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Home My WebLink About05-3788 o Thomas D. Gould Attorney for Plaintiff I.D. II 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05- 3 7 ~ f CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A jUdgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 NOTICE QE AVAILABILITY QE COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Thomas D. Gould Attorney for Plaintiff 1.D. # 36508 2 East Main street Shiremanstown, PA 17011 (717) 731-1461 MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.C6-,3'1\l'iS CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Mark D. Jordan who resides at 2902 Chesterbrook Court, Apartment 208, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Kathleen S. Jordan who resides at 3 Sna Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 25, 1993 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. There were two children born of this marriage: Kaitlyn Louise Jordan, born July 15, 1994 and Abigail Jo Jordan, born August 15, 1997. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. 1h-- O. ~ Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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. 4904, relating to unsworn falsification to authorities. Date: 7/2..6/2-<>0'> ~p~ Mark D. JOrdan ~ ~, ~ ~[\ ~ ~ ~ - ~ <5' ~ ~ ...s::: V\ -...1 e\ \J ~. \ o ~~~ 0 C' ,::-:'l -n C-~ c_ :? ~.:~:.: {11 'v G' ~ .l7 f') Lindsay Gingrich Maclay. Esquire Daley. Zucker & Gingrich. LLC 1029 Scenery' Dri,'e Harrisburg. P A 17109 (717) 6574795 Imada\',a'dzclaw.colll IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA MARK D. JORDAN, Plaintiff No. iCiCfS - D3'Wf> v. CIVIL ACTION - LAW KATHLEEN S. JORDAN, Defendant (In Divorce) PROPERlY SETILEMENT AND SEPARATION AGREEMENT THIS AGREEMENT is made this ~day of ---.1~.u: 2005, BY and BETWEEN Kathleen S. Jordan, of 3 Sna Lane, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as Wife, A N D Mark D. Jordan, of 2902 Chesterbrook Court, Apartment 208, Camp Hill, Pennsylvania, hereinafter referred to as Husband. RECITALS R.I: The Parties hereto are Husband and Wife, having been joined in marriage on September 25,1993, in Mechanicsburg, Cumberland County, Pennsylvania; and R.2: Two (2) children were born of the marriage: Kaitlyn Louise Jordan, whose date of birth is July IS, 1994 and Abigail Jo Jordan, whose date of birth is August 15, 1997; and KSJ ~SJ Page lof25 MDJ ~p1 R.9: Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Wife has been independently represented by Lindsay Gingrich Maclay, Esquire of Daley, Zucker & Gingrich, LLC, and that Husband has been independently represented by Thomas D. Gould, Esquire; and R.1O: Both Husband and Wife each covenant that they have made full and complete disclosure to the other of his and her respective property holdings and income; and R.ll : Each Party has had an opportunity to verify the financial disclosure of the other. Discovery, if any, has been conducted to the satisfaction of each Party. Each Party has had the opportunity to investigate further the financial disclosure of the other, and has had access to any desired books and/or records to investigate further. Each Party had an opportunity to do an independent valuation of the assets, liabilities and income of the other Party. To the extent either Party decided not to pursue further discovery and investigation, he or she did so voluntarily and specifically waives the right to challenge this Agreement based on the absence of full and fair disclosure. NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by t:ach Party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the Parties, intending to be legally bound, hereby agree as follows: KSJ t<SJ' Page 3 of25 MDJ <?'J1 PJ' (1) SEPARATION: It shall be lawful for e~lCh Party at all times hereafter to live separate and apart from the other Party at such place or places as he or she from time to time may choose or deem fit, free from any control, resllraint or interference from the other. Neither Party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Neither Party shall disparage or discredit the other in any way, nor in any way injure his or her reputation; nor shall either of them act or permit anyone else to act in any way which might tend to create any disaffection or disloyalty or disrespect between the members of the family of either Party. Each Party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the tlrnIS of this Agreement or any Custody Agreement andlor Order. The foregoing provision shall not be taken to be an admission of the part of either Husband or Wife of the lawn.dness or unlawfulness of the causes leading to their living separate and apart. (2) DIVORCE: The Parties acknowledge that the marriage is irretrievably broken and that upon the filing of the Divorce Complaint and the subsequent expiration of the mandatory 90-day waiting period they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the expiration of the mandatory 90-day "cooling off" period provided for in the Divorce Code, the Parties shall execute the Affidavits of Consent and Waiver of Notice Forms necessary to finalize said Divorce. Upon execution thereof, said Affidavits and Waivers shall be immediately filed with the Cumberland County Prothonotary's Office. KSJ t<s.J Page 40f25 MDJ~tlf If either Party fails or refuses to execute and file the foregoing documents, said failure or refusal shall be considered a material breach of tI1~s Agreement and shall entitle the other Party at his or her option to terminate this Agreement. (3) REAL PROPERlY: The Parties are the joint owners of certain real property located at 3 Sna Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055 (hereinafter "Marital Residence"). Contemporaneously with the execution of this Agreement, Husband agrees that as part of this property settlclment, he will convey all of his right, title and interest in and to the Marital Residence to Wife, free of all encumbrances except the outstanding first mortgage with Washington Mwtual Home Loans, which Wife agrees to assume and pay in due course. The balance on the Parties' joint mortgage obligation as of January 27, 2005 was One Hundred Twelve Thousand Two Hundred Sixty- Three and 22/100 ($112,263.22). A copy of the January 27, 2005 statement from Washington Mutual Home Loans is attached hereto as Ellhibit "A" and is incorporated herein by reference as if set forth fully herein. Husband shall, simultaneously with the execution of this Agreement, execute and deliver to Wiife a Special Warranty Deed conveying Husband's interest in and to the Marital Reside:nce to Wife. Nothing in this Agreement shall require Wife to refinance the mortgage obligation solely into her name. Wife shall, pursuant to Paragraph 8 of this Agreement, waive her interest in and to Husband's FERS pension in return for Husband conveying his right, title and interest in and to the Marital Residence to Wife pursuant to the terms of this Agreement. KSJ K5:J Page 5 of25 MOJ '0J tV' Wife specifically agrees to hold harmless Husband with regard to all payments associated with the Marital Residence from the date of separation, forward, including, but not limited to the mortgage payments, taxes, homeowner's in:mrance and repairs. (4) DEBT: A. MARITAL DEBT: Other than those debts enumerated within, Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations whidl are marital or for which the other might be liable incurred prior to the signing of this Agreement i. Each of the Parties will pay all current bills and outstanding bills incurred on or before the date of separation of the parties, January 16, 2005, to the same extent that he or she has been paying then in the pam and neither Party shall incur any unusual bill which will bind the other Party. Husband hereby agrees to return to Wife any and all joint credit cards or charge plates that he may have in his possession. The Parties further agree that any debts incurred on said joint credit cards or charge plate:~ subsequent to the date of separation, shall be the sole and exclusive responsibility of the Party who incurred said debts and the debt-incurring Party shall save harmless the other Party from any obligation or institutions of suit thereunder. The Parties shall, within twenty (20) days of the execution of this Agreement, take all necessary steps to either close any joint credit card accounts or remove the other Party from the obligation and from the account. B: POST SEPARATION DEBT: Except as otherwise herein provided, in the event that either Pmty contracted or incurred any debt since the date of separation on January 16, 2005, the Party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. c: FlJTlJRE DEBT: Except :118 otherwise herein provided, from the date of this agreement neithm' Party shall contract or incur any debt or liability for which the other