adams County, Pennsylvania,
in Deed Book Volume 360, Page 922, granted and conveyed unto Gary R.
Wegrzynowicz and Patricia A. Cassel, single persons. The said
Gary R. Wegrzynowicz has since intermarried with Patricia A. Cassel
and together they are the Grantors herein.
ENTERS'9 FOR ~ CORD TAX~;, ~'o
JUL 17 I ~ PH 'SG
J~,,~-~, . Township,,
Adams County, Pennsylvania
REAL ESTATE TRANSFER TAX RESOLUTION
Amount of Tax ~9~. ~o
Received P~en~
chool District, Adams Codrnty, p~ ~
REAL ESTATE TRANSFER TAX RESOLUTIO~'i
Amount of Tax ~t.~..i~~
04 1 0382
hereby generally
the property hereby conveyed,
and seal s the day and year first ab,we written.
ha~e hereunto set their
GA~ IR. WEGRZ~ICZ/~
r~,t~zc~ ~. ~G~Z'.~O~XC~ U
warrant
hah&,
On tkis, the day of 19 , before me
0431 0383
kaolin to me (or satisfaatorily pvovea) to be the person whose aame sube~ribed to the withi~
i~stmme~ and o~ekamo~ tAGt he ~ the same for the purpose therein aontained.
IN WITNE~ WHEREOF, I have her~nto set my hand and seal.
~,~t~ of
On this, the day of 19
the undurfsigaed o~, personally appeared
Imoum to rn~ (or sa~sfaetorily prov~ to b~ th~ Inn'son whose narn~ subscribed to tl~ within
instrument, and adenowl~g~d O~at I~ ~ th~ sarn~ for t~ gurgo~e thsrdn contain&
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
i
INVOICE
I
O
I
C
E
101/14/02 101/04/02 I MH I HALL 123-2391423 I 717-'Z66-4686
Purchaser/Borrower ~a~l~ Galen & Pamela
Property Address 1751 Mountain Road
City York Springs Subdivision
County .~l~azz~ State PA
Legal Description Attached
Reference
Unit
Zip 17372
Amount ........................................................................
Mail or Handling Fee .....
Additional Charges 1 ... 15% Fee if Paid 30 Days Past Receipt .
Additional Charges 2 ....
Additional Charges 3 ....
Sales Tax ........................................................................
Thank you for your business [ Total Amount of Invoice
275.00
275.00
Please detach and include the bottom portion with your payment... Thank you !
01/14/02 01/04/02 MH 02-02M1 HALL 657-4795
AMOUNT
~.:':' ?::' :: ~ ~ ~ ~ ~::~:::' ~: DUE
~ 275.00
ENCLOSED
TfiR~O - Balane~ duo upon ro~oipt of in~oioo
Pl~a~o fotura thi~ portion with ~our pa~mont. Thank ~ou !
MARK E HILBERT & ASSOCIATES
~e r~o: 02 - 02M1
APPRAISAL REPORT
of
1751 Mountain Road
York Springs, PA 17372
Sunmmr~Appraisal Report
PREPARED FOR:
Cara A. Bo~anowski Esq.
1029 Scenery Drlve
Harrisburg, PA 17109
AS OF:
January 4, 2001
PREPARED BY:
MARK E. HILBERT & ASSOCIATES
14 North Walnut Street
Mechanicsburg, PA 17055
MCS, a Division of ACI Development {800) 697-7783
MARK E. HILBERT & ASSOCIATES
Property Description UNIFORM RESIDENTIAL APPRAISAL REPORT ' File No. 02-02M1
P,~,~yAaa,.o~ 1751 Mountain Road city York Sprinqs statePA ZipCode 17372
Legal Description Attached County Adams
Ass~s0r's Parco, NO. Tax Year R.E. Taxes, Special Asses .... ts, NO=. ~O..
Borrower"m]1, ~.l.n ~ ~.--.]. Current Owner ~"'~ Occupant ~Owner ~.enant
Neighborhood o~ Proiect Name ~to~e~ea~ ~[~kes Map Reference Census Tract 23
S~les Price t ~.~.~[~e Oate of Sale ~/[ Oescription and 8 amount af pan charaes/concessions to be paid b~ seller
Lender/Client CaTe A. B~an~ski Esq. Address 1029 Scene~ Drive HarrisburgtPA 17109
Appraiser ~rk E. F41~ert Address 1~ North Walnut Street/Mechanicsburq~ PA 17055
Location ~ Urban ~ Suburban ~ Rural PM~i~ ~ f~i~ ~. ~ I~ ~ % ~
Builtup OOver75% ~25-75% OUnder25% ~ PRICE$(O00} AGE(yrs) Onefamily ~ O Notlikely ~Likely
Gromh rate 0 Rapid ~ Stable OSlow ~O .... 70 tow N.W 2-~ ,a.ily 0S O In process
Prope~yvalues ~ Increasing 0 Stable 0 Declining 0 Tenant 22S Hi,h 35 Muai-familV 00 To: Residential
Demand/supply O Sh0rtage ~ In balance O0 ..... pply ~ Vacant (0-5%, :::~}~{~ P r ~ 0 m i n a n t i];~]?:~?:~?~?:{~?:~ C o m. e r c i a I 01
Marketin, time B Under 3 .... ~ 3-6 m0s. ~ Over 6 mos. ~ Vacant (over 5%) 1~0 18 Vac~d 45
Neigh~rh0~ b0undades a~ characteristics: Property is located along Mountain Road in the Develo~nt of Stonehead
Estates, Lat~mre T~ship. ~ C~ty, Pe~sylvania.
Factors that affect the marketab,,,W of the properties in the neighborhood (proximity to employment and amenities, emp,oyment stability, appeal t .... ket..tc.k
Property has good access to ~l~ent and so.ices.
are not re~ire~ to offer sales or fin~cing consessions. Fin~cing is really avail~le
~1~,.~ {If .pplicabie)-*ls the developer~uilder in control of theHomeO ..... 'Association(HOA)? O Yes O No
Approximate total .u~ber o, unitsi, the subject project "/~ . Approximate total number of units for sale i~ the s.bject project
Oimensions2~0 X [~0 X 260 X ~7.[2 X [20 Topography S[~ag ~o Aea~
SiteArea &0~305.6 S~s~e Eee~ ComerLot ~Yes ~ No Size 0.925
Specific zoning cl,ssificati .... d description .ee~ea~a[ Shape
Zoning comp,lance ~ Legal ~ L~al ...... formi~ IGrandfa,hered use} ~ megal ~ No zoning Drainage Appease ade~a~e
Highest & best .... S improv~ ~ Present use ~ nth ..... (explain) View
..... . . Landscaping
UtdAms Pubhc Other Off-s~e Type Pubhc Pnvate '
Electricity ~ 200 ~ Street ~csa~ __ _ ~ ~ Apparent Easements ~C~[
Gas ~ ~o~e Curb/Gutter ~oae ~ ~ '
Water ~ Private Sidewalk ~-- - 0 ~ FEMA Special Flood Hazard Area ~ Yes ~No
Sanitary Sewer ~ Private Street lights None ~ ~ FEMA Zone C Map Date 6-1-79
Storm Sewer ~ None Alley ~-- - ~ ~ FEMA Map ~2
Comments(apparent adverse easements, encroachments, special assessments, slide areas, illegal or legal nonconforming zoning, use, etc,): Non~ apparent. S~j act
h~ver to rese~ations, eas~ents, conditions ~d right of way of record.
GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION BASEMENT INSULATION
No. of Units ~e Foundation Co,crete Slab No Area Sq. Ft. 1~ 204 Roof
No. of Stories ~e Exterior Walls Br/Vi=~l Crawl Space No % Finished Part Ceiling
Type(Det./A~.)Detached Roof Surface C~osit :Basement ~11 Ceiling Insulatio Walls
Design (Style) ~ch Gutters & Dwnsms Al~n~ Sump Pump None Walls D~a11. Floor
Exi~ing~roposed ~Bt~q Window Type Dbl.~n~ Dampness Non~oted Floor C~crete None
Age (Yrs.) 21 Storm/Screenshot1 Se~lement Non~ote~ Outside Entry Yes Unknown
Effective A~e (Yrs.) 6 - 8 Manufamured H~S~O Infestation Non~ote~
ROOMS Foyer L[vinR DininR Kitchen Den Family Rm. Rec. Rm. Bedrooms ~ Baths Laundry Other Are~ Sq.Ft.
Basement i Stq. 1~ 20&
Level I i i~ea i i 3 2 1 1,~80
Level 2
Finished area a~ve ~rade contains: 6 Rooms; 3 Bedroom[s); 2 Bathls); 1~ 480 Square Feet of Gross Livin~ Area
INTERIOR Materials/Condition HEATING KITCHEN EQUIP. ATTIC AMENITIES CAR STORAGE
Floors Ca~et/Avq Type Saseboard Refrigerator ~ None ~ Fireplace(s) 8 ~ None~
Walls D~a11/A~ Fuel Electric Range/Oven ~ Stairs ~ Patio Conc/2 Bric~ ~ Garage g of Cars
Trim/Finish Wood/A~ Condition Average Disposal ~ Drop Stair ~ Deck ~ Attached 2
Bath Floor Vin~l/A~ COOLING Dishwasher ~ Scuttle ~ Porch Front ~ Oetached
aathWain~ot F~erglass Central Yes Fan/Hood ~ Floor ~ Fence ~ Built-in
Doors 6 Panel/Arq Other None Microwave ~ Heated ~ Pool ~ Carport
Condition Average Washer/Dryer ~ Finished ~ Coal Stye ~ Driveway 4
Adverse environmental conditions (such as, but not limited to, hazardous wastes, toxic sub.encee, etc,) present in the improvements, on the site, or in the immediate vicinity of the subject
property: There are no visible or apparent adverse enviro~ental conditions that ~uld negatively
~ac~ the value of the s~ect. S,,~ Appraisal Report
MCS, a Division of ACl Development (800) 697-7783 Page 1.1 Fannie Mae Form 1004 6-93
MARK E. HILBERT & ASSOCIATES
V~lu'at~on ~ection UNIFORM RESIDENTIAL APPRAISAL REPORT File No. 72-02M1
ESTIMATED SiTE VALUE ........................ = $ 30,000 Comments on Cost Approach (such as source of cost
estimate, site value, foot calculation and for HUD,
ESTIMATED
REPRODUCTION
COST-NEW
OF
IMPROVEMENTS:
square
Dwelling 1,480 Sq. Ft. @ $ 49.15 = $ 72,742 VA, and FmHA, the estimated remaining economic life of
Basement 11204 Sq. Ft. @ $ 12.50 = 151050 the property): In reproduction cost of
Porch/3 Patio/Coal Stove. = 6,000 improvement, Marshall & Swift Handbook
Garage/Earport 460 Sq. Ft. @ $ 16.35 = 7r521 and local contractors are referenced.
Total Estimated Cost New .................. $ 101,313
Physical External
Less 04 % Functional
$ 4 ~ 052
Depreciation 4,052 I =
Depreciated Value of Improvements .................. $ 97,261
"As-is" Value of Site Improvements ................. $ 2,400
INDICATED VALUE BY COST APPROACH ............ = $ 129~ 661 Re~ainin~ Econcatic life 30-35 Years
ITEM I SUBJECT COMPARABLE NO. 1 COMPARABLE NO. 2 COMPARABLE NO. 3
1751 Mountain Road 1456 Mountain Road 17 Cold Spring Road 84 Green Briar Road
Address York Springs~ PA IDillsburg, PA Dillsburg, PA York SpringsI PA
Data and/or C · P.M. L. C. P.M. L. C. P. M. L.
V~rification Sources Inspection Agent Agent Agent -~.
VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION ~(-)$ Adiustment DESCRIPTION +(-)$ Adjustment DESCRIPTION +(-)$ Adjustment
Concessions ? ??i? ?!??!? ?:?:? f :':':'!'F'(:'::::,':::'?::':' f ? f T:r' Conventional Conventional Conventional
Data of Sale/Time 10-26-01 10 -1-01 10 -10-01
L0catio. Average Average Average Average
Leasehold/FeeSimple Fee Simple Fee Simple Fee Simple Fee Simple
site 0.925Acre/Avg 4.14 Acre/Arq -10,000 0.81 Acre/Avq 1.0 Acre/Avg
View Average Average Average Average
Design and Appeal Ranch/Avg Ranch/Avg Ranch/Avg Ranch/Avg
Duality of Construction Brick/Vinyl Vinyl Vinyl Vin%rl
Average ,
C0nditio~ Above Average Above A~.[. Above Av.~. +3 000
RoomAb°ve Gradecourlt 6T°tal ;drrn, ;aths 5T°tal ~Bdrrns2Baths 6T°ta' 3Bdrms/acths2 8T°tal ~Bdrms 2Baths
Gross Livin~ Area 11480 Sq. Ft. 1,200 Sq. Ft. +41200 11232 Sq. Ft. +31700 1,152 Sq. Ft. +41900
Basement & Finished Full Partial +1,000 Full Full
Rooms Below Grade Bed Roc~ Rec. Rm. Fem. l~m-Rec. Rm -2,500 Un£inished +1,500
Functi0.a~ U~iHty Average Average Average Average
Heating/Cooling EBB/CA Heat Pump/CA Heat Pump/CA EBB/None +2,500
Energy Efficient ~tems None None None
None
Porch, Pctio. Oeck, Porch/3 Patio Porch/Deck +2,500 Deck +3,0001Deck +3,000
Fireplace(s)'etc' Coal Stove Woodstov. 2 Fireplac.. -4,500 Woodstove
Fe"ce' Po0~ etc. None None None None
None Jacuzzi -1,500 None None
$
[-~- 19,900
C~ar~l~les chosen ~re the best closed salas avail~le within a reason~l~le distance of the
subject.
Subject is on well/septic which is typical of the neighborhood and does not adversely impact
marketability.
The lack of storm sewers, curbs, gutters, sidewalks, and/or street lights is typical of the
neighborhood and does not adversely ia~act marketability.
The property's heating, plumbing, and electrical systems appear to be functioning properly to
the best of the appraiser's knowledge and expertise.
iris noted that co~arable No(s) 1-2-3-4 is/are more than three miles for surburban location
It is noted that the price per sc/uare foot of gross living area for comparable No (s). 1-2
varies by mmre than $10.00 per square foot c~=~ared to the subject. The core, arables chosen are
the best available.
The vacant land in the area is changing to single family and does not have a negative effect
on the value.
I am unable to verify the insulation 'R' factor. The presence of UREA-FOP/~T.~EHYDE FOAM
INSOLATION could not be determined. If UFFI is present, the appraisal market value may be
adversely affected or voided. Any information about insulation stated on the appraisal was
provided by inspection, owner, or agent, and is assumed to he accurate.
The appraiser is not aware of the existence of Radon Gas and/or Radon Daughters, and does not
have the necessary equipment to test for the presence of same. If a future test shows
unacceptable levels of Radon present, the appraised market value may be adversely effected or
voided.
