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HomeMy WebLinkAbout01-3300 MICHAEL S. CROZIER, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CNIL ACTION - LAW : NO. 01 - 3.1,.,., CIVIL TERM KATHY A. CROZIER, Defendant : 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty A venue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J, Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Carlisle, PA 17013 (717) 243-7922 --~'-_.._-~.. MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 01 - J.1..... : IN DNORCE CNIL TERM KATHY A. CROZIER, Defendant 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3 I 66 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty A venue Carlisle, PAl 7013 (717) 243-7922 MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW :NO.OI. 3:>>U-O CNIL TERM KATHY A. CROZIER, Defendant : IN DNORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE COMES NOW, Plaintiff MICHAEL S. CROZIER, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE I. Plaintiff is MICHAEL S. CROZIER, an adult individual who resides at, ] 117 State Road, Duncannon, Dauphin County, Pennsylvania. 2. Defendant is KATHY A. CROZIER, an adult individual who resides at, 1117 State Road, Duncannon, Dauphin County, Pennsylvania. 2. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 3. The Plaintiff and Defendant were married on March 27, 1999 in Hershey, P A. 4, There have been no prior actions of divorce filed in his matter. 5. Plaintiff and Defendant are not members of the United States Armed Forces. 6. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c). 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff requests this court to enter a decree in divorce. COUNT II - CUSTODY 8. Paragraphs I -8 are incorporated herein as fully set forth. 9. Plaintiff seeks shared legal and physical custody of the following child: Name Present Residence Age Joshua M. Crozier, I I 17 State Road, Duncannon, P A born February 24, 2000. Age 15mths. The child was born in wedlock. 10. The child is presently in the custody of the mother Kathy A. Crozier and father Michael S. Crozier. I I. Since birth, the child has resided with the following person( s) at the below address( es): Birth to present: With the mother and father at 1 I 17 State Road, Duncannon, Dauphin County, Pennsylvania. 12. The mother of the child is Kathy A. Crozier residing at! 117 State Road, Duncannon, Dauphin County, Pennsylvania. She is married. I3. The father of the child is Michael S. Crozier, residing atll 17 State Road, Duncannon, Dauphin County, Pennsylvania. He is married. 14. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the child and the following person(s): Name Relationship Kathy A. Crozier Wife 15. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with the following person(s): Name Relationship Michael S. Crozier Husband 16. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 17. The best interest and permanent welfare of the child will be served by granting shared legal and physical custody of the child to the mother and the father as both have been the primary caretakers of the child through his life and the child will continue to benefit from living with both parents. 18. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, names below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim None WHEREFORE, Plaintiff requests the court to grant shared legal and physical custody to the Plaintiff and Defendant. Respectfully submitted, Date: May 29, 2001 {/ r/ lit, Jam~__E+ 4Li e::"lyAV~'Ue Car s~ e, PA 7013 (711}1243-7 2 VERlFICATION OF PLEADINGS The foregoing document is based upon infonnation which has been gathered by my COLU1se] and myself in the preparation of this action, The language of the document may, in part, be the language of my cotUlsel and not my o\m. I have read the statements made in this document and to the extent that it is based upon information which] have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have rdied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 P A. 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"',:.,.';', " ,; ':"j,J' '".' , 'i', ::~<';';~'::~<\i,:" ":-~<;'~'?;:-::Y'>:' ',.. " " :;':, :}"''':;'~ ":'-; '(':~ ' , , -~::'; , , ',' , ,. . ':'.1'" "-,h. .' ':,' " " :,,:~,::,.::~,; ',::/;"}::::~,,.: .,. 'i, "., ',..'':.,~:~(;r':Y'},:,,,'..:~'.::;;::::'" , ;:'~:. ,,' "" r,: :>Y' ' :,~:,:,:;.y '~; '.,' '<>'; ';:,', :",:. " '" .' '.::.'" ",' : \~f X>:, ":-'",':: L . 'u ' ""',;',,,; % ",': ,'" "',' , ,""; "': n, " ','''' -., ~,' ;., - '! ,A "_:,"-' ,....J ~, .:r GG6L-8VG (HL) nOH 1fd '<>js!pe:::> . en,ue^v !\jJeqll '3 17 . 1l0l '\jJaqll u01ljlJodJQ:::>.IBUOISS8jQJd V UMOJ~PU~ Ja^e)l MICHAEL S, CROZIER PLAINTIFF V, KATHY A, CROZIER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3300 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, June 01, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, June 27, 2001 at 2:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney, Esq.!\'({\. Custody Conciliator ! J I ' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A TIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , n/ ~'~ 7J:t? ~ ~t/ ~) ;P? r ~ ~ ~jL, ~d r ~ ~ /PrA9/ .~ /i/'.5 '? Jrl, j '1 /t'l.J'J \iiN'v1\1;\SNN3d JJ.Nt'1Q8 ('<f" F1gv~nJ 01 :/ V' !:_I,r,r. '^ .::) ..- l{li! I U IU\/iu....,:, ' AU _ "...'1 . ,~', -'", , _....:..'""".. .:J...);~~~<f ~: ' MICHAEL S, CROZIER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 01 - 3300 CIVIL KATHY A. CROZIER, Defendant CNIL 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 reliefrequested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Perry County Courthouse, East Main, New Bloomfield, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyers' Referral Service 100 South Street p, O. Box 186 Harrisburg. P A 17108 800-692-7375 Dated: March 2{,' 2004 MidPenn Legal Services 213 N. Front Street Ha isburg, PA 17101 1 800-932-0356 or SQUIRE igh Street MICHAEL S. CROZIER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 01 - 3300 CNIL KATHY A. CROZIER, Defendant CIVIL ACTION - LAW IN DNORCE SUPPLEMENTAL COMPLAINT IN DIVORCE ADDING COUNTS COMES NOW, Defendant, Kathy A. Crozier, by her counsel, Jerry A, Philpott, Esquire, and files this Supplemental Complaint in Divorce Adding Counts as follows: COUNT II Request for a No-Fault Divorce Under 9 3301(d) of the Divorce Code 9, The prior paragraphs of this Complaint are incorporated herein by reference thereto, 10, The parties are living separate and apart and at the time of a hearing, defendant will submit an affidavit alleging that the parties have lived separate and apart for at least two years, WHEREFORE, defendant respectfully requests the court to enter a decree of divorce pursuant to 9 330I(d) of the Divorce Code. COUNT III Request for Equitable Distribution of Marital Property Under 9 3501(a) of the Divorce Code II. The prior paragraphs of this Complaint are incorporated herein by reference thereto, 12, Plaintiff and defendant acquired property and debts, both real and personal, during their marriage from March 27,1999, until June 1,2001, the date of their separation, 13, Plaintiff and defendant have been unable to agree as to an equitable distribution of said property, WHEREFORE, defendant prays for the entry of an Order distributing all of the aforementioned property, real and personal, as the Court may deem equitable and just, plus costs. COUNT IV Request for Counsel Fees, Costs and Expenses Under SS 3507(A) and 3702 ofthe Divorce Code 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15, Defendant has employed Jerry A. Philpott, Esquire, to represent her in this matrimonial cause. 16, Defendant is unable to pay her counsel fees, costs, and expenses, 17. Plaintiff is employed and has the ability to pay Defendant'scounsel fees, costs and expenses. 18, Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to the final hearing, Defendant requests that, after final hearing, the Court order Plaintiff to pay pay Defendant'sreasonable counsel fees, costs and expenses, WHEREFORE, defendant respectfully requests the Court to enter an order directing Dated: March 25,2004 ~ A, PHILPO SQUIRE Box 116,227 rth High Street uncannon, P A 17020 (717) 834-3087 Attorney for Defendant MAR-24-2004 WED 02:01 p~ DCCMU F4X NO. 17172328537 , I 1'PR-i!4-eli!e'l 12:38 FlUOltPHlLJ'OTI" I'ROSl:iER L 71lB3'l-54:J7 TO:~.:lr I verifY that the statements madCI in ~S Suppl.c:ment:a1 COPIPlaint in Divorce Adding Couot& are true lIl'Id correct. I under&taod ttuf false slatementl< huein arc: made subject to tbe _ofl8"='__":_"_~ d P. U;:/U~ p.e"e ....... -.t: "8 ~ ~ " (J ~ iCJ ~ ~ It. f'jk t;" ~ D (). I B ~ ~ ~ ,....:::., ~ o C" " "'t~ lfJ :';JP-, .?:l ~; ~<- :.:::; - '~'.<> :(' ~ 0 ~ "'"11 ~ 5! ~ mj; ", 15 9 (7, 9~ ." =jj :n :1; ~O ,::~rn .:.: (Jl_, ~.< MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 01 - 3300 CIVIL TERM KATHY A. CROZIER, Defendant : IN DIVORCE PRAECIPE FOR SETTLEMENT AND DISCONTINUANCE TO THE PROTHONOTARY: Please mark the Plaintiffs Count II of the Custody Claim filed in the above referenced matter as discontinued, settled and ended. Respectfully submitted, Dated: June 6, 2001 it r og '" ;:+ ::l.,< ~r _roo --.J- ;:l: ~'U --.J ro . -:J "':J.... ...."'m ",,<. I<r- -.......I D> __ "':JeT I'.;) -- ro "'''';:+ ~'< --.Jl> 0< ~ro "':J C ro >- ~ ex; <:. Z ,.- M :::> LLJ \;-:~. <<' n __:'-t ( ) ~'~ ::) 2;: ;-;--l,' ~... i-;" 0__ (-::::: i ::::j 1 r-- >- (I) u. I ?~ ~'.. -.- :J CLl ---... :!J [L _:.. L+ ::J [ <..-:> U l>" ~nl S,,< ro CD ~ .., 5' nl ~ ~ -c. o Q OJ '0 .., o 0 OJ <: g< :J ~ < Kayer and Brown A Professional Corporation Liberty Loft . 4 E, Liberty Avenue . Carlisle, PA 17013 (717) 243-7922 .' .- " ., ".,. '~~:} ~: >;:~f: :,,," , "l'~~ . oll'~ . ".' " c-' F,-. , ",' '^/' ~ " " '_,1 " ",-'.- . . """ ;;;p t/r"", ~ ~ 'JUN 2 2 2001 tIJ MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-3300 CIVIL TERM KATHY A. CROZIER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 22ND day of June, 2001, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 7t1,ti acq line M. Verney, Es~stodY Conciliator MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 01-3300 CNIL TERM KATHY A CROZIER, Defendant : IN DIVORCE MOTION FOR APPIONTMENT OF MASTER Michael S. Crozier, Plaintiff, by and through his Attorney, Galen R. Waltz, moves the court to appoint a Master with respect to the following claims: Divorce, Distribution of Property, Counsel Fees, Cost and Expenses. In Support of the Motion, Plaintiff states: 1, Discovery appears to be complete as to the claims for which an appointment of a Master is required 2. The Plaintiff has appeared in the action by his Attorney, Galen Waltz, Esquire, 3. The statutory grounds for divorce is 3301(c). 4. It is expected that the action is contested with respect to the following claims: a. Property distribution and it is further averred that the defendant's intentional and knowing destruction of marital assets may be issues. 5. The action does not involve complex issues oflaw of fact. 6. The hearing is expected to take one half to three quarters days. 7. Counsel for the defendant is Jerry A. Philpot, Esquire, P.O. Box 116, 227 North High Street, Duncannon, PA 17020-0116, 8. Service ofthe complaint was accepted by the Defendant's former counsel Melanie Erb on August 6, 2001. (Exhibit one attached and corporated herein) Wherefore, the plaintiff seeks the appointment of a Master with respect to claims of divorce, property distribution, counsel fees, cost and expenses. MICHAEL S. CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CNIL ACTION - LAW : NO. 01- 33$D CIVIL TERM KATHY A. CROZIER, Defendant : IN DNORCE ACCEPTANCE OF SERVICE .l(" "V }~ I, Melanie Erb, Esq., hereby accept service this L, of.Aln'e';'200I of the Notice to Defend and Complaint in Divorce filed in the above captioned matter. ~fr~/..fJ; Mela6feErb, Esq. Attorney for Defendant Suite 20 I 2880 Linglestown Road Harrisburg PAl 7 Il 0 CI,I'-f,J- Cf.h,J:" II 'I , I CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Motion of Appointment of Master upon Jerry A. Philpott. Esquire, and btJdepositing same in the United States Mail, first class, postage pre-paid on the ! J./,J., day of J:J";4 _ ~....