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HomeMy WebLinkAbout02-0768SCOTT T. WOODRUFF, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA 62. -76-00 V. NO. CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION - LAW Defendant IN DIVORCE NOTTCF. You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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, PA 17013 (717) 249-3166 SAIDIS SHUFF, FLOWER & LINDSAY ATMRIEYS•AT•I.AW 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY Date:-11- OZ By: Jo na J. pecky, Esquire 6 West igh Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO.601 ?CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT I DIVORCE 1. Plaintiff is Scott T. Woodruff, who currently resides at 925 Shiremont Dr., Mechanicsburg, PA 17050, Cumberland County, Pennsylvania. 2. Defendant is Deborah A. Woodruff, who currently resides at 925 Shiremont Dr., Mechanicsburg, PA 17050, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 25, SAIDIS SHUFF, FLOWER & LINDSAY ATMRNEYS•AT•LAW 26 W. High Street Carlisle, PA 1981 in Binghamton, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. COUNT II EQUITABLE DISTRIBUTION 8. The allegations in Paragraphs one through seven, inclusive, are made a part hereof and incorporated herein by reference. 9. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. WHEREFORE, Plaintiff requests this Honorable Court to determine marital property and to order an equitable distribution thereof. Respectfully submitted, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Date: 0? - //"0Z SAIDIS, SHUFF, FLOWER & LINDSAY By: J na J. opecky, squire West gh Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 2 SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT I, Scott T. Woodruff, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject SAIDIS SHUFF, FLOWER & LINDSAY ATTORM?YS•ATH.AW 26 W. High Street Carlisle, PA to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated 0 -2- - ?L /VioV/ Scott T. Woodru , Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I L/y D Dated: q4yu-c it, Zoe-,- Scott T. Woodruff, Plaintiff SAIDIS SHUF$ FLOWER & LINDSAY ATrORIEYS•AT•I.AW 26 W. High Street Carlisle, PA ? ? a G C -Ikk r `,^ L c 0 c ?- rv ! C , l ? _1 "C -l SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-768 CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION - LAW 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 in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, 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 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, PA 17013 Telephone: (717) 249-3166 SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02-768 CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION - LAW Defendant : IN DIVORCE ANSWER AND COUNTERCLAIM COUNTI 1. Admitted. 2. Admitted. For purposes of clarification, Defendant's name is Deborah D. Woodruff. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of this averment, and therefore it is denied. Denied. It is denied that the marriage is irretrievably broken. To the contrary, the Defendant believes and therefore avers that with the aid of counseling the marriage could be saved. COUNT II - EQUITABLE DISTRIBUTION No responsive pleading is necessary. 9. Admitted. COUNTERCLAIM COUNTI ALIMONY 10. Paragraphs one through nine are incorporated herein by reference. 11. Defendant lacks sufficient property to provide for her reasonable needs. 12. Defendant is unable to sufficiently support herself through appropriate employment. 13. Plaintiff has sufficient income and assets to provide continuing and indefinite support for the Defendant. WHEREFORE, Defendant respectfully requests this Honorable Court compel the Plaintiff to pay alimony to the Defendant. COUNT II ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 14. Paragraphs one through thirteen are incorporated herein by reference. 15. By reason of the institution of the action to the above term and number, Defendant will be and has been put to considerable expense in the preparation of her case, in the employment of counsel, and the payment of costs. 16. Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 17. The Defendant's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 18. The Plaintiff has adequate earnings to provide support for the Defendant and to pay her counsel fees, costs and expenses. WHEREFORE, Defendant respectfully requests this Honorable Court compel the Plaintiff to pay alimony pendente lite as well as pay the Defendant's counsel fees, costs and expenses. Respectfully sub fitted, ziYj.e Es5922 oad Harri12 (717) 671-1500 ID No. 57911 Attorney for Defendant SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 02-768 CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of Defendant's Answer and Counterclaim was served upon Johnna J. Kopecky, Esquire, on January 26, 2002, by first class mail, postage pre-paid, addressed as follows: Johnna J. Kopecky, Esquire 26 West High Street Carlisle, PA 17013 L Date: I /,,? O Renee Dreisbach AFFIDAVIT I (4infation ertify that the aforegoing is true and correct to the best of my kno, d belief.I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: u h r? i ?. w? F,.? LLa 2, o U D SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 2002-768 CIVIL TERM DEBORAH A. WOODRUFF, IN DIVORCE Defendant/Petitioner DR# 31736 Pacses# 785104532 ORDER OF COURT AND NOW, this 24`s day of May, 2002, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on July 15, 2002 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11® (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Mail copies on Petitioner 5-24-02 to: < Respondent Kristen Reinhold, Esquire Johnny Kopecky, Esquire Date of Order: May 24, 2002 BY THE COURT, George E. Hoffer, President Judge R J. hadday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 /-) ? ? C-) : (V Y1 f;'• fn -d L ._ U) C- y r Z In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DEBORAH D. WOODRUFF ) Docket Number 02-768 CIVIL Plaintiff ) VS. ) PACSES Case Number 785104532 SCOTT T. WOODRUFF ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 25TH DAY OF OCTOBER, 2002 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other ALIMONY PENDENTE LITE filed on MAY 5, 2002 in the above captioned matter is dismissed without prejudice due to: AN ORDER OF SPOUSAL SUPPORT BEING ENTERED UNDER PACSES C#193104495 AND DOCKETED AT NO.400 S 2002 Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: JUDGE Form OE-506 Service Type M Worker m 21005 ;, ,r C - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT T. WOODRUFF, Plaintiff V. DEBORAH D. WOODRUFF, Defendant NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that Deborah D. Woodruff, Defendant in the above-captioned action, [X] prior to the entry of a Final Decree in Divorce or [ ] after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Deborah Donnelly, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: D3 Deborah D. Woodruff TO BE Deborah A. 1 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF DAUPHIN ) SS: On the 26`h day of AUGUST, 2003, before me, a Notary Public, personally appeared DEBORAH D. WOODRUFF, to be hereafter known as DEBORAH A. DONNELLY, known to me to be the person whose name is subscribed to the within document, acknowledged that she executed the same for the purpose contained therein. EFBRII M. SNNII NOTARY PUELIC W1Y Of NARPoSBURQ pAUpIUN COUMIY MY COMMI SI N PI S fi T,q TORS IN WITNESS WHEREOF, I ve hereunto set my hand and official seal blic . , _ No v E;! FT! DL -c t :_' :?t77 -f SCOTT T. WOODRUFF, Petitioner V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-768 Civil Term Civil Action - Law In Divorce MOTION FOR APPOINTMENT OF MASTER Scott T. Woodruff, Petitioner, moves the court to appoint a master with respect to the following claims: (X) Divorce ( ) Annulment (X) Alimony ( ) Alimony Pendeme Lite and in support of the motion states: (X) Distribution of Property ( ) Support (X) Counsel Fees (X) Costs and Expenses (Equitable Distribution) (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant, Deborah A. Woodruff appeared in the action and is represented by counsel, Donald T. Kissinger, Esquire SAIDIS SHUFF, FLOWER & LINDSAY A77ORNEYS•AT•IAW 26 W. High Street Carlisle, PA (3) The statutory ground(s) for divorce is/are .3301(c) and/or (d) (4) Delete the inapplicable paragraph(s). (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action complex issues of law or fact. (6) The hearing is expected to take. SAIDIS SHUFF, FLOWER & LINDSAY ATrORMYS-AT-LAW 26 W. High street Carlisle, PA (7) Additional information, if any, relevant to the motion: Date: 1. Carol J. Lin #ay, M( Attorney ID 44193 26 W. High Carlisle, PA 17013 Phone: 717,243.6222 Fax: 717.243.6510 SCOTT T. WOODRUFF, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vii. : No. 02-768 Civil Term DEBORAH A. WOODRUFF, Civil Action -Law Defendant In Divorce CERTIFICATE OF SERVICE AND now, this 1 day of 2005, I, Sharon A. Morrell, Paralegal, of the law firm of SAIDIS, SNUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Motion for Appointment of Master this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Donald T. Kissinger, Esquire HOWEfT, KISSINGER & CONLEY, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By. .r + iz_? OL )WL- R-V Sharon A. Morrell 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS HUFF, FLOWER & LINDSAY ATFORIEYS•ATNAW 26 W. High Street Carlisle, PA U - ty ? rt a Co w SCOTT T. WOODRUFF, Petitioner vi. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-768 eivil Term Civil Action - Law In Divorce ORDER APPOINTING MASTER loy? AND NOW, this . r I day of 2005 SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS•AT•LAW ZG W. High Street Carlisle, PA ?11u Esquire, is appointed master with respect to the following claims: By the Court, Q> Y Q I ?? G °f V V V SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-768 Civil Term Civil Action - Law In Divorce PETITION FOR VOCATIONAL. EVALUATION AND NOW, comes Scott T. Woodruff, by and through his counsel, Saidis, Shuff, Flower & Lindsay and Petitions This Honorable Court as follows: 1. The parties hereto are husband and wife having been joined in marriage on April 25, 1981 and having separated on or about May 12, 2002. 2. Petitioner has filed a request for the appointment of a Master. 3. Respondent seeks alimony. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 4. Although Respondent graduated from law school in May, 2004, she remains unemployed and avers that she is virtually unemployable. To that end, she has produced a report from a psychologist. 