MCS, a Division of ACI Development 1800) 697-7783 Page 2.1 Fannie Mae Form 1004 6-93
MARK E. HILBERT & ASSOCIATES
,Val{mti~on S~fion UNIFORM RESIDENTIAL APPRAISAL REPORT File No. 02-02M1
Please be advised that in the market data analysis grid, bathrooms are adjusted for on the
first line and gross livlng area/room count are adjusted together as a slngle adjustment on
the second line.
It is noted that the net adjustment for cc~parable No(s). 3 exceeds 15%. This adjustment is
larger than normal, but the com~arables chosen are considered the best available. Other
c~,,garables analyzed would have required less desirable adjustments and were not used for that
reason.
All coa~arable sales are settled to the best of the appraiser's knowledge. Verification of
settlement is with County and/or Realtor.
ITEM SUBJECT COMPARABLE NO. 1 COMPARABLE NO. 2 COMPARABLE NO. 3
Date, Pricea~Oata None None None None
Source for prior sales N/A N/A N/A N/A
w~thi,¥earofedpra~$a~ Owner's Deed C.P.M.L./Court House C.P.M.L./Court House C.P.M.L./Court House
Analysis of any current agreement of sale, option, or listing of the subject property and analysis of any prior sales of subject and comperables within one year of the date of appraisal:
N/A
INDICATED VALUE BY SALES COMPARISON APPROACH .............................................. $ 130 000
Estimated Market Rent $ /Mo.
The appraisal is made "as is" subject to the repairs, alterations, inspections ot conditions tisted below subject to completion per plans and specifications.
Conditions of Appraisal :The appraiser assumes a marketable title and that all of the equipment associated
with the {~rovement is in working order.
Fina~Rec0nci,ation:The market approach reinforced by the cost approach is a good indicator of Fair
Market Value. The fact that the seller is or is not paying any portion of the closing costs
has no effect on this a~raisal or resale.
The purpose of this appraisal is to estimate the market va~ue of the real property that is the subject of this report, based on the above conditions and the certification, contingent and limiting
conditions, and market value definition that are stated in the attached Freddie Mac Form 439/Fannie Mae Form 1004B (Revised 6/93 ).
I (WE) ESTIMATE THE MARKET VALUE, AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OF THIS REPORT, AS OF
January' 4~ 2002 ¢~fi~-I~.~/~E~DAT~,~OF INSPECTION AND THE EFFECTIVE DATE OF THIS REPORT) TOBE$ 130~000
Signature .~'~~~____~~ Signature [] Did [] Did Not
NarneMafk ~. Nill~ert w Name Inspect Property
Date Report Signed J~..--~ua:r~ 28 t 2002 Date Report Signed
State Certification # ~ 000388-1', State [3A State Certification # State
Or State License # [~.~- 02 ~755-A State ~A Or State License # State
Frl~ddie Mac Form 70 6-93 MCS, a Division of ACI Development {800) 697-7783 Page 2.2 Fannie Mae Form 1004 6-93
MARK E. HILBERT & ASSOCIATES
SALES COMPARISON ANALYSIS
File No. 02-02M1
The undersigned has recited three recent sales of properties most similar and proximate to subject and has considered these in the market analysis. The description includes a dorlar adjustment,
reflecting market reaction to those items of significant variation between the subject and comparable properties. If a significant item in the comparable property is superior to, or more favorable
than, the subject property, a minus {-) adjustment is made, thus reducing the indicated value of subject; if a significant item in the comparable is inferior to, or less favorable than, the subject
property, a plus {+) adjustment is made. thus increasing the indicated value of the subject.
ITEM I SUBJECT COMPARABLE NO. 4 COMPARABLE NO. COMPARABLE NO.
1751 ~untain Road 418 Little John Drive
Address York Springs~ PA Dillsburg, PA
Data a~:l/o¢ C · P · M ° L °
Verification Source Inspection Agent
VALUE ADJUSTMENTS DESCRIPTION DESCRIPTION +{-}$ Adiustment DESCRIPTION +1-)$ Adiustmen DESCRIPTION
Concessions Cash
Location Average Average
Leaseh0~dmeeSimp~e Fee Simple Free Simple
Site 0 · 935Acre/Avg 0.30 Acre/Avg
View Average Average
Ranch/Avg Ranch/Avq.
of C0nstruct~0n Brick/Vinyl Brick/Alum
21 22
Condition Above AVerage Above Average
]
,Ab°ye Grade Total I Bdrms Baths Total I Bdrms Baths Total Bdrms Baths Total Bdrms Baths
Room Count 6 ~3 2 7 !3 2
11480 Sq. Ft. lt800' Sq. Ft. -41800 ,, Sq. Ft, Sq. Ft.
Basement&Finished ~tll Crawl Space +1,000
Rooms Below Grade Bed Room Unfinished +11500
Functional Utility Average Average
EBB/CA Heat Pump/C-A
Efflciem ~tem. None None
2 Car Garage 2 Car Garage
Porch, Patio, Deck, Porch/3 Patio Patio/Deck
Fireplacels). etc. Coal St~ve Fireplace -2 ~ 000
None In Gr-Pool -4,500
None Cabana - 2,000
............ . ............................................. ::[i::::?:~ ~
of Comparable .......................................................................... ~.:.: iii~iii!i~iiiiii?i?iiiiili!ii~!~i?i~iii!?i!~i, 134,2 0 0 i::iiiiii~iiii~iiiiiiiiiiii~iii~iiiiiii ..... ?:~:::':::¥ .....................................
Date, Price and Data None None
Source for prior sales N/A N/A
wiminyearofappraisel Owner's Deed C.P.M.L/Court House
Additional Comments
MCS. a Division of ACI Development {800) 697-7783 MCS Form UAC
I"~ I I'l~l[~K Ul- ~U~.I~L; I
Borrower/Client Hall, Galen & ps_me_la
File No 02-02M1
State PA Zip Code $7372
, Prooertv Address 1~_51 Moun~'a~. Road
City %'b~k Springs
County~d~m"
Lender Ca'fa A. Boyanowski Esq.
FRONT
REAR
STREET SCENE
Form PP1 Mark E. Hilbert & Associates MCS, a Division of ACI Development (800} 697-7783
I~orrower/Client Hall, Galen & P~e_!a
_~Pppert¥ Addre..~s 1751 Monna's'in Road
City Y~rk Springs
~.XTFRIOR OF SUR. IFCT
File No. 02-02M1
State PA Zip Code ,17372
County ~lam.
Lender Cara A. Boyanowski Esq.
Form PP4 Mark E. Hilbart & A~sociatel MCS, a Division of ACl Development (800) 697-7783
COMPARABLE SALES
, Bor, ro,wer~'C~;e-~t H&11t Ga!~n & Pamela
File No. 02-02M1
ProoertyAddress E751 Mountain Road
City York Springs County ARm~"=
Lender Cara A. Boyanowski Esq.
State PA
Zip Code 17372
COMPARABLE 1
1456 Mountain Road
Dillsburg, PA
COMPARABLE 2
17 Cold Spring Roa
Dillsburg, PA
COMPAP~BLE 3
84 Green Briar Roa
York Springs, PA
Form PP6 MARK E. HILBERT & ASSOCIATES MCS, a Division of ACI Development (800} 687-7783
Berrow'~?Client File #
Property Address
City County State Zip Code
Lender
BUILDING SKETCH
o~
Marysvilb
LOWE
M IDDL
H A"',M
MIDI
DICKINSON
0 U 'T
D D
W A
G H A N
A
East E
M
0 X F
;/ Bonnon,~vi)~
P T /
MARK E. HILBERT & ASSOCIATES
File No, 02-02M1
Borrower/Client Hall~ Galen & Pamela
Property Address 1751 Mountain Road
City York Springs County A~ams
Lender Cara A. Boyanowski Esq.
State PA Zip Code 17372
ADDENDUM B
APPRAISAL CERTIFICATION
I certify that, to the best of my knowledge and belief:
- the statements of fact contained in this report are true and correct.
the reported analyses, opinions, and conclusions are limited only by the reported
assu~mtions and limiting conditions, and are mypersonal, unbiased professional analyses,
and conclusions.
I have no (or the specified) present or prospective interest in the property that is the
subject of this report, and I have no (or the specified) personal interest or bias with
respect to the parties involved.
my c~mensation is not contingent upon the reporting of a predetermined value or direction
in value that favors the cause of the client, the amount of the value estimate, the
attainment of a stipulated result, or the occurrence of a subsequent event.
- the appraisal assigament was not based on a requested minlmumvaluation, a specific
valuation, or the a~roval of a loan.
my analyses, opinions, and conclusions were developed, and this report has been prepared in
conformitywith the ~niformStandards of Professional Appraisal Practice and also
requirements of the Code of Professional Ethics and the Standards of Professional Practice
of the Appraisal Institute.
- the use of this report is subject to the requirements of the Appraisal Institute to review
by its duly authorized representatives.
- I have (or have not) made a personal inspection of the property that is the subject of this
report.
no one provided significant professional assistance to the person signing this report. (If
there are exceptions, the names of each individual providing significant assistance must be
as stated.)
as of the date of this report, I, Mark E. Hilbert
have c~=mleted the requirements un'er the continuing education programs of the Appraisal
Institute.
A review of this agreement of sales has been detemined that personal property items, and/or
intangible items, that are not real property, HAVE NOT been included in the agreement of sale.
Personal property items, and/or intangible items {{AVE NOT been considered in detemining the
subjects estimated market value.
NO YES
1. X
2. X
3. X
January 4, 2002
Date
The subject sold during the last year.
Sale price $ Date
The subject was listed for sale at the t/me of inspection.
Listing price $
The subject was under agreement at the time of inspection.
Agreement price $
Apprai~~
(X) Did ( ) did not inspect property
Form FH5 MCS, a Division of ACI Development {800) 697-7783
MARK E. HILBERT & ASSOCIATES
APPRAISAL REQUIREMENTS
MANDATED BY FIRREA
I certify that the appraisal conforms to the Uniform Standards of Professional Appraisal Practice (USPAP) promulgated
by the Appraisal Standards Board of the Appraisal Foundation.
The subject [] {is) [] (is not) listed for sale, the listing price is $
period of the subject property is
· My estimate of the reasonable marketing
If an approach to value was not used, the following is an explanation why it was not considered.
Cost:
Market:
Income: n/a
The appraisal assignment [] (was) [] (was not) based on requested minimum or specific valuation or on the approval
of a loan,
I [] (have) [] (have no) financial interest in the loan transaction and do not stand to benefit in any way from the
value placed on the property.
I [] (have) [] (have not) included a separate assessment of personal property, fixtures, or intangible items which
are attached to or located on the real property. These items [] (do) [] (do not) affect the market value of the
real property.
Any creative financial or sales concessions that are known to the appraiser have been adjusted in the comparables of this
appraisal.
In performing this appraisal, I was not able to review the:
Taxes
(insert N/A if inapplicable)
The above items should be obtained by the lender when reviewing the appraisal report.
This appraisal was done with an "as is" market value. This is the value of the property in its current physical condition
and subject to the zoning in effect as of the current date of value.
I certify that I have t~he approp~te knowledge and experience that was necessary to complete this assignment.
This appraisal report conforms to the Uniform Standards of Professional Appraisal Practice
(USPAP) adopted b~ the Appraisal Foundation.
The builder/seller is paying % points {$ )
and/or $ in concessions on the subject property.
The following personal property, fixtures, and/or intangible items are not included in the
appraised value but are a part of the sale of the subject property.
ITEM ESTIMATED VALUE
1. Refrigerator $ 475.00
2. Range/Oven/Hood $ 525.00
3. Dishwasher $ 275.00
4. Washer/Dryer $ 400.00
It should be noted that the appraiser is trained in the valuation of Real Property, not
Personal Property, therefore, the above estimated values may have dicrepancies from real
value.
Form FIL MCS, a Division of ACI Development (8001 697-7783
COPYRIGHT ~,985
tgt~l,~ GARY R, WEGI~;~YNOWICZ and PATRICIA A, WEGRZYNOWICZ
{formerly Patricia A. C,.~ael), his wife, of York Springs, Adams
COunty, Pennsylvania
GRANTORS
AND
GALEN G. HALL. single ~,an, of Dillaburg, York County, Pennsylvania
GRANTEE
........................ Dog,rs,
his ~t~i*'~ ~m/~/F~,
AL~ THAT CERTAIN piece o~ parcel of land, ai~uate on the w~e~ aide
of Mo~n~atn Road, L.R, 6500~, in the Township of ~etimore, Coon~y
of Adamo, Commonwealth of PennsyZvania, more particularly bounded
andd~aeribed according to a final plan of lots Of Section ~-A of
S~one Head ~statea p~ep,,~md by Jerry D. LaRge, Registered surveyor,
4ate~ A~ril 21, 1978 as £ollows, to wit~
BEGINNING at a~ iron pin on the dedicated right-of-way llne on t~e
East aide of Mountain Road, L,R, 66001, at the coat, on lo% line of
lots 13 and ~4 of the ~l'oresaid plan: thence along the common lot
line of Lots No. ~3 and 24, South fifty-five (55) d~grees fifty-
eight (58) minutes ~Or~y-sight (48) seconds East two hundred ninety
and no hundredths (290.00} feet to an iron pin; thence a3ong other
lands of Grantors South thirty-four (34} 4egrees One (1) minute
twelve (12) seconds West one hundred fifty end no hundredths
feet to a concrete mo~)umsnt on the dedicated right-of-way line of an
unnamed ~t=eet; thence along said unnamed street No~th fifty-five
(55) degrees fifty-ei~h% (58) minutes fo~t~-eight (48) seconds West
two hundred sixty and no hundredths (2~0,00) ~eet to a point: thence
on a curve to the right, having a tangent of thirty (30) feet, an arc
of forty-seven and twelve hundredths (47,12) feet, add a radius
thirty (30) feet along the right-of-way line of the aforeaai~ un-
named street and Mount;'{.n Road, North ten (10) degrees fifty-eight
(5~) minutes forty-eigl,t (48) seconds West to a point on the
right-of-way line of the said M0ontain Road; thence alen~ the
· ight-ef-wa¥ %ina of said M,~untain Road North thirty-four (34) degrees
one (1) minute twelve (12) ascends East One hundred twenty and no
hundredths (120.00) feint to an iron pin. the point and piece of
~ZGINNING,
BEING bet No, 24 ~f th~ afor~,said final ~lan of ae~%ion 3-A of Stone
~oad ~$tates recorded .La A~ms County ~lan Book 21, Page 45.
MARK E. HILBERT & ASSOCIATES
File No. 02-021v1'1_
DEFINITION OF MARKET VALUE: The most probable price which a property should bring in a competitive and open market
under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeably and assuming the price is not
affected by undue stimulus, implicit in this definition is the consummation of a sale as of a specified date and the passing of title from
seller to buyer under conditions whereby: (1) buyer and seller are typically motivated; (2) both parties are well informed or well advised,
and each acting in what he considers his own best interest; (3) a reasonable time is allowed for exposure in the open market; (4) pay-
ment is made in terms of cash in U. S. dollars or in terms of financial arrangements comparable thereto; and (5) the price represents
the normal consideration for the property sold unaffected by special or creative financing or sales concessions* granted by anyone as-
sociated with the sale.