- . 2003, from Carlisle. Pennsylvania. addressed as follows: Jerry A. Philpott. Esquire 227 North High Street Duncannon, PA 17020 TURO LAW OFFICES /5h a en R. Waltz. Esquire 28 South Pitt Street Carlisle. PA 17013 (717) 245-9688 Attorney for Plaintiff . c::., 0 c.) " ':/) .; ,'1 ::J ,) c , ,~....) <11 .;; ? .,U ~. , . " ,C , 2.l C) ---,} , en '> .' ~ Q -< n c .' ~ 'T"'," -;..' . -;';, " ~=.~ ; - ._, MICHAEL S. CROZIER, Plaintiff v. KATHY A CROZIER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO, 01-3300 CNIL TERM : CNIL ACTION - CUSTODY ORDER APPOINTING MASTER AND NOW, this ~ RJI'tuJ ~h~f c.c. Jerry A. Philpott Galen R. Waltz / tJ 'It BY THE COURT, f.J. '-i~:,.i ~f.\~ .:.:::'S;': ~:',d AlNnr,-~ (~'. -;/,o)'.li;8 02:1 ::d 0 I 83.:l ~noz ^b'\flC~-,:OH10cd 3Hl :10 -'''11 ':1-0311" :,J:.:,L :J ~I~/O~~ MICHAEL S. CROZIER, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 3300 CIVIL KATHY A. CROZIER, Defendant IN DIVORCE TO: ~ Galjn R. Waltz Jerry A. Philpot , Attorney for Plaintiff , Attorney for Defendant DATE: Friday, February 13, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. ~~J!()I 6ATE ( ...-( ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. 9;,tj/Ol~ MICHAEL S. CROZIER, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 3300 CIVIL KATHY A. CROZIER, Defendant IN DIVORCE TO: Galan R. Waltz Jerry A. Phi~ , Attorney for Plaintiff , Attorney for Defendant DATE: Friday, February 13, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. J J/ ;., r I' DATE ) ------- NOTE: PRETRIAL DIRECT ES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. I." \il lI' \; f! QUIRt \' 'il .1. I. , _,":-r;---"" r,. .7''"\ ---_.-.~ " \ "i' \ 1NIT!t: COURT OF COMMON PLE},~ or CUMBERLAND CO! i'-il'Y PENNSYLVA~IA , L{r 'Al<"ll"L,L ~), CKuntR.. Plaintiff v. KATIIY A, CROne-X Dctendan t NO, 01-3300 C;"I IN mVORC[ DEFENDANT'S INVENTORY C( )1\1 ES Nt l\V dekndant Kathy A Crozier, by her counseL Jerry A Philpott. Esquire, and liks her inventory pursuant to Rule ,1920,3J. (The claim under Section 350] orthe D",orcc Coee \"'" tiled on ,\-Iarch ]6, 2C04,) Marital property: Marital residence at] J 17 State Road, Duncann(\n, Perry Countv, acquired during the marriage and titled soldy in thc name ofplaintilf Marital debts eonsisting of credit card debt in the approximate amount (,f S3,,600, An income tJx rctund jointly owned but cash cd by plaintiff]n the amount of $600. Separate, non-marit,t1 property: Defendant's position is that all other property eithcr party possessed was nOIl- marital. Subsequent to the separation, defendant has acquired a new vehicle in her own name and a new home, Simil;v: ,p 'ntijfhas undoubtcdly acquired property since the separation, ( I \espectfu ~ J ell}j . Philpo ;E quire Su eme Court ill 47624 7 No, High Street. uncannon, P A 17020 Counsel for defendant -.. DaIC'! :\pril J.5. 200,) {1l6 ----,_....",..~.....",.,' ,,,,,,,,,.,..',.," "" .'...."..1.. II I, I , MICHAEL S, CROZIER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COURNTY ,PENNSYLVANIA v. : NO, 01-3300 CNIL TERM KATHY A CROZIER, Defendant : CNIL -DNORCE ~; C} ~~ .'11 :t..... ::.::.! PRETRIAL STATEMENT ~:; hi;:}] :'fr~3 NOW Comes, Plaintiff, Michael S. Crozier by and through his AttorneY;Da/en:R. Waltz, Esquire, pursuant to the March 26, 2004 Divorce Master request for a:Wetrlijli~; statement. f~ ' ," L) L;' I. Background of Case: Plaintiff, Michael S. Crozier, filed a Divorce Complaint under 3301 C at the Court of Common Pleas, Cumberland County on May 30, 2001; the Cornplaint contained two counts (one count in Divorce and one count in Custody.) James A. Kayer was the Attorney for the Plaintiff at that time. Acceptance of service was signed by Attorney, Melanie Erb, Esquire, Attorney for the Defendant and the service was accepted August 6, 2001. On June 7, 2001 a Praecipe for Discontinuance and Settlement of Plaintiff count 2 of the custody claim was filed and marked accordingly; the Custody Action was pursued in Perry County where jurisdiction is currently maintained. On September 18, 2003 the Plaintiff filed a Motion for Appointment of Master as it related to distribution of property, Divorce, Counsel Fees and Expenses. Subsequently a Master was appointed and a Director from the Master has issued requesting a pretrial statement be filed and on or before April 16, 2004, On March 26, 2004 Defendant file a supplemental Complaint in Divorce adding count 2,3&4 whereby count 2 requested a 3301D no fault divorce, Count number 3 seeks equable distribution. Count number 4 requests counsel fees and expenses. II. Factual Witnesses: Michael S. Crozier address 1117 State Road, Duncannon, PA 17020 and Nancy Wolf address 1123 N. Pitt Street, Carlisle, I PA 17013. Expert witness: Scott p, Archibald, 5955 Lingelstown Road, Harrisburg, PA III. Issues: Whether the real estate residence, solely in Plaintiff's name, with a loan for the property solely in the Plaintiffs name, wherein the Defendant resided for approximately 8 months whether any equity existed in that very short period of time and even if any equity did exist whether the Defendant is entitled to any portion of that equity? Suggested Answer: NO II I- I I Whether the Defendant is liable for outstanding bills that arose during the course of Defendants cohabitation relative to PP&L, West Shore Oil, Sprint, Grolier Books, Blue Ridge Cable, Food Spoilage, College Tuition, Cash advance on a credit card? Suggested Answer: YES Whether or not the Plaintiff is liable for Credit Card debt when credit card is solely in the Defendant's name and control throughout the relationship? Suggested Answer: NO Whether or not the Defendant is entitled to one half of the tax rebate during the year prior to separation after she agreed to split the divorce costs? Suggested Answer: NO Whether or not the 1997 Pontiac Sun Fire owned by the Defendant and the 1992 Ford Explorer purchased by the Plaintiff constitute a set off in value? Suggested Answer: YES Whether or not the Crozier Family "Baby Crib" should be returned promptly to the plaintiff or in the alternative the cost of a replacement crib be assessed to the Defendant? Suggested Answer: YES Whether or not duplicate family photos in the possession of the Defendant should be immediately provided to the Plaintiff? Suggested Answer: YES IV, Exhibits: The settlement sheet of the State Road Property and valuation at date of separation; Burlington Coat Factory receipt for a crib, Country Wide Home Loan Statement, Commitment for Title Insurance, Receipt for Divorce filing, Phil Haven Visa Statement and Providian Statement. V. Anticipated Length of Trail: one half day for Plaintiffs case. VI. Plaintiff reserves the right to amend: the above factual witness list II 'I' I I I as it relates to both fact witness names and those that will be named at a later date; the plaintiff reserves the right to amend the above expert witness list and exhibits contained herein. ~Ir~ 10 I Date C:A'~i -Galen R. Waltz, Turo Law Offic s 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 Attorney For Plaintiff II II CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Pretrial Statement upon Jerry A. Philpott, Esquire, and by depositing same in the United States Mail, first class, postage pre-paid on the I fp M day of 11 r ~ ) , 2004, from Carlisle, Pennsylvania, addressed as follows: Jerry A. Philpott, Esquire 227 North High Street Duncannon, PA 17020 TURO LAW OFFICES ~a Galen R. Waltz, Esqu' 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff MICHAEL S. CROZIER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01 - 3300 CIVIL KATHY A. CROZIER, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Galen R. Waltz , Attorney for Plaintiff Jerry A. Philpott , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 3rd day of June 2004, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 4/20/04 E. Robert Elicker, II Divorce Master MICHAEL S. CROZIER, Plaintiff IN THE COURT OF COMMON PLEAS OF1 YfQ' 11,0 CUMBERLAND COUNTY VI/, /0'1 'f-- PENNSYLVANIA v. KATHY A, CROZIER, Defendant NO. 01-3300 Civil IN DNORCE DEFENDANT'S PRETRIAL STATEMENT COMES NOW defendant Kathy A. Crozier, by her counsel, Jerry A. Philpott, Esquire, and files her pre-trial statement pursuant to Rule I 920.33(b). 1. LIST OF MARITAL AND NON-MARITAL ASSETS Marital assets a. Marital residence at 1117 State Road, Duncarmon, Perry County, acquired during the marriage and titled solely in the name of plaintiff. Defendant believes, based on her memory of a written appraisal obtained at the time of purchase, which plaintiff possesses, that the home was worth approximately $68,000 at that time. It was purchased for only $61,900, and had an initial mortgage lien of$61,535, which defendant does not think has declined substantially. b. Marital debts consisting of credit card debt in the approximate amount of $3,600. c, An income tax refund jointly owned but cashed by plaintiff in the amount of$600. Non-marital assets Defendant's position is that all other property either party possessed was non- marital. Subsequent to the separation, defendant has acquired a new vehicle (although it is not in her name) and a new home, which she later sold. Similarly, plaintiff has undoubtedly acquired property since the separation. 2. EXPERT WITNESSES Defendant plans to use no expert witnesses. 3. OTHER WITNESSES Defendant plans to call only herself in her case. 4. EXHIBITS Regarding the marital home, defendant has copies of the deed, note, mortgage, and HUD- I, but does not have a copy of an appraisal that was obtained during the marriage. Plaintiff possesses a copy of that appraisal. Defendant requests that plaintiff produce it. Copies of defendant's exhibits are attached with a list on top. 5, INCOME STATEMENT Defendant's most recent semi-monthly pay stub and her 2003 income tax return are attached. As of this date she had not yet prepared her Pennsylvania 2003 income tax return; a copy will be furnished as soon as it is available. She currently earns $29,819 gross per year, and takes home about $22,863 net per year. The details of deductions are shown on the pay stub. 6. EXPENSE STATEMENT Defendant does not intend to offer any testimony as to her expenses. 7. PENSIONS Defendant intends to make no claim regarding and to offer no evidence regarding pensIOns. 8. COUNSEL FEES Defendant has been represented by two counsel. She has looked for documentation about the cost of SerateIli, Schiffinan firm and can not find it. The cost was approximately $5,000. Details will be furnished as soon as they can be found. The details of the cost of her representation by the undersigned are attached as Exhibit 10. 9. DISPUTED PERSONAL PROPERTY At an earlier stage of negotiations there was a dispute about photographs. Defendant does not have any of the photographs she was accused of taking. The dispute was not about value, but about obtaining copies. 10. MARITAL DEBTS See attached regarding a credit card acquired during the marriage that had a balance as of the date of separation, which defendant has subsequently paid off (although she continued to use the card). Attached are: (I) a statement showing a "previous balance" as of about June 1,2001, of $3,602.49; (2) a history of payments after that to the extent the defendant could find records to substantiate them; including (3) a statement reflecting a payment $3,617.57 on October 7, 2002, which paid off what was owed at that point. 