5. Petitioner seeks a vocational evaluation by a psychologist and vocational expert to include an interview with Respondent and a review of respondent's expert's findings. 6. On or about April 21, 2005, Petitioner retained James Ryan, Ed.D. to perform a vocational evaluation of Respondent. Dr. Ryan was willing to perform the evaluation in the office of Respondent's counsel, and had set up an appointment for that purpose in the first half of June, 2005. 7. The scheduled evaluation was canceled when Respondent averred she had had an accident affecting her ability to walk. 8. By telephone and, ultimately, by a letter of July 11, 2005, counsel for Petitioner requested the rescheduling of the vocational evaluation. 9. Respondent has not provided a response to any request to reschedule the evaluation. 10. On information and belief, Petitioner avers that Respondent is refusing to engage in the evaluation. 11. The Master's Hearing is delayed until this evaluation can be performed. WHEREFORE, Petitioner prays this Honorable Court enter a Rule upon Respondent to show cause why the Respondent should not submit herself immediately to an evaluation by Dr. Ryan. Respectfully submitted, SAIDI cS Uj IF, FLOWER & LINDSAY Date: (r?l? By: / ` Caro say, Esq 're Atty. ld # 693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S. §4904, relating to unsworn falsification to authorities. 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE AND NOW, this - day of August, 2005, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Petition for Vocational Evaluation this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Donald T. Kissinger, Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P. O. Box 810 Harrisburg, PA 17,108 SAIDIS. SHUFF. FLOWER & LINDSAY By: Carol J. Lindsay 'E; ID# 44693/ 26 West 1- tree Carlisle, PA 17013 (717)243.6222 SAIDIS >HUFF, FLOWER & LINDSAY ATTOPMYS•AT•LAW 26 W. High Street Carlisle, PA N n d ? A n ?1 - C P fi -- r__ c' ( o m : ?'?? ` -? z. ?= ., ? '? ? c? ?m ? f __ c' ? ? w .^ _- ..? ! A RECEIVED AUG 15 200K SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. : No. 02-768 Civil Term DEBORAH A. WOODRUFF, Civil Action -Law Defendant In Divorce ORDER OF COURT AND NOW, this 22 r day of .?t.F., 2005, upon consideration of the within Petition, a Rule is issued upon the Respondent to show cause why the relief requested should not be granted. RULE RETURNABLE ZO DAYS FROM THE DATE OF SERVICE. BY THE COURT: J. SAIDIS SHUFF, FLOWER & LINDSAY ATMMYS-ATYUw 26 W. High Street Carlisle, PA y WD F1LECl-t?'rFiCc OF THE PRO T"ONOT4BY 2005 AUG 22 PM 4, 02 SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-768 Civil Term Civil Action - Law In Divorce CERTIFICATE OF SERVICE AND NOW, this 29th day of August, 2005, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, hereby certify that I served the within Order of the Court this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Donald T. Kissinger, Esquire Howett, Kissinger & Conley, P.C. 130 Walnut Street P. O. Box 810 Harrisburg, PA 17108 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant/Petitioner __ /1-) - SAIDIS CHUFF FLOWER & LINDSAY By: Carol J-Li say, Es, ID# 4409V 26 We igh Street Carlisle, PA 17013 (717) 243-6222 26 W. High Street Carlisle, PA RECEIVED AUG 15 2005 SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. : No. 02-768 Civil Term DEBORAH A. WOODRUFF, Civil Action - Law Defendant In Divorce O R OF C URT AND NOW, this day of 2005, upon consideration of the within Petition, a Rule is issued up) the I?espondent to show cause why the relief requested should not be granted. RULE RETURNABLE I xa DAYS FROM THE DATE OF SERVICE. SAIDIS SHUFF, FLOWER & LINDSAY A7TORMYS-AT•LAW 26 W. High Street CarHele, PA TRUE CORy In Testimony wherco and yI seal of said/C FR€">M RECORD 1 lr, ???yn cwt MY hand ?r1 aivrlisle, Pa, BY THE COURT: f.'? ? "? » ?? T, y. C.., f?i ?:... G') -?) r L.aS r ?'l 1-., `*? -Tl T : ? , ?' ? , 'E ;1'ta ? ? ,' . ? t . l ? i '? Lj] SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. : No. 02-768 Civil Term DEBORAH A. WOODRUFF, Civil Action -Law Defendant In Divorce CERTIFICATE OF SERVICE AND now, this 31" day of August, 2005, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, hereby certify that I served the within Response to Request for Production of Documents Re: Business Assets this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Donald T. Kissinger, Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: d Carol J. Linds y, squire ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATTORMYS•AT•I.AW 26 W. High Street Carlisle, PA SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-768 Civil Term Civil Action - Law In Divorce PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS RE: BUSINESS ASSETS To: Donald T. Kissinger, Esquire Howett, Kissinger & Conley, P.C. 130 Walnut Street P.O.Box 810 Harrisburg, PA 17108 AND NOW, comes the Plaintiff, Scott T. Woodruff, by and through his attorneys, Saidis, Shuff, Flower & Lindsay, and respectfully answers the Request for Production of Documents Re: Business Assets as follows: 1. Attached hereto is the 2004 Federal Income Tax Return for Central PA Rentals, Inc. Attached also are end-of-the-year inventories for 2002, 2003, and 2004. Attached also is a list of assets as of June 30, 2005. 2. All depreciation schedules for Central PA Rentals, Inc. are attached to the tax returns. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff SAIDIS SHUF$ FLOWER & LINDSAY ATrORNEYPAT•LAW 26 W. High Street Carlisle, PA Date: V 5 26 West High Street Carlisle, PA 17013 (717) 243-6222 c, FTI :i} 4 T t ? -J n SCOTT T. WOODRUFF, Plaintiff VS. DEBORAH A. WOODRUFF, Defendant TO: Carol J. Lindsay THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 768 CIVIL IN DIVORCE , Attorney for Plaintiff Donald T. Kissinger Attorney for Defendant DATE: Tuesday, July 19, 2005 CERTIFICATION i ] 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. Mr. Woodruff is the owner of a business. On October 26, 2005, two business valuators, counsel and an accountant are meeting to see if we can come to terms as to the value of that business. In addition, a vocational evaluation has been performed of Mrs. Woodruff and although we have a preliminary letter, the full report has not been delivered. I expect we will have that report by November 1, 2005. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. See (a) above. 'DATE TE COUNSEL FOR LA NTIFF COUNSEL FOR DE NDANT ( ) 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. JUL 19 2009 r .? J f.i': IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT T. WOODRUFF, ) Plaintiff/Respondent ) V. ) DEBORAH D. WOODRUFF, ) Defendant/Petitioner ) NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PETITION FOR INTERIM ATTORNEYS FEES AND EXPENSES PURSUANTTO 23 PA C.S.A. §3702 AND/OR PARTIAL ADVANCED DISTRIBUTION PURSUANT TO 23 Pa.C.S.A. §3502(f) AND NOW, comes Defendant, Deborah D. Woodruff, by and through her counsel, Hewett, Kissinger, Conley & Hoist, P.C., who files this Petition for Interim Attorneys Fees and Expenses Pursuant to 23 Pa.C.S.A. §3702 and/or Partial Advanced Distribution Pursuant to 23 Pa.C.S.A. §3502(f) and in support thereof states as follows: Petitioner, Deborah D. Woodruff ("Wife"), the Defendant in the above- referenced case. Respondent, Scott T. Woodruff ("Husband"), the Plaintiff in the above- referenced case. The parties are married but separated. 4. Husband filed the above-captioned divorce action. Wife has already incurred significant attorneys fees in the divorce action and anticipates incurring substantial attorneys fees and expert fees as the matter proceeds. Wife cannot meet her reasonable attorneys fees, costs and expenses necessary to prosecute and defend this proceeding from her income or her separate assets without incurring adverse tax consequences. Husband is well able to meet his reasonable attorneys fees and costs from his income which is generated by the marital business. 8. 23 Pa.C.S.A. §3702 provides, inter alia, as follows: In proper cases, upon petition, the court may allow a spouse reasonable alimony pendente lite, spousal support and reasonable counsel fees and expenses. Reasonable counsel fees and expenses may be allowed, pendente lite (emphasis added) 9. Moreover, 23 Pa.C.S.A. §3502(f) provides as follows: Partial Distribution.-- The court, upon request of either party, may at any stage of the proceedings enter an order providing for an interim partial distribution or assignment of marital property. 10. Wife will be prejudiced if this Court does not, after hearing, enter an order granting her reasonable attorneys fees and costs pendente lite or a partial distribution of marital assets or a combination of both in that she will not be on par with Husband in defending and prosecuting the pending action. WHEREFORE, Defendant respectfully requests this Honorable Court schedule a hearing and, following the hearing to enter an order directing that Plaintiff pay Defendant's reasonable counsel fees and costs pendente lite and/or directing a partial distribution of marital property or directing a combination of both so that Defendant is provided with attorneys fees/advance of no less than Twenty Thousand Dollars ($20,000.00). Respectfully submitted, Date: Donald T. Kissinger, Esquir HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant/Petitioner, Deborah D. Woodruff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT T. WOODRUFF, Plaintiff/Respondent ) NO. 02-768 CIVIL TERM V. ) DEBORAH D. WOODRUFF, ) CIVIL ACTION - LAW Defendant/Petitioner ) IN DIVORCE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Deborah D. Woodruff, Defendant in the above-captioned action, hereby certify that a true and correct copy of the foregoing Petition for Interim Attorneys Fees and Expenses Pursuant to 23 Pa.C.S.A. §3702 and/or Partial Advanced Distribution Pursuant to 23 Pa.C.S.A. §35020 was served upon Carol J. Lindsay, Esquire, counsel for Scott T. Woodruff, Plaintiff, by facsimile and by depositing same in the United States mail, first class, on January 26, 2006, addressed as follows: Carol J. Lindsay, Esquire SAIDIS, SNUFF, FLOWER & LINDSAY" 26 West High Street Carlisle, PA 17013 o? Date: Donald T. Kissinger, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant/Petitioner, Deborah D. Woodruff '^J it C7 ?r ? L - )? t' • .. h) < CJ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT T. WOODRUFF, ) Plaintiff/Respondent ) V. ) DEBORAH D. WOODRUFF, ) Defendant/Petitioner ) NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this .04day of e '?r 12006, upon consideration of the Petition for Interim Attorneys Fees and Expenses Pursuant to 23 Pa.C.S.A. §3702 and/or Partial Advanced Distribution Pursuant to 23 Pa.C.S.A. §3502(f) the court hereby schedules a hearing to address said Petition to occur on 2006, at 14'.m0in' ourtroom #Yof the Cumberland County Courthouse. BY THE COURT: /f /'9? J. ?? ?? ?? ',u ,. ,a, t ?. ? ?uut ,, ,t? ? ? ? < SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA V. : NO. 02-768 CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOA1, this -?