* Adjustments to the comparables must be made for special or creative financing or sales concessions. No adjustments are necessary
for those costs which are normally paid by sellers as a result of tradition or law in a market area; these costs are readily identifiable
since the seller pays these costs in virtually all sales transactions. Special or creative financing adjustments can be made to the
comparable property by comparisons to financing terms offered by a third party institutional lender that is not already involved in the
property or transaction. Any adjustment should not be calculated on a mechanical dollar for dollar cost of the financing or concession,
but the dollar amount of any adjustment should approximate the market's reaction to the financing or concessions based on the app~
raiser's judgment.
STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION
CONTINGENT AND LIMITING CONDITIONS: The appraiser's certification that appears in the appraisal report is subject to
the following conditions:
1. The appraiser will not be responsible for matters of a legal nature that affect either the property being appraised or the title to it. The
appraiser assumes that the title is good and marketable and, therefore, will not render any opinions about the title. The property is app-
raised on the basis of it being under responsible ownership.
2. The appraiser has provided a sketch in the appraisal report to show approximate dimensions of the improvements, and the sketch is
included only to assist the reader of the report in visualizing the property and understanding the appraiser's determination of its size.
3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency (or other data
sources) and has noted in the appraisal report whether the subject site is located in an identified Special Flood Hazard Area. Because
the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding this determination.
4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question, unless
specific arrangements to do so have been made beforehand.
5. The appraiser has estimated the value of the land in the cost approach at its highest and best use and the improvements at their con-
tributory value. These separate valuations of the land and improvements must not be used in conjunction with any other appraisal and
are invalid if they are so used.
6. The appraiser has noted in the appraisal report any adverse conditions (such as, needed repairs, depreciation, the presence of hazar-
dous wastes, toxic substances, etc.) observed during the inspection of the subject property or that he or she became aware of during
the normal research involved in performing the appraisal. Unless otherwise stated in the appraisal report, the appraiser has no know-
ledge of any hidden or unapparent conditions of the property or adverse environmental conditions (including the presence of hazardous
wastes, toxic substances, etc.) that would make the property more or less valuable, and has assumed that there are no such conditions
and makes no guarantees or warranties, express or implied, regarding the condition of the property. The appraiser will not be respon-
sible for any such conditions that do exist or for any engineering or testing that might be required to discover whether such conditions
exist. Becat~se the appraiser is not an expert in the field of environmental hazards, the appraisal report must not be considered as an
environmental assessment of the property.
7. The appraiser obtained the information, estimates, and opinions that were expressed in the appraisal report from sources that he or
she considers to be reliable and believes them to be true and correct. The appraiser does not assume responsibility for the accuracy of
such items that were furnished by other parties.
8. The appraiser will not disclose the contents of the appraisal report except as provided for in the Uniform Standards of Professional
Appraisal Practice.
9. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfactory comp-
letion, repairs, or alterations on the assumption that completion of the improvements will be performed in a workmanlike manner,
10. The appraiser must provide his or her prior written consent before the lender/client specified in the appraisal report can distribute
the appraisal report (including conclusions about the property value, the appraiser's identity and professional designations, and
references to any professional appraisal organizations or the firm with which the appraiser is associated) to anyone other than the
borrower; the mortgagee or its successors and assigns; the mortgage insurer; consultants; professional appraisal organizations; any
state or federally approved financial institution; or any department, agency, Or instrut~entality of the United States or any state or the
District of Columbia; except that the lender/client may distribute the property description section of the report only to data collection or
reporting service(s) without having to obtain the appraiser's prior written consent. The appraiser's written consent and approval must
also be obtained before the appraisal can be conveyed by anyone to the public through advertising, public relations, news, sales, or
other media.
Freddie Mac Form 439 6-93 MCS, a Civision of ACI 0evelopment (800) 697-7783 MCS Form LC5 Page 1 of 2 Fannie Mae Form 1004B 6-93
MARK E. HILBERT & ASSOCIATES
APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees that:
1. I have researched the subject market area and have selected a minimum of three recent sales of properties most similar and
proximate to the subject property for consideration in the sales comparison analysis and have made a dollar adjustment when
appropriate to reflect the market reaction to those items of significant variation. If a significant item in a comparable property is super-
ior to, or more favorable than, the subject property, I have made a negative adjustment to reduce the adjusted sales price of the comp-
arable, and if a significant item in a comparable property is inferior to, or less favorable than the subject property, I have made a pos-
itive adjustment to increase the adjusted sales price of the comparable.
2. I have taken into consideration the factors that have an impact on value in my development of the est[mate of market value in the
appraisal report. I have not knowingly withheld any significant information from the appraisal report, and I believe, to the best of my
knowledge, that all statements and information in the appraisal report are true and correct.
3. I stated in the appraisal report only my own personal, unbiased, and professional analysis, opinions, and conclusions, which are sub-
ject only to the contingent and limiting conditions specified in this form.
4. I have no present or prospective interest in the property that is the subject to this report, and I have no present or prospective per-
sonal interest or bias with respect to the participants in the transaction. I did not base, either partially or completely, my analysis
and/or the estimate of market value in the appraisal report on the race, color, religion, sex, handicap, familial status, or national origin
of either the prospective owners or occupants of the subject property or of the present owners or occupants of the properties in the
vicinity of the subject property.
5. I have no present or contemplated future interest in the subject property, and neither my current or future employment nor my
compensation for performing this appraisal is contingent on the appraised value of the property.
6. I was not required to report a predetermined value or direction in value that favors the cause of the client or any related party,
the amount of the value estimate, the attainment of a specific result, or the occurrence of a subsequent event in order to receive my
compensation and/or employment for performing the appraisal. I did not base the appraisal report on a requested minimum valuation, a
specific valuation, or the need to approve a specific mortgage loan.
7. I performed this appraisal in conformity with the Uniform Standards of Professional Appraisal Practice that were adopted and pro-
mulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place as of the effective date of this appraisal,
with the exception of the departure provision of those Standards, which does not apply. I acknowledge that an estimate of a reason-
able time for exposure in the open market is a condition in the definition of market value and the estimate I developed is consistent
with the marketing time noted in the neighborhood section of this report, unless I have otherwise stated in the reconciliation section.
8. I have personally inspected the interior and exterior areas of the subject property and the exterior of all properties listed as compar-
ables in the appraisal report. I further certify that I have noted any apparent or known adverse conditions in the subject improvements,
on the subject site,or on any site within the immediate vicinity of the subject property of which I am aware and have made adjustments
for these adverse conditions in my analysis of the property value to the extent that I had market evidence to support them. I have also
commented about the effect of the adverse conditions on the marketability of the subject property.
9. I personally prepared all conclusions and opinions about the real estate that were set forth in the appraisal report. If I relied on sig-
nificant professional assistance from any individual or individuals in the performance of the appraisal or the preparation of the appraisal
report, I have named such individual(s) and disclosed the specific tasks performed by them in the reconciliation section of this appraisal
report. I certify that any individual so named is qualified to perform the tasks. I have not authorized anyone to make a change to any
item in the report; therefore, if an unauthorized change is made to the appraisal report, I will take no responsibility for it.
SUPERVISORY APPRAISER'S CERTIFICATION: If a supervisory appraiser signed the appraiser report, he or she certifies
and agrees that: I directly supervise the appraiser who prepared the appraisal report, have reviewed the appraisal report, agree with
the statements and conclusions of the appraiser, agree to be bound by the Appraiser's Certifications numbered 4 through 7 above, and
am taking full responsibility for the appraisal and the appraisal report.
ADDRESS OF PROPERTY APPRAISED: 1751 Mountain
APPRAISER: ~-~. ~ ...~/ ~
Name: ~,~: - E. gil~t ~
Date Signed: January' 28r 2002
State Certification No.: P,L 000388-L
or State License No.: l~B-029755-A
State: Pennsylvania
Expiration Date of Certification or License: 6-30/03
Road, York Sprin.gs, PA 17372
SUPERVISORY APPRAISER (only if required):
Signature:
Name:
Date Signed:
State Certification No.:
or State License No.:
State:
Expiration Date of Certification or License:
[] Did [] Did Not Inspect the Property
Freddie Mac Form 439 6-93 MCS, a Division of ACI Development (800) 697-7783 MCS Form LC5 Page 2 of 2 Fannie Mae Form 1004B 6-93
QUALIFICATIONS OF APPRAISER
Mark E. Hilbert, CR.MA, ICA, GRI
Broker Appraiser
Education:
Real Estate Pennsylvania Title Insurance, Harrisburg
Real Estate Theory and Practice
Real Estate Law
Real Estate Math
Real Estate Appraisal I
Real Estate Advanced AppraiSal
Standards of Professional Practice - Part A
Standards of Professional Practice - Part B
Market Extracti~ns
Fannie Mae Review Seminar
Professional Memberships and Designations:
Senior Member - International Organization of Real Estate Appraisers
American Fraternity of Real Estate Appraisers
Graduate Real Estate Institute
Candidate Appraisal Institute
Harrisburg Board of Realtors
Pennsylvania Board of Realtors
Pennsylvania Association of Realtors
National Association of Realtors
Pennsylvania State Certification Number - RL-000388L
Experience:
C.M. Detweiler Real Estate Inc.
March 1971 to April 1976
Stuard Derrick Real Estate Inc.
April 1976 to October 1981
RE/MAX Realty Associates
October 1981 to February 1986
Mark E. Hilbert a Associates
February 1986
Real Estate Licence: March 1971
Associate Broker: April 1976
Appraising since 1979
Appraisal Experience:
Appraisals for= first mortgage, second mortgage, equity loans, employee
transfers/relocations, single family, condo.
Cumberland, York, Dauphin and Perry Counties.
Completed Assignments for:
Banks, Savings and Loans, Mortgage Brokers, Relocation Ccm%panies, Trust
Departments and Attorneys.
Client List availeble upon request.
Just T.H.E. Fax
T.H.E. Financial Group, Ltd,
1 Kacey Court, Suite 201
Mechanicsburs, PA 17055
Phone: 717-766-4561 Fa:c: 717-691-3299
Company:
~a~: oq HID - q Dq ~
Phone:
Date: r-/_ ~_ Oc~
# Pages (Including coy.er): I
From:,_~t~
To view account datell,, cllck the Oel~i~ Ink.
4coeur: 6460:2§45 '~ex ~o,,~sN: 177-54-4684
, Of INASHING.T~:~ MUTUAL INVESTuR:$ FUND.CLASS
THE tNYE ST'~=NT COMPANY
NEW~RSP~C~ FU~C~S
~E N~ ECQN~ FUN~
Vlnlon~
AcceuntV.ll~ ~: $44,~,15
Total Value: $ 44,i~1L18
ITeachers Insurance and AnnaRy A~ociation
Collide R~tirem~at Equities Fund
Republ/c Plaza, Suile 200, 370 Sevenl~enth Street
D~n~er, CO S0'202-5C:02
I,,,llh,,llh,,,h I,II,,,,,Ih, ll,,,h,h h,llh,,I
PAMELA Y HALL
5145 E TRINDLE RD # J
MECHANICSBURG PA 17050-3644
Iune 27, 200'2
Re: Verification of Deposit Request
Dear Participant:
I am writing in response to your request for information regarding your annuity(ies). II is my
pleasure to assist you.
You currently have the following annuity(ies):
TIAA-.CREF Retirement Annuities
TIAA-CREF Retiremem Annuities (RAs) and Group Retirement Annuities (GRAs) are
designed to guarantee a lifetime annuity income or to pay a death benefit to a beneficiary in
the event the participant dies before be~nning income. Cash withdrawals may be available,
subject to the provisions cf the eihlaloyer's rmlrement plan.
The following chart provides annuity value information as of lune 25, 2002.
· ::: :~ ;:,ii i i ~::::~i:;:: : ::'::i:~ .::: : .:. :: :
TIAA. RA Real Estate C920077-9 04/01/1999 Yes $831.92
CREF RA U920077-7 04/0111999 Yes $4-,562.12
TIAA Traditional accumulations will increase in the future as they are credited with addition~
premiums (if any) and interest earnings. The valu~ of TIAA Real Estate Contracts and CREF
Certificates will increase or decrease in the fuvaxe depending on the investment experience of
the underlying accomam in which the funds are invested.
TIAA-CREF Individual and Institutional Services, Inc.
Headquarters: 730 Third Avenue, New York, New York 10017-3206 Tel: 212 490-9000
I trust this inforraation is helpful. If you have any questions or require ~rther assistance,
please contact our Telephone Counseling Center toll flee at ! 800 84-2-2776, weekdays 8:00
am to 11:00 pm ET, or weekends 9:00 am to 6:00 pm ET.
Sincerely.,
SERVICE CENTER WEST
FJAholdusA
Ahold USA, Inc. 401(k) Savings
Plan for Salary Associates
Retireme; ~t Savi ent
June 7, 2001 - June 25, 2002
#BWNFXTG
PANELA Y HALL
51~S E TR[~DLE RD
APT J
HECHANZCS~URG, PA t7050
ENV~EG0002B3
MG 35846A
~' For iniormatio~, aboui ~ur account or for questions
about this ~tatement, you carl c~ll the
t~ll-free number at
Your Account Summary
Beginning Balance $0.00
Your Contributions 3,684.13
Employer ContribUtions 832.50
Fees -0.70
Change In Market Value -$9.15
Ending BManee $4,456.78
Additional In/~,'/.ation
~ Vexed Balance $3,966.19
+ Dividend & J['~terest ~29.$0
Your:Per'nat R&~,~ of Return
This Period -3.8%
Year to Date -2.1%
Your Pers~.qal ~eAe ~' Ret~m is cal~lated with a
f~mula, wid~y us~ by tin~clai a~s ~ ~lata Inv~em
e~bgs II re~$ ~e r~ulls of yo~ in~a~ent ~lec~ons as
wee ~ any ~t~i~/i~ ~ ~ a~oun~) shown. ~re
Per~ R~e ~ Return formulas used ~ may ~e~
re~l~.
Your Asset Allocation
Stocks 79%
~}ond= 2 i %
account is currently aliocaled among ~he aSset cla~ses
specified above. Percentages and totals may nct be exact due
Market Value of Your Account
Displayed in If~ sect~n is the value o~ your ao=ount fo~ the statement psriod, in bo[h sba'es an~ dollars
Sherea o~ Sheree on Pri;e on Price on Market Value
Investment 06/06/2001 ~/25~ ~1 ~/~2 ~06~
F~e]~ ~ui[y thc 0.0~ ~ 8.~0 $54.31 ~44.62 0,00
F~eli~ L~ Pr Stk O.O~ 33.391 $26.89 $28.79 0.00
MSIFT Vabe Adviser 0.0~ 30.101 $16.~ $13.72
S~an US EQ Index 0.0~ 11.472 $45.09 $~.54 0.~
84t.~9
961.33
396.24
Please r~d ~hl$ statement carefully. Any e~r~r must be reported ~ Fldei~ty fnv~stn~ents wilhin go days.