11. RESOLUTION OF ECONOMIC ISSUES Defendant proposes that plaintiff reimburse her for half of the marital debt that she had to payoff ($ I ,800) and pay her half ofthe tax refund that plaintiff cashed in ($300). As to the marital residence, she proposes that it be sold and the parties split the proceeds. Finally, she asks that her attorney fees be paid. Dated: April 15, 2004 I 2 3 4 5 6 7 8 9 10 LIST OF EXHIBITS 8- I 0-2000 deed to I I 17 State Road, Duncannon 8- I 0-2000 note for same 8-10-2000 mortgage on same 8-10-2000 HUD-I regarding same 2003 1040 for Kathy Crozier Earnings statement for period ending 3/31104 and check dated 4/5/04 Providian credit card statement for 7/3/0 I History of subsequent payments on credit card Providia credit card statement for 1115/02 Itemization oflegal services by J. Philpott through 4/14/04 4pp. 2pp. 10pp. lp. 2pp. 1 p. I p. I p. 1 p. 5pp. ".-"", f '; \. ) ~ ..... ~1 THIS DEED Pem tounty .. IlocUIeIIt St_ David I lime, Recorder Date 00/1712000 nile 09:06:48 1 of j Ha: 2000-00026928 GEH Book 1289 Paw TAX PARCEL NO. Made the 10 ih day of August, 2000, BETWEEN LINDA B. BRANDT, now known as LINDA B. WERT, a..,.Dlin"rl.x:., wom&lJ', herein designated as the Grantor" AND MICHAEL S. CROZIER, a married man, herein designated as the Grantee, WITNESSETH, that the Grantor, for and in consideration of SIXTY -ONE THOUSAND NINE HUNDRED ($61,900.00) DOLLARS lawful money of the United States of America, to the Grantor in hand well and truly paid by the Grantees, at or before the sealing and delivery of these presents, the receipt whereof is hereby acknowledged and the Grantor being therewith fully satisfied, do by these presents grant bargain, sell and convey unto the Grantees forever, their heirs and assigns, ALL THOSE TWO (2) CERTAIN pieces, parcels and tracts ofland situate in Penn Township, Perry County, Pennsylvania, more particularly bounded and described as follows, to wit: TRACT NO.1: BEGINNING at a point at the southwest corner of State Highway and Chestnut Road, which pint is sixty (60) feet West from the southeast corner of State Highway and Chestnut Road; thence southwardly along the West side of Chestnut Road, 110 feet to a point at the north side ofFariview Avenue, to be opened; thence weStwardly along the North side of Fariview Avenue, to be opened, 50 feet, more or less, to a point at the line of Lot No. 138 in Plan of Mountain Side Park, Perdix; thence northwardly along the line of said Lot No. 138, 80 feet to the corner of Lot No. 70 in Plan ofPerdix Heights, Perdix; thence northwardly along the line of said Lot No. 70, 30 feet to a point at the South side of State Highway; thence eastwardly along the South side of State Highway, 40 feet to the place of BEGINNING, containing 4,950 feet, more or less, having thereon erected a frame cottage. TRACT NO.2: BEGINNING at the intersection of lands now or formerly of George F. Shrauder and Fayella A. Shrauder, his wife, and lands now or formerly of Harry M. Rudy and wife; thence South by lands now or fonnerly of George F. Shrauder and Fayella A. Shrauder, husband and wife, 50 feet to an iron pin; thence. West b lands now or formerly of Eda G. ..,.' ;:~ I \ , Date CBI17J2000. Tile 09'06148 2 at KG: 2000-00026928 GEllIoak 1289 h!e Gutshall, single woman, 50 feet to an iron pin at the line of Lot No. 139 owned by Harry M. Rudy and wie; thence North by the Rudy line, 50 feet to a corner; thence East by the Rudy line, being the northen part of Lot No. 138,50 feet to the place of BEGINNING. The Plat of the aforesaid lot numbers as laid out by A. C. Young is recorded in Perry County Deed Book 95, Page 647. GRANTING AND CONVEYING unto the Grantee, its successors and assigns, and additional 25 feet, being one-half of that portion of land designated as "Fairview Avenue" as more particlularly set forth in an agreement between D. E. Lucas and Sarah E. Lucas, his wife, and Geroge F. Shrauder and Fayella A. Shrauder, his wife, dated August 8, 1944, and recorded in Perry County Deed Book 129, Page 630. Said "Fariview A venue" was offered for dedication to the Township on or about 1917, but said offer was never accepted by Penn Township and the public has never used said street. Therefore, since the dedication was not perfected within 2 I years, the Act of May 9, 1889, P. 1. 173, No. 192, Sec 1,36 P. S. 1961, extinguishes the public right in the road and provides that the said "Fariview A venue" cannot be opened "without the consent of the owner or owners of the land on which the same has been, or shall be, laid out." BEING the same premises which Federal National Mortgage Association, a corporation organized under an Act of Congress and existing pursuant to the Federal National Mortgage Association Charter Act, by their Deed dated October 30, 1996 and recorded November 6, 1996 in the Office of the Recorder of Deeds in and for Perry County, Pennsylvania, granted and conveyed unto Linda B. Brandt, a single person, the Grantor herein. The said Linda B. Brandt has since married and is now known as Linda B. Wert. St.. /101 2OOO-OO4:l38 CGnsid: lOCI fEIIH nP CaIIorIwraltlt at PeIVI511vania PElII11MCSIIIP SlfY SUSlllENITA SCIIlll DISTRICT BYI llt Total 61.900 Afft: ~ 619.00 309.50 309 .SO 1,238.00 . ~ I } Datt 08117/2000. Tile 09~06:48 2 of ~ No: 2000-00026928 GEM Book 1289 P8e Gutshall, single woman, 50 feet to an iron pin at the line of Lot No. 139 owned by Harry M. Rudy and wie; thence North by the Rudy line, 50 feet to a corner; thence East by the Rudy line, being the northen part of Lot No. 138,50 feet to the place of BEGINNING. The Plat of the aforesaid lot numbers as laid out by A. C. Young is recorded in Perry County Deed Book 95, Page 647. GRANTING AND CONVEYING unto the Grantee, its successors and assigns, and additional 25 feet, being one-half of that portion of land designated as "Fairview Avenue" as more particlularly set forth in an agreement between D. E. Lucas and Sarah E. Lucas, his wife, and Geroge F. Sbrauder and Fayella A. Sbrauder, his wife, dated August 8, 1944, and recorded in Perry County Deed Book 129, Page 630. Said "Fariview Avenue" was offered for dedication to the Township on or about 1917, but said offer was never accepted by Penn Township and the public has never used said street. Therefore, since the dedication was not perfected within 2 I years, the Act of May 9, 1889, P. 1. 173, No. 192, Sec 1,36 P. S. 1961, extinguishes the public right in the road and provides that the said "Fariview Avenue" cannot be opened "without the consent of the owner or owners of the land on which the same has been, or shall be, laid out." BEING the same premises which Federal National Mortgage Association, a corporation organized under an Act of Congress and existing pursuant to the Federal National Mortgage Association Charter Act, by their Deed dated October 30, I 996 and recorded November 6, 1996 in the Office of the Recorder of Deeds in and for Perry County, Pennsylvania, granted and conveyed unto Linda B. Brandt, a single person, the Grantor herein. The said Linda B. Brandt has since married and is now known as Linda B. Wert, Stall> No: ~ CltIsid: Loc: PEIIH nP Callanllealth ot PEmsYIV3llia PEHH tolIlSIIIP SIIV SllSQUEJIITA sam. DISTRICT BY: lit lotal 6lt9oo Afft: ~ 619.00 3Q9.50 309.50 1,238.00 Date ~/1712OOO Tiu ~06:483 of /In: 200H0026928 lD Beak 1289 Page TOGETHER with all and singular the buildings, improvements, ways, woods, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances to the same belonging or in anywise appertaining; and the reversion and reversions, remainder and remainders, rents, issues and profits thereof, and of every part and parcel thereof; AND also all the estate, right, title, interest, use, possession, property, claim and demand whatsoever of the Grantors both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with the appurtenances. TO HAVE AND TO HOLD all and singular the premises herein described together with the hereditaments and appurtenances unto the Grantee and to Grantee's proper use and benefit forever. AND the Grantor covenant that, except as may be herein set forth, they do and will FOREVER SPECIALLY WARRANT AND DEFEND the lands and premises, hereditaments and appurtenances hereby conveyed, against the Grantor . In all references herein to any parties, persons, entities or corporations, the use of any particular gender or the plural or singular number is intended to include the appropriate gender or number as the text of the within instrument may require. Wherever in this instrument any party shall be designated or referred to by name or general reference, such designation is intended to and shall have the same effect as if the word "heirs, executors, administrators, personal or legal representatives, successors and assigns" had been inserted after each and every such designation. IN WITNESS WHEREOF, the Grantor have hereunto se~hand. md seal' or if a corporation, it has caused these presents to be signed by its proper corporate officers and its corporate seal to be affixed hereto, the day and year first above written. SIGNED, SEALED AND DELIVERED b1 the presence of or ArrESTED by ~.0>i;ta~ , l ~ ~ .~vlL) Linda B. Brandt ~'Ari,^ J.fl1. 11 krt LindaB. Wert , t'. , ,'- (,.~ "j Date 08I1712OOD. Tile 09:06:48 . of No: 2000-00026928 GEII Book 1289 Paw COMMONWEALTH OF PENNSYLVANIA, COUNTY OF~ ~~....... /" ) , ; BE IT REMEMBERED, that on (]lI ('). JD ' ,2000, before me the subscriber personally appeared Linda B. Brandt. now b;~, Linda B. Wert and Ronald Wert, known to me (or satisfactorily proven) to be the person whose name is subscribed to within deed and acknowledged that she executed the same for the purposes therein contained. WITNESS my hand and seal the day and year aforesaid. 7f'aJ1;vJJ J itA UvvuUC NOTARY PUBLIC ~elllii'1T1kS~9!} Expires: ",.;';,,, ~ .C\~~:3u ';"O{SEAL) ~.. r.. t-;~"l \1) ,... ". r~\~ ,':::=' $;+- t' ~'~"",/' . ~ :' "',0 ::.-;:; :: a I ~" ,I..', -"-,- .{... _ _~ ...~ ~ . ' = ~ Nf;P,.':3i/.::v,.:;, u.). ": (':;:;"~. ' "ut -. ....-:,I"h. 4D ,\~;.".o. .. '.... - _ ~ - ~ :;:"'~;'~'T...~~ : S-5:~~; -..." /"'" ""~."'"JI"'_',, }:-::<'::X;,~:~t\~~} , , '" <;$<;'::J., ,,..' . ~"~~~:;~r::~~;~~f~~: I NDIarIaI Seal I Valerie S. SlacIcnldc, NoIary Ptdc .~_:~. CI.mbedand C<ulty -T ~..,....... Ellpireo Nav. 3ll. 2000 M8IIlI>er, PonnsylvanJa Association at Nolar1os The undersigned certifies that the precise residence and complete post office address of the Grantee is: 11/7)W.lL RL Dv.n.~/POJ, I?()~O ~ : l/rLLtuJ!) ILk (]f'Kru d COMMONWEALTH OF PENNSYLVANIA COUNTY OF RECORDED on this Office of the said County, in Deed Book day of ,Page ,2000, in the Recorder's GNEN under rny hand and the seal of the said Office, the date above written. , Recorder Multistate .~ NOTlit.. ' t:,,-.. '-,. '" lfj '_ I1tfrl 17020 ~ C L~ ~ 'Borrower' means each person signing at the end of this Note, and the person's successors and assigns. '~~ GreenPoint Mortgage Funcling, Inc. .,,-- , . FHA CUe No, .41-6329915 August 10, 2000 [Date) 1117 State Road Duncannon, Pennsylvania [Property Add....) and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In retUrn for a loan received from Lender, Borrower promises to pay the principal sum of Sixty-One Thousand rive HUndred Thirty-rive and 00/100ths Dollan (U.S. $ 61,535.