Party or his or her property or estate might be responsible and shall indemnifY and save the other Party harmless from any and all claim$ or demands made against him or her by reason of debts or obligations incurred by the other Party. KSJ KS:f Page 6 of 25 MOJ <'9A e> f (5) MOTOR VEmCLES: The Parties adrnowledge that the Parties, jointly, hold title to a 1998 Pontiac Transport Van, which Van is currently in the possession of Husband. Wife hereby relinquishes any right, title or interest she may have in and to the Pontiac Van. Husband shall acquire and maintain separate insurance on and assume full responsibility for any encumbrance on the Pontiac Van, and shall hold hann1ess and indemnify Wife from any loss thereon. Within twenty (20) days of the execution of this Agreement, the Parties hereby agrees to execute any and all documents needed to have the 1998 Pontiac Van properly registered solely in Husband's name with the Pennsylvania Department of Transportation. The parties further acknowledge that the Parties, jointly, hold title to a 2003 Toyota Camry, which vehicle is currently in the possession of Wife. Husband hereby relinquishes any right, title or interest he may have in and the Toyota Camry. Wife shall acquire and maintain separate insurance on and assume full responsibility for any encumbrance on the Toyota Camry, and shall hold hann1ess and indemnify Husband from any loss thereon. Within twenty (20) days of Wife's receipt of the title, the Parties hereby agrees to execute any and all documents needed to have the 2003 Toyota Camry properly registered solely in Wife's name with the Pennsylvania Department of Transportation. KSJ KSf' Page 70f25 MDJ~W (6) TANGmLE PERSONAL PROPERTY: The Parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each Party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the Parties hereto. This Agreement shall have the effect of an assignment or bill of sale from each Party to the other for such property as may be in the individual possession of the Parties hereto. (7) SAVINGS BONDS: The Parties hereto own a number of savings bonds. Wife owns some of these bonds individually. Some of these bonds were Wife's pre-marital property. A number of the bonds are jointly-owned, and a number of the bonds are owned by the Children, jointly with one parent. A listing/accounting of the bonds is attached hereto as Exhibit "B" and is incorporated herein by reference. All bonds solely in Wife's name, regardless ofwhetber said bonds were marital or not, shall become Wife's sole and separate property. Husband hereby waives any right, title or interest he may have in and to the bonds solely in Wife's name. To the extent that Husband has possession of any of these bonds, he hereby agl'l~s to return the bonds to Wife within ten (10) days of the execution of this Agreement. KSJ _KSS Page 8 of 25 MDJ'7n~ All the bonds owned jointly by Husband and Wife and shall become the sole and separate property of Wife. Husband hereby waives any right, title or interest he may have in and to the jointly-owned bonds. To the extent that Husband has possession of any of these bonds, he hereby agrees to return the bonds to Wife within ten (10) days of the execution of this Agreement. Additionally, from time to time as may be necessary to give full force and effeci to this Paragraph, Husband agrees to execute any and all necessary documents, within ten (10) days of a request by Wife to do so, to ensure that Wife has full authority to dispose of, transfer, or cash in, the savings bonds referenced in this Paragaraph. All bonds owned by either of the Children, either individually or jointly with Father, which are earmarked for the Children's education or other nt:eds, shall become the sole and separate property of the Child whose name is on the bond. To the extent that Husband has possession of any of these bonds, he hereby agrees to retwn the bonds to Wife within ten (10) days of the execution of this Agreement. Additionally, from time to time as may be necessary to give full force and effeci to this Paragraph, Husband agrees to execute any and all necessary documents, within ten (10) days of a request by Wife or the Child to do so, to ensure that the Children have full authority to dispose of, transfer, or cash in, the savings bonds referenced in this Paragraph. The Parties hereto recognize and agree that any and all savings bonds referenced in Paragraph 7 are earmarked for the education and benefill of the Children and unless otherwise agreed by the Parties hereto, shall be used solely for that purpose. KSJ }<SJ Page 90f25 MOJ ~J7f (8) INTANGmLE PERSONAL PROPERTY: Excepi as otherwise provided herein, each Party hereto hereby relinquishes any light, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other Party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits, including retirement accounts, savings plans, pension plans, stock plans, 40lK plllllls, and the like. Husband hereby acknowledges that the marital property of the Parties' may include any marital portion of Wife's American Funds Money Market, account number 64468327 (hereinafter referred to as "American Funds Account"). Wifes American Funds Account is solely in her name. The value of Wife's American Funds ACl:ount as of December 31,2004 was Five Thousand One Hundred Forty-Two and 90/100 ($5,142.90) Dollars. A copy of Wife's December 31,2004 American Funds Account statement is attached hereto as Exhibit "e" and is incorporated herein by reference. Husband further acknowledges that he has been informed of his right to obtain an independent appraisal and/or valuation of Wife's American Funds Account and any marital interest he may have therein, and, notwithstanding same, Husband hereby forever waives and relinquishes any right, title interest or claim he might otherwise have in and to Wife's aforesaid American Funds Account. KSJ kSS Page 10 of 25 MOJ /)-Mar Husband hereby acknowledges that the marital propc::rty of the Parties' may include any marital portion of the Janus Portfolio (hereinafter refillTed to as "Janus Portfolio"). Portions of the Janus Portfolio are joint and portions of the Janus Portfolio are solely in Husband's name. The value of the Janus Portfolio as of December 3 1,2004 was Seventeen Thousand Seven Hundred Four and 88/100 ($17,704.88) Dollars. A copy of the December 3 I, 2004 Janus Portfolio statement is attached hereto as Exhibit "0" and is incorporated herein by reference. Husband further acknowledges that he has been informed of his right to obtain an independent appraisal andlor valuation of the Janus Portfolio and any marital interest he may have therein, and, notwithstanding same, Husband hereby forever waives and relinquishes any right, title interest or claim he might otherwise have in and to the Janus Portfolio. Husband hereby agrees that within ten (10) days of a request by Wife to do so, Husband shall cooperate in the removal of his name from any joint accounts within the Janus Portfolio. The Parties hereto recognize and agree that the Janus Portfolio is earmarked for the education and benefit of the Children and unless otherwise agreed by the Parties hereto, shall be used solely for that purpose. The Parties acknowledge that they currently hold VilVO (2) Janus accounts, one for the benefit of each child. As of December 31, 2004, Kaitlyn's Janus account balance was Two Thousand Five Hundred Sixty-Three and 88/100 ($2,563.88) Dollars (hereinafter referred to as "Kaitlyn's Janus Account"). A copy of the Oecember 31,2004 statement for Kaitlyn's Janus Account is attached hereto as Exhibit "E" and is incorporated herein by reference. As ofOecember 31,2004, Abigail's Janus account balance was Two Thousand Five Hundred Fifty-Five and 85/100 ($2,555.85) Dollars (hereinafter referred to as KSJ KS.:J Page 11 of25 MDJ/7nPJ "Abigail's Janus Account"). A copy of the December 31, 2004 statement for Abigail's Janus Account is attached hereto as Exhibit "F' and is incorporated herein by reference. The Parties hereto acknowledge and agree that these accounts shall be retained for the further education and benefit of the children and that, if possible, Wife shall move these accounts into a 529 account through her employer. Husband agrees to cooperate in and to execute any and all necessary documents to effectuate these accounts into 529 accounts, if possible. Husband hereby acknowledges that the marital property of the Parties' may include any marita1 portion of Wife's 40lK with Hoover Rehabilitation Service, Inc. (hereinafter referred to as "Hoover 40IK"). The Hoover 40lK is solely in Wife's name. The value of the Hoover 40lK as of December 31, 2004 was Thirty-Three Thousand Six Hundred Twenty-Nine and 51/100 ($33,629.51) Dollars. A copy of Wife's December 31, 2004 Hoover 40lK statement is attached hereto as Exhibit "0" and is incorporated herein by