"~)28~ MG000285 00(~1 ;~0020827 MC-.4K
Fidelity' Investments, P O_ B~x 7 ' '
70003, C~nclnnati, OM 45277-0065
Pe~= ; of 6
Ahold USA, Inc. 401 (k) Savings
Plan for Satapj Associates Statement Period: 06/07/2001 to 00125,'2002
Market Value of Your Account (continued)
Shares on Share~ on ~ce on ~ on Mmket ~al~ ~et value
0.o0 ~.al
-~-~i: ~ ' ~'~' - '~ "~
Re~er lhat a ~vi~nd pa~t to fund ~hamh~lders reduces ~e s~are p~e of ~e
peri~ ~ not n~e~se~ily re~ecI I~er ~ p~. tu~, ~ a ~ri~ in ~ sha~ prm for ~ ~l~enl
Your Oo~lri~uIion El~cIio~s as of 0~/2~/2~2
~is '
se~ d~a~s ~e funds l~ ~ic~ ~m ~e c~t~bu~ ~ ~ i~e~d
F~e~ty Low Pr Stk 2~ 20%
Man~ B~d Fund 2~ 20%
MSI~ Va~e ~viser 1~ 10%
Spa~ US Eq index t~ 10% 10% 1~ 10%
A~ ~ny
Year ~ D~e $2.019.13 $~2.~
Vested Percent
100.00
ill
40.00
Account Activity bY Source
Use Ibis section a~ a summary 3~ transactions fi)at occu~ed In your aocount during Ihe statement period.
Activity Ass~L;te Company
Vo~l~Mrv
Beginning Balance ~ . ~.~ ~.~
Y~r Co~tri~s 3,6~. 13 0.00 3,684.13
EmPbver Contrib~ns 0.00 832.50 ~2..~
Fees -0.58 -0.12 -0.70
Ch~ In M~ Value -44.42 ;14.73 -59.15
End lng aNan~e ~,639.13 $817~5 ~,456,~
V~sted P~entag~ 100.00 % 40.00 %
Vesled Balance $3,639.13 $327.06 $3, g66.19
Div~end & line,est $27.67 $2.13 $29.80
0283 MG0002,33 , II
0001 20020627 ~iG4K ,
Fidelity Investments, P.O. Box 770003, Cincinnati, OH 45277-0065 -
Page 2 of 6
Ahold USA, inc, 401(k} Sa'br~gs
Plan for Salary Associates
Statement Period: 06/07/2001 to 06]25/2002
Your Account information
If ~nformaUon batnw is incorrect, please contacl your Benelits Olfic~.
General Informati~l
Participant Status Active
Dlv~ion 406
Employee Number
o~
Defe~als
Associate Voluntary 6%
A Message From Ahold USA
Starling next quarter, you will receive your quarte~y participant ~tatement online through NetBenefits. An annual printed s+,atemen!
of actMt¥ will be sent to you at the end of each year. It you do not have access to the internM, or if you prefer to contin-e ~ eceiving
your quarterly statement through the mail, simply call 1-800-249~015 to ~hange your statement election or Icg or1 to NetB~netits at
www,401k.com and change Four elecliOll within the "Mail Preferences" under the Savings tab.
Fund Performance
A summery of investment performan~;e of all funds available in the pl~q. Funds you c~m are mar~ed wiU1 an asterisk.
I Cum'utat/v'~* I An.uafT. talFteturn, l Aven~.AnnuefTemlRe,urn~asoro3~J1/=tte21t~ep,lor,'
Fidelity Divers lntl' 8,10 8,34 -12.99 -8.96 50.65 1.04 5.90 ~.18 11.43 ~0.~
Fidelity _Equity I~ 0.70 0.06 -5.02 8,54 7,15 4.80 3.82 10.39 13.77 13.81 0.~h 6/1966
Pide§ly C-i~w & Inc ~3.05 -4.48 -9.36 -1,98 10.42 2.~0 -1.00 10,32 13,55 15.89 12r30/1985
Fidelity Lm~ Pr $tk' 8.70 g.77 26.71 1&,83 5,CS 30.40 ~2.! 1 18.51 17.38 18.50 12/27/1989
FI4ality ldage#an .3.4.O -8.05 -11,65 4).29 24.05 -(3,76 -3.07 10.72 12.80 20,35 05~2/1953
Ja~us Twenty Fund -7.73 -13~ -20.20 -32.4~ 64.G0 -11.48 -15.44 10.49 12.0~ 14J~) 04/28/1985
Ja~u~ Woddwld~ -1 ,~¢, -7.09 -22.88' -16.87 64.37 -7.72 ~1.73 8.43 13,48 14.56 06/16/1991
LdAbb~'t Day Grth A 0.49 -5.79 `8.~8 -1759 38.16 12.75 1 44 9.07 12,20 11.37 10/10/1973
MSIF¥ Value Adviser* 1.46 0.39 4,27 23.20 -2.34 9,54 10.00 8.95 N/A 12.22 07h7119~6
Sl-'~tan U~, Eq Index* ~3.29 -6-b-7 -12_05 -9.18 20.86 0.04 -2.69 g.98 13.02 13.54
II~rkst ladiee~~' 02/17/1988
S&P 500 Index .3.25 -5.50 -11.89 -9,10 2:1,04 0.~4 -~,53 10.18 13.Z6 N/A
World index 1_02 -2.91 -16.82 -13,18 24.93 ,4.24 -4.39 5.38 9,02
Fid Free, em ~000 q3.O9 -062 -0.0~ 3.98 12-$6 3.21 4.47 9.20 N/A &8~ 10/17f10~
Fid Freedom 20iO -0.4a -1.75 -4.34 0,67 10.04 2-31 3,48 10,39 NrA 9.99 10/17f19~6
Fid Freedom 2020 -o.go -3.34 `9.07 -3.03 25.31 1.12 1.99 10,38 N/A t0.0~
Phi Freedom z030 -1.07 -4 ~.2 -11.60 -8,07 28.~3 0.25 O.~ 9,B1 N/A · 9. B4 ~0/17f1~
Fid F. reedorn 2040 -1.13 -4.74 -13.50 NtA N/A -0.40 N/A N/A NiA -15.80
Mortal'jarl Bond Ftmd~' 1.34 2,48 8.~ 0.70 L00 5,47 6.30 N/A N/A 644 09/02J1997
Market
Dow dorm~ Index -1.36 -0.24 -5.39 -~.71 27.13 7,23 3.75 11.42 t4.79 N/A
Upper Baten,~e~ Fund irlclex -O,31 .I_86 -3.24 2..39 898 2-4~ 2.25 8.40 9.73
~- Past per[~'rnanc~ i~ no guere~ee of ~JlLIre results. Total returns ,&ce hJstori~aJ ar,d ii~c%de the cha~ge irt share value and reim/estm~,'~t of dl~kfen~
and capital ~irl distribu§ons, If any. Cumtdative returns are reported as of Ihs peri,ds shown. Li~ ~f fund ligures are trorn commencemen! d~te to
1he perl~x:l show,~. Due to regulatory mquimmenf~ Ihs average a~lnaal tota~ returns are reported a~ of the m~,t re~ent calendar ClUel't~r f~[
c,ofllrlOU.~Orl,S macle ttlrough your co~P, pany s employee bene~l plan. If sales charges ~A,~re iacluded r,~l~rn~ wo~'~i haw been I~-,~
s~..r~m..F~,.,m~.._(.e_{[.o~_ ~p~, _.m~r;ey.m'z~k, et ~unds), yield, end return wlit vary, and you ma~ have a gafn or cie when you sel~ your ~h aYe-s'~ ........
r~..~.{), ~w~a[.~ ~ruemellonat sssessas a s~o~t-term tradb~g fee of 1 01~',~ tar shares held la, ss Iha~ 30 days.
Fidelity Low-Priced ~Btook Fund assesses a short-term t~&~irl~ fee of 1 50% f~' shams held less #lan g0 da~s
M°lga~ Sta~te¥ In~§~ttena[ Fund Trust Value Ps.folio - Adviser Class was formerly known as MAS Value'P~llf~lo - Adviser Class.
0283 MG000283 0001 20020627 MG4K '
Fidelity Investments, P,O. Box 7;70003, Cincinnati. OH 45277-0065 Page 3 of 6
Ahold USA, Inc. 401 (k) Savings
Plan for Salary Associates
Statement Period: 06/07/2001 to 06/25t2002
Fund Performance (continued}
~y ,~.nds ?e, .men,aged ~y ,non-Fide;ity sn~as. Please con suit ~a prot, pecKis, lsct sheet or Su P an Descr tlon iq'
· IraPp.a?~?la, o~?ss o; snares may vaty. PleasecormultyourPlandocumml~:3nfor~r~s ~ ~) . ,more
plan. Pe~orman~e ~nforn~atien for non-Fide~ funds w ~ ;,a,.~ ~... ,~..~ ............ ~ . ct. aa, s of shares available ~rough
Fidelity Is ternporarll¥ relmbur~lrg a per,on ol Spartan U.S. EquRy Index Fund's expenses Absent such reimbursement, returns wc=JtCt have been
Ioleer.
The Morgan S~mnJey Capital Inlernationr~t W~'Id In~x (~o~ld Index[, is an unmanaged ~:i~x ~ovar 14GO deme.e, fdc and t~ra~ n .
* The S&P 500(R) Is a registered service mar'(( of The Mc~'aw-Hffl Companies. Inc., and has been ilcensed for usa by F~dsl[~ Di$~'lbu~rs
The Dow Jones I~lclust~ Avmrag~
relnveatment of div~ends, i donas) ~s a~, unrnancgae mclex o~ cornmop stock~ al the 30 major mdustded companies and assumes
make ~r In~ment on~& Pt~li I ' . ~ ~e~y ~fore
~ nve~ants b~utl~ ~s ~y, In~ 82 De~h~ ~e~ ~s~n MA 0~1~.
A Message From Fidelity
You've heard the expression. "Donl put alt yOur eggs in one bas, et" Well that saying also applies to inveshn Diffe
c asses (stocks bonds and shore-term investments~ re~d .~a-::-,,_ ,_' .......... ! g. ' ran! asset
be riSing, another may be falling. DlVeralf cation across asset classes spreads your risk across a variety of financial I
potentially reducing the impact that any One investll, lent iS likely tO have on vd=i; overall ,,ortfc, U~ T~^ ~: .-. ::: .... ~?~ es,.tments.
investments among the d~fferent a~sel classes I~ to employ an Investrnent strategy called a et allocation'. So check your asset
allocation today to make sure you are ~Jffiotently diversified.
DJversitlcatk)n does no! en~ure a profit or guarantee
Gi300283 000~ 20020627 MG4K "
Fidelity Investments, P.O. Eiox 770003, Cincinnati, OH 45277-0065 Page 4 of 6
Ahold USA. Inc. 401(k)
PI~ for Salaly ^ssociams
Fund Notification Messages
S~al6ment Pert~d: 06/07/2001 to 06,~25/2002
irFiydeity Freedom Fu,'~cls(RJ provide asset aJ ocation f~, nvestlng in o~ RdNi R s~k. ~
e~ hc~ he Fid~i~ HI-h Ir~- c..~ ~,. _. ,~ ...... ~( ) . no ~d mo~y ~rket funds. As ot /1~ ~
~cate ~ h~gl~ld ~nds ............... . .m ~m ~un~ except ~or FI~iw Fr~dom '~ Fund/Rt .~,?~se
Fidelity tr~vestments, p 0 I~_~,4 770003, Cincinnati, Oil 4527742065
P e..cje 50f6
Ahold USA, Inc. 401 (k)Savings Stalement PerioO: 06/07/200 ! to 06/25/2002
Plan for Salary Associates
Your Statement Glossary
Average Annual Total Return
This ia t~e hypornatJ~ai rate of m~m, ~t If ~ ~ves~e~t ~on a~ie~ it ~er a y~r's ~. w~ p~
ream If ~e Inve~enl option ped~ed ~ns~ste~ over ~e entire p~. A tot& mk~rn is e~ressed in a ~men~ ~d ~fls you h~
~ch ~e i~t has ~r~d or lost ov~ fi~, as~m~g th~ a~ ~vi~ ~d ~i~ g~ns are r~nv~d.
~ c~ [n~[ue ~fl~ts ~a~ns In the p~ ~ ~e ~ ~ I~es~nl opaon ~se of ch~ in the r un~Hy~g
~mu~Sve T~I Return
~is ~r tells ~ ~ invee~e~rs ~F~ ~ Ior a caren p~od of t~. R ~t~ return is expense
~ m~ money y~ nave e~n~ ~ ~o~ ~ an m~menl over time, ~sum~g ~t ~1 ~nds and c~t~l gains
~VI~s
In ~e in~l op~s ~ y~r pl~. im~u~ mutu~ ~S and c~ st~k (~ ~E~) dlvU~ds am m~ey ~ ~ sh~eho~ers
· at ~ ~*~. ~he ~n~es~nt ~co~ ~ ~e ~und has ~d. ~n~ on :ha ~es of your pl~. ~vi~nds
m~e~ ~b your mUre~t a~unt or pad to ~u ~ ~,
~ket VaI~
M~et Vabe ~ ~a ~lar v~ue of the in~s~ in y~ ~o~[ You c~ ~cula~ ~ ~ value by usi~ ~e ~ng ~o~u~:
M~t Va~e - Nu~r of ~s In ~ ~ x ~e per share of ~
~s ~ your u~ts of ownership of eab~ b~vas~tent in yo~' ac~unC
Share ~
~ v~ue of ~e she~ of ea~ Inves~t in yo~ so.ant is ~led s~ pdt. It b ~t~m~ by ~ ~e ~1 va~e ot ~e whole
in~s~l option on a ~ven ~y ~d d~v~g it by the n~et ~ s~res o~s~ng.
V~llng
V~t~g m~;s ~ ~ ~ ~ own~sh~ ~ ~mpany ~n~8~s a~ ~y ~s~d e~hgs. When the ~y
~ ~um:~t msi~s in ~' a~t, un~r y~; n~. Th;~ ~y b~s ~lv vows o~e ~, have =~'~
e; ~ur pl~. ~u ~ ~w~ enflS~ to 1~% of your ~b~ ~d ~y a~~s. ~ ...............
Asset Allocation
tn~$lrnenls oan be dlvidedlnt~ Ihr~a m~, asset ~ses;
~ ~m~t ~es.~f unde~lng;~e; t~ ~y be
mves~nl op~oni;l you ~. Plea~ n~ ~al you may
a blen~ ~ ~e~ ~e ;und h~ngs ~e In~est~ ~ ~re lh~ one
~set ~s.
r~m~m owne~ or e~l~ ~ e comfy. ~ks
p~nfi~ to o~orm ~her t~; M ~s~ over ~ ~ng
te~. H~ver, s~c~ ~nd to h~e w~ ~ ~afi~s over
s~ p~io~ of fl~ ~n other se~es,
· gon~
re~e~n[ a I~n ~ a ~o~ota~n ~ ~v~nt A~noy, and
pr~e ~e o~o~i~ fm higher c~rrent l~me ~ she-term
inves~m~. U~Ilke ~-~m ~ve~ments ~d ~ ~lua
in~m, ~d ~ces fl~ wi~ ~s In int~est
+ Sho~ Term
Sho~ te~ ~wstm~ c~ add s~b~ ~ y~r po~.
provide ~r~nt ~me end ~ek to pm~we ~e va~e of y~r
~n~s~[ They ebo m~d ~ prov~ ~he ~we~ returns owr
~fl~les 0f d~0~t (CDsL Treas~ B~is ~ Money M~et
A Market index can measure ~e genera trends In ~; p~e ot
P~ m~t se~. y~ ~ use ~he appmp~te ~ket
to o~p~ ~ ~oe (Av~e Annual ~m) ~ the
~ you're I~e~d.