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Kight and 750/1000 percent ( 8.750 %) per year until the full amount of principal has been paid. 3. PROMISE TO'PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar securily instrument that is dated the same date as this Note and called the 'Securily InstrUment. ' The Securily Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) 11me Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on October 1ST , 2000 . Any principal and interest remaining on the first day of September 2030 , will be due on that date, which is called the 'Maturily Date. ' (B) Place Payment shall be made at PO Box 3459 He.. York, H_ York 10008-3459 or at such place as Lender may designate in writing by notice to Borrower. (C) AmOllllt Each monthly payment of principal and interest will be in the amount of U.S. $ "4.10 . This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Insuument. (D) AIloJige to this Note for paymeat acijustment.t If an aIlcmge providing for paymeIIt adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. (Check applicable box) DGraduated Payment Allonge Dorowing Equity Allcmge DOther [specify} S. BORROWER'S RIGHT TO PREPAY Bom:lwcr has the right to pay the dc:bt evidenced by this Note, in whole or in part, without cbarge or penally, on the first day of any JDODth. Lender shall accept prepayment on other days provided that Bom:lwcr pays interest 011 the amount prepald (or the ,.,.".inder of the month to the extent required by Lender and pennined by regulatiOllS of the Sec:rctaIy. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly paymenl unless Lender agrees in writing to those changes. _.1R f1J8Ono~ MuIIloCate I'Iud ItaIo Nola. 10195 VM' "ORT_ FOlIMS. '_121-728' U( _'012 _ ,...~, 0/01379550 BBAE-OI ~~ 6. BORROWER'S, FAILURE TO PAY (A) Late Charge Cor Overdue Pa)'lllents If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragrapl 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the ,;m1OIUI ofrour and 000/1000 percent ( 4.000 %)oftheovetdueamountofeachpayment (B) Default If Borrower defaults by falling 10 pay in full any monthly payment, then Lender may, except as limited by regulation! of the SecretaIy in the case of payment defaults, require immediate payment in full of the principal balance rem.ini"g due an( all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequenl default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require imml"1liate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, 'SecretaIy' means the SecretaIy of Housing and Urban Development or his or her designee. (C) Pa)'lllent of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs sha1I bear interest from the dale of disbursement at the same rate as the principal of this Note. , . ~'>' ,""',;;" ~2 7. WAIVERS Borrower and any other penon who has obligations under this Note waive the rights of presentment and notice of dishonor. 'Presentment' means the right to require Lender to demand payment of amounts due. 'Notice of dishonor' means the right to require Lender 10 give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mall to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER nus NOTE If more than one penon signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any penon who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any penon who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each penon individua1ly or against all signatories together. Anyone person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. ~~.tfy~ (Seal) -Borrower (Seal) -Bonower (Seal) -Bonower (Seal) -Borrower (Seal) -Bonower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower _ .1R 111011.01 'lfe2Clf2 BJIAE.Ol 0101319550 r-, \,,1 Parcel Number: 210.135.01-036-000 ISpoce Abo.. TbII LIDe For RecordlDl Dalll) Commonwealth of Pennsylvania MORTGAGE fFHA Cue No. 441-6329915 MIN 100013801013795509 THIS MORTGAGE ("Security Instrument") is given on 08/10/2000 The Mortgagor is Michael S. Crozier, A Harried Man ("Borrower"). 'Ibis Security Instrument is given to Mortgage Electronic Registration SystemS, Inc. ("MERS"), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as beneficiary. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. GreenPoint Kortgage J'ImcIing, Inc. ("Lender") is org.ni71'lll and existing under the laws of The State Of New York , and has an address of1100 Larkspur Landing Circle, suite 101 Larupur, california 94939 . Borrower owes Lender the principal sum of Sixty-ane Thou.and rive Hundred Thirty-rive and 00/100tha Dollars (U.S. $ 61,535.00 ). FHA f\uu.ll._ Mortpl" wlIh MERS. 4196 . -4NlPAI IOOOO' #- .... 2IllI . .....,... ,_ JU>C VMP MORTGAGE FOFlMS -18001121-72'1 BJIAE.OI 010\379550 c') \t"\"Y'r This debt is evidenced by Bonower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on Septltlllber 1, 2030 . This Security lnstnunent secures to Lender: (a) the repayment of the debl evidenced by the Nole, with interest, and all renewals, CXlC1lSions and modifications of the Note; (b) the payment of all other sums, with inlClesl, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Bonowcr's covenants and agreements under this Security Instnln1Cnt and the Note. For this purpose, Bonower docs hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in Perry County, Pennsylvania: which has the address of 1117 State Road ])uJ1CJUlDOl1 ("Property Address"); TOGBTHER WITH all the improvements now or hereafter erected on the property, and all e:l'-',. appurtcIIaIlcCS and fixlnres now or hereafter a part of the property. All repl............ts and additions shall also be covered, by this Security lnstnunent. All of the foregoing is referred to in this Security lnstnunent as the "PJup..rly." Bonowcr UDdcrstands and agteCS that MERS holds only legal title to the interests granted by Borrower in this Security Inslrumcnl; but, if JlI'C"$!'"')' to comply with law or CUSlOIII, MERS, (as nominee for Lender aDd Lender's successors aDd assigns), has the right: to exercise any or all of those interests, iDcIuding, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but nol limited to, releasing or Cll"C"ling this Security Instrumcnl. BORROWER COVENANTS that Bonower is lawful1y seized of the estate hereby conveyed and has the right 10 mongage, grant and convey the P.c.jMly aDd that the Property is uncncumbcred, except for CIlCUJIIblllllCeS of record. Borrower wammts aDd will defend generally the title to the Property against all claims aDd_d_, subjCClIo any cncumbranccs of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform COVClllllllS with limited variations by jurisdiction to constilute a uniform security inslrumcnt covering real property. (CiIy), Pennsy)vania17020 (s....,) (Zip Code) ~ -4NIPAI ...... _, tfI~ c.. BJlAE.Ol ,..201. OIOI3795S0 ~ \:~~1JiP o \{:,:t;:) Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Prlndpal, Interest and Late Charge. Borrower shall pay wben due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Tues, Insurance and OtIier Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and specia1 aSS""nnents levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium 10 the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender stil1 beld the Security InstrUllleDt, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the SecretaI}', or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is beld by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the SecretaI}', these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and bold amounts for Escrow Items in an aggregate amount DOt to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 el seq. and implementing regulations, 24 CPR Pan 3500, as they may be amended from lime 10 time ("RESPA "), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts beld by Lender for Escrow Items exceed the amounts permitted 10 be beld by RESP A, Lender shall account to Borrower for the excess funds as required by RESP A. If the amounts of funds beld by Lender at any time are not sufficient to pay the Escrow Items wben due, Lender may notify the Borrower and require Borrower to make up the shonage as permitted by RESP A. The Escrow Funds are pledged as additional security for all sums secured by this Security instrUment. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance """';'1;"g for all inst.Il""",. items (a), (b), and (c) and any mortgage insurance premium inst.Il""",. that Lender bas DOt become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. rmm..d;o<<-ly prior to a foreclosure sale of the PIOperty or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. AppUcation of l'aJments. All payments under paragraphs 1 and 2 shall be applied by Lender as follows: rUII, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, specia1 as"Cl'""""'''. leasehold payments or ground rents, and fIre, flood and other hszaId insurance premiums, as required; TbinI, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4."l'ire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including file, for which Lender requires insurance. This insurance shall be maintained in _, tf,fSt: _ -4NIPAlIOOOfI B~t '.3011 0101379550 , r, I I , '/ Q ~fjf1 the amoUDts and (or the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secrelary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in (avor 0(, and in a (arm acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if nOI made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make paymenl for such loss directly 10 Lender, inslead of 10 I3orrower and 10 Lender jointly. Allor any part o( lhe insurance proceeds may be applied by Lender, at its option, either (a) 10 the reduction of the indebtedness under the Note and !his Security Instrument, fIrSt to any delinquent amoUDts applied in the order in paragraph 3, and then 10 prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not exlend or postpone the due date of the monthly payments which are tl:ferred to in paragraph 2, or cbange lhe amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the NOle and !his Security Instrumenl shall be paid 10 the entity legally entitled thereto. In the evenl of foreclosure of !his Security InStnnnent or other transfer of title to the Property that extinguiahes the indebtedness, all righI, title and inlereSl of Borrower in and to insurance policies in force shall pll$S to the purchaser. 5. Occupancy, Preservation, MalDteDllDce and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, eslablish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrumenl (or within sixty days of a later sale or lraDSfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date o( occupancy. unless Lender determines that requirement will cause UIldue hanlsh.ip for Borrower, or unless eXlenuating circumslances exist which are beyond Borrower's conrroI. Borrower shall notify Lender of any extenuating circumstances. Bol'roWer shall nol commit waste or destroy, damage or substantially change the Property or allow the Property 10 deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacanl or abandoned Property. Borrower shall also be in defaull if Borrower, during the loan application process, gave materially false or inaccurate information or slPlMJents to Lender (or faiIed to provide Lender wilh any material information) in conneclion wilh the loan evidenced by the Note, including, but not limited to, representations coJlCCjDing Borrower's occupancy of the Property as a principal residence. If !his Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. H Borrower acquires fee title to the P..ujdly, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condeamatlon. The proceeds of any award or claim for damages, direct or consequential, in connection with any CQnrl........tiOll or other laking of any part of the Property, or for conveyance in place of c:c:mrlr.mnotion, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid undei' the NOle and !his Security Insttumeot. Lender shall apply such proceeds to the mluction of the indebtedness UIlder the NOle and !his Security 1nstrtImenl, first 10 any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred 10 in paragraph 2, or change the amounl of such payDlenlS. An)' excess proceeds over an amount required to pay all ontstOlJding indebtedness under the NOle and this Security !nstrumellt shall be paid 10 the entity legally entitled thereto. ~ -4NtPAllOOOlll ....... uS ( BBAE-OI "'4019 0101379550 ~ \.dL~ 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and imposilions Ihal are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would advez:selyaffect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agRCDICDts contained in this Security Instrument, or there is a legal proceeding Ihal may significanlly affect Lender's rights in the Propetty (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necemry to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbuned by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear intetest from the date of disbursement, at the Note rate, and at the option of Lender, shall be imm<odiate1y due and payable. Borrower shall promptly discharge illy lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a IIlaIU1C1' acceptable 10 Lencfer; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceMings which in the Lender's opinion operate to prevent the enforcement of the lien; or (e) secures from rhe holder of rhe lien an agRCDICDt satisfactory to Lender subordinating rhe lien to this Security lnslrumenl. If Lender determines Ihal any part of rhe Property is subject to a lien which may attain priority over this Security Insl1'llD1eDt, Lender may give Borrower a notice identifying rhe lien. Borrower shall satisfy rhe lien or take one or more of the actions set fonh above within 10 days of rhe giving of notice. 