reference. Husband further acknowledges that he has been iinformed of his right to obtain an independent appraisal and/or valuation of Wife's Hoover 401K and any marital interest he may have therein, and, notwithstanding same, Husband hereby forever waives and relinquishes any right, title interest or claim he might oth,erwise have in and to Wife's Hoover 401K. Wife hereby acknowledges that the marital property of the Parties' may include any marital portion of Husband's Thrift Savings Plan with the Federal Government (hereinafter referred to as "TSP"). The TSP is solely in Husband's name. The value of Husband's TSP as of February 25, 2005 was One Hundred Sixty Thousand One Hundred Forty-Seven and KSJ KS.f Page 12 of25 MDJ ""'Jd 59/100 ($160,147.59) Dollars, all of which was vested. A copy of Husband's February 25, 2005 TSP statement is attached hereto as Exhibit "If' and is incorporated herein by reference. The value of Husband's TSP as of September 2003 was Fourteen Thousand Eight Hundred Fifty-Eight and 92/100 ($14,858.92) Dollars. A copy of Husband's September 1993 TSP account statement is attached hereto as Exhibit "f' and is incorporated herein by reference. The Parties hereto agree that for purposes of this Agreement, the marital portion of Husband's TSP account is One Hundred Forty-Five Thousand Two Hundred Eighty-Eight and 67/100 ($145,288.67) Dollars (hereinafter "Marital Portion of TSP"). Wife further acknowledges that sbe has been infOlmed of her right to obtain an independent appraisal and/or valuation of Husband's TSP arid any marital interest she may have therein; however, she has decided that sbe will not undcmake the expense to do so and both Parties hereto agree to use the Marital Portion ofTSP, as defined above, for purposes of this Agreement. The Parties further agree that Wife shall be entitled to half the Marital Portion of Husband's TSP, or Seventy-Two Thousand Six Hundred Forty-Four and 34/100 ($72,644.34) Dollars, which Husband sball convey to Wife from his TSP into a qualified account in Wife's name through the use of a QDRO or otherwise, which sum of money shall become Wife's sole and separate property. Husband shall, within thirty (30) days of the date of this Agreement, execute the necessary paperwork to commence the roll-over process. Except as otherwise herein provided, Wife hereby forever waives and relinquishes any right, title, interest or claim she might otherwise have in and to Husband's aforesaid TSP. KSJ \'<S1' Page 13 of 25 MDJ -1??.td Wife hereby acknowledges that the marital property of the Parties' may include any marital portion of Husband's Basic Benefit PlanIPension (hereinafter "Pension") through the Federal Employee's Retirement System (FERS). The Pension is solely in Husband's name and according to an appraisal by Pension Appraisers, Inc, the value of the marital portion of Husband's Pension is Fifty-Six Thousand Thirty-Three and 91/100 ($56,033.91) Dollars. A copy of the June 30,2005 Pension Valuation is attached hereto as Exhibit "f' and is incorporated herein by reference. In exchange for Husband signing over his right, title and interest in and to the Marital Residence, Wife hereby forever waives and relinquishes any right, title interest or claim she might othenll'ise have in and to Husband's aforesaid Pension. (9) TIMESHARE: The Parties hereto are joint owners of a Timeshare in James County City, Virginia at Manor Club at Ford's Colony (hereinafter "Timeshare"). Contemporaneously with the execution of this Agreement, Husband agrees that as part of this property settIement, he will convey all of his right, title and interest in and to the Timeshare to Wife. Husband shall, simultaneous with the execution of this Agreement, execute and deliver to Wife a Special Warranty Deed conveying Husband's interest in and to the Timeshare to Wife. From the date of execution hereof, Wife hereby agrees to indemnify and hold harmIess Husband with respect to any and all obligations associated with the Timeshare. KSJ j( ~ .f' Page 14 of25 MDJ~tl:1 (10) WAIVER of ALIMONY: The Parties acknowledge that each has income and assets satisfactory to meet his and her own reasonable needs. Each Party waives any claim he or she may have, one against the other, for alimony, spousal support or alimony pendente lite. (11) DIVISION OF BANK ACCOUNTS: The Parties acknowledge that they jointly own a savings account with Diocese of Harrisblllfg, which as of December 31, 2004, had an account balance of One Thousand Twenty and 89/100 ($1020.89) Dollars. A copy ofthe December 31, 2004 Diocese of Harrisburg Account Statement is attached hereto as Exhibit "K" and is incorporated herein by reference. Husband agrees that simultaneous with the execution of this Agreement, this savings account shall become the sole and separate property of Wife. Husband hereby relinquishes any right, title or interest he may have in and to the joint Diocese of Harrisburg Savings Account. All other joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. Additionally, the Parties acknowledge that the Children each have accounts with Member's First Federal Credit Union, with Husband as joint owner thereof. The Parties agree that the Children's accounts shall remain the property of the Children and shall be used for the benefit of the Children. As of December 31,2004 Kaitlyn's account had a balance of Three Thousand Six Hundred Thirteen and 691100 ($3,613.69) Dollars and Abigail's account had a balance of Three Thousand Five Hundred Seventy-Six and 861100 ($3,576.86) Dollars. /.' KSJ KS:J Page 15 of25 MDJ -'In (XI Further, the Parties hereto acknowledge and agree that Wife, individually, has a savings account with Commerce Bank, account number 0626561013, which as of March 31, 2004, had a balance of Fourteen Thousand Twenty-I'our and 73/100 ($14,024.73) Dollars (hereinafter "Commerce Account"). A copy of the December 31, 2004 Commerce Account statement is attached hereto as Exhibit "L" and is incorporated herein by reference. Husband agrees that simultaneous with the execution of this Agreement, this Commerce Account shall become the sole and separate property of Wife. Husband hereby relinquishes any right, title or interest he may have in and to Wife's Commerce Account. (I 2) AFTER-ACQUIRED PROPERTY: Each of the Parties shall own and enjoy, independently of any claims or rights of the other all real property and all items of personal property, tangible or intangible, hereafter acquired, V\1th full power to dispose of the same as fully and effectively as though he or she were unmanied. Any property so acquired shall be owned solely by that party and the other party shall have no claim to that property. (13) TAX MATTERS: The Parties have negotiated this Agreement with the understanding and intention to divide their mutual property. The Parties have determined that such division conforms to a right and just standard wi11h regard to the rights of each party. The division of existing marital property is not, except as may be otherVlise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of Section 1041 of the Internal Rl,venue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. KSJ \<S.1 Page 16 of25 MDr1ntd (14) DEPENDENCY EXEMPTIONS: For so long as Wife is the primary custodian, the Parties agree that Wife shall be entitled to claim the deduction for the dependency exemption for the parties minor children under Section 152(e) of the Internal Revenue Code of 1954, as amended. If necessary, Husbarld agrees that he will sign the Internal Revenue Form 8332 or any other declaration requirl:rl by the Treasury Department or the Internal Revenue Service to implement this Agreeml:nt and agrees to provide such declaration to Husband, within ten (10) days of a request to sign such document. (15) ARRANGEMENTS FOR COLLEGE: Husband and Wife agree to provide financial support for their Children's undergraduate: college educations, provided that (1) such contribution would not create undue financial hardship; (2) each child demonstrates an ability, willingness and desire to pursue and complete a course of study; (3) each of the parents is consulted and permitted to participate in the choice of educational institution and course of study; and (4) each child makes all reasonable efforts to obtain grants, scholarships and/or educational loans. To the extent that a college fund, trust or UGMAIUTMA account may exist, such financial resourc~s shall be exhausted before Husband or Wife shall be required to make any contributions, (16) CHILD SUPPORT: The Parties hereto have reached an agreement with regard to Husband's payment of child support to Wife. The fully-executed Stipulation and Agreement for Payment of Child Support is attached hl:retO as Exhibit "M" and is incorporated herein by reference as if set forth fully herein. KSJ KS3 Page 17 of25 MDJ ~tV (17) LIFE INSURANCE: The