· Sm~rd ~d ~'s ~
~ ~ ~ ~r~es a bro~ b~ ot 5~ s~. ~clu~
;n~sb~, uaa~, a~ ;na~ia ~m~. ~ of Its
~ ~ mo~e ~mo~. I ~e comp~ms ~ ~ke up the ~&P
Excha~, as ~1 ~ ~ Over-~e-~nt~
· Lehmm Br~. A~a~ ~d Index
10 ye~.
· ~ ~y EAFE~d~
ouls~e ~e Unl~ ~e and ~n~ T~ M~I EAFE index
l~ a m~er~ se~ce ~ ~ ~ S:~ley and h~
II~d ~ usa by FMR Corp.
npRR MG000283 ' 0001 2O02oe:~? MG4K '
Fidelity Investments, P.O. Box 770003, Cincinnati, OH 45277-0065
l tl lllillllIIllllllllllllilftlllllilllllallII
1 !~1t lift I~l III ~11 III II Illlll BI IIII II! II lB III1 II~I II II
Page
Hartford Life
Hartford Life and Annuity Insurance Company
505 Highway 169 North Minneapolis, MN 55441-6400
POLICY NUMBER 101 LU0955779
POLICY OWNER
GALEN G HALL
1751 MOUNTAIN RD
YORK SPRINGS PA 17572-9790
Year Ending
Policy Date
NOVEMBER 29, 2001
ANNUALREPORT
NOVEMBER 28, 2001
NOVEMBER 28, 1988
INSURED GALEN G HALL
CURRENT DEATH BENEFIT 120,000.00
Pleaseseepage2 ~ranyadditionalcoverages.
SCHEDULED PREMIUM
102.50 QUARTERLY
This report summarizes the transactions that have occurred in your account during the past year.
After reviewing, please place it with your policy as your record of the status of your policy.
We are very pleased that you have chosen The Hartford as the company to provide you with this
valuable coverage. That decision by you is especially important when you know that you are with a
company that distinguishes itself in the insurance and financial services industry. The Hartford offers
safety, security, financial strength and product innovation. As a member of the The Hartford Insurance
Group, you have a 180-year history of growth and stability behind you.
We are also proud of the services that are available to you from your Hartford agent and from our
Customer Service Department. Servicing your needs is our way of thanking you for placing your
confidence in us. We will be here when you need us.
CUSTOMER SERVICE
800-833-5575
Page I of 4
Mlohallloebllg, PA 17065
wwv/.momb~l~t, org
MII~/~ (717)697-~6~ or(800)283-2328
CII-~: (717) ~7..4372 or (800) 283-4372
Dl~.~.l.~m~ (717) 79~-~053 ~r (800) 723-4~.
Lel~. (717) 79~040 or (~00) 283-23~$ ext. 6040
'l'lll~l'~ (717) 7~ or (800) 237-7288
9floeh:tm~md: (~17) 697-B312 or (800) 263-2326 ext. ~312
(717) ~ O~ (e88) ~
~ II)lp~ (717) 7g~-6026 (31' (800) 2~3-2326 ext. 60~6
JOIN US IN CELEBRATING CREDIT
UNION DAY, OCTOBER 21STI STOP BY
ANY BRANCH AND SEE HON HE'RE
HARKING THIS SPECIAL EVENTI
OALEN O HALL
1751 HOUNTAZN RD
YORK SPRTNOS PA 17372-9790
Total Banking Statement
OALEN G HALL
PAMELA y HALL
1751M 0 UNTAN RD
YORK SPRIqOS PA 17372~790
Relationship Overview
~.~k ~---~-~_-~.'~ ~--:-:-~.
ln.te~t Ch~;r~. 51-404:5-7216
Savings 51-3039-2607
Total ~poMts
Keep your valuables secure...
A ~ U tk~out d:~:~3tm~ ~ p~ ku~ P Jan · ) c~m~"~- aa~ cg' fl:~-/3a~l el~l Ii ade ,.l~.,-t~, ~ ~o~.,~4~._ _3~~ :_.. -~t
2,469.74 ~
815~4
Choice Plan
Interest Checking Account Summary
2.373~8 3,61~;.03 3.518.77 2.469.74
2,722.57 .00
0.'75~ 27 2,76808 1.54
Total Banking Statement
3024
3025
33,'/5 07/21
~ v ems ( checks b~ed ,ou~nv
Zl~am wma, ~ 0 n~,- cwg/,,.,~*~ ~
Total Banking Statement
Daffy Bal~n~ I~tall
~/Ol 2,2~ ~ 2,~1.91 ~'~
~116 2,919.43
~/12 2.71Z~ ~/19 2,~!.~ ~ 2.~
~/~ 2,9S5.~ ~/14 2,ml.~ ~ ~43 ~ 2,~78
Savings Accou~ S~ma~
8,613.~0 20Z24 8,000.00 815.$4
I 0 0 1
0 0
Intere~ &ummaty o o
30 1.~ 2~4
071~ 1~.~ O~ D~. ~
~Z16 81 ~ ~ 8~5.~
PAMELA Y. HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERI,AND COUNTY, PENNSYLVANIA
: NO. 02-188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
INCOME AND EXPENSE STATEMENT
UNDER RULE 1920,31
I hereby file the Statement of Income and Expenses required under Rule 1920.31 and verify
that the information therein contained is true and correct to the best of my knowledge, information
and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
§4904, relating to unswom falsification to authorities.
Ph6ntiff
INCOME AND EXPENSE STATEMENT
OF
PAMELA Y. tL~LL~ PLAINTIFF
Employer:
Address:
Type of Work:
Payroll Number:
Pay Period:
INCOME
Giant Foods, LLC
1149 HmTisburg Pike
Carlisle, PA 17013
Risk Management
177-54-4684
Weekly
Gross Pay Per Pay Period:
Itemized Payroll Deductions:
Federal Withholding
Social Security
FICA - HI
Local Wage Tax
State Income Tax
Retirement
Health Insurance
Dental Insurance
Net Pay Per Pay Period
$980.50
$165,13
$ 60.33
$ 14.11
$ 9.81
$ 27.25
$ 58.83
$ 3.55
$ 3.78
$637.71
Net Pay Per Month
OTHER INCOME: NONE
HOME:
Rent
Utilities:
Electric
Telephone
Cell Phone
Water
Cable Television
EMPLOYMENT:
Lunch
INSURANCE:
Renters
Automobile(s)
AUTOMOBILES:
Fuel (all vehicles)
Repairs
EXPENSES
$2,763.41
$545.00
$ 80.00
$ 35.00
$ 50.O0
$ 25.00
$ 50.00
$ 50.00
$ 8.33
$ 35.00
$100.00
$ 50.0O
MEDICAL:
Doctor
Counseling
Dentist
Medicine
PERSONAL:
Clothing
Cosmetics and Toiletries
Food
Hairdresser
Credit Payments
Credit Card
MISCELLANEOUS:
Entertainment
Vacation
Gifts
L~gal F~s
Dry-cleaning Expenses
TOTAL EXPENSES PER MONTH
$ 15.00
$ 50.00
$125.00
$ 24.00
$150.00
$ 50.00
$20O.O0
$ 15.00
$100.00
$100.00
$150.00
$100.00
$ 30.00
$250.00
$ 50.0O
$2,437.33
· S2£
PAMELA Y. HAI.I.~
Plaintiff
GALEN G. I~ALL,
Defendant
: IN ~ COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02=188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE
Cara A. Boyanowski, Esquire. being duly sworn according to law, deposes and says that she
is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on
the 26th day oflanuary, 2002, she did serve upon Galen G. HaH, the Defendant in the foregoing case,
a true and correct copy of the Complaint in Divorce by sending same to him, by certified mail,
addressed to 1751 Mountain Road, York Springs, Pennsylvania, 17372. The receipt for said
Complain~ is attached.
Said copy ofthe Complaint was duly endorsed with notice to Defendant to appear and answer
or the matter would proceed without him.
Sworn to and subscribed before me this
~"day of ~x~. ~. ,2002
By:~ ~~'
ara A Boyanowsld, ~squir~
Attorney No. 68736
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorney for Plaintiff
· Complete Iterns 1, 2, and 3. Al~e eem~
Item 4 If Restricted Ekdlvery is desired.
"m Print your name and address on the reverse
so that we nan return the card to you.
· Attach this card to the back of the rnailpiece,
or on the front If space permits.
B. Rm~elved by (Prfntecl Name) ;. Date of Dellvm'y
D. Is dellva'y ad~ dlffm'e~ h~m item
If YES, entre' delivmy address I~ow: No
3. Se~,ice Type
,~Ce~tified Mail [] Expr~s Mail
[] Registered [] Return Receipt for Memhandise
[] Insured Mail [] C.O.D.
4. Restricted Delivery? (Extra Fee)
2. ArUcle Number
PS F~ 381 1, A~ust 2~1 ~ ~ ~
102595-01-M-2509
JAN 2
Postage
Certified Fee
Return Receipt Fee
ru (Endorsement Required)
r~
Restricted Delive~ Fee
(Endorsement Required)
$5.8%
Postmark
Here
Total PoMage & Fees
tSent To~.-, .
........................................
...............
City, State, I + 4 '
PAMELA Y. HALL,
VS.
GALEN G. HALL,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· CIVIL ACTION - LAW
: NO. 2002-188 CIVIL
IN DIVORCE
action.
PETITION FOR ALIMONY PENDENTE LITE,
ATTORNEY'S FEES AND AWARD OF ALIMONY
SUBSEQUENT TO THE DIVORCE ACTIO;!
Petitioner is Galen G. Hall, the Defendant in the above-captioned divorce
action·
Respondent is Pamela Y. Hall, the Plaintiff in the above-captioned divorce
3. Respondent filed the divorce action on or about January 14, 2002·
4. This divorce matter has been referred to the Cumberland County Divorce
Master for disposition.
5. Petitioner requests that his claims for alimony pendente lite, permanent
alimony and attorney's fees be considered by the court in conjunction with the granting
of the divorce action.
WHEREFORE, Petitioner respectfully requests that claims in reference to
alimony, alimony pendente lite and attorney's fees be considered in conjunction with
the granting of divorce in this action.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
By: .
Robert L. O'Brien, Esquire
Attorney for Petitioner
I.D. # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
rlo.dirldomesticlhallalimony.pet
I verify that the statements made in the foregoing Petition For Alimony Pendente
Lite, Attorney's Fees and Award of Alimony Subsequent To The Divorce Action 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.
Gale~] ~. Hall
CERTIFICATE OF SERVICE
I hereby certifi7 that on July ?>O, 2003, l, Robert L. O'Brien, Esquire of O'Brien,
Baric & Scherer, did serve a copy of the Petition For Alimony Pendente Lite, Attorney's
Fees And Award Of Alimony Subsequent To The Divorce Action, by first class U.S.
mail, postage prepaid, to the party listed below, as follows..
Cara A. Boyanowski, Esquire
1029 Scenery Drive
Harrisburg, Pennsylvania 17109
Robert L. O'Brien, Esquire
PAMELA Y. HALL,
Plaintiff
Ve
GALEN G. ItAI J,~
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-188 CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
AMENDED INVENTORY
UNDER RULE 1920.33
Plaintiff, Pamela Y. Hall, files the following amended inventory of all property owned or
possessed by either party at the time this action was commenced and all property transferred
within the preceding three years.
She verifies that the statements made in this emended inventory are tree and correct. She
understands that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904
relating to unswom falsification to authorities.
.fPamela Y. Hall, Pl~ntiff
ASSETS OF PARTIES
PAMELA Y. HALL MARKS ON THE LIST BELOW ITIOSE ITEMS APPLICABLE
TO THE CASE AT BAR AND ITEMIZES THE ASSETS ON 'rilE FOLLOWING PAGES.
() 3.
() 4.
(X) 5.
(X) 6.
() 7.
()
(X) 9.
()
()
()
()
()
()
10.
11.
12.
13.
14.
15.
Real Property
Motor Vehicles
Stocks, bonds, securities and options
Certificates of Deposit
Checldng accounts, cash
Savings accounts, money marke~ and savings certificates
Contents of safe deposit box(s)
Trusts
Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
(x)
16.
()
(x)
Employment termination benefits - severance pay, worker's compensation
claim/award
17. Profit sharing plans
18. Pension plans (indicate employee contribution and date plan vests)
19. Retirement plans, Individual Retirement Aceount~
20. Disability payments
21. Litigation claims (matured and unmatured)
22. Military/V.A. benefits
23. Education benefits
24. Debts due, including loans, mortgages held
25. Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute)
( ) 26. Other
HALL v. HALL
Date of Marriage - October 22, 1988
Date of Separation - July, 1999'
MARITAL ASSETS
Assets Wife's Husband's Difference Notes
Value Value in Value
Real E~t2t~
Marital Residence: $130,000.00 Pre-Marital Property.
1751 Mountain Road (Appraisal) Property appraised in January,
York Springs, Pennsylvania $54,000.00 2002.
(Marital : Husband purchased property in
Portion) 1986 for $76,000.00.
Marital property consists of
increase in value of real
~roperty since 1988.
No mortgage exists on the
property.
Retirement Aceonnts
EBI $44,968.15
Retirement Account (date of
0 rffe) separation
value)
$46,309.71
(presently)
TIAA-CREF (Borough Retirement) $5,394.04
Retirement Account (date of
( rffe) separation
value)
$5,582.75
(presently)
MARITAL ASSETS
AHOLD USA, Inc. $0.00 Pre-Marital Property.
401 (k) Savings Plan Wife's participation in account
Giant Foods began after date of separation.
Cvv~)
Appleton Papers $16,094.00 Actuarial Value.
Retirement Account
(Husband)
Appleton Papers 401 (k) Plan $64,894.46 Value of account as of
(Husband) September, 2002.
Appleton Papers Severance Pay $16,312.47 Husband received severance
(Husband) pay on June 1, 2001.
Husband deposited severance
into joint Checking account no.
51-4045-?Z16.
IRA Account $3,298.37
(Husband)
Automobiles
1996 Ford Taurus $3,670.00 In possession of Wife.
(Wife) No lien exists on this vehicle.
1986 Ford Bronco Proceeds
(Husband) f~om sale:
$200.00
Life Insurance Polity
Hartford Life and Annuity Insurance Face Value: Value of policy as of
Company $120,000.00 November 28, 2001.