8. Fees. Lender may collect fees and cbarges aurhorized by the Secretazy. 9. Grounds for Ac:cderatlon of Debt. (a) Default, Lender may, except as limited by regulations issued by rhe Secretary, in rhe case of paymi:nt defaults, require Imm<odWe payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment requited by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by fiiling, for a period of thi:tty days, to perfOlJD any other obligations contained in this Security Instrument. (b) Sale Without CrecJlt Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Gam-St. Germain DepositOI)' Institutions Act of 1982, 12 V.S.C. 1701j-3(d)) and with the prior approval of the Secretaty, require jmmedj.t~ payment in full of all sums secured by this Security Instrument if: ' (i) All or part of the P:to~, or a beneficial interest in a trust owning all or part of rhe Propetty, is sold or otherwise lraDSfemd (other than by devise or descent), and Cti) The PIO~1y is not oc:cupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has DOt been approved in accordaacc with the requirements of the Secretary. (c) No Waiver. If cm:.tmct~ occ:ur Ihal would permit Lender to require lmtnl.fj~te payment in full, but Lender does DOl require such payments, Lender does DOl waive its rights with respeclto subsequent events. em -4N(PAI 1??oo, . BBAUI ,. 5 019 010137"50 ......,#~c ~! ".:.-.; 13. Notices. Any notice to Borrower provided for in this Security Instnunent shall be given by delivering it or by mailing it by rust class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender sbaIl be given by first class mail to Lender's address stated herein or any address LeIIder dosig>'..... by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragnph. 14. GovemlDg Law; Severability. This Security InstrumeDt sbaIl be governed by Federal law and the law of the jurisdiction in which the Property is localed. In the event that any provision or clause of this Security lnstrumeDt or the Note conflicts with applicable law. such contlict shall not affect other provisions of this Security InstrumeDt or the Note which can be given effect without the contlicting provision. To this end the provisions of this Security instrUment and the Note are declared to be severable. IS. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security lnstrument. 16. Hazardous Substances. Borrower shall not cause or pennit the presence, use, disposal, storage, or release of any Hazardous Substances On or in the Property. Borrower shall DOt do, nor allow anyone else to 40, anything affecting the Property that is in violation of any Environmental Law. 'Ibe preceding two senteDces shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give LeIIder wrinen notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Pterpetty and any Hazardous Substance or Environmental Law of which Borrower has actUal knowledge. If Borrower learns, or is notified by any gOVCl'T'''''''''''' or regulatory authority, that any removal or other fPm...n..ion of any Hazardous Substances affecting the Property is ~~~ry, Borrower shall promptly take all necessary remedial actions in accoa1ancc with Environmental Law. As used in this paragraph 16, .Hazardous Substances. are those substances defined as toxic or hazardous substances by Environmental Law and the foUowing substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, .Environ........' Law. means federa1laws and laws of the jurisdiction where the Property is located that relate to health, safety or enviro""""".l protection. NON-UNIFORM COVENANTS. Borrower and Lender funher covenant and agree as follows: 17. .lnfgl''''l!IIt 01 ReDts. Borrower UIICOIIditiODally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to coUect the rents and revenues and hereby directs each tenant of the Property to pay the rents'to Lender or Lender's agents. However, prior to Lender's DOtice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trostee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender sbaIl be entitled to collect and receive all of the rents of the PIOpdty; and (c) each ..- ft/5 c: .. -4NIPAllOOOfI . BBAE-OI ~7of9 0101379550 r) ," "-~' @"" ~,;,~~;';: '--'" (d) Regulatloas of HVD Secretary. In many cin;umslallCCS regulations issued by the Secretary will limit I.cndcr's rights, in the case of payment defaults, to require immediate payment in full and foreclose if DOt paid. This Security InstrUDlCDt docs not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (el Mortgage Not Iasured. Borrower agrees that if this Security Instrument and the Note arc DOt determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require imme(liate payment in full of all sums secured by this Security Instroment. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, sha1I be deemed conclusive proof of such ineligibility, Notwithstanding the foregoing, this option may not be cxc:rcised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mongage insurance premium to the Secretary. 10. Relnstatement. Borrower bas a right to be reinstated if Lender bas required immMi.t" payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings arc instituted., To reinstate the Security Instrument, Borrower sha1I tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they arc obligations of Borrower under this Security Instroment, foreclosure costs and reasonable and customuy attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Insuumcnt and the obligations that it se<:urcs sha1I remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinsratement if: (i) Lender bas accepted reinstatement after the commencement of foreclosure p~;1\gS within two years immMi.lt!ly preceding the COlDlllCl1CClIlClt of a current foreclosure proceeding, (Ii) rcinstatcmcnt will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not RelC8SCd; Forbearance By Lender Not. Waiver. Extension of the time of payment or modific:ation of amonization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower sha1I not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to com_ P......-!;l'lV against any successor in interest or refuse, to cxtcod time for payment or otherwise modify amonization of the sums secured by this Security 1nstrumcJIt by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the cxcn:isc of any right or mnedy. U. S..-rs aDd AssIgns Bound; JolDt aDd Several LIability; Co-Slgners. The covenants and agrccmcnts of this Security Insuumcnt shall bind and benefit the successon and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agrccmcnts sha1I be joint and several. Any Borrower who co-signs this Security lDstromcnl but docs not execute the Note: (a) is co-signlng this Security 1nstrumcnt only to mongage, grant and convey that Borrower's interest in the Property under the tcnns of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Inslrumcnt; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. _ -4NIPAI 10001) ""...., 1-15c BJlAE.aI '9 . oil 0101379550 ;--') Q) \~,;:,. teuant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the teuant. Borrower bas not executed any prior assignment of the renlS and has not and will not perform any act that would prevent Lender from exercising its rights under this paragtaph 17. Lender shall DOt he required to enter upon, talce control of or maintain the Propeny before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy' of Lender. This assignment of rents of the Property shalltemUnate when the debt secured by the Security InstrUlDent is paid in full. 18. Foreclosure Procedure. U Lender requftes Immediate payment In IuD under paragraph 9, Lender may loreclose this Security Instrument by Judicial proceeding. Lender shaD be entitled to coDed aD expenses InCWTed In pursuing the remedies provided In this paragraph 18, including, but not limited to, attorneys' lees and costs 01 title evidence. ' U the Lender's Interest In this SecurIty Instrument Is held by the Sec:retary and the Sec:retary requftes Immediate payment In lull under Paragraph 9, the Sec:retary may Invoke the nOIVudidal power 01 sale provided In the Single FamDy Mol'tgage Foreclosure Act of 1994 ("Act") (12 V.S.C. 3751 ef seq.) by requesting a foreclosure c:ommlssloner designated under the Act to commence foreclosure and to sell the Property as provided In the Act. Nothing In the preceding sentence shall deprive the Secretary 01 any rights otherwise avaDable to a Lender under this Paragraph 18 or appUcable law. 19. Release. Upon payment of all sums secured by this Security Instrument, lbls Security Instrument and the estate conveyed shall terminate and become void. After such OCCWTence, Lender shall discharge and satisfy this Security Instrument without cbarge to Borrower. Borrower shall pay any reconlalion costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defec:ts in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachmJmt, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hoUt prior to the oom"-'('CIllent of bidding at a sheriff's sale or other sale pursuant to this Security 1nstnJment. 22. Purchase Money Mortgage. If any of the debt secured by this Security Insttument is lent to Borrower to acquire title to the Property, this Security InslI1JlJlenl shall he a purchase money mongage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mongage foreclosun: shall he the rate payable from time to time under the Note. ) 24. Riders to this SecurIty Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenantS of each such rider shall he incorporated into and shall amend and supplement the covenants and agreements of this Security Instroment as if the rider(s) were a pan of this Security Instrument. [Check applicable box(es)]. o Condominium Rider E3 GlOwing Equity Rider 0 Other [specify] o Planned Unit Development Rider Graduated Paymenl Rider cG/. -4NIPAJ 1<'00'" I"'....' ;<.{ S c BBAE-OI ,..lof8 0101379S50 !