-Zno( dayof V? ?iLcr?2? , 2006, upon cunsideration of SAIDI[S, FLOWER & LINDSAY nrmRrvEtS.u- 26 West High Street Cadid, PA the request of counsel for Respondent, it appearing that Petitioner's counsel does not object, the hearing of March 3, 2006 is continued to the a7-4 day of 2006 at y 36 o'clock A-M in Courtroom Number 4 of the Cumberland County Courthouse in Carlisle, Pennsylvania. J? BY THE COURT C:' .'! 7 ii a SCOTT T. WOODRUFF Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-768 - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE INVENTORY AND APPRAISEMENT OF PLAINTIFF, SCOTT T. WOODRUFF Plaintiff, Scott T. Woodruff, files this inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff, Scott T. Woodruff, verifies that the statements made in this inventory are true and correct. Defendant further understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Scott T. Woodruff, Plaintiff SAIDIS, FLOWER & LINDSAY ATRIRNM6,VT.WW 26 West High Street Cadkle. PA ASSETS OF PARTIES SAIDIS, FLOWER &i LINDSAY MT-UW 26 Wes[ High Sae.[ Cadid, PA Plaintiff, Scott T. Woodruff, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. M 0) (v ) ( ( ( ( 1. Real property 2. Vehicles 3. Stocks, bonds, securities and options 4. Certificates of deposit 5. Checking accounts, cash 6. Savings accounts, money markets and savings certificates 7. Contents of safe deposit boxes 8. Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyrights, invention, royalties 14. Personal property outside the home 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) 16. Employment termination benefits-severance pay, worker's compensation claim/award 17. Profit sharing plan 18. Pension plan (indicate employee contribution and date plan vests) 19. Retirement plans, Individual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and unmatured) 22. Military/V.A, benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list of distribution of such assets is in dispute) 26. Other , T LIABILITIES OF PARTIES SAIDIS, FLOWER & LINDSAY ATRIM'E At•IAW 26 West High Street Czdid, PA Plaintiff, Scott T. Woodruff, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED (L/? 1. Mortgages ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other secured liabilities UNSECUf (?) 5. ( ) 6. ( ) 7- ( ) 8. (?) 9. ZED Credit Card balances Purchases Loan purchases Notes payable Other unsecured liabilities CONTINGENT OR DEFERRED ( ) 10. Contract or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other contingent or deferred liabilities I I ' O' ' '? O I ? I ? B p i I O I ? I I ? I Y R ? I I : IO? I I ? jCj I I I II ? O ? _I- I I Z p., I _ I I I I ? I I I O j ?? ?'I I I ? I I I? I I I I, I ?I N N, ? ra I Z - I rn I G N N OiN O O cc [ 'NO 0101 X10 N NI C O 7 r?{ Y r R ?O jN IO O lO r p OIOIN ?N?NIO I?I ?I?pIN IO M N N? NiM I IM•"'-+ I ?I ?" ? I? ?N N Il0 Cpl y I` - I . I Cl CI I ifn Q I :O? 11 Ir I'" I ? I Ipld .?y tv'i I I? I NIco Ian ool?l I r O I ?plor? I Iol? ? O ?pI OD ?, dO' MI I00 "T i/ni? I I?Id II rn I oo I ?? O O? v' IOIN ??I I I I, ? ? i I I I I i ? II I I I J I I I •? •?? I ? I I I ? I ? I I I I I I 1 j I I I ? 1 I ? I I I I I I I - dl Q ?I I l l ? II I ?I I, ? I ?I I ?: ?I bl I b o ,.? I I ? I,QIwI ?IQ I oI ? ?I?Ix ? y '" o .? 13 I r o x col Ix3 l o? ? ?-. `"'p I ti 171 U I b01 x-11 U .? g? .r- ?IQ yI? ?I I E I o NI ? I?' c??,? m IUII?!?I' ?I>x O 'yµ ? .• I ?????? 1W? U R OI p ! y v? y NI?, ? c?C T, ? U,.Q b ? b •?I ' ???I'?I?C +?IP?I,? ,?I I? I N y '?r.'i d ? Q f??H,?I? I ^I LEI I ?I?j ?`? ?I UI it •y, p;, dIP, ? r P ?I?' o ?I ??? ? cj ICS ?- Gi _ 1 Z p?? Z_ ?-?- I I I I????I?IrnI-- I ? 01 I, I ?!I ICI ? ' II II 7 I I III ? I NI ?I ? 6I N N CJ ?I: N.,•? ca '' R W ? I [ o 0 ?oMO? ??? ?° ?M 4 0 M rs?_ I ? y I . m c ! I ?`'? j?° ! I i !? ? of l a? .t o O o I, ^myp? Vlw?a? +?? ? C r SCOTT T. WOODRUFF Plaintiff V. DEBORAH A. WOODRUFF Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-768 -CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PLAINTIFF SCOTT T. WOODRUFF'S INCOME AND EXPENSE STATEMENT SAIDIS, FLOWER & LINDSAY ATIORNkVSAT•IAW 26 Wes, High Smre , Carlisle, PA e CASE: Woodruff v. Woodruff CIVIL ACTION - DIVORCE NO. 02-768 CIVIL TERM Date: 11110105 INCOME, AND EXPENSE STATEMEN'C THIS FORM MUST BE FILLED OUT INCOME S IA'I EMEN't OP'. SCOTFT. WOODRUFF I VERIFY TI IAT TI -IL SIATEMEN'l S MADE IN I I IIS INCOME AND EXPENSE STATEMENT ARE TRUE AND CORRF.C I. I UNDERSTAND TI IAT FALSE STATEMENTS HEREIN ARE SUBJECT F0 THE CRIMINAL PENALTIES OFIB PAC.S. Section 4904 KI.I.A l INO I0 UNSWORN FALSIPICAI ION TO AUTHORITY -? Kate Scott T INCOME: EMPLOYER ADDRESS: TYPE OP WORK Payroll No. Defendant Self-employed 665 Independence Avenue Suite H, Mechanicsburg, PA 17055 Owner Gross Pay Annually: Pay Period: Biweekly $2,800.00 ITEMIZED PAYROLL DEDUCTIONS FEDERAL WITHHOLDING $ 271.90 SOCIALSECURITY $ 214.20 LOCAL WAGETAX $ 47.60 ST-All'. INCOMI''IAX $ 85.96 RETIREMENT SAVINGS BONDS EMG. SER. TAX LIFE INSURANCE HEALTH INSURANCE OTIIER DEDUCTIONS-Domestic Relations $ 1,153.85 PROCESSING FEES $ 1.00 OPTI-WAGE TAX-U.C. $ 2.52 TOTALS Net Pay per Period $1,022.97 Form IN -008 Service Type Pagel of 5 Worker ID Income and Expense Statement PACSES Case No. Fill in Appropriate Column Other Income WEEK MONTH YEAR Interest Dkidends Pension Annuitti Social Security Rents Royalties Expense Account Gifts Unem IoymentCom . Workmen's Comp. IRS Retuml Other Income Other W I AL INCOME $0.00 $0.00 Expenses (Fill in Appropriate Column) WEEK MONTH YEAR HOME Mortgage/Rent $ 1,200.00 Maintenance $ 100.00 Untilities Blu,tric $ 175.00 Clas Oil Telephony $ 50.00 Water $ 25.00 Sewer . $ 1200 Form IN -008 Service Type Page 2 of 5 Worker ID Income and Expense Statement PACSES Case No: EXPENSES (Fill in Appropriate Column) continued WEEK MONTH YEAR EMPLOYMENT Public Transportation Lunch $40.00 TAXES Real Estate Personal Property Income- Faxon pension INSURANCE Homeowners $ 150.00 Automobile $ 1,400.00 Lite $ 2,800.00 Accident I-lealth $ 610.00 Other AL TOYIOBILE Payments $ 300.00 Fuel $ 100.00 Repairs $2,000.00 MEDICAL Doctor $ 150.00 Dentist $350.00 Orthodontist Form IN -008 Service Type Page 3 of 5 Worker ID r Income and Expense Statement PACSES Case No. EXPENSES (Fill In Appropriate Column) continued WEEK MONTH YEAR Hospital Medicine $ 120.00 Special Needs: $400.00 (glasses, braces, orthopedic devices) EDUCATION Private School Parochial School College Religious PERSONAL Clothing $ 200.00 food $ 300.00 Barber/Ilairdresser $ 10.00 Credit payments: $ 500.00 Crcdit Card Char c.Accomu Memberships LOANS Credit Union MISCELLANEOUS iloaschoid lid Child Care Paper/hooks/magazines Entertainment $ 250.00 Pav Tv $ 85.00 Vacation $3,000.00 Form IN -008 Service Type Page 4 of 5 Worker ID Income and Expense Statement PACSES Case No. EXPENSES (Fill in Appropriate Column continued WEEK MONTH YEAR Gills $500.00 Leaal Fees $ 1,000.00 Charitable Contributions $2,000.00 Other: Child Support Alimony Payments OTHER: Internet $ 80.00 TO CAL EXPENSES: $40.00 $ 5,267.00 $12,600.00 Form IN -008 Service Type Page 5 of 5 Worker ID SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed February 12, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: Scott T. Woodruff PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERG 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAMIS, FLOWER & LINDSAY ATMZWM?AMAW 26 West High Street Carlisle, PA 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: Scott T. Woodruff ~ °n c ' ? ?.; , ;; ?, ?.?- ?, ,- _ ? ,? ?, _.,1 ?.__f i •' i , .y ' 1 ? ( am h SCOTT T. WOODRUFF, Plaintiff VS. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 768 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this o5?{ day of , 2007, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated April 11, 2007, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, ? G 11 1?s Edgar B. Bayley, P.J. cc: X rol J. Lindsay Attorney for Plaintiff Znald T. Kissinger Attorney for Defendant a u CJ _ (\j - 4 N MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN DEBORAH D. WOODRUFF AND SCOTT T. WOODRUFF Donald T. Kissinger, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Deborah D. Woodruff Carol J. Lindsay, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Counsel for Scott T. Woodruff MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this _L1 ?aay of _06 , 2007, by and between DEBORAH D. WOODRUFF, of Cumberland County, Pennsylvania, and SCOTT T. WOODRUFF, of York County, Pennsylvania; WITNESSETH: WHEREAS, Scott T. Woodruff (hereinafter referred to as "Husband") was born on April 26, 1953 and currently resides at 130 Red Haven Road, New Cumberland, York County, Pennsylvania; WHEREAS, Deborah D. Woodruff (hereinafter referred to as "Wife") was born on May 9, 1951 and currently resides at 1459 Hillcrest Court, Apt. 506, Camp Hill, Cumberland County, Pennsylvania; WHEREAS, the parties hereto are husband and wife, having been lawfully married on April 25,1981; WHEREAS, the parties have lived separate and apart since on or about May 12, 2002; WHEREAS, three children were born of the marriage between the parties, namely, Michael, born August 22, 1982; and Alexa and Nicholas, both born on October 5, 1987, all of whom are emancipated; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of these premises, and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. Each party acknowledges he or she has had the opportunity to receive independent legal advice from counsel of his or her selection (Donald T. Kissinger, Esquire for Wife and Carol J. Lindsay, Esquire for Husband). Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable; it is being entered into freely and voluntarily; the execution of this Agreement is not the result of any duress or undue influence; that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs of litigation. 