Parties acknowledge that Wife has a $135,000.00 term life insurance policy through her employment with Hoover. Husband will be removed as beneficiary of this life insurance policy upon entry of a Final Decree in Divorce and Wife shall list the children, as irrevocable beneficiaries under the policy. The Parties further acknowledge that Wife has a $100,000.00 term life insurance policy. Husband will be removed as beneficiary of this life insurance policy upon entry of a Final Decree in Divorce and Wife shall list the children as irrevocable beneficiaries under this policy. The Parties further acknowledge that Husband has a $200,000.00 life insurance policy through his employment with the federal government. Husband shall retain this policy and upon entry of a Final Decree in Divorce, Husband shall list the children as irrevocable beneficiaries under the policy. Neither Party shall borrow against or in any way encumber the life insurance policies referenced in this Paragraph. (18) ATTORNEY'S FEES: Except as otherwise provided herein, each ofrthe Parties waives the right to receive a payment for counsel fees form the other, and each shall be responsible for his or her own counsel fees, costs and expenses, if such fees or expenses are incurred. KSJ K S3 Page 18 of25 MDJ -7hl';f;f Wife has paid the initial consultation fee ($150.00) 8J~d retainer ($500.00) to Daley, Zucker & Gingrich, LLC, and Husband has agreed to pay all other fees and costs associated with the finalization of the Divorce, Custody and Support matters. Wife will provide to Husband redacted copies of the invoices and Husband shall pay to Wife Twenty-Five ($25.00) Dollars every two (2) weeks, to coincide with his pay, until Wife is paid back in full. (I 9) ADVICE of COUNSEL: The Parties hereto acknowledge and declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Wife has been independently represented by Lindsay Gingrich Maclay, Esquire, of Daley, Zucker & Gingrich, LLC, and that Husband, has been independently represented by Thomas D. Gould, Esquire. Each Party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. (20) ADDmONAL INSTRUMENTS: Except as otherVlise herein provided, each of the Parties shall from time to time, at the request oftbe other, execute, acknowledge and deliver to the other Party, within ten (10) days of any request to do so, any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. KSJ \<.sj Page 19 of25 MDJ hnttf (21) INCOME TAX: The Parties hereby acknowledge that have filed joint federal, state, and local income tax returns for the year of 2004. The Parties hereto agree to equally divide any and all income tax returns for the tax year 2004. The Parties hereto agree to file separate returns for all ongoing years, specifically including 2005 and 2006. (22) BANKRUPTCY: The Parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files: such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other Party shall have the right to declare this Agreement to be null and void and lto terminate this Agreement in which event the division of the Parties' marital assets and all other rights determined by this Agreement, including alimony, shall be subject to court determination the same as if this Agreement had never been entered into. (23) COMPLETE DISCLOSURE: Each of the Parties hereto acknowledges that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for production of documents, the taking or oral depositions, the filing of inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each Party further acknowledges that he or she has had the opportunity to discuss Vlith counsel, if desired, the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The Parties do hereby acknowledge that there has been full and fair KSJ kS;:( Page 20 of25 MDJ /]'hllf disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly, in the name of one Party alone or in the n.lll1le of one of the Parties and another individual or individuals. Each Party agrees that any right to further disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby specificaIly waived, and other than provided herein, the Parties do not wish to make or append hereto any further enumeration or statement. Specifically, other than already provided, each Party waives the need for copies of additional bank statements, insurance policies, retirement plan statements or any other documentalion. Each Party warrants that he or she is not aware of any marital asset, which is not iderltified in this Agreement. The Parties hereby acknowledge and agree that the division of assets as set forth in this Agreement is fair, reasonable and equitable, and is satiSfactOlY to them. Each of the Parties hereto further covenants and agrees for himself and herself llnd his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other Party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to fuIl disclosure, or that there was any fraud, duress, undue influence or that there wals a failure to have available to him or her full, proper and independent representation by lega~ counsel. KSJ 1<5:f Page 21 of25 MDJ /lVJf (24) WAIVER of APPRAISALS: The Parties acknowledge that they are aware of their respective rights pursuant to the Pennsylvania Divorce Code to obtain formal valuations or appraisals of the real estate, the personal property, the vehicles, and 401K's and IRA's, some or all of which were acquired during the marriage and therefore constitute marital property. However, the Parties have determined that they will not undertake the expense to have these items appraised and/or valuated, and that the division of property as set forth in this agreement, represents a fair and equitable distribution. (25) RIGHTS and RESPONSmILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (26) FULL SETTLEMENT: Except as herllin othernise provided, each Party hereby releases the other from any and all claims, or demands up to the date of execution hereof It is further specifically understood and agreed by and between the Parties hereto that each Party accepts the provisions herein made in lieu of and in full settIement and satisfaction of any and all of said Party's rights against the other for past, present and future claims on account of support, maintenan(;e, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distributioll of marital property and any other claims of the Party, including all claims which have been raised or may be raised in an action for Divorce. KSJ Ksf Page 22 of25 MDJ/1>"aJ (27) RELEASE of ALL CLAIMS: Except as otherVlise provided herein, each Party releases and discharges completely and forever the other from any and all right, title, interest or claim of past, present or future support, division of property, including income of gain from property hereafter accruing, right of dower or curtesy, the right to act as administrator or executor of the estate of the other, the right to a distributive share of the other's estate, any right of exemption in the estate of the othl:r, or any other property rights, benefits or privileges accruing to either party by virtue of their marriage relationship, or otherVlise, whether the same are conferred by statutory or common law of the Commonwealth of Pennsylvania, or any other state, or of the statutory or common law of the United States of America. Except as provided herein, thl: Parties specifically waive any and all rights that they may have to equitable distribution of marital property and/or alimony and counsel fees, except those counsel fees sought in the event of a breach of this Agreement, or any other marital rights as provided in the PemlSylvania Divorce Code, Act 26 of 1980 or any amendment thereto. It is further specifically understood and agreed by and between the Parties hereto, that each Party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said Parties' rights against the other for any past, present and future claims on account of support; maintenance; alimony; alimony pendente lite; counsel fees, costs and expenses, except those counsel fees, costs and/or expenses sought in the event of a breach of this Agreement; equitable distribution of marital property and any other claims of each party, including all claims raised by them in any future Divorce action between the Parties. KSJ K S.J Page 23 of25 MDJ /NJJ (28) SEPARABILI1Y of PROVISIONS: If any term, condition, clause or provision of this agreement shall be determined or declar,:d to be void or invalid in law or otherVlise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this agreement shall continue in full force, effect and operation. (29) GOVERNING LAW: All matters affecting the interpretation of this Agreement and the rights of the Parties hereto shall be governed by the laws of the Commonwealth of Pennsylvania. (30) INCORPORATION into DIVORCE DECREE: The Parties agree that this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. Upon