~~ ,f ~ ~ff1s) BY SIGNING BELOW, Borrower accepts and agrees 10 the lerms contained in this Insl1'WllCllI and in any rider(s) neculed by Borrower and recorded with il. Witnesses: Security ~~~ Michael S. Crozier (Seal) ~Borrower (Seal) ~Borrower (Seal) -Bonowet (Seal) ~Borrowe:r (Seal) -Bonower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower CertHlcale of Residence I, address of the within-named Lender is , do hereby certify that the correct Witness my hand this day of A,mlof Lendor COMMONWEALTH OF PENNSYLVANIA, CUllberland On this, day of personally appearlld Michael S. Crozier County ss: , before me, the undersigned officer, known 10 me (or satisfactorily proven) 10 be the person whose name subscribed 10 the within instrumenl and acknowledged that executed the same for the puI]lOIeS herein contained. IN WITNESS WHEREOF. I hereunlO set my hand and official seal. My Commission Expires: _ -4NIPAI COOOOI BJIAE.OI '1"'1110 of OIIiccr p....... 0101379550 (j Exhibit ~ ~~$~4t) "A" ". All choue ewo (2) ce:ta1n pieces, parcel. and tracts of land situate ~n penn rowlIMp, Perry Couney, Pennsylvania, lllOre particularly bounded anc1 deacrlbed 1I.1!l follows, to wit: Tract Bo. 1:. aeginning at a point in the southwest corner o~ state Hlgh'd.Y and Chesenut Road, which point ie sixty (60) teet Weat from the southeast co:ner of State Highway and Chlll8tnut Road, thence south~ly along the Weat .ide ot Chestnut Road, 110 teet to a point at the North aide of Fa.irview Avenue, t.o be opened; thence welltwardly along the North side of Furview Avenue, to be opened, 50 teet, more or lesB, to a point at the line of Lot No. l38 in Plan ot MOuntain Side Park, Perdix; thence northwardly along the line of .aid Lot No. 138, 90 feet to the corner of Lot No. 70 in Plan ot Perdix Height~, perdix; thence northwardly along the line of Maid Lot No. 70. 30 fee~ to a point at the South side of state HighwaYi thence eastwardly along the South aide of Statlll Highway, 40 feet to the place of Beginning. Contal~ .,950 square f..t, more or less, having thereon erected a fr&.lllQ cottage. ~act No. 2. Be~lnn1.n9' at the ineeraeetien of lana t1QW or ~ormerly of Oeorge P. .Shrauder and Faye1J.a A. Shrauc!er, his wif.., and lands now or formerly of Ha~ M. Rudy and _if.; thence South by lands now or formerly of George r. Shraudllr and Fayella A. Shrauaer. husband aDd wi~e, 50 fe.t to an iron pin; thenee Weet by lands now or formerly of Ida G. Qut.hall, single woman, SO feet to an iron pin at the line of Lot NO. 139 owned Dy Harry M. Rudy and. wife; thence North by the Rudy lina, SO feet to a corner; thence saat by the Rudy lino, being the northern part of Lot No. 138, SO feet to the place of Beginning. The Plat of the aforesaid lot numbers as laid out by A.C. Young is recorded in Perry County Deed Book 95, page 647. Granti%lg and. conveying unto the Grantee, is successors and _signs, an addit1~1 2S feet, ~ing one-halt of that port~on o~ land designated as "Pairview Avenue" as mo~e pare~cularlr set forth in an agreement between'P.B. x.uc:e.. aM Sarah 2. Lucas. h s wife, and o..crge F. shrauder and Paye~ta A. Shrauder. his wife. dated August 8, 1944 and recorded in Per~ county Deed Book l29, page 630. Said .~.irview AVenu.e. waa of:fe:z:oed tor decU.c:ae:ion to chs Township on or about 1917, wt said o:f:fer __ l1aver accellt.d by Penn TownsMp and the publio halll never used said str..t. ~er.~ore, s:ince dedication Was not per:fectod within 21 years, tbe Act of May 9, lBB~, P.L. 173, No. 192, Sec. 1 36 P.S. 1911, extingui.he. the publ.ic dght in the :l:'oad and pJ:Ovides tb4e the said "Pairv:iew Avenue- cannot bc opened w:ithout: the COtulent: of the owne%' o:e owners of the land on which the ..ams has tleen, or sbal1 be, lAid oul:. ~~;na.;~e~~ pre~eeB which Federal National Mortgage ~.ociation by p ,te October 30, 1996 and recorded N'oveml:ler 9. loSS/ii :in l:h:- l;;ry~~;ycl ~!~icB o:f the Recorder of Ceeda, in Record Book 977. page , ... ..."'" conveyed unto Linda B. BrAnde. A. U,S, DEPAImlENT OF HOUSING and URBAN DEVELOPMENT SETTLEMENT STATEMENT 'OMB No, 2602-Cl265 nTlEPRO L...rprinl . . I ., B. TYPE OF LOAN 4705 East Trlndle Road Mechanlcsburg, PA 17055 Phone: (717) 730-9664 Fax: (717) 730-9665 1, aq FHA 4.[ JVA 6, FILE NUMBER: 992023 8, MOAT, INS, CASE NO,: 2, [ J FMHA 5, ( J CONY. INS. I 7. LOAN NUMBER: 0101379550 3, ( J CONY. UNINS. C, NOTE: Thlllorm Illu,..,l8hed to give ~ a Itatemenl 01 acluelselllemenl coSls, Amounts paid 10 and by Ihe selllement agent 81e shown, Items marked '(p.o.c.)' were paid outside the ciollng; they are lhown here lor informallonal purposes and are nOllncluded In the lotals. D, NAME AND AllDAESS OF BORROWER: E, NAME AND ADDRESS OF SELLER: F. NAME AND ADDRESS OF LENDER: MICHAEL S. CROZIER LINDA B. BRANDT GREENPOINT MORTGAGE FUNDING G, PAOPEfll'Y LOCATION: DUNCANNON 111 7 STATE ROAD PENN TOWNSHIP PERRY County H, sern.EMENr AGENT: I, SETILEMENTOAIE: HERITAGE SETTLEMENT SRVS PlACE OF SEIILEMENT: 4705 E. TRINDLE RD., MECHANICSBURG, PA oa/l0/00 J. SUMMARY OF 1I0RROWER'B TRANSACTION: 100. GRoea AIIOUNT DUII'IlOM BORROWER 10l.COI\lractlalet'prlce 61900.00 '0', ",,..,,,aI property 103,Setll8ll\4lIlt charget to borrower (line 1400) 512a . 72 104. 10S. K. SUMMARY OF SELLER'S TRANSACTION: '00. GROSS.....OUNT DUE TO SEU.ER ,01.00n1racl salel price ,0"Personal property '03. .... 0405. 61900.00 Adjultm.ntllor Ileml paid by I8l1er in advance 101, CllylTown lox 10 107,CO!lnlylox Oa/l0/00t0 12/31/00 IDa. Alae'Imen.. to 'DO, SCllOOL Oa/l0/00t0 06/30/01 55.07 Ad)ultmonls for iteml paid by lell071n advance ...,CllylTown lox 10 'o7,CO!lnlylox Oa/l0/001O 12/31/00 408.A.....m.nt. to '00, SarooL Oa/l0/001O 06/30/01 410. 10 411. 412. 55.07 420.01 420.01 110. 111. 112. 10 120. GRoea AMOUNT DUE FROII BORROWER 200, .....OUNTS PAID BY OR IN BEHAlF OF BORROWER 675 0 3 . a 0 420, GROSS .....OUNT DUETO SELlER 62375.0a 6OO.REOUCl10NSIN AMOUNT DUE Tn AFt I CD APR-15-2004 THU 09:33 AM DGGMU Form 1040A Label {See page 19,} U.. the IRSlebel. Otherwise, please print or type. Presidential Election Campaign (Seell"!l8 20,) Filing Status Ch.ck only one box. .. Exemptions If more than six depen~ts, see page 21. Income Atia.h Form/I) W.2 here, "'"0 IIta"" Form(.) 1088-R ~ lox wu wtthhe'd. 11 you did not getaw-2.ete page 24. EndclIe. ... de not 8It8ch. any pilyrnent. Adjusted gros. income Deplll1lnenl of 1I1e Treasury -Inlemel_ 5ervIce U.S. Individual Income Tax Return KATJfY A CROZIBR 451 W HIGH STRBBT APT. 44 BLIZABBTHTOWN, PA 17022 {1) First name L-ast name FAX NO. 7172320935 (99) 2003 JOSHUA CROZIBR d Total number at 8X8lY'Iptlons daimed. 7 wage., .......1... lips, .te, Sa b Sa b lOa b 11. T._1e in_I. Attach Schedul. 1 if reoulred, Tax- ...mDtlntere&l Do not include on Hne Sa. Ordinary divldentle, AIIach S_ I If "'<luJred, aue_ dlvidontle (_ _ 25.) Call1bol goIn distributiollo (see page 25), PQ8t'-Mev 5 capital gain dlst.dbullons tSfltJ page 25), IRA distributfons. i1a Psnolons and annuities. 12a (2) O.p.nd.nrs 60alaJ security number 203-7B-9032S0N 8b 9b lOb lib T_I. _moon! (__25), 12b Taxable amounl (see _ 26), 13 144 lJnemployment compensation and Alaska Permanent Fund dividends. SodaI security I 14b Taxable amount bonefits. 14. (..... P_ 28), j!l!.O!_~I..,~,~,... ..._ __. ,,_~ _......fP.1~~:1!l(\11.1a 120 15 Add lin.. 7lhtCugh 14b (Isl r1ghlcolumn), rhisis)'OultofaJlncoml. 18 Educelot..........(__28), 16 17 IRA deduellon (.... pell8 28). 17 18 StudenlJoen 1018__ (..._31). 18 1. Tuition andfseadedU<Uonroee_31), 19 20 Add lfnes 16 through 19. Theseareyourtotal........... KBA 21 Sub1ractli1. 20 from 1In. 15. Thisisyour~_'ncom.. For Dlocloeu... Privacy Ac:l, and ""_rlc Roductlon Ad NotIce, ... _. 57. P. 02 IRS u.. 0fI~. Do not_.,....,.ln lhlB.PI' OMS No, 1545-0085 Your eocIaJ ucurfty number 595-56-9976 Spousels social security numi (3) O.p.ndeflrs relationsh'p to you .. ~4),A. qU<l. I child for IChfJdC8Xcr. (S8& pg 23) :~ I i I 7 10. lIb 12b 13 14b .. 15 20 .. 21 Importantl You must enter your SSN(s} above, .livedwllt1 you .did not live with you dIJ8 to diVorce or separation (see page 23) Dependents on6C not er.1ered abol/e Add numbe,(s r OIl lines , i1iDove ' 27,296 Sa 9_ 27,296. 27,296. Fomrl040A (2003) APR-15-2DD4 THU 09:33 AM DCCMU FAX NO. 7172320935 P. 03 FOml 1Q4(JA(2003\ KATHY A CROZISR Tax, 22 Enter the amountf""" Un. 21 (od)ol_grooaincomo), credits, and payments Standord Deduction for- . People who checked any box on 11M 23a or 23b or who con be claimed 38 a dependent, see page 32. . All others: Single or Marned flHng sepa~. $4.750 Marriedfiing 10;.''''.''' Quamylng widoWi'f), $9,500 Head of household. $7.000 2'" CMck {8 You w_bombofo", Janu1lIy2. 1939. 8 Blind}Tolalbo'.. ff: 1Ipou.. we. born before Januory 2, 1939. BIIn<i ""oeked ~ b II you are married Mng separately and your spouse -. deductions. see page 32 and check here 204 'Entsryourllund.rddeductlon (see left margin). 25 Subtnoc1llne 24 from line n,lfDn. 2418 mar. tI1.n Ilnan.entar-O-, 26 MuIUpI)' $3.050 by the ~ n"-r of ..ampllans cIaImod OIl Hne 6d. 27 Sub_ IIna 26 from line 25, If line 261."""" tI1an Ilne 25. enter .()'. This Is your taxable Income. 28 Tax, including any altemative minimum tax (see paQe 33). 29 Credit for chid and depend.-rt care eJl:peI'l5eS. Attach Schedule 2, 30 CredIt for the elderly or the disabled. Attach Schedule 3, 31 Education credits. Attach Form 8863. 32 Rattremenl savings contributions credit. Attach FOml 8880. 33 Child tax cmdlt (... pege 37), 34 Adoption credit. AUach Form 8839. 315 Add 1i06529 through 34. These are your total credit.. } 38 Subtract line 35 from Une 28. If line 35ls more than line 28, enter -0-. 37 Advance eamed income credit payments from form(s) W-2. 38 Add linss38and 3r. ThislsyourtotaltalC. 39 Federal income tax withheld from Forms W~2 and 1099. 40 2003 estimated tax paymenls and amount appUed (rom 2002 return. Earnld Income coredtt(EIC), Add~lonal child lax aadll Altac:Il Form 8812, Add line8 39 throuqh 42. Thet8 are yourtotll payments. If IIna 4318 mo'" tI1an line 38, llUbtracllne 38 from lne 43, This i6 the am ouol you overpaid. 45a Amountofline44you want refunded to you. 1 29 I II you hove L aquallying 41 child. attach r 42 Sch.dul. EIC. 43 44 Refund Dirac! daposil? See pago 50 and ftH In 45b,45o. and 45d. Amount you owe Third party designee Sign here Joint reMn? See page 20, K_. copy ror,.,... racooIs, PaId PI'8parer's use only "'95-56-9976 p. ", . 22 27,25 238 D n ~ 23b 24 25 28 7,00 20,29 6,10 ~ 27 28 14,19 1,62 30 31 32 33 34 600. 35 60 38 1,02 37 ~ 38 1,02 3,032. 39 40 41 42 ~ 43 3,03: 44 ~ 45& 2,001 2,001 I ~ c Typo: [!J Checking 0 Saving. ~ b ::::~ ~31372387 .. d Accout1t I- number 1U200072120 48 Amount of Un. 44 you want applied to your 2004 ..ttmated tax. 46 47 Amount you aWB. Subtrad line 43 from line 38. For details on how to pay, see paqe 51. .uJ EslImatod tax penally (see paQo 52). 48 Do you wanttD allow another person to discuss this return with the IRS (see page 52)? U Yes. Complelethefolowing. I.!J II De8ignee'. name Phone no. Personal 10 numb.er ~ ~ (PIN)~ I Under ~of Deri".y, I . I hlW8UMined this rllturn and ~Ing sctJedtJIM.and lItetements, S1d 10 Ihebesl of IllY. knowtBdQllll belief;: f11aret OOfrect, and~li8tallamowtsnsourcesaffncomeJreoeIY<<Idurlngth8t8ll:year. Dl!.lClritkln of the !I blllMidonall irlforritionofwhlch theprepa-er ".~knawlelSge. Dote Your oc:cupeIIan Day&ne phon. number ~:T-oJi ==~U:R ~ IChedt K I Preparar's SSN or PTIN self_odn 1~~enCl I Date Pnlp....... .... signature" Frrm's I'l8mIt (or . yours Wself_Ioyod), address, and ZIP code 1~(i!G!!3)_. '.. ,__ ___ ,,"_ _..' ..EDj~~2,'!1I.II1.18 ~ 47 Fonnl040A{2OC ..... ,.., <.uu" tAU U~:j4 An DCGMU FAX NO. 1l/2320!J3o P. 04 ,:n ~Il.E:, IX:"l, ':c~<<x ~'No""~ HEI !~ 012 'XN5llf' '1lOIlb140D>'3 I . ' "'" eMU MANAGEMENT - PAYROLL ACCOUNT 1100 SOUTH CAMERON STREET HARRISBURG. PA 17104 " ,. '. Taxable MBJitaI status: Single Exemptions/Aftowa.nces: Federal: 1 State: N/A local: 1 Eaminlla Regular Social Security Number: 595-56.9976 ...hI hou..' Ih;. period 1242,46 1',242.46 ""lj,.ti}.iiY10ibWti~JtHKli~~ii'.J Deductions SlalulDry ,.,F'i<1.r:lt I"""me ~,-- SocIal Security Tax Medicare Tax PA Stale Income Tax Harrisburg C Income Tax PA SUI/SDI Tax Olher Check Pretax BclBs OPT Travel Reimb N I" ' .,', "'ll)' '" ....... '74 2~ -76,42 -17.87 -37,84 ,12.32 -1.12 ,952,64 .10,00' "..:: : ': ',':: ",'tII"ln, Earnings Statement . , ~ Period Ending: Pay Dale: 03/31/2004 04/05t2004 KATHY A. CROZIER 451 W, HIGH STREET ELlZABETHTOWN. PA 17022 y..r tQ date 8,663.97 B.663,97 -034 7t:. 532,B3 124.61 263 ,B6 85.91 7,80 70,00 10,00 -107,62 . Excluded from lederel lexabl" _g"e Your tederal laXable wages this period are $1,232,46 .1'lII''''')['.,,,,,- . , .'J:"Y.