Policy No. 101-LU0935779 Cash
(Husband) Surrender
Value:
$3,340.89
Bank Accounts
Members First Husband: Balance of account as of
Savings Account $98.15 August, 1999: $3,949.64.
No. 112581
(Joint) Wife:
$3,851.49
American Fulld$®
PO Box 2560
Quarterly Statement
~, 2003
Januaw i-June
Page 1 of 5
CB&7 CUST IRA/ROt. LOVER
PAMELA Y HALL
5145 E TRIN~LE RD APT J
MECHANIC£SURG PA 17050-3644
FiNaNCIAL NETWORK INVESTMEN?
CORPORATION
5 KACEY CT $TE 101
MECNANICSBLI~G PA ~7055-~220
See how our o~dine tools can help you
M~in~7 Thinking about invss~in~ monthly? W~ether you ws~t
to ~han$e yoar address, make lEA ~ltr~utians ur any ~tbur
in~=stmen~, aut enl~e too~ csn belp ~u do it. To see all ~e
For more account iaJoIu~ation
· Call your fir~ancial adviser
· Automated information and san/ices
American Fur~daLin~ ® - 8g~/325-359~
I Pemonal as:s~stance - 8 a.m ~ 8 p.m. Eastern ti~
Shar~hoEer So,ices - 800142~-018~
C, IB&T CUST ~,A/BOLLOVER
PAMELA Y ~
The ¢m~h Fund of
The New Economt gund-A
New Perspectiw Fuad-A
$MALL~F World
The i.vestment Company
05 64602545 growth 423.702 $21.11
14 64602545 growth 453370 glS,BB
07 ~802545 gro~h 453,718 S1~ 87
3b 64662545 graph 16~ gs8 $2~,92 $~,493.39
C4 ~602545 graph & income 322.144 325 41 $8,185 68
Total S46,305,71
Your investmeut portfolio About the pie chart at left
I ~ro~r~ 61. ~V, Each alice o/the pie chart represents' a r/po of ~und. A slice s',er~ds
holding& The le:2ead to the right ofthe p;e shows the percentage of
i American Funds
January 1 -.June 3o, 2003
Page
Year-to-date dividends a-nd capttal gakn ..............................................................................................................
~B&T CUST II~/ROLI.OVt~R
The investment Com~ny of Am~ric~-A 04
Washington Mutual I~w~tor~ Fund-A 0~ ~4602545 $99.17 ~0 ~0 ~D 00
Tots I $182.57 ~. O0 $0.00
Transactions for ....................................................................
CB&T CUST ~RAc~OLLO~R
The Growth Fund of Amerlca - [~$nss A
No a ctiv!~ thi~ psnolt
0GtS0/0S Ending share balsnce 42~.702
The New Econm? Fund - Cla~ A
No acOv~ thi~ period
06/30/03 Ending ~hme balance 450,370
New Perspective Fund - Class A
Fund number 07
Accou~l number ~4802545
Dividends and cap,ta~ §sins reitwe..t~,d
No act~ tllb pedod
06/30/03 Ending share balance
5MALLCAP World Fund - Class ~
Fund number 35
Account n~mber §46{)254§
DMdends and c~pital gains reinw~smd
No activi~ this period
0fi130,'03 Ending share balance
Th; dght the]ce tbr the [or~g term
American Funds*
January 1 - June 30, 2003
Page 5 cf 5
The Inv~stmem Company of America - Class A
Fund nuzabem 04
Divide~!C~ end ,:ap~al ~irts rebvesred
01/01~3 Beginning share b~iance
03/03~3 int~cm9 gwide*~d 0.13 ~1.¢3 $22.28 ~.880 320.510
06/06/03 income tg[vid..~d 0 13 ~1.67 $25.59 1.328 322~
0~'30/03 Endir.,9 share bmanc.~ 322 t~
Washington Uotual I~v~st~r~ Fu~d- Class A
Fond number ~1
D~vJde~s and cagitel gains reinvested
................................................................................................................... ~¢~7.300
0~/0!/03 Beginning share balance
03/28/03 lnccr~ DJvid,~d 0,115 $49.59 $22,~3 2,201 369.501
06~20~3 Interne D[~id~d ~.135 $49,88 $26,24 I .901 371.402
To add to your Lnvestment
Make chack p=yabie m ¢$& TurCaphal Bank aad
PO ~x 2560
No~folk V& 23501-2580
CB&T CUS~ ZRA/ROLLOVER
PAMELA Y HALL
ff iavest;,n9 ,'n a ~owfut~d, p.~eas,~ obtain a
prospectus from yourfinanciul adviser
Check total $
I IIlllillllilli)llll#
AFl-OOOO73B2013
April 1, 2003 - ]une 30, 2003
I,,,llh,,lli,.,,hl.lh,,.il.lh,,h.hMIh.I
?AMELA Y HALL
145 E TRIN~DLE PO.3 # )
MECHANICSBURG PA 17050-3644
730 Th2rd Avenue, New York, NY 15017-3206
portfolio summary
~]~l~li_ll~_valtle a,~ of:
Changes during the period:
Coatributioas
(~0~,31/03)
Nvt investm.~nt gain/loss
Ending value:
total value .~ of 06/30/03:
85,582.75
You can receive your statements faster with e-delivery. Ju~.t 8o to www.flaa-cref.org/profite an~ log
in wi~ your Us~r ID ~d password. ~m you can choo~ to rezcive yo~ Qt~nerty R~'ic~ s~t~mcms
and ~her c~)r,~u~,mtions by ¢-rmil, If you'd like to mques,t ¢-de~ve~ of all ~-C~F docu~s as
flxey become a~ffiable, just select "alt"
your investment results & returns
gains/losses gnins/Iosses value as of
this_quarter this year 06/30/03
Equities
CREF Stodk 183.42 139.66 1~9~ ~J
CREF Grow th 88,32 8 l 72 __ ? 30 [ 9
_ _CR_ ~2r:.[rlU~7/tndex t4-5.59 1162t 1~52.7~
__.~L~IT.._Globa[ ~_~.,.ujtics_ 97 ~9 68.10 698,33
Real IE~tato
T1AAReal Estate 14.74 26.38 870,84
Fixed Income
CR.EF Bond Market 24.35 38,66 937. ~.9
$553.81 $470.73 $5,582~7~
to,al value as of 06~30~03 $5.5~.75
For rat=~ of ' ~tal t~mm or currem iutere~ ra~es for ali TI~-CREF accounts as of 06/30/03, refer m the
enclos~ ~.r~ormnce care,
asset allocation
total value
by asse~ class
~ Equities 68%
~_ Fixed Income 17%
· RealEatate 15%
To lransfer funds, visit oar Web Center o£ call our Autonmted
Telephone Se:trice at $00 842-22.52. To create a personalized
portfolio allocation, go to www.tiae-eref.orpdcalea or call
800 842-2776,.
acco=ne values
Retirement Annuities
tIAA Real Estate $856.10 $8'70.84
(#, 856 un_irs ~_$_176 7._976_~
, c ~ $1,110.05 $1,29~ 47
/8 957 u. ni~: ~$123 9809 L__
CRE} Bored Mark=I $912,84 $937,
12 0 77, ut ~ts 71 6941
......... (~.072 units @$~9,8_3L7~
CREF G~,oba/ Equitie~ $600,94 $b98.3~
account values
(continued]
a~ of
Retirement Annuities
CILEF Gruwth
CP~EF Eqmty
(12.337 untt~ @$48, 7102~) G 2.3 3 7 ~nit$ ~ $ 56.604 4 )
$641,87 $730.19
--. (12.107wut~42.4~3~ ___
$907.14 $1.052/23
_ j17.415 ~mi~ ~52.~950 L~.~15 u.i~g~60.4498,
$$,028.94 $5,582.75
total valuo: $5,021~.94
for your information
We reserve the dghr to correct clerical errors. Plea.se revie~v your stateinent promptly to ensure its
accuracy. You can ahvays check your account information m~ our Web (?enter at v, av~.tiaa-~ref.org or
call uS at 800 842-2776 if you lmve any clu~tion~.
definitions
l%~folio smnmary: a h,gh-level overview that totals all your retirement ¢oraracts logether and shows
yea ho,,o dais value ;hanged from the beg:mag of dsc quarte to 06, 30. 0~, arid from the beginning of tee
year to
Net inve~tment gain/loss: the dollars ca.ned as a result of the performance ef year fimds invested across
all the accounts,
Asset allocation: a breakdown of how your total retirement portfolio i~ allocated across five major
classes - equities, fixed income, real estate, money market and guaranteed.
Effective date: the date Mnds begin participating i~ ~ investment results of the accounts.
III [ll IIilill Ilth I I il Il
Managing money jLr people
Conrad M. Siegel, Inc.
Actuaries/Benefit Consultants
501 Corporate Circle · P.O. Box 5900 · Harrisburg, PA 17110-0900
I~ON~ (717) 652-5633 · Fax (717) 540-9106 · www.cmsbenefits.co~n
II
JUL 1 0
Conrad M. Siegel, ILS.A.
Harry M. Leister, Jr., F.S.A.
Clyde E. GingxiclL ES.A.
Earl L. Mummert, M.A.A.A.
Robert J. Dolan, A.S.A.
David F. SLiding, A.S.A.
July 9,2003
Cara A. Boyanowski, Esq.
Daley Law Offices
1029 Scenery Drive
Harrisburg, PA 17109
Re: Pamela Y. Hall v. Galen G. Hall
Dear Ms. Boyanowski:
You provided me with the following information concerning Galen G. Hall:
1. Date of birth - November 3, 1956.
2. Date married - October 22, 1988.
3. Date separated - July 1999 (I assumed July 15, 1999).
Accrued monthly pension as of May 16, 2001 under the Retirement Plan for
Employees of the Harrisburg, Pennsylvania Plant of Appleton Papers Inc. -
$564.30 to commence at age 65.
5. Benefit service as of May 16, 2001 under tlhe Retirement Plan for Employees
of the Harrisburg, Pennsylvania Plant of Appleton Papers Inc. - 19.8.
Currently, Galen G. Hall is 47 years of age (age nearest birthday).
The Retirement Plan for Employees of the Harrisburg, Pennsylvania Plant of
Appleton Papers Inc. is a defined benefit pension plan. The figure that is marital
property for divorce purposes is the present value of the pension earned during the
marriage.
As previously indicated, Galen G. Hall had accrued a monthly pension as of May 16,
2001, of $564.30. Since this pension benefit takes into account service both before
the date of marriage and after the date of separation, it is necessary to multiply by
a "coverture fraction" in order to determine the portion of the pension earned during
the marriage. The numerator of the "coverture fi'action" is 10.73 (the years from
the date of marriage until the date of separatian) and the denominator is 19.8 (the
years of benefit service as of May 16, 2001). Thus, the "coverture fraction" is .54
(10.73 divided by 19.8).
The portion of Mr. Hall's pension earned during the marriage amounts to $304.72
($564.30 multiplied by .54).
Conrad M. Siegel, Inc.
Cara A. Boyanowski, Esq.
July 9, 2003
Page 2
The present value of a monthly pension of $304.72 for a male now age 47 with such benefit to
start at age 65 amounts to $16,094.
The present value has been determined based upon the assumptions promulgated by the
Pension Benefit Guaranty Corporation for annuity valuation~s. The interest rate is 4.3% per
year for 20 years followed by 5.25% per year. The mortality is in accordance with the 1983
Group Annuity Mortality Table.
In my opinion, the assumptions promulgated by the Pension Benefit Guaranty Corporation for
annuity valuations are appropriate for the purpose of determining the present value.
With best regards,
Yours sincerely,
HML:kad
II
5/!5,'2003 03:45,56 PM ACCOUFI[ Workbook
Account Info
35999211 - HALL GALEN G
J236 CS1 4C
HILLiP~r4D LYONS CU:-;T FOR
C-.~ALEN G HALL ~A
1T~1 MOUNTAIN RD
'YORK SPRINGS PA 17372-9790
A,.Itc MMF 5weep - A!i Types
PrirT~an/MMF - PIN
P¢oxy DiSClOsure
Mgn Inst iRA Account
DIv~l Inst Hold Funds
Ir~v~,t Obi
3,296,37
II
II
Account WoAbook
Activity
35999211 - HALL GALEN G
I HILL!ARD LYONS CUST FOP MMF ~IN
II
Blue Book Csec: Ca~ ~ alues
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Th~ T~'u~'d Resource
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1996 Ford Taurus LX Sedan 4D
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Mileage: %22,000
Equipment
Air Conditioning
Power Steering
Power Windows
Power Doer Locks
Tilt Wheel
Cruise Control
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Print "For Sidle" Sijn
p~Le_v~f.T h i~ Car
FIn~.t_h_s_~r ¢~ e~B:~y Hoto~$
AM/FM Stereo Leather
Cassette Dual Power SeatS
Multi Compact Disc Flip-Up Roof
Premium Sound Rear Spoiler
Dual Front Air Bags Alby Wheels
ABS (4-Wheel)
Consumer Rated Condition: Good
"Good" condition means ~hat the vehicle is free of any major defects,
The paint, body and interic, r have only minor (IF any) blemishes, and
there are no major mechenical problems. In states where rust is a
problem, this should be very minimal, and a deduction should be
~,ade to correct it. The tires match and have substantial tread wear
left. A clean ~;_~tt~ hls_tpr~/. A "good" veh~c.e w h need some
recond!tloning to be sold et retail; however major reconditioning
should be deducted from the value. Most recent model cars owned by
consumers fall into thi~ category.
Private Party Value $3,670
Private Party value represents what you might expect to pay for a
used car when purchasing from a private p~rty. ~t may also represent
the value you might expect to receive whet, selHng your own used
car to another private party.
b. ttp:h'www kbb.co:pJkb/ki d:l/kw.kc.urr?kbb.PA;904353;PAO41&l?O50;sed;p&75!;F°rd;L" 6/10/2003
CLAUDE C. WOLFE & ASSOCIATES
AUCTIONEERS & APPRAISERS
FAMILY OWNED SINCE 1912
2009 LINCOLN STREET" CAMP HILL, PA 17011
717-761-2763
February21, 2003
Appraisal for Pam Hall
5145 East Trindle Road, Mechanicsburg, PA 17050
LIVING ROOM
2 Crocks
Picture
Rush seated chair - pre marriage
Cheese box - pre marriage
Nail keg - pre marriage
Tin box
Sofa & chair - Oak trim
Oak coffee and two end tables
Sunbeam heater
Basket
Lake scene picture - poor condition
Picture of great great grandparents
Spinning wheel - gift from parems
Tic can - Fleischmanns - poor condition
Old pressed back rocking chair
Misc. live plants
Misc. contents of living room
3 Drawer chest - pre marriage
Old scales
Picture of chickens
Glass basket - not old
Bicycle
DINING AREA
5.00
1.00
20.00
2.00
2.00
2.00
300.00
110.00
3.00
3.00
15.00
40.00
225.00
3.00
75.00
10.00
25.00
65.00
8.00
10.00
4.00
30.00
CLAUDE C. WOLFE & ASSOCIATES
AUCTIONEERS & ^??R^ISER$
FAMILY OWNED SINCE 1912
2009 LINCOLN STREET' CAMP HILL, PA 17011
717-761-2763
Hall appraisal
Page 2 of 4
DINING AREA - continued
Panasonic microwave
School desk
Father's Navy uniform
Coat/hat tree
2 Daguerreotypes - poor condition - pre marriage
Small bisque doll - from grandfather
3 Old bottles
KITCHEN
Misc. Tupperware
Hand mixer
Rival mixer
Pots & pans - old
Lantern with red globe - pre marriage
3 Bottles
Saltines tin
2 Blue vases
Tin lunch box
Wire chicken egg holder - reproduction
Brass spittoon
Wooden chicken crate
Cookbooks
Cake tin - cover
BATH
Kenmore dryer - 10 years old
Wooden drying rack - old
Wash board - pre marriage
30.00
40.00
30.00
25.00
10.00
5.00
3.00
2.00
2.00
3.00
10.00
25.00
3.00
5.00
2.00
7.00
3.00
5.00
15.00
5.00
3.00
35.00
15.00
7.00
CLAUDE C. WOLFE & ASSOCIATES
AUCTIONEERS & APPRAISERS
FAMILY OWNED SINCE 1912
2009 LINCOLN STREET* CAMP HILL, PA 17011
717-761-2763
Hall appraisal
Page 3 of 4
LANDING
3 Shelf heart shaped stand
McCoy green vase
Wall mirror - gift from parents
MASTER BEDROOI~.