entry of the Decree, the provisions of this Agreement may be incorporated by reference or in substance, but they shall not be deemed merged into such Decree. The Agrl:ement shall survive any such Decree in Divorce, shall be independent thereof, and the Parties intend that all obligations contained in this Agreement shall retain their contract:wal nature in any enforcement proceedings, whether enforcement is sought in an action on the contact itself at law or in equity, or in any enforcement action filed in a Divorce action. KSJ KSJ Page 24 of 25 MDJ flYoof (31) BREACH: It is expressly stipulated that in the event that either Party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other Party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (32) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the Parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (33) AGREEMENT BINDING on PARTIES and HEIRS: It is understood and agreed that not only the Parties hereto, but also their heirs, administrators, executors and assigns, shall be bound by all the terms, conditions and clauses of this Agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and year first above written. WITNESS: ~ 1s:b4Jndtk,) ~l S. Jord -11w. dh~. ~ Thomas D. Gould, Esquire Attorney for Husband ~~#~ Mark D. Jordan;TIefendant KSJ ",.:;1' Page 25 of25 - MDJ ~OJ LO o o N ~ <( ::J Z <( -, I- Z w 2 w ~ U) Z <( o ---1 W 2 o :r: fla Washingto9 Mutual HOME LOANS Washington Mutual Bank, FA Customer Service: Toll free 1.866.926.8937 Se habla espanal TDO: Dial 7-1-1 for relay assistance www.WaMuHomeLoans.com #BWNCLNN #3959729601926396# 200451001 AT0.292 -Auro T60901617055-4B68 MA1 1..,111,"11I...,1,1.,1,1..1..11..1,.11..1..1.11...,.11...11,1 MARK D JORDAN KATHLEEN 5 JORDAN 3 5NA LN MECHANICSBURG PA 17055-4868 I Your Next Payment Next Payment Due: Principal and Interest: Escrow: Current Payment: T otel Amount Due:* $ $ $ <.C: March 01, 2005 1.126.04 274.31 1,400.35 1.400~ I Important Messages * To avoid a late charge of $56.30, we must receive your payment of principal, interest, and any escrow deposi-ts and/or past-due paym~ts by 03116105 during our business hours. If this date falls on a weekend or holiday, your payment must be received by the next business day. Please see the reverse side for Recent Account Activity. 20045100004514 Page 1 of2 Home Loan Statement January 2005 Statement Date: Activity Since: Your loan Number: January 27, 2005 December 31, 2004 5972601263 I Your Property and Loan Information Property Address: 3 5NA LANE. LOWER ALLEN lWP. PA 17055 $ 112,263.22 5.75000% 1,914.76 Principal Balance: Interest Rate: Escrow Balance: $ Did You Know? It is not nece;sary to send us your regular current real estate tax bill unless we reguest it. In most cases, the current real estate tax bill, is a copy of the bill the taxing authority has alrea_dy supplied to the mO,rtgage company for loans with an escrowaCCOLIOt. Itis generally the customer's responsibility- to pay supplemental, occupancy and special assessment bills. I Year to Date Account Activity Principal Paid: $ Interest Paid: $ Property Taxes Paid: $ Insurance Paid: $ 585.31 540.73 0.00 0.00 Please return bottom portion with your payment (allow 7-1Q days for po$tsl ~eIive'ry). -. FQfC! e Marital Property Serial Number M62719011EE C655228415EE C664179452EE C662120975EE C659576324EE C660737485EE C654445842EE C638504966EE C633674575EE C631394359EE C621866347EE C628377153EE C620602119EE C615153190EE C614069461EE C433895314EE C43461160lEE C577254694EE C580516982EE C595270707EE C593428319EE C51480106lEE C509357499EE C604419973EE C551312236EE C508589625EE C47262260lEE C463883463EE C46456246lEE C486551260EE C487085474EE C487390599EE C464857197EE C435321393EE C447807974EE C447279122EE C473224708EE C503956707EE C493939466EE C516789103EE C522608629EE C535000496EE Face Amount $1,000.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 BONDS Issued To Kathleen Sweeney Jordan KSJ or Mark Jordan KSJ or MJ KSJ or MJ KSJorMJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJorMJ KSJ or MJ KSJ or MJ KSJ KSJ KSJ KSJ KSJ or MJ KSJ or MJ KSJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ Date Issued 12/95 10/98 3/99 1/99 11/98 12198 10/98 3/98 2/98 12/97 10/97 11/97 9/97 8/97 7/97 9/93 I 1/93 8/96 9/96 1/97 12196 3/95 2/95 3/97 12/95 1/95 6/94 2/94 3/94 9/94 9/94 10/94 4/94 12/93 1/94 12/93 6/94 12/94 11/94 5/95 6/95 5/96 Marital Property Serial Number C571529260EE C566915835EE C58535072lEE C583607402EE C572863876EE C548104065EE C540825142EE C530277946EE C53231380lEE C535688408EE C537958058EE C504924285EE C552932827EE C557041288EE C560611476EE C606242956EE C597894925EE C610977465EE C60232262lEE C613727890EE C639270953EE C640826767EE C645749013EE C649547435EE C646703663EE C651235228EE BONDS (Cont.l, Face Amount $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 $100.00 Pre-Marital Property SmalNumb~ Face Amount C326904942EE $100.00 C326931166EE $100.00 C321469750EE $100.00 C321469792EE $100.00 C321469675EE $100.00 C381703006EE $100.00 C381703147EE $100.00 C382380352EE $100.00 C382380513EE $100.00 C382421940EE $100.00 C321850286EE $100.00 C321850305EE $100.00 C433476895EE $100.00 Issued To KSJ KSJ or MJ KSJ KSJ KSJ KSJ KSJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ KSJ or MJ Issued To Kathleen A. Sweeney KAS KAS KAS KAS KAS KAS KAS KAS KAS KAS KAS KAS Date Issued 6/96 4/96 I 1/96 10/96 7/96 12/95 10/95 7/95 7/95 8/95 9/95 1/95 1/96 2/96 3/96 4/97 4/97 6/97 6/97 7/97 3/98 5/98 5/98 7/98 6/98 8/98 Date Issued 7/92 9/92 10/92 11/92 12/92 1/93 2/93 3/93 4/93 6/93 6/93 7/93 9/93 BONDS (Cont.) Abigail's Bonds Serial Number Face Amount Issued To Date Issued C650527877EE $100.00 Abigail J. Jorrum or MJ 8/98 L003762040I $50.00 AIJorMJ 8/01 C703632343EE $100.00 AIJorMJ 8/00 C669457194EE $100.00 Abigail L. Jordan or MJ 8/99 C774876630EE $100.00 AIJorMJ 8/03 C745595335EE $100.00 AIJ or MJ 8/02 C620602416EE $100.00 AIJ or MJ 9/97 L560593073EE $50.00 Abigail Jordan or MJ 9/97 L560593072EE $50.00 AIJ or MJ 9/97 Kaitlyn's Bonds Serial Number Face Amount Issued To Date Issued C647111155EE $100.00 Kathlyn L. Jordan or MJ 7/98 C668334073EE $100.00 Kaitlyn L. Jordan or MJ 7/99 C695228107EE $100.00 KLJ or MJ 7/00 C744804927EE $100.00 KU or MJ 7/02 C725919039EE $100.00 KLJ or MJ 7/01 C77487663lEE $100.00 KU or MJ 8/03 L527437517EE $50.00 KLJ or MJ 8/94 L52741276lEE $50.00 KU or MJ 8/94 C481348672EE $100.00 KLJ or MJ 8/94 C530511724EE $100.00 KLJ or MJ 7/95 C486474496EE $100.00 KLJ or MJ 8/94 L52738740lEE $50.00 KLJ 8/94 L526789736EE $50.00 KLJ or MJ 8/94 C572437129EE $100.00 KLJ or MJ 7/96 The right choice for the long term3 @ American Funds" PO Box 2280 . Norfolk VA 23501-2280 Divi4erid Confirinatio:n . becember31; 2004 Your financial adviser KATHLEEN S JORDAN 3 SNA LN MECHANICSBURG PA 17055-4868 1,.,III",III""I.I"I,I"I"II.,I"II"I~I,II.",,11",11,1 AMERITAS INVESTMENT CORP. C/O WEAVER FINANCIAL SRVCS INC 887 S ARLINGTON AVE HARRISBURG PA 17109-5004 Rep name WEAVER Transactions THE CASH MANAGEMENT TRUST OF AMERICA-A Fund number 09 Account number 64468327 Dividends (reinvest) and capital gains Ire invest) Sheres this T!.~!!!_~~.~l!...............~l!.~:!.iJ!.~{f!.'!......._.........._........_._................m___.........._.........J}.'!.!{~La.l}!f!-'!.'!Lmm~~!~.!.!E!.{~-'~....._...._.............._..~!!.~!!~~~!!.................._......?~~r:...~~!~'!.~~ 12/31/04 BEGINNING SHARE BALANCE INCOME DIVIDEND $7 .01 $1. 01] 7.010 5,135.B9o 5,142.900 Ending value as of 12/31/04 was $5.142.90 Year-to-date income summary ............................-.............................-.-....-............................................-............. Dividends $51.52 Short-term cepital gains $0.00 long-term capitel geins $0.00 For more account information . Callyourfinancialadviser . 24-hour automated infonnation and services American FundsLine@l 800325-3590 American Funds Web site www.americanfunds.com . Personal assi:;tance - 8 8.m. to 8 p.m. Eastern time M - F ShareholderSe",ices 1800 421-0180 To add to your investment __........................._.._.....................................m.._......_._.............................................__......._......_...................................................._........_.._..__.....__............................_..........._.. Make check payable to American Funds Service Company. Please write your account number on your "check. Do not send cash. KATHLEEN S JORDAN If investing in a new fund, please obtain a prospectus from your financial adviser or our Web site. Fund Fund Account numher number Investment amount AMERICAN FUNDS SERVICE COMPANY PO BOX 2280 NORFOLK VA 23501-2280 1"1,1.,11"1,1,1',,,,,,11,,1,1,,1,11,,1,11,,,1,,',11,,,1,1,,1 ~_E__~_S_~_I.1~~~g.M.!,.lfl")11.U.s.IQE.A_M_~~I~~:~________________ ._~9._._ .._~~~9.32!____ ~___..__._._......______.