~'~~"'~~~, ~'Il"'I;1IJ/'''''''''I''''f'''rqr'''1!I~''W'''''fJN;'Ol~'''a''~''''''''~'''fI'*if~~~:Wt~:J,,~~~j::~~'1~~ ~RJ!1}};'!ill&))~}::f~}:fXfM,: " . ' 'AdVice ~um~r;;~i~\;}~~~~~1F~!JB~i, ......"" ,......' ~, leN'T., '_, "~,;<\.~F\OLL ACCOUNT Pay ctill..,_ '~. .."......, ,', '~,~, '... "..' ",'"'' t." ;~ [.'~1:;woou'rI>l'CAMERON STREET ~":;,, f' ";/ ',,;"?'><' , , i';' \~Ailtu\aflU"!lG;'pAt71jJ4 V"::,::'\ .: Ii, ; ')t '" ".. \;' " '~i L....-'!/' ,-,." , . ,_ r: _ ~, , ,~i*tto llwilccOuntof ~ ~= ",$ ~ aCcounl numbel" '" ~A KA;J'HY'AiCRQ%lE!A -- ~ - 0200072120 ~313 123~.' !~~\ '" "'J - "- , :o2:!i!' ~'~-., - ,'~= ~ ,"~,~\~Sl \v ~~~- -~ ~ ,..-,' , - = . -' ~ -~ mmn.nl '$952,6" NON-NEG'OTIAEn~e ' < '.~" '. } .... ,. .....""'.... - - .-..::'.",....."". ._~~... _ _W7 .uU VOi jO All OCGl'lU FAA NO. I1I~j~U9::Jb P.U6 5~\~tm+, QAk d' .' "1/ 3/tJ\ -yOur .nal"lil~ _1"0".11.. N..b......1c; lUIIn, ....; " .~.. ,.' - - - . - . '- , IIIE11A1in PRoM VISA -, , , r ,'" ,'.":,'.)~....~i!f-,-- '. y.._.....~IOt""'*"'O,.,..."..'. " ~-~,. _,_,~-"',~~'c..-;~"~;'<'''''=~=:~;'''~,j};:7:: ," "n. . -~~. . --- ~roOt~,,,,,,,,,,,,,,,,,,,,~,,:~~~;;:.~...._ .--",',',.', .. .,..,,-._-.....,.....'.. .. . "',-"-", ","'.',.""" ,"., ',.":;.' ,,",' ",' . " "".~JiIoOOid~~___ ' " .Ign. .You""',............. '~,"'1Q'llI""'or.~..."'--IllIWNIon,..BIOI~1-81N1J1llEFT' ~ .',.:. , .. ~...... , ,'-.'.." ;. .. .. .. -. . ..' >'," '..' . . - .' .. , .. ".'. ..-""""'"'.....-.,......,........... VlU(IIl_ '~........~lIpoIII(II).~VIllollCll~ IIIdIoiOjjIlOlofo(R).....', , ,,: 1II1ll(1ij.~___.,.~...W_~tor_. ~..,),:;;_ '; , ,':,'_ r.. ". .. .,' .:.':: :.',.- :".",::'.', . ...,\'iIUt,-JdIoiybllllmh, 'lI'.oquloll. 00"""" IIlCI no"'""", ""__' :' :,< ',> .', "Vlt!!.......f'"lIliHon.,ioOoilOifo'r' ',.. . ,I f=~":",;,d,'.,,: ", '4,,- ," -""1;, -,:Ju-.. 1'IfMlc YQII, , ItN5 ," 'lllllr.."," " " ' " -A"~~CR&WT '" ,', .. YOIit TOW~"..IlitlI. CradftJ. $SOU8, ,,',' , ... "-0Ut 01 iout AVdab/a,OadltCan b... , d rorClllibAdval!c,., ' .. 11\,tpiutloirilf:i,)ijr mdltlhl........,ba.... ,for cMlt~"'lImltAld.fd.,07t.oo. "~I'Y.I _,".fli ,~8UMMA1IV '~......' ,..iClail(ftl: :.;,i,:;,:~~- , + I!iioo:I....U ,...." a...- +'-.r'Aaii tI ~JI . +FIIlA1tC* ,CIMI!G!':' .CM.~ lJ...:..... . +..~' .. ...'.. AIlCI 'oOOtGeeOO__ .. , , 'P<A'_>>. ,.,~.. ...,. ~'..___~ ~. ,." '--"~"'___"'_.:'_' '-;- .,~. ." '," .. . '. 1"O!t8llUJ4GDltOJ\. AND IWOIttAftr.JHtoRMAT/()N.,S~ItMRSEalDE. v' ~A_i.qllAll '.'~,1'A'IWlEHT:~~,..",., R'" ~..~lft...~ '.,;:i~~.:i4int....w.'~~in~'m" ',..' ~, "-"'~. ,-..:~. f;;,~~~__74 'J;i~t.~__::;~ " " '.,.~./lArr:' ...."~ tt.Ric5.;"........... ,......0.. 1111,' " ,.,' .. '" ,,' " _'" '.\10 DdJ l'oIIiOoh....--". ' , ' '.llIII_U"'..1t....1llla1lltL. t:l;llII;~t, ' "", ...., M,II7t ...... ,"II1~ 1I11ll8A'11 , , .'" ,.... .-' ./,. " ~...... ....y.,y. ..... ... c.uu.. InU Uli;j4 At! OCGMU fAX NO. ill232Ull3b P. 05 Listed below are payments from the credit card that we discussed. I did ask the credit card company about statements from the time the account was open until time of separation, and I had to order them. I should get them in 10-15 days. I have attached two statements.....one dated for 7/3/01 (separation date being 6/8/01) with a previous balance on it of$3,602.49 and another dated 11/5/02 (after the separation date) which shows a payment made by me for $3,617.57. Providian account number: 4479-4107-2461-1723 5/23/02.... ..125.00 6/20/02......104.00 7/17/02......104.00 8/15/02.,." .125.00 9/26/02.,... .105.00 10/7/02.. .....3,617.57 1113/02.,... .20,00 12/17/02..... .30.00 2/2/03.. ....20.00 2/10/03.... ..500.00 3/13/03,.,.,.75.00 4/12/03.... ..55.00 516/03..... .60.00 6/9/03..... .100.00 7/14/03......100.00 8/21/03.... ..125.00 9/5103..... .125.00 Just let me know if you need any more payment info. I will see what I can do. APR-15-2004 fHU 09:36 AM DCCMU FAX NO. 7172320935 P. 07 pA,/~ 00113.lcH51 0'<\ 10/.7/02- YOq, -.o.-1It":-"'iiiWlit~'~(~:';~:,'riJ.'''~~,Ti;;''',''. ""R~l!s ~ 1II&A J, ' :.jr... , , . "., .,' !~""'b..~,j~~--"f'~~i\ . , ' ';';;,C. " ::,~..,"...",..;_.,"QIi/. " ." .. .-: ' '''''-', ....,~.~"."Xltj,lf'-Ii ':") lii':\~'IJI~+),~;ll::;:;:li""ii,.t.f:C ~tt~~#~~. ~::~ ,:=r:~~:&~~;~Ii: 1O-u ..'..'-...MAi""'1......."" " lN2~~~_I'O,T,~,q"j"~Ciji:" 1/!!8."" '10-25' iii..........:, ,.' " ""OIJYIU:' .-.IMlirlI' ,." lN6 '_.....~':!..~.,.'A netS ~Y:.., :,fP . 0:," . .,'. "'., " ,;..,' iICH," , ....";11I ,'..'.,j,~'t _~.l'" ~.,. \,.,.,' , "c,', ,-. ;',' '.,'- .'-';:"""'-;:".>---:- .-<-':....;......,-,'- . .:~.~. -, , -'>A~~~::'::' If.617.57 pv ' U.Dl 7,.42' u... 6I~44; '..4_ -17.. 7.... ' .':. '-',-,.'"', , .. '-. -;,,~ ". '.'~;:: '0 "_ , " ,...~.._it..oIiT~J'IHRmMATlC)N.siE..~~.B_;, B;~j~tl.~,t; .. .~~. ;~:. "'?,:.'~ . <''';:'' ;':::~:,. >ft, _:~~~.~~- .~.''':'-1...' - ;.~..,. . - '. .; .,~',;' -.... ';0-1;: . ',~ >~~;;.:. '~~,,,>.;.~-, """"""'.-" ."'-", -- ~., '.",.'. .'.c..,__-:....... ". ~....'. . 4/14/2004 1:19PM SPECIAL SLIP LISTING FOR A CLIENT All slips for the client listed below for the beginning and ending dates shown (or all dates, if no date selection is shown), whether billed already or not, whether billable or not; at billing value with time rounded per usual rules Selection Criteria Client (hand select) Include: Crozier, Kathy Date Ally Activity Description of activity Time ValuE 05/06/02 JP Initial meeting About taking over her custody and divorce case from Melanie Erb; hearing 2:10 250,01 on May21 05/07/02 MLC Secretarial Transcribe dictation. 1:20 05/08/02 J P Work on file Review dictation and place call for Melanie Erb to coordinate change of 0:10 208: counsel 05/08/02 J P Telephone call Talk to Attorney Erb; dictate letter sending her a praecipe to 0:10 208: withdraw/enter appearance to move that along 05/09/02 MLC Secretarial Transcribe dictation. 0:20 05/09/02 JP Work on file Review dictation 0:10 20,8: 05/15/02 JP Work on file Review her file 0:30 62,51 05/15/02 JP Work on file Continue to review the file; direct staff on how to organize our file 0:30 62,51 05/16/02 MLC Secretarial Transcribe dictation, 0:20 05/16/02 MLC Secretarial Transcrie dictation. 0:10 05/16/02 JP Work on file Review dictation 0:10 20,8: OS/20/02 MLC Secretarial Copy binder per JP instructions. 0:40 OS/20/02 JP Telephone call Talk to Kathy; she will have the information that Attorney Waltz has 0:30 62,51 requested with her, but we will not give it to him in advance: we decide it is more effective to go ahead with the hearing in light of Dr Walker's position on this and the pigheadedness of the other side OS/21/02 JP Trial Custody "hearing" that was totally a bust for Mike: Kathy gave in 2:20 35001 reasonabiy about the upcoming wedding, but otherwise Mike got nothing out of this trip to court exceptto annoy Dr. Walker OS/21/02 J P Mileage To and from hearing 7,31 OS/22/02 MLC Secretarial Transcribe dictation. 1:20 OS/22/02 JP Work on file Review dictation offile memo and letters I dictated in car on way back 0:20 41,6 yes terday 05/30/02 JP Work on file Move alon9 some stuff that came from Waltz 0:10 20,8 05/30/02 MLC Secretarial Transcribe dictation, 0:10 05/30/02 JP Work on file Review dictation 0:10 20,8 05/31/02 OM Postage 05 05/31/02 OM Photocopies 2,0' 07/17/02 JP Work on file Review letter from Attorney Waltz to Dr Walker: letter to Kathy about that 0:10 20,8 07/17/02 MLC Secretarial Transcribe dictation, 0:10 07/29/02 JP Telephone call Touch base with Kathy, who was responding to my letter 0:20 41,6 08/27/02 JP Telephone call Mike is taking the child on a 4-wheeler without a helmet; she wants 0:30 625' some relief, Mike has bragged about it as well as a neighbors telling her; she is not being hyper-sensitive about this 4/14/2004 JERRY A, PHILPOTT 1:19 PM Slip Detail from Report Designer Page SPECIAL SLIP LISTING FOR A CLIENT See first page for parameters Date Atty Activity Description of activity Time ValUE 08/27/02 JP Work on file Prepare special relief petition 0:20 41,6: 08/29/02 JP Work on file Finalize petition to file it today 0:20 416: 08/30/02 OM Work on file File and wait for judge to sign Spec Relief then have court admin 1:00 4501 schedule, etc, 08/30/02 OM Work on file Letter to AttyWaltz with Order and petition, fax then mail, cc client 0:40 3001 09/05/02 JP Telephone call Review response to our special relief petition, denying the acts, adm itting 0:30 6251 that helmets are a good idea and that he uses them, counterclaiming about speeding tickets Kathy didn't pay, and demanding attorney's fees; touch base with Kathy-- she paid the tickets; try to call Waltz to see ifhe would simply agree to an order that helmets be used without hearing; can't get him; do a fax instead 09/05/02 jp Telephone call Talk to Attorney Waltz: add an order 0:20 416' 09/05/02 jp Telephone call Talk to Attorney Waltz again; he's ok with the order; place call for the court 0:10 20,8: to get the hearing off the calendar 09/09/02 jp Telephone call Letter to Kathy will copy of AttorneyWaltZs letter seeking a hearing 0:10 208: 09/09/02 MLC Secretarial Transcribe dictation. 0:10 09/09/02 JP Work on file Review dictation 0:10 20,8: 09/11/02 JP Work on file Letterrelaying Judge Rehkamp's letter, with comments 0:10 20,8: 09/12/02 MLC Secretarial Transcribe dictation. 0:10 09/13/02 JP Work on file Review dictation 0:10 20,8: 09/23/02 JP Telephone call Discuss letter I fOlWarded to her; Dr, Waiker is recommending exactly 0:20 41,6' what the present order orders; after weighing the trade-off of "surprise" versus "heading off the hearing", do a letter to Judge Rehkamp in the hope he will head off the hearing or set up a call to accomplish that 09/25/02 MLC Secretarial Transcribe dictation. 0:10 09/30/02 JP Telephone call Make sure she knows tomorrow's hearing is still on (leave voice mail) 010 208 10/01/02 jp Trial Was supposed to be a custody hearing: devolved into a prolonged 1:50 27501 teleconference because Kathywasn'lthere; she appeared byphone and was very eloquent on her own behalf: judge left ilthat the two attorneys would submit proposed orders 10/01/02 jp Telephone call Coordinate with Kathy as to what went on after the court portion and 0:10 20,8: develop a strategy 10/01/02 jp Work on file Draft proposed order 0:50 104,1 10/02/02 jp Work on file Review Galen WaltZs letter/order: letter to Kathywith copy 0:20 416' 10/03/02 MLC Secretarial Transcribe dictation, 0:20 10/03/02 JP Work on file Review dictation 0:10 20,8 10/03/02 MLC Secretarial Transcribe dictation, 010 1 0/04/02 ML C Secretarial Transcribe dictation. 0:10 10/07/02 JP Conference Drop in about the order, which she wanted to challenge; I encourage 0:30 62,5' long-range planning instead 10/07/02 jp Telephone call About the holiday aspects of the order 0:10 20,8 11/13/02JP Work on file Review letter from Attorney Waltz: pass it on to Kathy 0:10 20,8 11/13/02 MLC Secretarial Transcribe dictation, 0:10 11/14/02 JP Work on file Review dictation of letter 0:10 208 11/20/02 JP Work on file Message from Kathy that she rejects the proposed settlement and will 0:10 20,8 respond with her own proposal 12/26/02 jp Telephone call Review faxfrom Attorney Waltz; try to call Kathy at 503-3249; not a good 0:10 20,8 number any more; do a letter instead 4/14/2004 JERRY A. PHILPOn 1:19 PM Slip Detail from Report Designer Page SPECIAL SLIP LISTING FOR A CLIENT See first page for parameters Date Atty Activity Description of activity Time ValuE 12/27/02 JP Telephone call Talk to her about letter; letter to Waltz about her "compensatory lime" 0:20 41,6~ 12/27/02 MLC Secretarial Transcribe dictation. 0:10 12/27/02 MLC Secretarial Transcribe dictation. 