Mission Oak book stand
Depression glass container
Oak dresser
Boudoir lamp
Jewelry box
Misc. old hats - pre-marriage
Child's rocking chair - pre-marriage
Nail keg - pre-marfiag, e
Rug beater - pre-mamage
Teddy bear - Boyd's
Plato stand - pre-marriage
Wooden box
Cedar chest - pre-marriage
Misc. live plants
Marbles
Misc. contents of bedroom
BAT _
Straight razor
Shaving bowl
Razor and box
Shaving brash
Cobalt blue eye cup
3.00
8.00
10.00
60.00
8.00
135.00
6.00
20.00
5.00
10.00
2.00
15.00
20.00
8.00
3.00
45.00
2.00
10.00
15.00
3.00
3.00
2.00
3.00
5.00
CLAUDE C. WOLFE & ASSOCIATES
AUCTIONEERS & APPRAISERS
FAMILY OWNED SINCE 1912
2009 LINCOLN STREET · CAMP HILL, PA 1701
717-761-2763
Hall appraisal
Page 4 of 4
Oak jewelry armoire
Ironing board
Electric iron
Small chest
Cradle - pre-marriage
Rocking horse - pre-marriage
Luggage
Basket with artificial flowers
Misc. stuffed animals
Cast iron chicken door stop
Clear glass table lamp
Misc. contents of bedroom
SPARE BEDROOM
70.00
1.00
1.00
10.00
5.00
25.00
20.00
5.00
5.00
1 ;00
2.00
10.00
JEWELRY
Diamond(16 chips) pendant on 14K yellow gold chain
Sapphire pendant on a yellow gold chain
(4) Gold rope bracelets
Diamond chip tennis bracelet - very small diamond chips
14K yellow gold ring with blue Topaz 8:10 diamond chips
Seiko wrist watch - 8 years old
Misc. costume jewelry
70.00
30.00
40.00
50.00
100.00
15.00
10.00
APPRAISAL TOTAL $ 2,119.00
This Fair Market value appraisal is tree and correct to the best of my ability as an
auctioneer and appraiser with 35 years experience.
Member: Certified Appraisers Guild of America
W. K. "Dusty" Chapman, CAGA
PAMELA Y. HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02=188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
2002.
1. A Complaint in Divorce under §3301 (c) of the D~vorce Code was flied o~ January 14,
2. The marriage of Plaimiff and Defendant is irretrievably broken and ninety (90) days
have elapsed fi-om the date of filin4g and service of the Complaint.
3. I consent to the entry of a final decree of divome aRer service of notice of intention
to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statements hesein are made subject to the penalties of 18 Pa.C.S.A. {}4904 relating!to unswom
falsification to authorities.
rate:Iq-O
Pan~la Y, Hall,
Social Secufitymo.
PAMELA Y. HALI~
Plaintiff
GALEN G. HALL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-188 CINIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(C) OF ~ 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 ifI do not claim them before a divorce is gr..ed.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relatin~ to unswom
fals/fication to authorities.
PAMELA Y. HALL,
Plaintiff
GALEN G. lt~lJ~
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-188 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(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 ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a diw)rce decree is entered by the Court
and that a copy of the decree will be sent to me immediately at, er 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.A. §4904 relating to unswom
falsification to authorities.
Galen G. Hall, Defendant
PAMELA Y. HALL,
Plaintiff
Ve
GALEN G. HALL,
Defendant
IN ~ COURT OF COMMON PLEAS
CUMBE~ COUNTY, PENNSYLVANIA
NO. 02-188 CVOL TERM
CIVIL ACTION - LAW
IN DIVORC~
AFFIDAVIT OF CONSENT
2002.
1. A Complaim in Divorce under §3301 (c) of the Divorce Code was filed on January 14,
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the emry of a final decree of divorce a~er service of notice of intention
to request entry of the decree.
I verify that the statements made in this Affidavit are tree and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating ~o unsworn
falsification to authorities.
Galen G. Hall, Defendant
Social SeeurityNo.
AGREEMENT
BETWEEN
PAMELA Y. HALl.,
AND
GALEN G. HALL
Cara A. Boyanowski, Esquire Robert L. O'Brien, Esquire
Counsel for Wife Counsel for Husband
TABLE OF CONTENTS
SECTION I:
Introduction
3
SECTION H:
General Provisions
4
SECTION Il/:
Alimony and Alimony Pendente Lite
Provisions
10
SECTION V:
Property Distribution Provisions
10
SECTION VI:
Closing Provisions and Execution 13
SECTION I
INTRODUCTION
ms *G EM NT maae day of oo3,
between PAMELA Y. HALL ("Wife") and GAI,EN G. BALI, ("l~lusband").
W1TNESSETH:
WI~EREAS, Pamela Y. Hall, Social Security Number~lnl[~l~i~ was bom on February
11, 1960, and currently resides at 5145 E. Trindle Road, Apartmem J, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
WI~I~REAS, Galen G. Hall, Social Security Number,:l~lm~lll~lll~, was bom on November
3, 1956, and curremly resides at 1751 Mountain Road, York Springs, Adams County, Pennsylvania
17372.
WI~EREAS, the parties hereto are Husband and Wife, having been married on October 22,
1988, in Carlisle, Cumberland County, Pennsylvania.
WlCIEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their
natural lives, and 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 equitable
distribution of such property; the settling of all matters between them relating to the past, present and
future support and/or mainteamnce of Wife by Husband or of Husband by Wife; and, in general, the
settling of any and all claims and possible claims by one against the other or against their respective
estates.
NOW, TI~F~REFORE, in consideration ofthe mutual premises, set forth herein and for other
good and valuable considerations, Wife and Husband, each inten&ng to be legally bound hereby agree
as follows:
SECTION H
GENERAL PROVISIONS
1. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of
Section 3301 (c) of the Divorce Code of 1980, as amended and will execute the documents necessmy
to effectuate a divorce under those provisions concurrently with the execution of this Agreement.
2. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect at, er such time as a final decree in divorce may be entered with
respect to the parties.
3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE
DECREE
The provisions of this Agreement may be incorporated by reference but shall not be deemed
merged into any judgment or decree for divorce obtained by either party. This agreement shall
survive any such final decree of divorce, shall be entirely independent thereof, and the parties intend
that all obligations contained herein shall retain their contractual nature in any enforcernent
proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement
action filed to the divorce complaint.
4. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agr(~nent shall be defined as the date
upon which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date
of execution by the ~ last executing this Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and thek legal effect have been fully explained to Wife by
her attorney, Cara A. Boyanowski, Esquire, and to Husband by' his attorney, Robert L. O'Brien,
Esquire. The parties acknowledge that they fully understand the facts and have been fully informed
as to their legal rights and obligations, and they acknowledge and accept that this Agreement is, in
the circumstance, fair and equitable and that it is being emered into freely and volumarily, afrer having
received such advice and with such knowledge and that execution of this Agreement is not the result
of any duress or undue influence and that it is not the result of any collusion or improper or illegal
agreement or agreements.
6. TAX PROVISIONS
The parties believe and agree, and have been so advised by their respective attorneys, that the
division of property heretofore made by this Agreement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property.. Each party promises not to take
any position with respect to the adjusted basis of the property assigned to him or her or with respect
to any other issue which is inconsistent with the position set forth in the preceding sentence on his
or her federal or state income tax returns.
The parties have heretofore filed joim 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 and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely
and entirely by the individual who is finally determined to be the cause of the misrepresentations or
failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall
be free from any contact, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her may
seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the
respective families of each other nor compel or attempt to compel the other to cohabit or dwell by
any means whatsoever with him or her.
8. MUTUAL REI,EASES
Except as otherwise expressly provided by this Agreement:
A. Each party hereby absolutely and unconditionally reieases and forever discharges the
other and the estate of the other for all purposes fi.om any and all :fights and obligations which either
my have or at any time hereat~er have 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, agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the
other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally :releases and forever discharges the
other and his or her heirs, executors, administrations, assigns, property and estate fi.om any and all
rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existin8 or hereaRer arising..The above release shall be eit~ctive
regardless of whether such claims arise out of any former or future acts, contracts, engagements or
liabilities or the other or by way of dower, curtesy, widow's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take against the spouse's will, or the fight 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 or the United States, or any other country. It is expressly understood,
however, that neither the provisions of this release nor the subsequent entry of a divorce decree are
intended to defeat the right of either party to receive any insurance proceeds at the death of the other
of which she or he is the named benefieiary (whether the beneficiary designation was made prior or
subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest
or residuao, portion of the other's estate under his or her will, or to act as personal representative or
executor if so named by the will of the other, whether such will was executed prior or subsequent to
this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and 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 fi.om 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.
6
9. FINANCIAL DISCLOSURE
Thc parties have disclosed to each other and they are each aware of the extant of each other's
income, assets, liabilities, holdings and estate. Each of the parties acknowledge 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 documer~s, depositions and all other means of discovery permitted under
the Pennsylvania Rules of Civil Procedure. Each party is satisfied that no additional information is
necessary for the execution of this Agreement.
10. 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.
11. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
12. REME~BIES IN THE EVENT OF A BREACH
Any party breaching this Agreement shall be liable to the other party for all costs, including
reasonable counsel fees incurred by the non-breaching party to enforce his or her tights under the
provisions of this Agreement subsequent to the date of execufio,n of this Agreement, regardless of
whether litigation is instituted. In the event of default of any of the provisions of this Agreement by
one oftbe parties, the remedies available to the other are cumulative and include ali remedies at law
and in equity, including those for breach of contract, under theories or equity, under the Domestic
Relations Code as emended, including Section 3105 of the Domestic Relations Code (which includes
contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies
specifically referred to in this Agreement.
7
13. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
14. AGREEMENT BINDING ON ~IE1RS
Except as may otherwise be provided, this Agreement shail be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
15. INTEGRATION
This A~reement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other
than those expressly set forth herein.
16. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will fortlnvith (within ten (10) days at most
aider demand thereof) execute any and ail written instruments, assignments, releases, satisfactions,
deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of
this Agreement.
17. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance
of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to
enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver
of any subsequent default of the same or similar nature, nor sha~ the waiver of any breach of any
provision hereof be construed as a waiver of sttict performance of any other obligations herein.
18. SEVERABHATY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed
to be a separate and independent covenant and agreement. If any term, condition, clause or provision
of this Agreement shall be de~ermined or declared to be void or invalid in law or otben~ise, then only
that term, condition, clause or provision shall be stricken front this A~reement and in all other
respects this Agreement shall be valid and cominue in full force, effect and operation. Likewise, the
failure of any party to meet her or his obligations under any one or more of the paragraphs herein,
with the exception of the satisfaction of any conditions preeedent, shall in no way avoid or alter the
remaining obligations of the parties.
19. MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Wife shall be sent by certified mai[ remm
receipt requested, to Pamela Y. Hall, 5145 E. Trindle Road, Apa~hi,ent J, Mechanicsburg,
Pennsylvania 17050, or counsel for Pamela Y. Hall, or such other address as Wife from time to time
may designate in writing.
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Galen G. Hall, 1751 Mountain Road, 'York Springs, Pennsylvania 17372,
or counsel for Galen G. Hall, or such other address as Husband fi'om time to time may designate in
writing.
20. 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 mearfing, construction or effect.
9
SECTION m
ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS
The parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted
by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony pendente lite or
alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any fight to
seek fi.om the other payment for support, maintenance, alimony pendeme lite or alimony.
SECTION IV
PROPERTY DISTRIBUTION PROVISIONS
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rags,
carpets, household equipment and appliances, pictures, books, works of art and other personal
property. Wife agrees that all of the property in the possessim~ of Husband shall be the sole and
separate property of Hushand; and Husband agrees that all of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do hereby specifically waive, release,
renounce and forever, abandon any claims which either may have with respect to the above items,
which shall thereafter be the sole and exclusive property of the other.
2. RETIREMENT BENEFITS
The parties agree that Wife shall retain sole ownership and possession of all of bet retirement
benefits and plans and Husband specifically releases and waives any and all interest, claim or right that
he may have to these assets.
10
The parties further agree that Husband shall retain sole ownership and possession of all of his
retirement benefits and plans and ~Ftfe specifically releases and waives any and all interest, claim or
right that she may have to these assets.
3. BANK ACCOUNTS
Husband and Wife are the owners of individual bank accm~nts. Husband and Wife agree that
these accounts shall be the sole and separate property of the person in whose name they are titled and
each party waives any right, rifle or interest they may have in the other parties' account.
4. AUTOMOBILES
Wife is the owner of a 1996 Ford Taurus automobile. Husband and Wife agree that the 1996
Ford Taurus shall be the sole and separate property of Wife, and Husband waives any right, rifle, or
interest he may have in this vehicle.
Husband acknowledges that he owned a 1986 Ford Bronco which has been sold subsequent
to the parties' date of separation. Husband received the stun of $200.00 for this vehicle. Husband
and Wife agree that the sales proceeds realized fi.om the sale oftbe 1986 Ford Bronco shall be the
sole and separate property of Husband and Wife agrees to waive any right, title, or imerest she may
have in same.
5. LIFE INSURANCE
Husband is the owner of a Hartford Life and Annuity Insurance Company life insurance
policy. Husband and Wife agree that this policy, and its cash surrender value, shall be the sole and
separate property of Husband and Wife agrees to waive any right, title or imerest she may have in this
asset. Husband shall be responsible for any premiums due upon his policy under this Agreement.
6. CURRENT ~ JABILITIES
Wife and Husband represent that they have taken all steps necessary to make sure that no
credit cards or similar accoums exist as of the date of execution of this Agrcemem which provide for
joim liability, except those provided herein. From the date of execution of this Agreement, each party
shall use only those credit cards and accounts for which that party is individually liable.