2 2. DISCLOSURE OF ASSETS. Each of the parties warrant and represent that he/she has given the other party a full, complete and accurate disclosure of all assets, of any nature, whether or not the assets were held jointly or in one name alone. Each party confirms that he/she is relying upon the substantial accuracy of the asset disclosures provided in this action as an inducement to the execution of this Agreement. Each party has made whatever discovery he or she wished and was fully satisfied with the discovery which he or she received. In the event any material marital asset is determined, after execution of this Agreement, to have been omitted by either party, the non-disclosing party shall pay to the other party fifty percent (50%) of the value of the omitted marital asset. 3. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and, thus, any divorce action with respect to these parties shall be limited to a claim for no-fault divorce only. The parties acknowledge that, on February 12, 2002, Husband initiated a divorce action under, inter alia, the no-fault provisions of the Divorce Code by filing a Complaint docketed at action number 02-768 in the Court of Common Pleas of Cumberland County, Pennsylvania. The parties further acknowledge the ninety (90) day waiting period provided for under section 3301(c) of the Divorce Code has expired. Therefore, contemporaneously with the execution of this Agreement, each party will sign an Affidavit of Consent to Divorce and Waiver of Notice of Intention to Request Entry of Divorce Decree and deliver same to counsel for Husband who shall promptly submit said affidavits and waivers to the Court along with all other documents necessary to precipitate the prompt entry of a divorce decree. 5. EQUITABLE DISTRIBUTION. (a) Marital Residence Sales Proceeds. The parties acknowledge that at the time of separation they were the titled owners, as tenants by the entireties, of that certain house and lot and all improvements thereupon situated at 925 Shiremont Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. The parties further acknowledge that on or about June 17, 2005, the Marital Residence was sold and, after each party received advanced distributions of $36,271.39 from said proceeds, that the remainder of the sales proceeds have been placed into an attorneys' escrow account at Commerce Bank statement savings account number 626790224 which has an approximate balance as of March 20, 2007 of $112,693.04. The parties agree as follows with respect to the Marital Residence Proceeds: (1) Advance Distributions. Each party shall retain as his/her sole and separate property, free and clear of any and all right, title, claim and/or interest of the other, the advanced distribution from the Marital Residence Sales Proceeds each has received to date; and 4 (2) Remaining Proceeds. The remaining proceeds contained in the Commerce Bank statement savings account number 626790224 shall, as soon as practicable after execution of this Agreement, be withdrawn from said account and transferred in its entirety to Wife who shall thereafter be the sole and exclusive owner of said proceeds, free and clear of any right, title, claim and/or interest of Husband. (b) Motor Vehicles. (1) Husband agrees Wife shall retain possession of and receive as her sole and separate property any and all automobiles currently titled her name, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title, claim or interest of Husband. Wife shall indemnify and hold Husband and his property harmless from any and all liability, cost or expense, including actual attorneys' fees incurred in connection with any vehicles belonging to Wife by virtue of this subparagraph. (2) Wife agrees Husband shall retain possession of and receive as his sole and separate property any and all automobiles currently titled his name, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title, claim or interest of Wife. Husband shall indemnify and hold Wife and her property harmless from any and all liability, cost or expense, including actual attorney's fees, incurred in connection with any vehicles belonging to Husband by virtue of this subparagraph. (c) Central PA Rentals. Inc./Event Central. The parties acknowledge that at the time of separation they owned a ninety percent (90%) interest in Central 5 PA Rentals, Inc., doing business as Event Central (hereinafter referred to as "Event Central"), although said interest was titled to Husband alone. The parties agree that Husband shall receive the entire ninety percent (90%) interest in Event Central as his sole and separate property, free and clear of any right, title, claim and/or interest of Wife. Husband hereby represents and warrants that there is no debt associated with Event Central for which Wife, and/or her estate, is liable. However, in any event, Husband shall indemnify and hold Wife and her property harmless from any and all liability, cost or expense, including actual attorneys' fees, incurred in connection with Event Central. (d) Financial Accounts. The parties agree that Husband shall receive any and all financial accounts titled in his name alone, as his sole and separate property,ffree and clear of any right, title, claim and/or interest of Wife, including, but not limited to, the following: (i) Community Bank Checking Account; and (ii) Mellon Bank Checking Account. The parties further agree that Wife shall receive as her sole and separate property any and all financial accounts in her name, free and clear of any right, title, claim and/or interest of Husband, including, but not limited to, the following: (i) All First Checking Account; (ii) BSB Bank and Trust Account; and (iii) Merrill Lynch CMA Account. The parties further acknowledge that any and all joint accounts in existence as of the date of their marriage have been distributed to their mutual satisfaction. 6 (e) Life Insurance. Except as provided for herein, the parties acknowledge and agree each shall retain as his or her sole and separate property, any and all life insurance policies in his or her sole name, free of any right, title and interest of the other party. Notwithstanding the above, Wife shall be entitled, at her option, to obtain a life insurance policy, which will be owned by Wife but insure the life of Husband for up to a $400,000.00 death benefit. Wife shall be the sole and exclusive owner of this policy, free and clear of any right, title, claim and/or interest of Husband. Wife shall be solely and exclusively responsible for payment of any premium associated with said policy. However, Husband shall cooperate, in any way necessary with Wife in obtaining said life insurance policy, including, but not limited to, submitting to any and all physical examinations, within twenty (20) days of notice of need for same, providing any and all requested medical/psychological records or authorization for release of said records requested by the insurance company within seven (7) days, and, he shall fully and completely provide the information in his possession and signatures necessary to obtain said policy within seven (7) days of being requested to do so. Husband represents that he is unaware of any medical condition which would render him uninsurable. (f) Pension and Retirement Benefits. Wife and Husband each hereby specifically releases and waives any and all right, title, claim or interest that he or she may have in and to any and all retirement benefits (including but not limited to pension or profit sharing benefits, deferred compensation plans, 401(k) plans, employee savings and thrift plans, individual retirement accounts or other similar benefits) of the other party, specifically to include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties 7 agree that they shall execute any documents pursuant to the Retirement Equity Act or any similar act that may be required from time to time to accomplish the purposes of this subparagraph. Specifically, the parties acknowledge and agree that Husband shall retain as his sole and separate property, free and clear of any right, title, claim and/or interest of Wife, his Merrill Lynch Individual Retirement Account and that Wife shall receive as her sole and separate property, free and clear of any right, title, claim and/or interest of Husband, her Merrill Lynch Individual Retirement Account. (g) Furnishings and Personalty. (1) The parties agree that they have divided by agreement between themselves all furnishings and personalty, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. (2) Except as otherwise set forth herein, Husband shall retain, as his sole and separate property, free of any and all right, title, claim or interest of Wife, all of the personalty and furnishings currently in his possession. (3) Except as otherwise set forth herein, Wife shall retain, as her sole and separate property, free of any and all right, title, claim or interest of Husband, all of the personalty and furnishings currently in her possession. (h) Miscellaneous Property. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. 8 (i) Property to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. (j) Property to Husband. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property,_and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. (k) Liability not Listed. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all debts, obligations and liabilities. 9 (1) Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorneys' fees incurred by Wife in connection therewith. (m) Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to costs of court and actual attorney's fees incurred by Husband in connection therewith. (n) Warranty as to Future Obligations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach hereof. 10 6. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. The parties acknowledge that there is currently a support order in Wife's favor in the Court of Common Pleas of Cumberland County, Pennsylvania, Domestic Relations Section at PASCES Case Number 103104495 and docket number 00400-S-2002 in the amount of Two Thousand Eight Hundred and Forty Dollars ($2,840.00) in unallocated support. The parties agree that said support order shall continue in full force and effect until the date of entry of a Divorce Decree in this matter at which time it shall terminate. Any and all arrearages and/or credits being carried on the current support order as of the date of termination, including, any and all medical reimbursements in the agreed upon amount of Two Thousand Two Hundred Seventy-Eight Dollars and Seventy-Three Cents ($2,278.73) due Wife, shall be carried over to the alimony order. Husband shall fully and completely satisfy all regular unallocated support/arrearages existing as of the date of termination of the order within eighteen (18) months of the date of execution of this Agreement. Husband shall pay the uninsured medical reimbursements to Wife within thirty (30) days of the date of execution of this Agreement. The parties further agree that upon entry of the Divorce Decree, Husband shall pay alimony to Wife as follows: (a) From date of entry of Divorce Decree until the month in which Wife attains the age of sixty (60) years, Husband shall pay Wife Twenty-Eight Hundred Dollars ($2,800.00) per month as and for alimony. This initial alimony term shall be non-modifiable in amount and shall terminate only upon Wife's death, but not upon her remarriage or cohabitation. (b) Commencing with the month following the month in which Wife reaches the age of 60 years, Husband shall pay to Wife the sum of Two Thousand Two Hundred and Fifty Dollars ($2,250.00) per month as and for alimony. The second alimony term shall 11 terminate upon Wife's death, Wife's cohabitation, Wife's remarriage, or upon Wife's reaching her normal social security age permitting her to receive an unreduced social security retirement benefit, pursuant to the United States Social Security Office which the parties acknowledge is sixty-six (66) years. Commencing on the twelfth month anniversary and each twelve month anniversary thereafter, for so long as Husband has an alimony obligation pursuant to the second term of alimony, the alimony payments shall be increased by the same percentage as the percentage increase occurring the previous year in the Consumer Price Index as published by the United States Department of Labor Bureau of Statistics. The parties agree that all alimony payments provided for herein, shall be fully deductible by Husband on his federal income tax return and that Wife shall claim said alimony payments as income on her federal income tax returns. The parties further agree that said alimony payments shall be payable through the Domestic Relations Section of the Court of Common Pleas of Cumberland County, Pennsylvania pursuant to wage attachment. However, the parties specifically acknowledge that payment through the Domestic Relations Office is not intended, nor does it confer upon the court any authority to modify the terms of the alimony as set forth in this Agreement, except as provided for in this Agreement. Except as otherwise set forth herein, Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. The parties further release and waive any rights they may have to seek modification of the terms of 12 this paragraph in a court of law or equity, it being understood that the foregoing constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. 7. MEDICAL INSURANCE COVERAGE. The parties acknowledge that, Wife is currently being provided medical insurance coverage through Husband's policy available through his business. Husband shall continue to provide Wife with said insurance coverage until final entry of a divorce decree in this case. Husband represents and warrants that his company has elected COBRA coverage for its employees, including Husband. Husband shall continue to maintain said medical coverage to ensure that upon entry of a final Divorce Decree in this matter, Wife is offered and entitled to COBRA coverage for the three (3) year period following entry of the Divorce Decree. Husband further represents that the current cost for said COBRA is Two Hundred and Six Dollars and Eighty-Six Cents ($206.86) per month, although the parties acknowledge that said amount is subject to increases thereafter. Husband shall cooperate to the extent necessary, to permit Wife to obtain said COBRA coverage. The parties further acknowledge that every year, when Husband's business has its annual medical insurance renewal, Husband reviews other insurance carrier options to ascertain whether or not a change in insurance carrier would be economically beneficial to the business and his employees. Husband shall be entitled to, after such review, choose another insurance carrier, so long as the new insurance carrier will entitle Wife to continue with her COBRA coverage and the policy benefits are substantially similar to those currently provided. In the event Husband takes any action that terminates Wife's COBRA entitlement prior to the three (3) year COBRA term or reduces substantially the benefits available to her through said COBRA coverage, then Husband shall, for 13 the remainder of the three (3) year term, pay to Wife to obtain her own policy, or a supplemental policy necessary to provide her with substantially same benefits, the difference between the cost of the COBRA coverage and the cost of the new policy obtained by Wife. Upon entry of the final Decree in Divorce, each party shall be responsible for his/her unreimbursed medical expenses. 8. COUNSEL FEES, COSTS AND EXPENSES. Each party shall be solely responsible for his or her own legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their marriage, and the preparation and execution of this Agreement. 9. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 10. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, 14 final pay checks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 11. RELEASE OF CLAIMS. (a) Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to §3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces and forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds in the future. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the execution date of this Agreement with full power in him or her to dispose of the same fully and effectively for all purposes. (b) Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights 15 and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. (c) Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or.future acts, contracts, engagements or liabilities of the other or by way of dower, courtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. (d) Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes 16 of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 12. PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 13. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 14. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 15. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 16. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. 17 17. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. Notice to Husband will be sufficient if made or addressed to the following: Scott T. Woodruff 130 Red Haven Road New Cumberland, Pennsylvania and to Wife, if made or addressed to the following: Deborah D. Woodruff 1459 Hillcrest Court Apt. 506 Camp Hill, Pennsylvania Notice shall be deemed to have occurred upon the date received by the recipient. Each parry may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. 18. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 19. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 20. EFFECTIVE DATE. This Agreement shall become effective and binding upon both parties on the execution date. 18 21. EFFECT OF RECONCILIATION, COHABITATION OR DIVORCE. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 22. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 23. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties. 24. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 19 25. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either parry unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorneys' fees, costs, -and other expenses actually incurred as a result of such failure. 26. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. WITNESS 411&S'2 -&,LO WITNESS DEBORAH D. WOODRUFF SCOTT T. WOOD F 20 COMMONWEALTH OF PENNSYLVANIA COUNTY OFr) BEFORE ME, the undersigned authority, on this day personally appeared DEBORAH D. WOODRUFF, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this ? day of n 2007. Rotary P' b ' c in and for Commonwealth of Pennsylvania Typed or printed name of Notary: r^ r7ord?? My commission expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL GINGER L. GONTZ, NOTARY PUBLIC CITY OF HARRISBURG, DAUPHIN COUNTY MY COMMISSION EXPIRES MAY 11, 2008 21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF 1 Dot,( BEFORE ME, the undersigned authority, on this day personally appeared SCOTT T. WOODRUFF, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this day of 41zh?L-' 2007. Nokrv Public in Commonwealth of Pennsylvania Typed or printed name of Notary: MERLENE J. MARHE C, NOTARY PUBLIC My commission expires: CARLISLE, CUMBERLAND COUNTY, PA SiON EXPIRES JUNE 8, 2010 22 MARITAL SETTLEMENT AGREEMENT BY AND BETWEEN DEBORAH D. WOODRUFF AND SCOTT T. WOODRUFF Donald T. Kissinger, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Deborah D. Woodruff Carol J. Lindsay, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Telephone: (717) 243-6222 Counsel for Scott T. Woodruff MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this -0-tay of L , 2007, by and between DEBORAH D. WOODRUFF, of Cumberland County, Pennsylvania, and SCOTT T. WOODRUFF, of York County, Pennsylvania; WITNESSETH: WHEREAS, Scott T. Woodruff (hereinafter referred to as "Husband") was born on April 26, 1953 and currently resides at 130 Red Haven Road, New Cumberland, York County, Pennsylvania; WHEREAS, Deborah D. Woodruff (hereinafter referred to as "Wife") was born on May 9, 1951 and currently resides at 1459 Hillcrest Court, Apt. 506, Camp Hill, Cumberland County, Pennsylvania; WHEREAS, the parties hereto are husband and wife, having been lawfully married on April 25, 1981; WHEREAS, the parties have lived separate and apart since on or about May 12, 2002; WHEREAS, three children were born of the marriage between the parties, namely, Michael, born August 22, 1982; and Alexa and Nicholas, both born on October 5, 1987, all of whom are emancipated; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of these premises, and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL. Each party acknowledges he or she has had the opportunity to receive independent legal advice from counsel of his or her selection (Donald T. Kissinger, Esquire for Wife and Carol J. Lindsay, Esquire for Husband). Each party fully understands the facts and his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable; it is being entered into freely and voluntarily; the execution of this Agreement is not the result of any duress or undue influence; that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the court has the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Cumberland County, or any other court of competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs of litigation. 