___ $ Check total $ 40[J8269[J10 Rl"OOQ644663271" CRllllll001171BSSRCM004 0000 14754810 000644683278 0000009 "0 . g ~ ~ " rr~ U ~ ~ . . ..". 2 1;:' ~1l ~!!l ~." ~a o 0 o g ~ ~ I==~ n~ 1;;'3:' " ~ ~V:' 5.5 :r~ ~ S !f~ -' ifg, ""'" 5 a ~~ " ~ iL~ ~ if ~~ el r ~~ g ~ So g, ~ 0 ""s- o .. 5.!!l ." ~ o . rt ~ 00 ~ - !l'1r ~ S' "" o g ~ '" " SO ~. .,. o " '" ~ '" [ o S " .,. o " " :i ~ " '" " '" o " ~ ::r " ~ :;1 " '" ~. '" !' . >g ~ Ei" 0;:;' >-l :;l ~c:iil~if is... !!l::lOC!"d ~S."OS'O __FiiUlUl::l. ~'=s""~O' o..:::r~ a =' =:' "d /ii'"Q' a =r' 0 f9 lit g !;"< ~ g.~Z:ioga ;t s !.ff:. 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O-n e Q..,~~ '" o ~- ~ >-<: o~ ~ 0"'"'1:1 ::tfl.-O'q' e~ s n~ o tl " ::l " lD -.!;;! a " T ~ ~;..nn "1 (D '"d < &" S 0 0 0 1;:0 p..n !!l n go-", [l o '"1 ""C 0 n ,,0 a:lDElfl '"dr+'"1g "~!lJg " ~. ~w ~ ~~. ~ ~ 0 0 !' .. $8 ~ g :E so.." ~ !lll 'T1 i5: 13'" p~e s. ... ",,'~ r. g o~ o -n n.~ ~ ~ 0...8 S " '< (1) ~s _ ~ ~o ",~Cl.. ~ ..... 0" = i5"z iii ~ ::;!~ ,..., Cl.. c' c. p.. " p.. ~ g ~ ~ ~ ::l OOQ 0:' (b ~. S. 1:3 t:r f,I:I (0 (b ~ < I-tl ...... ~i ~ S i:j> ~ il (tI (D 0 J>> S'~f!~ Q '" !! 8 ~ s :::.. @ ~g ~ sc" EI ~::foCP ; 0 ....lD _'< = ~~t:l:l '"B. 0 S 5;"'<rg" . f1q "1 ., ~ -f>- ~ft-[l !D6 ~ r " ~ EI <l ~ ~ ~a.$p.. ...-~ g- ee. @ ~ :5,~;:; " ~ ~ ~ p_a . SCp..~ t:J . ~ 1l;" " ~ O...roUl 8 (;)~ ~~] ~ " 0 " p. " I ~~x g o' (0 5' Er n M- e: s ro n ~ ~ a ~ .,. 0 <"" 0" ~ " ".~ ~ a ~ ,," n' ~ ~ ~ ~ ,,<lD Ie., " . it g lii': E.. ~,,~ ~ '"," ct.W ~ n o' 0...1;]Q 0 - g ~ c' .1J : i g.~' t",t:J Q .....",,:<' . " ? it> <F> it> !1 ..g ~ ',< " ....'1;, .., S~q> 0 ~ 0"' !e n 0 ~ "" ~"'-~ 0 0 l1) !:r hl " ~oo 0 ~ '" '" ~..s: n"'~ 0 0 0 ~ ~ if '" 0 0 ri- e -f>- ~ N KATHLEEN S JORDAN 3 SNA LANE MECHANICSBI,IRG PA 17055 SSN: Dale of Birth: Date of Hire: HOOVER REHABILITATION SERVICE, INC 166 - 80074 Statement for the period of October 1,2004 to December 31,2004 This statement has been provided by Nationwide Financial, your employer, and your third party administrator. '<!1 ' . , r -, "':' ';'!@.!F '1Kiit'1ijc f,':iii.@jJ~'i'\i"'litJr"lt::" ' :' ~ ,', ~~,;<~, -, .'" ,- ''''' - < ." '~"-"- -,- .~ (,: 11~1i\ie~~~: (~~,j'.~~~f~I~~VrJi~tf~ ' ~,I,' o " , " ~ '" ~" ." t: \ ' XXX-XX-0662 01/17/1959 10/06/1980 YOUR RETIREMENT PORTFOLIO FROM 10/01/2004 TO 1?f31/2004 Your Recent Retirement Account History' $33,630 Openin9 Value on 10/01/2004 Contributions Investment Gain/(Loss) Total Account Value on 12/31/2004 $29 879,48 $1:404.90 . $2,345.13 $33,629.51 . o o ... p $0 $2G.87G $33,630 Sep 30, 2004 Dee 31, 2004 "Corrections made after the close of past periods are not reflected in this representation. -- !!!!!! -- - -- -- - -- -- Moderate 61.24 % -Growth Fund Of America R3 -Investment Co Of Amer R3 Drey Ap~reciation Fnd Rd Adv Equ Incm Fnd Cis A Janus Adv Worldwide Fnd Low 38.760/0 -Capital Income Builder R3 -Income Fund Of America R3 Aim Total Retum Fd Ic Fed Bond Fnd Cis F $124.96 $7,708;92 $0.00 $12,760.45 $0.00 $4,692.3G $8,342.79 $0.00 $0.00 1.255277 1.155718 0.974930 1.420199 0.595893 1275039 1.250576 1.158887 1.387270 -- - -- !!!!!! Total Account Value $33,629.51 . 100% Low Due to rounding, Total Account Value percentage may not equal 100%. Your actual balance may be different if you are not yet fully vested with your employer. Please contact your employer for details. 00000259 Page 1 of7 . Account Access, Account Balance Page 1 ofl Account Access Your Civilian Account Account Balance Your account balance based on the most recent share prices as of close of business 02/25/2005 is shown below. This information is updated by 6 a.m. eastern time of each business day. On occasion, heavy volume during the nightly processing cyqle may d~lay the update a few hours. Contributions to your account are being invested as follows: G FUND 0% , F FUND 0%, C FUND 100% , S FUND 0%, I FUND 0% , Investment Fund Shares Share Price Balance Distributior '\ G FUND GOVERNMENT SECURITIES 742.6190 $10.75 $7,983.16 4.98% F FUND FIXED INCOME INDEX 1,136.8870 10.46 11,891.84 7.43% C FUND COMMON STOCK INDEX 10,840.2310 12.94 140,272.59 87.59% S FUND SMALL CAP STOCK INOEX 0.0000 14.59 0.00 0.00% I FUND INTERNATIONAL STOCK INDEX 0.0000 15.82 0.00 0.00% Total $160,147.59 100.00% IAccount Access Menul .~; Your Account Balance I participant Statements I Contribution Allocations llnterfund Transfers I Loans I Withdrawals I Create Your Own PIN I Your TSP Address Ilocou! https:lltspweb2.tspsec.tsp.govINASApp/tso/accountBalance.do?GXHC OX 1 <t=')"277 4 7"... 7/?R/?OO'i APR-13-2005 21:00 P.02 .~ '. .... THRIFT SA~S PLAN : - P ARTICIP ANJ.<S.T A TEMENT H, . .~I J . . Your Thrift Savlng5 Plal"I lTsP) ~CCQUr,.t statement is issued every $ix months. by tne Niltionel Finance Center for the Fe.de.raf Rlt!irernent Thrfft Investment Bojrd. ~D~ .additional informatiOofl or to ~ot'tect Y4)Ur 8ddre-,s or any of the followinSil items, pleise oontact yOLlr agency e~'pl'o~f.(ng office. N.ms: "'ARK 0 JOROAN 5001.1 Sacurity NUlT1ber: 197-40'-€l113 D.te 01 Birth: 05/09/62 For thi,.- period: 05/01193 through 10/31/93 Relirement Covorogo: FERS (K) Separation StaW!;: Not sepM"it~d Total Service Raquir"d lor Ye..t~e:' '~ V.a.r. from 09/06/94 (TSP Service ComPutalion Dale) Parson. I Identification Number. i~N~ ':~485 for the TSP InQultY Lin. 504-255-6777 "[ , .' G FUND Govertttnent Securities Invutment FlJnd F FUND Fixed (ncQmll InoAx lnvest"'8 nt Fund C FUND Common stock Index Jnvestmel1t F:ur,d TOTAL ACCOUNT BALANCE Rates of Return * (Numbers in p.:lrenth!~~$ arC! negative) G Fund F Fund C Fund ,~egin,~r'lg S,II,nce TnJt)$~On$ ,This Period ~"IIlllS Thi. Poticd . . . Ending 9.laoee 'I , . . , l1~Qin~inQ Balanee TranselotKmS, Thts Period . I. "Ear!iil1!ls IThi. Period , . . . i;IIdil1ll eollnee ~'.9';bi09 a.lonee TransaC't)on'" Thi. Period .' . Ear:'nin~ This Period . . ,Eslding Balance ., ..a..g"",l~g e.Jance rn'f1s.ac~io,:,s' ,This Period &ornings'Till. Period ~din'g Balance Eh\pioyee 593.4,d 0.00 17.56 611.00 875.24 201.32 46.B4 1.'23.40 3,741.17 605.20 321. 19 4.867.56 5.209.85 1.008.52 385.59 6.601.96 Source elf Contributions Agem;y A.ui'omatie: (1961 Agency M.tohlng 2,177,52 1.298.60 0.00 0.00 64.51 38.46 2,242.03 , . SS7 . 06 214.55 759.38 0'/5.92 147.42 11.25 40,2/5 21'2.72 947.0/5 6Ei5.77 2.32S.22 '''7.42 SSS.S 1 ~iS. 73 203.92 859.92 3.122,95 3.0":~7.B.4 4.367.20 Ht4.3.4 737,23 1::12..49 2S2.64 3,3E14.61 5.407.07 1993 July Aueu.t Septomber O.tobor .49" .49% .45% .47" .55% 1.72% .26% .38% (,38%) 3.7S% 1.76"> 2,04% TSP-B~A: . . . ... Total 4.069.56 0.00' ,20.53' 4,190.~ 1.8,a9.17 3e5.~6 9B.3,!j 2.333. ,~ G.ne,le , .542.431 5B1.804 B.B=O.4,~ 12.644.89 ".92~.~ 800. 7~ 1~.37'3..1~(}c" lad 12 Mon"""" 'No. '92~Oot '9:l1: 6,35" 11.57% 14.94% . ,A.c:r"....1 r.tn. 01 return IIHer Ildm,lnistTe.'tiv,_ .:aepeMIll.... The rnon.,p.ly rilles of retUrrl 8t8 rl'l. r",..s. l,Islid TD campu!_ thE actUlilI1 al!tfl\rl\g'S on. your IJi;C~ ,ac:h mcomh, illS ducribed en 'the back of t'hh .l....~.bt. i~. 12-mO-rWt rtlr"$ oi rq(urn shew tha iJ'lw't!l!:tlli:lalll r.erfonnence 01 only 'hi' portioFl of your oIl,CC,(lollt\t that WI1I InV8$t.d fOT tk$ ~tln 12"mgn1h p.r,ro~' 8,daus.. of th. i'ltnin; .!lnd ~moun\ or '(aut cQntrlbutnrl'\s. nuufund ttllnli1eu. .ntl Qtl"lllr lr1lllnIJlIIe.1.iO!'lJ, you G:1lM'\ot WlIJII the 12"mDn.th l'Z1tU of tetUfJ'l s.hoNl\.attOVII '0 c.le:Ul&t& your 8ctLu,1 urJllng-; (or t~e Novetr\bclr leU. Ol;!tobor 1993 p.riQd. Th~f. i! risk !)f' h""lInm.nt loas. in bath. ,.hll , !1M 'hI! C Fundi_ Theu 1::1 PO ,....unnC'1I th" plfi'l ,,'tU' of rllW'" will bv r"p.~fild in thg fIJ!lJr~. " I=ORM TSP.S-A lFievla.eocf 1119,31 !$ your addre~s ineorrecr? See instruq"t1o~' at top of statsmsnL MIIY .51:% .10"" Z.6~~ June .51% 1.79% ,32% t, '. 8402~9'88pN ~~ 2~ '2177 2100655, 1-018'0 ":000009432 IlJJIIJlltIIIJIIIIIIJlllllll.llh\l:~~.lt:'li'lifiliIIIIIIIJlIIIIIII MA~I( 0 ..rORDljti ~1' 3 SNA LAI.1E MECHAN!CseClRGI ,p:i,.... i.'7055-4869 'I.,' .. ;. ."', .' TSP Clpen Sea50n is Nove'tlbar 15 - January' 3 of ~ To o~lange your con'tribu't1ons a5k you.r pa~:ton" n01 "Hic. fo~ tho TS~ Election Form' (1SP-"'). To Change the way money a 1 raady in ypur" aocOlln1: ;s invEls1:ed, a.sk your agenoy <for" an ' lnterfUnd Tr..nshr Request (Form TS~-30). or cC!.11 'trte TSP InQUiry 1.ine for ~he 'form. " '>, APR-13-2005 21:00 DETAIL OF ACCOUNT A€TJVJTY N.mal MARK 0 ~O~DAN A,ctlvlty Fl.yroll . Code Offic;~ Poy 0:11'11 ,. prOC:.lls . Dl!l'\. ~~Pl9Y"6 MONTH-END BALANCE APR 1993 o 21006551 05/07/63 O~/10/5~ o 21006551 05/~1/93 OS/24/93 E MONTH-END BALANCE MAY '563 o 2'005551 05/04/93 05/07/93 o 21006551 05/1B/93 06/21/93 E MONTH-END BALANCE ~UN 1993 o ~100B551 07/02/93 07/02/93 o 21006551 07/'B/93 07/'9/93 E MONTH-END BALANCE JUL 1993 o 2100B551 07/30/93 OB/03/93 o 21005551 OB/13/93 09/HIIIl3' o 21005551 OB/27/93 09/27/93 E MONTH-END 5ALANCE AUG 1993 o 2100.651 09/10/93 09/13/93 o 2100.551 09/24/93 09/24/93 E MONTH-END BALANCE SEP 1993 D 21006551 10/08/83 10/12/93 o 21006551 10122/53 '0/26/"3 E MONTH-END BALANCE OCT 1993 5,~09.55 70.88 70.85 105.0. 