7. CASH PAYMENT t~f
Husband shall pay to Wife the sum of$ ~ I ~C~o, O~Eft- . This payment shall
be made to Wife within ~) d. ays followilag the execution ,:late of this Agreement.
8. PAYMENT OF LEGAL FEES
Each party hereby agrees to be responsible for any legal fees incurred on their behalf.
9. AFFER-ACQUIRED PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or fight of the
other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired
by him or her at~er the parties' date of separation, with full power in him or her to dispose of the same
as fully and effectively, in all respects and for all purposes, as tlu'ough he or she were unmarried.
10. REAL ESTATE
A. Marital Residence - The parties agree as follows with respect to the Marital
Residence, located at 1751 Mountain Road, York Springs, Pennsylvania, which is tiffed in Husband' s
name alone, and was purchased prior to the date of the parties' marriage:
(1) Husband agrees to prepare and file all docamaentation necessary to
apply for a mortgage, or a home equity line of credit, in his name, for the Marital
Residence. Furthermore, Husband agrees that he will complete the mortgage process
within thirty (30) days following the date of the execution of this Agreement.
(2) Simultaneous with the mortgage process, Wife shall execute any
documents necessanj, including a quit claim deed, to transfer any right, title or interest
she may have in the Marital Residence to Husband, it! requested by the len. diOg
institution.
(3) Husband sball pay to Wife the sum of$ [41 ,q ,.~"30, (2~2) 8, ~],s~/t~forth
above in Paragraph Seven of this Marriage Settlement Agreement, fi-om the proceeds
of the mortgage process. The parties agree that this amount represents Wife's sbare
in the appreciated value of the Marital Residence.
12
SECTION V
CLOSING PROVISIONS AND EXECRITION
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on the date indicated below.
8-1q-o
DATE
WITNESS
GALEN G. HALL DATE
PAMELA Y. HALL, :
Plaintiff :
VS.
GALEN G. HALL, :
Defendant :
THE cOURT OF COMMON PLEAS OF
CUMBERLAND cOUNTY, pENNSYLVANIA
NO. 02 - 188 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this ~{~ day of ~ '
2003, the economic claims raised in the proceedings having been
resolved in accordance with an agreement dated August 19, 2003,
the appointment of the Master is vacated and counsel can file a
praecipe transmitting the record to the Court requesting a
final decree in divorce.
BY THE COURT,
cc:
/Cara A. Boyanowski
Attorney for Plaintiff
JRobert L. O'Brien
Attorney for Defendant
AGREEMENT
BETWEEN
PAMELA Y. HALL
AND
GALEN G. HALL
Cara A. Boyanowski, Esquire Robert L. O'Brien, Esquire
Counsel for Wife Counsel for Husband
TABLE OF CONTENTS
SECTION I:
Introduction
SECTION II:
General Provisions
4
SECTION III:
Alimony and Alimony Pendente Lite
Provisions
10
SECTION V:
Property Distribution Provisions
10
SECTION VI:
Closing Provisions and Execution 13
SECTION I
INTRODUCTION
THIS AGREEMENT made this IC~ day of 0,J4Oa,/A.~alC
between PAMELA Y. E[ALL ("Wife") and GALEN G. ltALL ("l~Iusband").
, 2003, by and
WITNESSETH:
WItEREAS, Pamela Y. Hall, Social Security Number~l~lllffi~ was bom on February
11, 1960, and currently resides at 5145 E. Trindle Road, Apartment J, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
WHEREAS, Galen G. Hall, Social Security Number..~ ' ]Et., was bom on November
3, 1956, and currently resides at 1751 Mountain Road, York Springs, Adams County, Pennsylvania
17372.
WHEREAS, the parties hereto axe Husband and Wife, having been married on October 22,
1988, in Carlisle, Cumberland County, Pennsylvania.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their
natural lives, and 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 equitable
distribution of such property; the settling of all matters between them relating to the past, present and
future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the
settling of any and all claims and possible claims by one against the other or against their respective
estates.
NOW, TltEREFORE, in consideration of the mutual promises, set forth herein and for other
good and valuable considerations, Wife and Husband, each intending to be legally bound hereby agree
as follows:
SECTION 1I
GENERAL PROVISIONS
1. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of
Section 3301 (c) of the Divorce Code of 1980, as amended and will execute the documents necessary
to effectuate a divorce under those provisions concurrently with the execution of this Agreement.
2. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect after such time as a final decree in divorce may be entered with
respect to the parties.
AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE
DECREE
The provisions of this Agreement may be incorporated by reference but shall not be deemed
merged into any judgment or decree for divorce obtained by either party. This agreement shall
survive any such final decree &divorce, shall be entirely independent thereot~ and the parties intend
that all obligations contained herein shall retain their contractual nature in any enforcement
proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement
action filed to the divorce complaint.
4. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as the date
upon which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date
of execution by the party last executing this Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Wife by
her attorney, Cara A. Boyanowski, Esquire, and to Husband by his attorney, Robert L. O'Brien,
Esquire. The parties acknowledge that they fully understand the facts and have been fully informed
as to their legal fights and obligations, and they acknowledge and accept that this Agreement is, in
the circumstance, fair and equitable and that it is being entered into freely and voluntarily, after having
received such advice and with such knowledge and that execution of this Agreement is not the result
of any duress or undue influence and that it is not the result of any collusion or improper or illegal
agreement or agreements.
6. TAX PROVISIONS
The parties believe and agree, and have been so advised by their respective attorneys, that the
division &property heretofore made by this A~'eement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property. Each party promises not to take
any position with respect to the adjusted basis of the property assigned to him or her or with respect
to any other issue which is inconsistent with the position set forth in the preceding sentence on his
or her federal or state income tax returns.
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 deticiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely
and entirely by the individual who is finally determined to be the cause of the misrepresentations or
failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall
be free from any contact, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her may
seem advisable. Wife and Husband shall not molest, harass, disturb, or malign each other or the
respective families of each other nor compel or attempt to compel the other to cohabit or dwell by
any means whatsoever with him or her.
5
8. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
A. 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 fights and obligations which either
may have or at any time hereat~er have 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 Divorco Code of 1980, its supplements and
amendments, as well as under any other law of any other jurisdiction, except and only except all
fights, agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the
other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges the
other and his or her heirs, executors, administrations, assigns, property and estate from any and all
fights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existing or hereaRer arising. The above release shall be effective
regardless of whether such claims arise out of any former or future acts, contracts, engagements or
liabilities or the other or by way of dower, curtesy, widow'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 or the United States, or any other country. It is expressly understood,
however, that neither the provisions of this release nor the subsequent entry of a divorce decree are
intended to defeat the fight of either party to receive any insurance proceeds at the death of the other
of which she or he is the named beneficiary (whether the beneficiary designation was made prior or
subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest
or residuary portion of the other's estate under his or her will, or to act as personal representative or
executor if so named by the will of the other, whether such will was executed prior or subsequent to
this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and 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, fights or demands
whatsoever, in law or in equity, which either party ever had or now has against the other.
9. FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each other's
income, assets, liabilities, holdings and estate. Each of the parties acknowledge 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, depositions and all other means of discovery permitted under
the Pennsylvania Rules of Civil Procedure. Each party is satisfied that no additional information is
necessary for the execution of this Agreement.
10. PRESERVAT/ON 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.
11. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and
signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
12. REMEDIES IN THE EVENT OF A BREACH
Any party breaching this Agreement shall be liable to the other party for all costs, including
reasonable counsel fees incurred by the non-breaching party to enforce his or her rights under the
provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of
whether litigation is instituted. In the event of default of any of the provisions of this Agreement by
one of the parties, the remedies available to the other are cumulative and include all remedies at law
and in equity, including those for breach of contract, under theories or equity, under the Domestic
Relations Code as amended, including Section 3105 of the Domestic Relations Code (which includes
contempt) as if this Agreement had been an Order of Court, and shall not be limited to those remedies
specifically referred to in this A4~,reement.
7
13. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
14. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shah be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
15. INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other
than those expressly set forth herein.
16. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most
at, er demand thereof) execute any and all written instruments, assignments, releases, satisfactions,
deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of
this Agreement.
17. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms ofthis Agreement. The failure of either party to insist upon strict performance
of any of the provisions of this Agreement shall in no way affect the right of such party herea~er to
enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver
of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of strict performance of any other obligations herein.
8
18. SEVERABIL1TY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed
to be a separate and independent covenant and agreement. If any term, condition, clause or provision
of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only
that term, condition, clause or provision shall be stricken from this Agreement and in all other
respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the
failure of any party to meet her or his obligations under any one or more of the paragraphs herein,
with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the
remaining obligations of the parties.
19. MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return
receipt requested, to Pamela Y. Hall, 5145 E. Trindle Road, Apartment J, Mechanicsburg,
Pennsylvania 17050, or counsel for Pamela Y. Hall, or such other address as Wife from time to time
may designate in writing.
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Galen G. Hall, 1751 Mountain Road, York Springs, Pennsylvania 17372,
or counsel for Galen G. Hall, or such other address as Husband from time to time may designate in
writing.
20. 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.
9
SECTION IH
ALIMONY AND ALIMONY PENDENTE LITE PROVISIONS
1. ALIMONY
The parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted
by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony pendente lite or
alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to
seek from the other payment for support, maimenanee, alimony pendente lite or alimony.
SECTION IV
PROPERTY DISTRIBUTION PROVISIONS
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs,
carpets, household equipment and appliances, pictures, books, works of art and other personal
property. Wife agrees that all of the property in the possession of Husband shall be the sole and
separate property of Husband; and Husband agrees that alt of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do hereby specifically waive, release,
renounce and forever, abandon any claims which either may have with respect to the above items,
which shall thereafter be the sole and exclusive property of the other.
2. RETIREMENT BENEFITS
The parties agree that Wife shall retain sole ownership and possession of all of her retirement
benefits and plans and Husband specifically releases and waives any and all interest, claim or right that
he may have to these assets.
l0
The parties further agree that Husband shall retain sole ownership and possession of all of his
retirement benefits and plans and Wife specifically releases and waives any and ail interest, claim or
right that she may have to these assets.
3. BANK ACCOUNTS
Husband and Wife are the owners of individual bank accounts. Husband and Wife agree that
these accounts shall be the sole and separate property oftbe person in whose name they are titled and
each party waives any right, title or interest they may have in the other parties' account.
4. AUTOMOBILES
Wife is the owner of a 1996 Ford Taurus automobile. Husband and Wife agree that the 1996
Ford Taurus shall be the sole and separate property of Wife, and Husband waives any right, title, or
interest he may have in this vehicle.
Husband acknowledges that he owned a 1986 Ford Bronco which has been sold subsequent
to the parties' date of separation. Husband received the sum of $200.00 for this vehicle. Husband
and Wife agree that the sales proceeds realized from the sale of the 1986 Ford Bronco shall be the
sole and separate property of Husband and Wife agrees to waive any right, title, or interest she may
have in same.
5. LIFE INSURANCE
Husband is the owner of a Hartford Life and Annuity Insurance Company life insurance
policy. Husband and Wife agree that this policy, and its cash surrender value, shall be the sole and
separate property of Husband and Wife agrees to waive any right, title or interest she may have in this
asset. Husband shall be responsible for any premiums due upon his policy under this Agreement.
6. CURRENT LIABII,ITIES
Wife and Husband represent that they have taken all steps necessary to make sure that no
credit cards or similar accounts exist as of the date of execution of this Agreement which provide for
joint liability, except those provided herein. From the date of execution of this Agreement, each party
shall use only those credit cards and accounts for which that party is individually liable.
7. CASH PAYMENT
Husband shall pay to Wife the sum of$ ~ [, C~(3, ~ ~ff- . This payment shall
be made to Wife within '.~hi~e-O0) d~ays followh0g the execution date of this Agreement.
Each party hereby agrees to be responsible for any legal fees incurred on their behalf
AFTER-ACOUIRED PROPERTY
Each of the parties shall hereatter own and enjoy, independently of any claim or fight of the
other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired
by him or her at, er the parties' date of separation, with full power in him or her to dispose of the same
as fully and eff'ectively, in all respects and for all purposes, as through he or she were unmarried.
10. REAL ESTATE
A. Marital Residence - The parties agree as follows with respect to the Marital
Residence, located at 1751 Mountain Road, York Springs, Pennsylvania, which is titled in Husband's
nan~e alone, and was pumhased prior to the date of the parties' marriage:
(1) Husband agrees to prepare and file all documentation necessary to
apply for a mortgage, or a home equity line of credit, in his name, for the Marital
Residence. Furthermore, Husband agrees that he will complete the mortgage process
within thirty (30) days following the date of the execution of this Agreement.
(2) Simultaneous with the mortgage process, Wife shall execute any
documents necessary, including a quit claim deed, to transfer any right, title or interest
she may have in the Marital Residence to Husband, if requested by the lendir~g
institution. ~/
(3) Husband shallpaytoWifethesumof$141,q ,~D. OC) , as ~,~t[forth
above in Paragraph Seven of this Marriage Settlement Agreement, from the proceeds
of the mortgage process. The parties agree that this amount represents Wife's share
in the appreciated value of the Marital Residence.
12
SECTION V
CLOSING PROVISIONS AND EXECUTION
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on the date indicated below.
8 1c -03
DATE
GALEN G. HALL
PAMELA Y. HALL,
Plaintiff
GALEN G. HALL,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-188 CIVIL TERM
:
: CIVIL ACTION = LAW
: 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 §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: A copy of the Divorce Complaint was
served upon Defendant by certified mail, restricted deliver, return receipt requested,
on January 26, 2002.
3. (Complete either paragraph (a) or Co). )
(a) Date of executiun of the affidavit of consent required by §3301(c) of
the Divorce Code: by Plaintiff: August 19, 2003; by Defendant: August 19, 2003.
CO)( 1 ) Date of execution of the affidavit required by §3301 (d) of the Divorce
Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the
respondent: N/A.
4. Related claims pending: None.
5. (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record; a copy of which is attached: N/A.
(b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: August 19, 2003.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with
the Prothonotary: August 19, 2003.
Respectfully submitted,
DALEY LAW OFFICES
Supreme Court I.D. No. 68736
1029 Scenery Drive
Harrisburg, PA 17109
(717) 6574795
Attorney for Plaintiff
IN THE COURT Of COMMON PLEAS
PAMELA Y.
OF CUMBERLAND COUNTY
STATE OF PENNA.
HALL,
Plaintiff
02-188 CIVIL TERM
VERSUS
GALEN G. HALL,
Defendant
DECREE 1N
DIVORCE
DECREED THAT
AND Galen G. Hall
Pamela Y. Hall
, IT IS ORDERED AND
, PLAINT[ FF,
, DEFENDANT,
ARE DIVORCED FROM THe BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF rECORD IN THIS ACTION FOr WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None.
The provisions of the
dated August 19, 2003,
into this Decree in Divorce.
parties Marriage S~]~m~n~ Agr~mmnt,
shall be incorporated, but not merged
PROTHONOTARY