2 2. DISCLOSURE OF ASSETS. Each of the parties warrant and represent that he/she has given the other party a full, complete and accurate disclosure of all assets, of any nature, whether or not the assets were held jointly or in one name alone. Each party confirms that he/she is relying upon the substantial accuracy of the asset disclosures provided in this action as an inducement to the execution of this Agreement. Each party has made whatever discovery he or she wished and was fully satisfied with the discovery which he or she received. In the event any material marital asset is determined, after execution of this Agreement, to have been omitted by either party, the non-disclosing party shall pay to the other party fifty percent (50%) of the value of the omitted marital asset. 3. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereafter acquired by the other. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and, thus, any divorce action with respect to these parties shall be limited to a claim for no-fault divorce only. The parties acknowledge that, on February 12, 2002, Husband initiated a divorce action under, inter alia, the no-fault provisions of the Divorce Code by filing a Complaint docketed at action number 02-768 in the Court of Common Pleas of Cumberland County, Pennsylvania. The parties further acknowledge the ninety (90) day waiting period provided for under section 3301(c) of the Divorce Code has expired. Therefore, contemporaneously with the execution of this Agreement, each party will sign an Affidavit of Consent to Divorce and Waiver of Notice of Intention to Request Entry of Divorce Decree and deliver same to counsel for Husband who shall promptly submit said affidavits and waivers to the Court along with all other documents necessary to precipitate the prompt entry of a divorce decree. 5. EQUITABLE DISTRIBUTION. (a) Marital Residence Sales Proceeds. The parties acknowledge that at the time of separation they were the titled owners, as tenants by the entireties, of that certain house and lot and all improvements thereupon situated at 925 Shiremont Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. The parties further acknowledge that on or about June 17, 2005, the Marital Residence was sold and, after each party received advanced distributions of $36,271.39 from said proceeds, that the remainder of the sales proceeds have been placed into an attorneys' escrow account at Commerce Bank statement savings account number 626790224 which has an approximate balance as of March 20, 2007 of $112,693.04. The parties agree as follows with respect to the Marital Residence Proceeds: (1) Advance Distributions. Each party shall retain as his/her sole and separate property, free and clear of any and all right, title, claim and/or interest of the other, the advanced distribution from the Marital Residence Sales Proceeds each has received to date; and 4 (2) Remaining Proceeds. The remaining proceeds contained in the Commerce Bank statement savings account number 626790224 shall, as soon as practicable after execution of this Agreement, be withdrawn from said account and transferred in its entirety to Wife who shall thereafter be the sole and exclusive owner of said proceeds, free and clear of any right, title, claim and/or interest of Husband. (b) Motor Vehicles. (1) Husband agrees Wife shall retain possession of and receive as her sole and separate property any and all automobiles currently titled her name, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title, claim or interest of Husband. Wife shall indemnify and hold Husband and his property harmless from any and all liability, cost or expense, including actual attorneys' fees incurred in connection with any vehicles belonging to Wife by virtue of this subparagraph. (2) Wife agrees Husband shall retain possession of and receive as his sole and separate property any and all automobiles currently titled his name, along with all rights under any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, free of any and all right, title, claim or interest of Wife. Husband shall indemnify and hold Wife and her property harmless from any and all liability, cost or expense, including actual attorney's fees, incurred in connection with any vehicles belonging to Husband by virtue of this subparagraph. (c) Central PA Rentals. Inc./Event Central. The parties acknowledge that at the time of separation they owned a ninety percent (90%) interest in Central 5 PA Rentals, Inc., doing business as Event Central (hereinafter referred to as "Event Central"), although said interest was titled to Husband alone. The parties agree that Husband shall receive the entire ninety percent (90%) interest in Event Central as his sole and separate property, free and clear of any right, title, claim and/or interest of Wife. Husband hereby represents and warrants that there is no debt associated with Event Central for which Wife, and/or her estate, is liable. However, in any event, Husband shall indemnify and hold Wife and her property harmless from any and all liability, cost or expense, including actual attorneys' fees, incurred in connection with Event Central. (d) Financial Accounts. The parties agree that Husband shall receive any and all financial accounts titled in his name alone, as his sole and separate property,free and clear of any right, title, claim and/or interest of Wife, including, but not limited to, the following: (i) Community Bank Checking Account; and (ii) Mellon Bank Checking Account. The parties further agree that Wife shall receive as her sole and separate property any and all financial accounts in her name, free and clear of any right, title, claim and/or interest of Husband, including, but not limited to, the following: (i) All First Checking Account; (ii) BSB Bank and Trust Account; and (iii) Merrill Lynch CMA Account. The parties further acknowledge that any and all joint accounts in existence as of the date of their marriage have been distributed to their mutual satisfaction. 6 (e) Life Insurance. Except as provided for herein, the parties acknowledge and agree each shall retain as his or her sole and separate property, any and all life insurance policies in his or her sole name, free of any right, title and interest of the other party. Notwithstanding the above, Wife shall be entitled, at her option, to obtain a life insurance policy, which will be owned by Wife but insure the life of Husband for up to a $400,000.00 death benefit. Wife shall be the sole and exclusive owner of this policy, free and clear of any right, title, claim and/or interest of Husband. Wife shall be solely and exclusively responsible for payment of any premium associated with said policy. However, Husband shall cooperate, in any way necessary with Wife in obtaining said life insurance policy, including, but not limited to, submitting to any and all physical examinations, within twenty (20) days of notice of need for same, providing any and all requested medical/psychological records or authorization for release of said records requested by the insurance company within seven (7) days, and, he shall fully and completely provide the information in his possession and signatures necessary to obtain said policy within seven (7) days of being requested to do so. Husband represents that he is unaware of any medical condition which would render him uninsurable. (f) Pension and Retirement Benefits. Wife and Husband each hereby specifically releases and waives any and all right, title, claim or interest that he or she may have in and to any and all retirement benefits (including but not limited to pension or profit sharing benefits, deferred compensation plans, 401(k) plans, employee savings and thrift plans, individual retirement accounts or other similar benefits) of the other party, specifically to include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties 7 agree that they shall execute any documents pursuant to the Retirement Equity Act or any similar act that may be required from time to time to accomplish the purposes of this subparagraph. Specifically, the parties acknowledge and agree that Husband shall retain as his sole and separate property, free and clear of any right, title, claim and/or interest of Wife, his Merrill Lynch Individual Retirement Account and that Wife shall receive as her sole and separate property, free and clear of any right, title, claim and/or interest of Husband, her Merrill Lynch Individual Retirement Account. (g) Furnishings and Personalty. (1) The parties agree that they have divided by agreement between themselves all furnishings and personalty, including all furniture, furnishings, antiques, jewelry, rugs, carpets, household appliances and equipment. (2) Except as otherwise set forth herein, Husband shall retain, as his sole and separate property, free of any and all right, title, claim or interest of Wife, all of the personalty and furnishings currently in his possession. (3) Except as otherwise set forth herein, Wife shall retain, as her sole and separate property, free of any and all right, title, claim or interest of Husband, all of the personalty and furnishings currently in her possession. (h) Miscellaneous Property. As of the execution date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled; if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. (i) Property to Wife. The parties agree that Wife shall own, possess, and enjoy, free from any claim of husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. 0) Property to Husband. The parties agree that Husband shall own, possess, and enjoy, free from any claim of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property,and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. (k) Liability not Listed. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability, other than those described in this Agreement, on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless from any and all debts, obligations and liabilities. 9 (1) Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or proceeding, whether or not well-founded, and indemnify her and her property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorneys' fees incurred by Wife in connection therewith. (m) Indemnification of Husband. If any claim, action or proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to costs of court and actual attorney's fees incurred by Husband in connection therewith. (n) Warranty as to Future Obligations. Husband and Wife each represents and warrants to the other that he or she will not at any time in the future incur or contract any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever, including actual attorneys fees, incurred in the event of breach hereof. 