5,.S5.57 70. e.e !O.5e 32.35 '5,83,0.7S , . " 70.5S 10.BS 7.67- 5,7&4,.S7 70.8B " ,85.06 h 85.06 1~.'; '6'.1'81.ge &s.05 S~.06 2:9.32- ~,32:5.iS 85.05 e.os l'OB.OB 6'h~O'l .95 For the psrlod: 05/CIl/S3 through 10/31/S3 Source Sooial Security Numbe" 167-4Cl-S;;3 At'6nc.,. Autorflo!ltic 11%' 3,047.84 14.18 14.18 29. 15 3,105.35 14.15 14. IS 17.32 3,151.03 14.18 14.18 9.29 3,1BB.68 14,1S 14,18 14. ,a 43.70 3,274,92 14. I a 14.18 4.5S 3,307.86 14.18 14. IS 28.45 3.~64.67 Ap-Dl'\CY Mo:\ching 4,387.20 S6.71 56.71 70.67 .4.571.2.9 S6.71 56.71 28.B3 4,713.64 55.71 S6.71 0.91 4.827.97 56.71 56.71 55.71 124.70 5.12~.BO 56.7' 56.71 13.94- 5, 222. 29 S6.71 56.71 71.37 5.407.07 13 Fund 4,<l6e.S6 0.00 0,00 20.89 4,090.4$ 0.00 0,00 20..5 4. '111. 10 0.00 0.00 20.23 4, '131.33 0.00 0.00 0.00 20.30 olI/. 'IS1.S:i 0.00 0.00 16.84 4,170.47 0.00 0.00 19.62 4, '90.0S Date 0 f Birth: Investment I=und F Fund 1.849.17 36.3a 25.38 ;. 97 1,907.76 25.36 2S .36 34.59 1,999.07 2B.38 28.36 11.07 2.068.S8 28.36 31_19 31.19 36.41 :2,194.01 31.19 31.19 5.65 2,262.05 31. 19 31.19 S.75 2,333.18 C Fund 6,726.16 113.41 113.41 182.12 7, 1~5.10 113.41 113..41 23.36 7.365.29 113.41 113.41 2S.17- 7,583.33 113.41 124.76 124.76 293.80 6,240.05 124.76 124.76 63.1S- 8.426.40 124.76 124.76 174.51 9,950.43 P.03 TSP-8""'A OS/09/6~ Total 12.'644,-,~~ IA1.7: 141 . 7~ 204.81 13, \a3,. 3' ',' ' 14",7: 1'41 ~ 7~ 7B.5t 13,41l5.41 141.7: 141'" '1~' 2'~F5~ 13.781'.5; 141. 7: 155. 9~ 155,."~ 350:~' 14.58S.7( 155.9~ 1a5.9/ 38.6t 14,858.9: 155.9! 155_9:: 202'.96 15,973..7,( " .' " , ' , ' " " , , o "' Oaposlt e . EllIrp;nS'~ L .. ~QolIln P .. MQhthly 1"f:lfI p,pymllnt lilummery Activity Cod Si 1': ,It, In-tarff,lnd tfI!lP.r.'h!r Ft, 'II: 'J!cirf.tr.d nctl"'esletl t'nOf.I;.8S . ,R.i lI: ~~\ored 6MOUl'It! A." ACiJustml!lnt c "' E~rnif1g$ tor'r$'~l'ion Y . Eblllj"fl!l cOIr.a.ctlo~ tlbrufer V .. Re....ets.a-I of e.~ming!; cotre.ction B . D~c hl.f!:d abarllje.necl o = Cou:n-grder,d p.....m.n'( W. Withdr.lil.....liIl ' M . Minimum di$trlbu'tion N - II Refund-ed ~)(e-a~~ de.fe~re.[ ~DnttdY ~arJtin.q~ ~n CZlJCIJJII~.Q' 'by 'm~~l.yII),5' the. rllU 1)' rerom for 11'Ie mor'1tll. I!l;h.owo D)' the sum of your prior lTlOht"'....nd bel.hl:!. ,n.d on....batl CJ{ , 1: . ,(~t:al 0 depOSIt.. and 108" rltp.l$ymlllfJ1:. ~qrJ"J ocl'l,. mcmth .hown. Earntngoa are c(fldited at the 1!l1'1l1 of thl; 1T10n'tl'1 '!hown. /It.djunlT).,.t5. ..rning& ;:~rr.lXi"n~,J tClrlffltLcre.!I., IOIln.;., relltClrul IlfTlo.uftta~ 8n" ,WI'f:hClf.a~11t atfac:t YCII.lr IICQount. for the Qal~L1latfDn of eamin;s !It the. end 01 the mOnth ~hoWl"]. InterfufJd 'tr~lif.r'" ~~oo c:~.'.'dYtOLl( .~cC"houn~_ a1 tdh~ .~d Qf tbe mCl)'\tb .hown. PIIY datI: is l.hc dpte ropor1i'd by your payroll C1'fflce tOt do!lpO!:iU .and OlSl'tcin &djV$Tments. a e r.. t e "",\9 epO&rU end foan ~'ayme.n~ """.r.. ptoclI8Sad' to you' l!lCCOUl'lt by tht= T,S;l r~Clordlctl-llP.r. FORM TSp-e-A (Revised, 11/~3) TOTAL P.03 A @ PENSION APPRAISERS INC. p.o. Box 4396 . Allentown, PA 18105-4396 1-800-447-0084. Fax 610-770-9342 JUl 05 2005 E.-MAIL: penapp@pensionappraisers.com WWW: http://www.pensionappraisers.com June 30, 2005 Lindsay Maclay, Esq. 1029 Scenery Drive Harrisburg, Pennsylvania 17109 RE: Present Value of Mark D. Jordan's Defined Pension Benefit File No. 06-27-0S-210-1630G Dear Attorney Maclay: We have determined the present value of the marital share of Mark D. Jordan's defined pension benefit by the GATT Method as of June 30, 2005 to be $56,033.91. This valuation was developed and prepared in conformity with the requirements of the Actuarial Standards of Practice No. 34. These Standards were developed by the Pension Committee of the Actuarial Standards Board of the American Academy of Actuaries. The purpose is to set standards for Members and Other Persons Interested in Actuarial Practice Concerning Retirement Plan Benefits in Domestic Relations Actions. Pension Appraisers, Inc. relies on the requestor to provide the information necessary to value pensions. In some cases, information not provided by the requestor may be obtained from plan summaries on file in Pension Appraisers, lnc.'s offices. All information received from the requestor is reviewed for practicability and reasonableness. Any information in question is verified with the requestor, when possible. Any deficiencies in data may materially affect the results of the appraisal. Pension Appraisers, Inc. utilizes thEl fractional rule allocation method in valuing all pensions for equitable distribution purposes unless otherwise stated. BIRTH DATE: May 8,1962 SEX: Male MARRIAGE DATE: September 25, 1993 VALUATION DATE: June 30,2005 PENSION PLAN: Federal Employees' Retirement System DATE EMPLOYMENT STARTED: September 6, 1984 (Assumed date pension holder began participation in the plan) DATE BENEFITS STOPPED ACCRUING: January 16, 2005 (Assumed date pension holder ended participation in the plan) ASSUMED DATE MARRIAGE ENDED: January 16, 2005 AGE WHEN BENEFITS COMMENCE: 60 Years "Valuators of Defined Pension Benefits for Equitable Distribution" GAIT Actuarial and Mortality Tables Method June 30, 2005 Mark D. Jordan - # 06-27-05-210-1630G Page 2 MORTALITY TABLES: 1983 Group Annuity Mortality Tables INTEREST RATE ASSUMPTIONS: 4.33 % and 2.33 % 30-Year U.S. Treasury Bond Constant Maturity Rate for the Month of the Date of Valuation. U.S. Treasury Bond Rate: Estimated Cost of Living Adjustment: Adjusted Rate: ASSUMED MONTHLY BENEFIT: $1,152.04 Monthly pension benefit the pension holder would receive at retirement age with a fully vested pension based upon compensation and plan provisions as of January 16, 2005. 4.33% 2.00% 2.33% Formula: 1 % of High-three Average Pay multiplied by Years of Creditable Service equals Annual Benefit Data: High-Three Average Pay: $67,900 2005 $ 71,479 2004 $ 68,989 2003 $ 63.232 $203,700 $203.700 = $67,900.00 3 Years Years of Creditable Service: 20.36 Years (9/6/84 - 1116/05) Analysis: 0.01 x $67,900 x 20.36 = $13,824.44 (Annual Benefit) $13.824.44 = $1,152.04 (Monthly Benefit) 12 Months REDUCTION FOR NON-VESTING: 1.0000 Represents a reduction for the probability of selvice to 100 percent vesting as equal to the portion already completeld. GATT Actuarial and Mortality Tables Method June 30, 2005 Mark D. Jordan - # 06-27-05-21 0-1630G Page 3 REDUCTION FOR MARITAL COVERTURE FRACTION: 0.5555 Represents that portion of the value of the benefits attributable to the marriage. The numerator of the fraction represents the total period of time the pension holder participated in the plan during the marriage and the denominator is the total period the pension holder participated in the benefits program. PRESENT VALUE BEFORE REDUCTIONS: $100,871.12 Reduction for Non-vesting: Reduction for Marital Coverture: x 1.0000 0.5555 x VALUATION FOR EQUITABLE DISTRIBUTION: $ 56,033.91 This valuation was not completed in compliance with our understanding of Act 175. Office of Financial Administration Diocese of Harrisburg PO Box 3651 Harrisburg, Pennsylvania 171 05 Phone (717) 657-4804 Fax (717) 671-7021 DATE: 12/31/2004 MARK K JORDAN AND KATHLEEN S JORDAN OR SURVIVOR 3 SNA LANE MECHANICSBURG PA 17055 STATEMENT OF ACCOUNT FOR QUARTER ENDING 12/31/2004 Account No. 01-21790 DATE DEPOSITS WITHDRAWALS INTEREST PAID BALANCE BEGINNING BAL. 12/31/2004 7.81 1.013.08 1.020.89 * INTEREST PAID YEAR TO DATE 20.89 Commerce .Banlc Commerce Bank/Harrisburg N.A. 100 Senate Avenue Camp HiII.PA 170'11 BBB-93.7~DDD4 STATEMENT DATE KATHLEEN S SWEEm:y 1970 TECHNOLOGY PK MECHANICSBURG PA 17050 03/31/05 0626561013 ACCOUlVf NO. *** SAVINGS *** PREMIER SAVINGS -ACCOUNT NUMBER 0626561013 PREVIOUS STATEMENT BALANCE AS OF.02/28/05 .... .... ... ....... ...... PLUS -I DEPOSITS AND OTHER CREDITS ................... LESS 0 WITHDRAWALS_ AND OTHER DEBITS ........ . . . . . . . . CURRENT STATEMENT BALANCE AS OF 03/31/05 . .... .... ..... ..... ...... NUMBER OF DAYS IN THIS STATEMENT PERIOD 31 BEGINNING RATE CYCLE-052 0.99500 14,012.89 11. 84 .00 14,024.73 ----------------------------------------------------------------------------------- *** SAVINGS ACCOUNT TRANSACTIONS *** DATE DESCRIPTION 03/31 INTEREST PAYMENT DEBIT,S CREDITS 11.84 ------------------------------------------------------.----------------------------- *** BALANCE BY DATE *** 02/28 14,012.89 03/31 14,024.73 PAYER FEDERAL 10 NUMBER INTEREST PAID YEAR TO DATE :23-2324730 34.35 ---------------------------------------------------- *** INTEREST EARNED THIS STATEMENT PERIOD DAYS IN PERIOD ......................... INTEREST EARNED ......... .......... ..... ANNlJAL PERCENTAGE YIELD EAJmED (APY).... *** 31 11.84 1.00% - ----- - - ----- - - -- -- ------ --------- -- - -.