0:10 12/27/02 JP Work on file Review dictation 0:10 20,8: 03/17/03 JP THlephone call She is at "logger-heads" with her ex; he won't agree to a change in the 0:30 6251 custody situation even though she is being most conciliatory in an effort to work with him: develop a game plan 03/17/03 JP Work on file Draft petition to modify; dictate letter to Attorney Waltz 0:40 83,3: 03/18/03 JP Work on file 0:10 208: 03/21/03 DM Filing fees Client Exp Ck #10431 5,01 04/03/03 JP Work on file Review file prior to conference today 0:10 20,8: 04/03/03 JP Work on fiie Custody conference; a new temporary (but not very good) schedule was 3:40 4583: agreed upon; hearing to be scheduled 04/07/03 JP Work on file Review dictation of file memo from 4/3 0:10 20,8: 06/02/03 JP Telephone call Touch base about upcoming hearing 0:20 416' 06/03/03 JP Telephone call Call from Galen Waltz: place call for Kathy; leave voice mail 0:10 208: 06/03/03 JP Telephone call Kathy returned mycall and filled me in: leave a message for Attorney 020 416' Waltz on his voice mail 06/04/03 JP Trial Hearing; memo to file in car on way back 3:50 57501 06/04/03 JP Mileage To and from hearing 731 06/05/03 JP Work on file Review dictation (partial) 0:10 208: 06/06/03 JP Work on fiie Review Waltz's draft order 0:10 20,8: 06/06/03 JP Work on file Review draft order: fax back an objection: place call for Kathy 0:20 416' 06/06/03 J P Tl!lephone call Talk to Kathy 0:10 20,8: 06/11/03 JP Work on file Get a fax 011 to Galen with Kathy's proposed changes 030 62,51 06/16/03 JP Work on file Faxto Cathy what I got from Waltz 0:20 41,6' 06/16/03 JP Telephone call Kathy returned call: out of office all week: she will go with my judgment on 030 62,51 the language issues: read it more carefully and do a fax to Galen Waltz 07/31/03 JP Work on file Letter to Kathy about issues Attorney Waltz is raising 0:10 208 08/04/03 JP Work on file Review dictation 0:10 20,8: 08/08/03 JP Tl!lephone call Kathy will go to DRO today and faxme a copy of the form; she will not 010 20,8 agree to divorce until the economic issues are resolved; letter to Attorney Waltz about that 08/12/03 JP Work on file Review dictation 0:20 416 08/18/03 JP Telephone call Modify my earlier letter and get it 011 to Waitz, after calling Kathy to see 0:20 41,6 what happened to the proof from DRO 09/03/03 JP Telephone call Letter to Waltz about the support issues being resolved, so he will stop 0:10 208 writing nasty letters 10/03/03 JP Telephone call Touch base 0:20 41,6 10/07/03 JP Telephone call Touch base with Kathy: she does want him in pre-school; the driving is 0:20 416 every bit as bad as she had anticipated: also, she has more family in the area and would like to have Friday evenings when she wants to make a family trip; he has not agreed to that when she requests 10/07/03 JP Tl!lephone call Conference call: followed by call to Gaien and to Kathy: judge forgot 0:40 83,3 everything; seems inclined to force a compromise on the daycare iss ue, butwe could not craft a compromise without more information on dad's work schedule: Galen will talk to dad and get back to me; if Galen and I 4/14/2004 JERRY A PHILPOTT 1:20 PM Slip Detail from Report Designer Page SPECIAL SLIP LISTING FOR A CLIENT See first page for parameters Date Ally Activity Description of activity Time Value (in consultation wtih our clients) can come up with a compromise, then the judge will endorse it; if not, he will decided (which is what he said iast time) 10/16/03 JP Teiephone cali Wants action: dictate a letter to Waltz 0:10 2083 10/16103 JP Telephone call Return call to Galen Waitz: get put into voicemaii: finally connect; he won't 0:20 41 67 budge on the pre-school issue, aithough he says that his ciient will negotiate specific "swaps" with Kathy to allow her more fiexibilityfor family visits 10/27/03 JP Telephone call Try to return call; eventually connect; make sure a letter to the Judge is 0:20 41 67 going out 10/28/03 JP Work on file Review dictation of letter to judge 0:10 2083 11/04/03 JP Work on file Review fiie before conference call from the Judge 0;10 2083 11/04/03 JP Telephone cali Teleconference with Judge Rehkamp: he wants attorneys to submit 020 4167 orders and he will sign one; try to reach Kathy 11104/03 JP Legal papers Draft an order, but waiting for Kathy to call back with any thoughts she has 010 20,83 on it 11/05/03 JP Telephone cali Try to reach Kathy again: her voice mail box is full; do a letter 0:20 4167 11/06/03 JP Work on file Review dictation 0:10 2083 11/10/03 JP Telephone call Touch base with Kathy 0:10 20,83 11/12/03JP Telephone call Judge's chambers asked me to re-faxthe proposed order; do that; then 010 2083 return call to Kathy: she tells me that Michael now wants his girlfriend to babysit, not his mom; let Diane (Judge Rehkamp's secretary) know that 11112/03 OM Work on file Fixed TSlnew address & phone #, 0:10 750 11/18/03 JP Telephone cail Cail from Kathy 010 20,83 11/26/03 JP Telephone cail To Kathy; letter to Waltz demanding copy of Michael's work schedule 0:10 20,83 12/01/03 JP Work on file Review dictation 010 2083 12/03/03 OM Teiephone call Phone re jurisdiCtion, etc, 010 01/14/04 JP Work on file Letter to Kathy about custody order 0:10 20,83 02/02/04 JP Telephone call Needs to get PFA; on the way; husband banged on her car and 0:10 20,83 threatened her life 02/09/04 JP Work on file Forward Attorney Waltz's letter 0:10 20,83 02/09104 JP Telephone call Get a call from the legal aid attorney, Jim Carney: fax him the letter I 0:20 4167 received from Waltz 02/10/04 JP Telephone cail Jim Kearny gave me a "heads upt" on what is going on 020 4167 03/01104 JP Telephone call Who is in contempt? Both are biaming the other, Kathy was out of town 020 4167 aller prior notice: He showed up on her doorstep on her return and says he will not return Josh tonight Discuss the alternatives, 03/02/04 JP Telephone call Galen Waltz making arrangements to exchange the child; talk to Kathy; 0:20 41 67 she's ok with the plan: leave message for Galen on his voice maii 03/03/04 JP Work on file Deal with the question of certifying discovery as compiete in this case: 020 41 67 check Cumberland County local rules: prepare the papers; letter to Kathy about all this 03/03/04 JP Work on fiie Review dictation 0:10 20,83 03/09/04 JP Teiephone cail Try to return call: leave message 0:10 20,83 03109/04 JP Telephone call Kathy called back: go over our divorce strategy, check the file; letter to 0:30 62,50 Kathy about the next steps 03109/04 JP Telephone cail Feedback from Jim Kearny 0:10 20,83 03/10/04 JP Work on file Review dictation 0:10 20,83 4/14/2004 . JERRY A, PHILfSoTT 1:20 PM Slip Detail from Report Designer Page SPECIAL SLIP LISTING FOR A CLIENT See first page for parameters Date Ally Activity Description of activity Time Valut 03/22/04 JP Work on file Forward Jetter from Divorce Master 0:10 20,8 03/24/04 JP Telephone call Talk to Kathy, prepare claim for equitable distribution; fax her a verification 1:20 166,6 03/25/04 J P Work on file Package up the supplemental complaint with the information Kathy 0:10 20,8 phoned back 03/25/04 JP Work on file Review dictation 0:10 20,8 03/26/04 OM Filing fees Client Exp Ck #50028 to Cumberland Cty Prothonotary 600 03/30/04 JP Telephone call Place call for Kathy to coordinate on strategy after getting back the 0:10 20,8 additional counts and the master's directive 03/31/04 JP Work on file Review dictation 0:10 20,8 04/08/04 J P Telephone call Talk briefly about our strategy before the di\lOrce master; she thinks the 010 20,8 file of previous counsel has the information I am looking for in it 04/12/04 JP Work on file Review dictation of my file memo and start on pretrial memo 010 20,8 04/13/04 JP Work on file Dig out the facts buried in the file; call Kathy and go over all this; prepare 100 1250 pretriai statement and inventory 04/14/04 JP Work on file Complete pretrial statement; including a call to Kathy, who will fax me 1,00 1250 some additional materials in the morning Grand Total 50.30 5.593,7 II I! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE MICHAEL S. CROZIER Plaintiff No. 01-3300 vs. KATHY A. CROZIER Defendant PETITION FOR TRANSFER OF VENUE 1. The Petitioner is Michael S. Crozier. He is an adult individual who is currently residing at 127 Village Court, Lebanon, P A 17042 Lebanon County, Pennsylvania. Petitioner has resided at this address for one year. 2. The Respondent is Kathy A. Crozier. She is an adult individual who is currently residing at 1217 Milmar Road, Lancaster, PA 17601, Lancaster County, Pennsylvania. Respondent has resided at this address for approximately 4 months. 3. Neither party resides in Cumberland County. Further, there was no point in time when either party resided in Cumberland County. 4. Petitioner's former attorney filed the Complaint in Divorce under Section 3301(c) of the Divoree Code in Cumberland County. The action is docketed at 01-3300. 5. Respondent's Counsel, Sandra Edward Gray, does not oppose this Transfer Petition. WHEREFORE, Petitioner respectfully requests your Honorable Court enter an Order directing the above referenced action be transferred by the Prothonotary of Cumberland County, Pennsylvania to Lebanon County, Pennsylvania. Respectfully Submitted,_ -3/ ~~~- Date ~ '-;~en R. Waltz, Turo Law Offi es 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 TI VERIFICATIm~ I verify that the statements made in the foregoing Petition For Transfer of Venue are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 94904 relating to unsworn falsification to authorities. tJ/-;,.?f-/J-> Date t, TI CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition For Transfer of Venue upon Jerry Philpott, Esquire and Sandra Edwards Gray, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the Vrt. day of /J1'iv<"J. , 2005. from Carlisle, Pennsylvania, addressed as follows: Jerry A. Philpott, Esquire 227 North High Street Duneannon, PA 17020 Sandra Edwards Gray 128 N. Lime Street PO Box 1597 Lancaster, PA 17608-1597 TURO LAW OFFICES n c_ ~-, C.J ~':;~ , , .-~ ::s, ;;j I "" ," ,-~ ' ,,-0 :5 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLV ANIA CIVIL ACTION - DIVORCE MICHAEL S. CROZIER Plaintiff MAR 0 9 2005 fJf' No. 01-3300 vs. KATHY A. CROZIER Defendant ORDER OF COURT AND NOW, this If"~ dayof ,r;J. , 2005, this Court directs that the Prothonotary of Cumbcrland County transfer the case and all documents associated with the filc to Lebanon County, Pennsylvania. Costs shall bc paid by Michael S. Crozier. /--; THE COURT' J. ATTEST: Copies to: Lg~en R, Waltz, Esquirc Attorney for Plaintiff tJ€rry A. Philpott, Esquire Attorney for Defendant ;> ~ndra Edwards Gray, Esquire Attorney for Defendant ') "":1 Curtis R. Long Prothonotary <l&ffice of tbe l)rotbonotarp Q[umberlanlJ Q[ountp R nee K, Simpson put y Prolhonotary John E. Slike Solicitor . =- ""0 '" ::E. CT. :1 <JJ I-' Court of Common Pleas ::._ Cumberland County, Pennsylv nia cD '-'" " \' ( //;Zu: /~,;ij,j ';)'L('JJA..t,". {.I /v.bJ Docket No, O/':i$t)O .(1' J/' / /.! /5 c27i--! cl ;./ (y,i.(T'7~/( J '1 '7. ('1 ,~" / '7 <)1 '-../ Ir ( , 'I / .,/:/ o( i?C"--2~"?<?)<' ~"-[><<~iZ, ~ _l>{.t<::f ,~--, (---LI'.r;-y,-, :'-c/y; - ~'-:,i/}~~'1:.-;/ v"" '."t. "" #~~a5- .;Y1;(l f, 0 Please acknowledge receipt of this case by signing and dating this document. Please send this back to: PROTHONOTARY OFFICE ..- CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 Attn: Becky Record received: Date: (signature title) One Courthouse Square . Carlisle, Pennsylvania 17013 . (7 I 7) 240-6195 . Fax (7 I 7) 40-6573 MICHAEL S. CROZIER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYL VANIA VS. NO: 01-3300 KATHY A. CROZIER, Defendant IN DIVORCE ORIGINAL PRAECIPE COMES NOW, Jerry A. Philpott, Esquire, and wi KATHY A. CROZIER. ) ?!r '1 (oS- Date e A. Philpo , Ire upreme Court ID # 47624 227 North High Street, PO Box 116 Duncannon, P A 17020 COMES NOW, Sandra Edwards Gray, Esquire, and enters her appearance as counsel for KATHY A, CROZIER. ~\a~u Date ~~)tro _. Sandra Edwards Gray, ESqUi~~ PYFER REESE 128 North Lime Street, PO Box 1597 Lancaster, PA 17608-1597 j~~\a\'1\O -