10 6. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. The parties acknowledge that there is currently a support order in Wife's favor in the Court of Common Pleas of Cumberland County, Pennsylvania, Domestic Relations Section at PASCES Case Number 193104495 and docket number 00400-5-2002 in the amount of Two Thousand Eight Hundred and Forty Dollars ($2,840.00) in unallocated support. The parties agree that said support order shall continue in full force and effect until the date of entry of a Divorce Decree in this matter at which time it shall terminate. Any and all arrearages and/or credits being carried on the current support order as of the date of termination, including, any and all medical reimbursements in the agreed upon amount of Two Thousand Two Hundred Seventy-Eight Dollars and Seventy-Three Cents ($2,278.73) due Wife, shall be carried over to the alimony order. Husband shall fully and completely satisfy all regular unallocated support/arrearages existing as of the date of termination of the order within eighteen (18) months of the date of execution of this Agreement. Husband shall pay the uninsured medical reimbursements to Wife within thirty (30) days of the date of execution of this Agreement. The parties further agree that upon entry of the Divorce Decree, Husband shall pay alimony to Wife as follows: (a) From date of entry of Divorce Decree until the month in which Wife attains the age of sixty (60) years, Husband shall pay Wife Twenty-Eight Hundred Dollars ($2,800.00) per month as and for alimony. This initial alimony term shall be non-modifiable in amount and shall terminate only upon Wife's death, but not upon her remarriage or cohabitation. (b) Commencing with the month following the month in which Wife reaches the age of 60 years, Husband shall pay to Wife the sum of Two Thousand Two Hundred and Fifty Dollars ($2,250.00) per month as and for alimony. The second alimony term shall 11 terminate upon Wife's death, Wife's cohabitation, Wife's remarriage, or upon Wife's reaching her normal social security age permitting her to receive an unreduced social security retirement benefit, pursuant to the United States Social Security Office which the parties acknowledge is sixty-six (66) years. Commencing on the twelfth month anniversary and each twelve month anniversary thereafter, for so long as Husband has an alimony obligation pursuant to the second term of alimony, the alimony payments shall be increased by the same percentage as the percentage increase occurring the previous year in the Consumer Price Index as published by the United States Department of Labor Bureau of Statistics. The parties agree that all alimony payments provided for herein, shall be fully deductible by Husband on his federal income tax return and that Wife shall claim said alimony payments as income on her federal income tax returns. The parties further agree that said alimony payments shall be payable through the Domestic Relations Section of the Court of Common Pleas of Cumberland County, Pennsylvania pursuant to wage attachment. However, the parties specifically acknowledge that payment through the Domestic Relations Office is not intended, nor does it confer upon the court any authority to modify the terms of the alimony as set forth in this Agreement, except as provided for in this Agreement. Except as otherwise set forth herein, Husband and Wife hereby expressly waive, discharge and release any and all rights and claims which he or she may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite, spousal support and/or maintenance or other like benefits resulting from the parties' status as husband and wife. The parties further release and waive any rights they may have to seek modification of the terms of 12 this paragraph in a court of law or equity, it being understood that the foregoing constitutes a final determination for all time of either party's obligation to contribute to the support and maintenance of the other. 7. MEDICAL INSURANCE COVERAGE. The parties acknowledge that, Wife is currently being provided medical insurance coverage through Husband's policy available through his business. Husband shall continue to provide Wife with said insurance coverage until final entry of a divorce decree in this case. Husband represents and warrants that his company has elected COBRA coverage for its employees, including Husband. Husband shall continue to maintain said medical coverage to ensure that upon entry of a final Divorce Decree in this matter, Wife is offered and entitled to COBRA coverage for the three (3) year period following;entry of the Divorce Decree. Husband further represents that the current cost for said COBRA is Two Hundred and Six Dollars and Eighty-Six Cents ($206.86) per month, although the parties acknowledge that said amount is subject to increases thereafter. Husband shall cooperate to the extent necessary, to permit Wife to obtain said COBRA coverage. The parties further acknowledge that every year, when Husband's business has its annual medical insurance renewal, Husband reviews other insurance carrier options to ascertain whether or not a change in insurance carrier would be economically beneficial to the business and his employees. Husband shall be entitled to, after such review, choose another insurance carrier, so long as the new insurance carrier will entitle Wife to continue with her COBRA coverage and the policy benefits are substantially similar to those currently provided. In the event Husband takes any action that terminates Wife's COBRA entitlement prior to the three (3) year COBRA term or reduces substantially the benefits available to her through said COBRA coverage, then Husband shall, for 13 the remainder of the three (3) year term, pay to Wife to obtain her own policy, or a supplemental policy necessary to provide her with substantially same benefits, the difference between the cost of the COBRA coverage and the cost of the new policy obtained by Wife. Upon entry of the final Decree in Divorce, each party shall be responsible for his/her unreimbursed medical expenses. 8. COUNSEL FEES. COSTS AND EXPENSES. Each party shall be solely responsible for his or her own legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their marriage, and the preparation and execution of this Agreement. 9. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their marriage, except the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 10. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, 14 final pay checks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. 11. RELEASE OF CLAIMS. (a) Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to §3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. Furthermore, except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces and forever abandons any claim, right, title or interest whatsoever he or she may have in property transferred to the other party pursuant to this Agreement or identified in this Agreement as belonging to the other party, and each party agrees never to assert any claim to said property or proceeds in the future. However, neither party is released or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her from the execution date of this Agreement with full power in him or her to dispose of the same fully and effectively for all purposes. (b) Each party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights 15 and obligations which either party may have or at any time hereafter has for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions. Neither party shall have any obligation to the other not expressly set forth herein. (c) Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or-future acts, contracts, engagements or liabilities of the other or by way of dower, courtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country. (d) Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes 16 of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 12. PRESERVATION OF RECORDS. Each party will keep and preserve for a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 13. MODIFICATION. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 14. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions, hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 15. BREACH. If either party hereto breaches any provision hereof, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 16. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other breach or any provision of this Agreement. 17 17. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or certified mail, return receipt requested. Notice to Husband will be sufficient if made or addressed to the following: Scott T. Woodruff 130 Red Haven Road New Cumberland, Pennsylvania and to Wife, if made or addressed to the following: Deborah D. Woodruff 1459 Hillcrest Court Apt. 506 Camp Hill, Pennsylvania Notice shall be deemed to have occurred upon the date received by the recipient. Each party may change the address for notice to him or her by giving notice of that change in accordance with the provisions of this paragraph. 18. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this Agreement. 19. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. 20. EFFECTIVE DATE. This Agreement shall become effective and binding upon both parties on the execution date. 18 21. EFFECT OF RECONCILIATION. COHABITATION OR DIVORCE. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 22. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 23. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties. 24. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully read this Agreement; that he or she has discussed its provisions with an attorney of his or her own choice, and has executed it voluntarily and in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 19 25. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done every other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorneys' fees, costs, -and other expenses actually incurred as a result of such failure. 26. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. WITNESS TNESS DEBORAH D. WOODRUFF SCOTT T. WOOD F 20 r COMMONWEALTH OF PENNSYLVANIA COUNTY OF i BEFORE ME, the undersigned authority, on this day personally appeared DEBORAH D. WOODRUFF, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this day of I l , 2007. t 11btary P4 byc in and for -j Commonwealth of Pennsylvania Typed or printed name of Notary: 91 n QCJ??:: L. rac My commission expires: COMMONWEALTH OF PENNSYLV-NIA NOTARIAL SEAL GINGER L. GONTZ, NOTARY PUBLIC CITY Of HARRISBURG, DAUPHIN COUNTY MY COMMISSiOH EXPIRES MAY 11, 2008 21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF BEFORE ME, the undersigned authority, on this day personally appeared SCOTT T. WOODRUFF, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed. GIVEN UNDER MY HAND AND SEAL OF OFFICE this day of 2007. NOTARIAL SEAL MERLENE J. MARHEVKA, NOTARY PUBLIC My commission expires: CARLISLE CUMBERLAND COUNTY, PA 22 Typed or printed name of Notary: Cl _ -2 C7 " . rn 13- ?. W SCOTT T. WOODRUFF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-768 CIVIL TERM DEBORAH A. WOODRUFF, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on February 15, 2002, a true and correct copy of Divorce Complaint was served upon Deborah A. Woodruff, by mailing those documents to the her address at 925 Shiremont Drive, Mechanicsburg, PA 17055, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Deborah A. Woodruff. SAIDIS, FLOWER & LINDSAY Carol J. Lindsa , uire Supreme Cou I o. 44 26 West High treet Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY ATIOMM AT tAW 26 West High Street Carlisle, PA J. • Coriiplete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the Ikverse sd that wejon return the card to you. ¦ Attach t& card to the back of the mailpiece, onon th%frpnt if space permits. V1. - 1. Alcle Addplidsed to: Deborah' Ajr, Woodruff 925 Shireraont Drive lechanicsburgr PA 17055 A. Rece' )y (Please Print Clearly) I B. Date of Delivwy Agent D. Is delivery address df lerent from #jW u re: If YES, enter delivery address ? No 3. Service Type JM Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandho ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ?s1 2. Article Number Dopy from service label) 7099 3400 0013 5047 7905 Ps Form 3811, July 1 ng DorttMtic RNttm RracMpt Ln O Q' r? SAMIS, FLV?V7?V-?FR & LENDSL 11 AT ORNEYB-AT uw 26 West High Street Carlisle, PA M1 Postage $ C3 Certified Fee ' D ? Ll'1 . : -. . Pos(matk Return Receipt Fee ?' '-- a W (Endorsement Required) C3 Restricted Delivery Fee uired) ment Re E d OL U +l C3 orse q ( n '? O Total Postage & Fees a ?? ?i• ! C3 c ?'• Recipients Name (Please Print Clearly) (to be camp/ tad; mailers ' 1 ' --------- - ------- M _l)ebar_ah_A._WQodru-ff----- -Zil------ ?. Street, Apt. No.; or PO Box No. tr- 925 Shiremont Drive C3 City State, ZIP+ r- Mechanicsburq, PA 17055 G? ? ? ? ? ,t, _ '> >. ? Z ? / 1 i` ?.,,, `?w?Y ?'x ? x ?+ ?.Jy ' f" ?`"'??i ?.?t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT T. WOODRUFF, ) Plaintiff ) V. ) DEBORAH D. WOODRUFF, ) Defendant ) NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on February 12, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: D N 90 C? ` s .._ 1 A r C D SCOTT T. WOODRUFF, Plaintiff V. DEBORAH A. WOODRUFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-768 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on February 15, 2002, via certified mail. Proof of service is being filed with the Court contemporaneously herewith. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: April 11, 2007 and filed with Prothonotary on April 12, 2007. By Defendant: April 6, 2007 and filed with Prothonotary contemporaneously herewith. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated April 11, 2007 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: April 11, 2007 and filed with Prothonotary on April 12, 2007. By Defendant: April 6, 2007 and filed with Prothonotary contemporaneously herewith. SAIDIS, LINDSAY ATIORNM AT IAW 26 West High Street Carlisle, PA SAIDIS, FLOWER & AY Carol J. Lindsay, s e Supreme Court Ip o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 C u ? "r7 --Orr, ` ^ tV '} f.J ?' 7 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. 02-768 SCOTT T. WOODRUFF VERSUS DEBORAH A. WOODRUFF DECREE IN DIVORCE AND NOW, .2 y 2eo? IT IS ORDERED AND SCOTT T. WOODRUFF DECREED THAT , PLAINTIFF, AND DEBORAH A. WOODRUFF , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated April 11, 2007 are incorporated, but not merged, into this Decree in Divorce. BY TX-0U- RT : ATTESX: _ w J. PROTHONOTARY Y' 4 4 ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT State Commonwealth of Pennsylvania 785104532 Co./City/Dist. of CUMBERLAND 02-768 CIVIL Date of Order/Notice 05/09/07 193104495 Case Number (See Addendum for case summary) 400 S 2002 Employer/Withholder's Federal EIN Number CENTRAL PA RENTALS INC STE H 665 INDEPENDENCE AVE MECHANICSBURG PA 17055-6623 104-44-7916 Employee/Obligor's Social Security Number 3152100971 Employee/Obligor's Case Identifier (See Addendum for plaintiff names associated with cases on attachment) Custodial Parent's Name (Last, First, MI) See Addendum for dependent names and birth dates associated with cases on attachment. ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these. amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not issued by your State. $ 2, 800.00 per month in current support $ 0. 00 per month in past-due support Arrears 12 weeks or greater? Dyes (9) no $ 0.00 per month in current and past-due medical support $ 0.00 per month for genetic test costs $ 0. oo per month in other (specify) for a total of $ 2, 800.00 per month to be forwarded to payee below. You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match the ordered support payment cycle, use the following to determine how much to withhold: $ - 646.15. per weekly pay period. $ 1292.31 per biweekly pay period (every two weeks). $ 1, 400.00 per semimonthly pay period (twice a month). $ 2, 8o0 . oo per monthly pay period. REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is needed (See #9 on page 2). If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580 for instructions. Make Remittance Payable to: PA SCDU Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112 IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO NOT SEND CASH BY MAIL. BY THE COURT: Date of Order: MAY 11, 2007 DRO: R.J. Shadday Service Type M O Original Order/Notice O Amended Order/Notice O Terminate Order/Notice RE: WOODRUFF, SCOTT T. Employee/Obligor's Name (Last, First, MI) Kevin A. --s, Judge Form EN-028 Rev. 1 OMB No.: 0970-0154 VAI.,rLor Ifl - I.u N Y sy ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS ? I zecke i you are required, to provide gopy of this form to yoursxloyee. If yorr employee works in a state that is di event rom the state that issued this or er, a copy must be provi to your emp oyee even if the box is not checked. 1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income. Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting agency listed below. 2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each employeelobligor. 3.* wages. You must comply with the law of the state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the withholding order and forward the support payments. 4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent possible. (See #9 below) 5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2517790600 EMPLOYEE'S/OBLIGOR'S NAME:WOODRUFF, SCOTT T. EMPLOYEE'S CASE IDENTIFIER: 3152100971 DATE OF SEPARATION: LAST KNOWN HOME ADDRESS: NEW EMPLOYER'S NAME/ADDRESS: 6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or severance pay. If you have any questions about lump sum payments, contact the person or authority below. 7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment, refusing to employ, or taking disciplinary action against any employeelobligor because of a support withholding. Pennsylvania State law governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs. 9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act 0 5 U.S.C. §1673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment. The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more than the amounts allowed under the law of the state that issued the order. 10. Additional Info: *NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state that issued this order with respect to these items. 11. Submitted By: DOMESTIC RELATIONS SECTION 13 N. HANOVER ST P.O. BOX 320 CARLISLE PA 17013 Service Type M If you or your employee/obligor have any questions, contact WAGE ATTACHMENT UNIT by telephone at (717) 240-6225 or by FAX at (717) 240-6248 or by internet www.childsupport.state.pa.us Page 2 of 2 OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT w, J?v ADDENDUM Summary of Cases on Attachment Defendant/Obligor: WOODRUFF, SCOTT T. PACSES Case Number 785104532 Plaintiff Name DEBORAH D. WOODRUFF Docket Attachment Amount 02-768 CIVIL $ 2,800.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Service Type M PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. PACSES Case Number Plaintiff Name Docket Attachment Amount $ 0.00 Child(ren)'s Name(s): DOB ? If checked, you are required to enroll the child(ren) identified above in any health insurance coverage available through the employee's/obligor's employment. Addendum OMB No.: 0970-0154 Form EN-028 Rev. 1 Worker ID $IATT .., = i n - rr, - zj C.J t.L7 01/15/2010 09:11 7172406248 CUMBERLANDCTYDRO PAGE 03103 o. ®a - -762 C I JAN 19 2?1A CUIMBE AND COUNTY DOMESTIC RELATIONS Date of Application: - Request for Support Record Search Narne: o I)Dt 9 G Address: I bo D 44,10?j Social Security Number: I D gF - Domestic Relations Case Number if PArty Requesting Information: qI l 01q_ c (Fax Nunn A Twenty Dollar ( Make check or o7 0 ?qbl N ?o X INITIAL REQUEST _ Has no Record in Domestic Relations as of,: (Date) -ra Support Arrears as of End of Month Prior to Date of Application: $ o?!o O 4 • S tv Monthly Total Support Obligation: $ Qb Q , O O ?- The Amount shown above is reflected in the Domestic Relations Section Office of Cumberland County, Pennsylvania. M eM b Q` -K 315 ,;? 1 0 09 -11 Domestic Relations Case Number: PQCS e S -7 8S 10 HS 3a Signed: W'1. '1? Lien i / D Search Coordinator) (bate) ( ) ( ) BARING-DOWN REQUEST Support Arrears: $ Signed: (Lien Coordinator) As Of: (mate) (Date) *** Lien Satisfisfaction Receipt Available Upon Request*** CC720 fee is Due -er Social Security Number order Qavable to: DRS/Lien Search t ?7 LIEN SATISFACTION Name: Scott Woodruff Member Number: M#3152100971 Pacses# 785104532 No. 02-768 Civil DR# 31736 Judgment Lien Satisfied as of: February 5, 2010 Amount Paid: $ 2609.55 Signed:. Lien Coordinator) 9' -Z Wd Z i 933 01OZ (Date) CC722