- - - - -... - - - - - --- NOTE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION Member FDIC STIPULATION AND AGREEMENT FOR PAYMENT OF CHILD SUPPORT THIS AGREEMENT is made this ~ day of 2005, BY and BETWEEN Kathleen S. Jordan of 3 Sna Lane, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Mother" A N D Mark D. Jordan of 2902 Chesterbrook Court, Apartment 20S, Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Father". NOW THIS AGREEMENT WITNESSETH lHAT: WHEREAS, the parties are the natural parerlts of two (2) minor children, namely Kaitlyn Louise Jordan, whose date of birth is July 15, 1994, and Abigail Jo Jordan, whose date of birth is August IS, 1997 (hereinafter collectivdy referred to as the "Children"); and WHEREAS, the Parties wish to determine the child support and college education arrangements for their Children and have therefore agreed to enter into this Stipulation and Agreement for Payment of Child Support; and WHEREAS, the Parties are hopeful that by entering into this Stipulation and Agreement, Mother can avoid the necessity of having to file for Child Support through the Domestic Relations Office; and WHEREAS, the parties have entered into this Stipulation and Agreement freely and voluntarily, and with such guidance, knowledge and advice as each has sought from counsel of their choice. Page 1 of3 NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the parties, intending to be legally bound, hereby agree as follows: 1. Father agrees to pay to Mother at least Six Hundred ($600.00) Dollars bi- weekly. These payments shall be made to Mother within three (3) days of Father receiving his paychecks until such time as the Children reach 18 years of age or graduate from high school, whichever occurs later. 2. Nothing in this Agreement will prevent either party from filing with Domestic Relations or from seeking a modification or termination of this support obligation in the event of a substantial and continuing change in circumstances, in accordance with PaRC.P. 1910.17 and the applicable child support guidelines. 3. The parties bereto understand and agree that Mother, as primary custodian, shall be entitled to claim the Children as an exemption for income tax purposes, so long as the Children qualify as dependents for income tax pwposes. 4. Father shall provide health, dental and vision insurance coverage for the minor Children through his employment. 5. The Parties agree to equally dividl: any and all unreimbursed medical expenses, which shall specifically include orthodontiu. 6. To the extent that he is economiCllIly able to do so, Father agrees to financially assist the Children in their pursuit of highclr education. Page 2 of3 7. All matters affecting the interpretation of this Agreement and the rights of the Parties hereto shall be governed by the laws of the Commonwealth of Pennsylvania. 8. In the event that either Party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 9. This Agreement constitutes the entire II1lderstanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. IN WITNESS WHEREOF, the parties hl:feto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and year first above written. WITNESS: -7X.._J>. ~ Thomas D. Gould, Esquire Attorney for Father -~~p~ Mark D. Jordan /' Page 3 of3 (j c:, -.:.::,(,) rY' ~- l:~}~:', V"~ ' ....,.~ :-::.C',' /,." , ; YC"" -z 2 ~ ~ ~ "" \ U) q. :t ;t 1:2,).., -'C~ li?> "-';-i'f\ 9- ...,., ~?l ...., :S x:- C> .s;- "... Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, P A 17109 (7\7) 657-4795 ImaclavlmdzQlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MARK D. JORDAN, Plaintiff No. 2.1TD5 - 2;"68 " CIVIL ACTION - LAW KATHLEEN S. JORDAN, Defendant (In Divorce) AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYL VANIA ) SS. COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of the Notice of Intention to Request Entry of a Divorce Decree. T verify that the statements made in this Affida.vit are true and corre.~t to the be~t of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4'0 relating to unsworn falsification to authorities. '. ".' . C Date: I 0 - d >{ - 06 .....' = c.J c..r1 :;1e: o """ ( ~~, ~,~. .:<' I '-" ~ :I!.." r:1F -OlD .uv C:)b ~~:H C"'_O ,:.... en ,:) .'-\ -;;.,."'" .D :..:; -::J ";j:': ~ t',) Cl Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, P A 17109 (717) 657-4795 Imaclavrmdzf!law.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MARK D. JORDAN, Plaintiff No. 2005- ,,'ffle, v CIVIL ACTION - LAW KATHLEEN S. JORDAN, Defendant (In Divorce) WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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! 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 I further understand 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 Waiver 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. 94904, relating to unsworn falsification to authorities. 1 ! I Date: '()/~51Jo5 I I Kat/en S. Jordan, D .-of}'.: \ .\.~, \.. :;fL '::.;." (.~~:' 9. ~-"",. ~ co <.r' ~ .- ~ \ ~ ,.., '4, ~e ~' ::fl .J '") , '.::--<'0.( -, ,...~, '~2~ tS' :::.\ T; ..2:. -cJ ~ c? 1" o ~ MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-3788 CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce on behalf of Kathleen A. Jordan and certify that I am authorized to do so. .1"" 19l 1)f1~~- 'J J...M-i'" I .. 'J~' ......, DATE'. re C2 (oe, ~ .,-:'J C.l" -;t:. '3: \ -' C) ~n ~~ - C;? .,- c. MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-3788 CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: // ///tlJ" /!~P ~ ~ MARK D. JORDAN ,..., 0 ,::::;:t '~n ,,:;:~ ~l ~ C'.:: ""';~, J.;:w. :3::", G) ];:.. o MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-3788 CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: II/; /tJ5 ~// # ~~/v-- MARK D. JORDAN ("'") r--' C.;:'l 0 C c;..':J ';;.J\ '"1"1 .-1 c:' :T..: ...,~:;: n-,?~~ I ~gF~ ....J ,,-)[.:.., :c= .~ -' C:0 '::-~ .',... -- ~:o c .< MARK D. JORDAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-3788 CIVIL TERM KATHLEEN S. JORDAN, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On July 28, 2005 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, November 1, 2005; By Defendant, October 28, 2004. 4 . Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on November 7, 2005. Date Defendant's Waiver of Notice in s 3301(c) divorce was filed with the Prothonotary on November 3, 2005. ~F).~ Thomas D. Gould, Esquire Attorney For Plaintiff (; c- ......' c.:.:;:' "'" rJ' -"~ ...:::::. ~' ....: ~~ ~, -\ --r -r' \Sir -n(}'J . l../ C) .,' " ~rn <? _c- o -. ......., ~ ~. ~~L :+:'4::+::+: + . . + :+: + ~ + ~+:+: +++~ +:+: +: ++:+: +: +: ~+:++:+:++++++:+++ +:+++++++:+: ~ . IN THE COURT OF COMMON PLEAS ; + + . . . + . OFCUMBERLANDCOUNTY PENNA. . . . . . + . . + . . . . . . . + STATE OF MARK D. JORDAN, No. 2005-03788 CIVIL TERM Plaintiff VERSUS . . . . + . . . . . . . . . . . . . . . . . . . . . . . . . + + + + + . + . . . . . . . + . . . . . . . . . . . . . . + . + . . + . . . . + + . . . . . . . KATHLEEN S. JORDAN, Defendant DECREE IN DIVORCE IV l>vn..,le.r l() /" , 7_001., , IT IS ORDERED AND AND NOW, DECREED THAT MARK D. ,TORDAN , PLAINTIFF, AND KATHLEEN S. JORDAN , 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 PROPERTY SETTLEMENT AND SEPARATION AGREEMENT DATED AUGUST 8, 2005, IS HEREBY INCORPORATED, NOT MERGED, INTO THIS DECREE IN DIVORCE. By THE COURT: .(1~~~ ' ROTHONOTARY H+ +'++'+':+: :t::+:+: .. +:+:'f. :+: :+: :+:'f.'4::+: +:+::+::+:+'+:+:+:+:+:+::+:+ + . + . . + + + . . + + + + + . . + + + . + . + . . . + . + . . . + . . . . + . . . . . . + . . . . . . . . . . . . . + . + . . . . . . . . . . . . . . . . J. . . . + . . . + . . . . :+::+: +:'f. ~w ir 4 ;7' w'1' .yd /4J f'? yo pI .,/ ~ rT 17" ~ __ ;J^}. .ff)<;(l. pl. J' . r r- 'l-'V . """ rv ~ '. . . .. ---------- Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, P A 17109 (717) 657-4795 Imaclavlaldzglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARK D. JORDAN, Plaintiff No. 2005-03788 (Civil Term) v. CIVIL ACTION - LAW l..:ATHLEEN S. .JORDAN, Defendant (In Divorce) NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that KATHLEEN S. JORDAN, the Plaintiff in the above- captioned matter, having been granted a Final Decree in Divorce on November 10, 2005, hereby intends to resume and hereafter use the previous name of KATHLEEN A. SWEENEY, aild gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, . .. . ~1ts '0 effective July I, 1980. TO BE KNOWN AS: ~ K"/ HLEEN A. SWEE. COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN ON this, the ~Ol day of rJOvertJ b.eA/, 2005, before me, a Notary Public, personally appeared KATHLEEN S. JORDAN, now to be known as KATHLEEN A. SWEENEY, known to me or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto s~.hand en..d .)fn~ial s~a. .c'" . -5::2: - ,oJ~ 'c COMM OF "EN .. I NOTARIAL NSY1VANIA DEBORAH S HO St:Al Hampden r;' OVER. Notary Public My Commlssi6r; E~~~~e~~;~ 3~~2~W9 Ai (::) '6q 11:- ^ :'< it (5 "'- '- ~ ~ f! ~ . -~ -<: ......... ~ , * c.;. C:' ~ r"./ fl[ -" ---c:...