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06-2454
vI NATHAN C. WOLF, ESQUIRE ATTORNEY In NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF STEPHANIE L. KROUSE, Plaintiff v. JEFFREY E. KROUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - CIVIL TERM : IN DIVORCE NOTICE 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 mayproceed 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 the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - .2 q5'41 CIVIL TERM :1N DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(0 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Stephanie L. Krouse, an adult individual residing at 1151 EasyRoad, North Middleton Township, Cumberland County, Pennsylvania 17013. 2. The defendant is JeffreyE. Krouse, an adult individual residing at 153 Garland Drive, Carlisle Borough, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were marred on July 13, 1992, in Snow Hell, Maryland. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. J 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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 unswom falsification to authorities. S Z 12006 2006 JUVJW 9. UAdL STEP ANIE L. KROUSE, Plaintiff High Street Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff ??? `?---? .,.; fi -? ?-? `? ".. r- G NATHAN C. WOLF, ESQUIRE ATTORNEY In NO. 97390 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotarys 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. S '2006 l U I,t 0 uLtAL- STEPHANIE L. KROUSE, Plaintiff NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF, ATTORNEYS AT LAW 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF STEPHANIE L. KROUSE, Plaintiff v. JEFFREY E. KROUSE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06 - 2454 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant, Jeffrey E. Krouse, accept service of the Complaint for Divorce, on behalf of Defendant, filed in the above-referenced matter. June K 2006 v Ann t Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110NATHAN C. WOLF, ESQUIRE _Z:. ITI ?'? iaJ l y co . I V' , Plaintiff vs. or- Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-2454 CIVL TERM IN DIVORCE PRAECIPE TO SUBSTITUTE COUNSEL TO THE PROTHONOTARY: PLR Please enter the appearance of Pamela L. Purdy, Esquire for Befendant- Stephanie L. Krouse, and withdraw the appearance of Nathan C. Wolf, Esquire and Wolf & Wolf as counsel for theZolendantfn the above captioned action. PLff P(IAAI Pa ela L. Purdy, Esquire 115 Pine Street Harrisburg, PA 17101 (717) 221-8303 Attorney I. D. #85783 Date: 1 ? La64 Carlisle, PA 17013 (717) 241-4436 Attorney I.D. #87380 ?r Qe` f? ?'6n CR ' y Ly w -V- -r+-l Pamela L. Purdy PA ID No. 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. JEFFREY E. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PETITION RAISING ECONOMIC CLAIMS AND NOW comes the Plaintiff, Stephanie L. Krouse, by and through her attorney, Pamela L. Purdy, Esquire, and files the following Petition Raising Economic Claims: 1. On May 2, 2006, Wife filed a Complaint in Divorce in this matter. COUNT I - EQUITABLE DISTRIBUTION 2. During the period of the marriage, the parties acquired various items of marital property, much of which is located within the Commonwealth of Pennsylvania and Cumberland County, Pennsylvania. -'r- V - R 3. The parties have been unable to agree on an equitable distribution of the marital property. COUNT ll - ALIMONY 4. Wife has insufficient income and assets to provide for her needs. 5. Husband is well able to provide for Wife's needs, but has refused or otherwise failed to provide for same on a voluntary basis. COUNT III - ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 6. Wife has retained an attorney to represent her in this action and has agreed to pay her a reasonable fee. 7. Wife is not financially able either to meet the expenses and costs of this action or the fees to which her attorney will be entitled in this case. 8. The costs and expenses incurred in this litigation have become and will in the future become onerous, making it difficult for Wife to maintain and support herself as well as her children during the pendency of this action. WHEREFORE, Plaintiff requests the Court to equitably divide all of the marital property acquired by the parties, and award Plaintiff alimony, alimony pendente lite, counsel fees, costs and expenses. B ?. Y Pamela L. Purdy Date: ( y/ 206 ( Attorney for Plaintiff 4;q4A? -2- f- f.. VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: q260 C, rr4 ._ r.,. CERTIFICATE OF SERVICE The undersigned certifies that on the ---? day of September, 2006, a true and correct copy of the foregoing Petition to Raise Economic Claims was served by first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 Pamela L. Purdy, Esquire Of Counsel for Defendant Ati 110 Y p 0 w .• J . . lY?. , 8934-1 4/DefIs ls` Set of Interrogs to Plf/AVL/mej?12/21/20062:39:29 PM STEPHANIE L. KROUSE, Plaintiff V. JEFFREY K. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, Attorney for Defendant, do hereby certify that on the day of December, 2006 I served the original and one copy of Defendant's Answers to Plaintiff's Request for Production of Documents addressed to counsel for Plaintiff in the above captioned matter, by depositing same in the United States Mail, first class, postage paid, addressed as follows: Pamela Purdy, Esquire 115 Pine Street, Suite 100 P.O. Box 11544 Harrisburg, PA 17108 Date: l c?- `.-, ' 0:6 Respectfully Submitted, SMIGEL, DERSON & SACKS, LLP By:1) LeRo Smigel, Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant 89'34-1-4jDef's 1'- Set of Interrogs to Plf/AVL/mej 12f-21/20Cii2:39:04 PM STEPHANIE L. KROUSE, Plaintiff V. JEFFREY K. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, Attorney for Defendant, do hereby certify that on the o? ( day of December, 2006 I served the original and one copy of Defendant's Answers to Plaintiff's Interrogatories addressed to counsel for Plaintiff in the above captioned matter, by depositing same in the United States Mail, first class, postage paid, addressed as follows: Pamela Purdy, Esquire 115 Pine Street, Suite 100 P.O. Box 11544 Harrisburg, PA 17108 Date: /2 Respectfully Submitted, SMIGEL, DERSON & SACKS, LLP By: LeRoy Smigel, Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401. Attorneys for Defendant STEPHANIE L. KROUSE, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY K. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, Attorney for Defendant, do hereby certify that on the 25`h day of January, 2007 I served the original and one copy of Defendant's Request for Production of Documents addressed to counsel for Plaintiff in the above captioned matter, by depositing same in the United States Mail, first class, postage paid, addressed as follows: Pamela Purdy, Esquire 115 Pine Street, Suite 100 P.O. Box 11544 Harrisburg, PA 17108 Date: / - ".), 5",-- (3 -) Respectfully Submitted, SMIGEL, DERSON& SACKS, LLP By: U LeRo Smigel, Esquire I.D.#: O X617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant - 9 - c> ? ` C t'? ?---- i _); i :. ?_s ?' ?? . ? "[?. ' ?.+ STEPHANIE L. KROUSE, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY K. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, Attorney for Defendant, do hereby certify that on the 25th day of January, 2007 I served the original and one copy of Defendant's First Set of Interrogatories to Plaintiff addressed to counsel for Plaintiff in the above captioned matter, by depositing same in the United States Mail, first class, postage paid, addressed as follows: Pamela Purdy, Esquire 115 Pine Street, Suite 100 P.O. Box 11544 Harrisburg, PA 17108 Respectfully Submitted, Date:/ - ?- S - z)7 SMIGEL, ANDERSON & SACKS, LLP By: LeRoy migel, Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant r.a i ?s CID Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO 23 PA.C S -§ 3502(f) AND NOW comes the Plaintiff, Stephanie L. Krouse, by and through her attorney, Pamela L. Purdy, Esquire, and files the following Petition for Interim Partial Distribution of Marital Property, and in support thereof, avers as follows: 1. Stephanie L. Krouse (hereinafter "Wife") and Jeffrey E. Krouse (hereinafter "Husband") were married on duly 13, 1992. 2. On May 2, 2006, Wife filed a Complaint in Divorce in this matter. 3. On June 8, 2006, Husband accepted service of the Complaint in Divorce. 4. On September 15, 2006, Wife filed a Petition Raising Economic Claims, including claims for equitable distribution, alimony pendente lite, alimony, and counsel fees. 5. Prior to separation, Wife had no access to or control of the parties' financial information or assets. 6. On November 15, 2006, Wife served Husband with Requests for Production of Documents and Interrogatories. 7. On January 25, 2007, Husband served Wife with his responses to Wife's discovery requests. 8. Husband disclosed in his discovery responses that the parties had $51,022.99 in an M&T Bank Market Advantage account as of December 1, 2006. A true and correct copy of Husband's December 1, 2006 M&T Bank Market Advantage account number ending 8846 statement is attached hereto as Exhibit "A" and incorporated herein as if fully set forth. 9. Said funds were earned during the marriage and, as such, are a marital asset. 10. Wife is not receiving alimony pendente lite and has no savings with which to pay her legal fees and establish a new residence. 11. In addition to the divorce litigation, the parties are engaged in custody litigation that is scheduled for trial on March 29, 2007. 12. Receiving an interim distribution of half of the balance of the M&T Bank savings account would allow Wife to pay her legal fees and establish a residence separate from her parents. 13. Section 3502(f) of the Divorce Code states that "[t]he 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." 14. Counsel for Plaintiff sent correspondence and telephoned Counsel for Defendant regarding an agreed upon interim partial distribution, and this Petition, has not received a response with regard to either issues as of the date of the filing of this Petition. WHEREFORE, Plaintiff Stephanie L. Krouse respectfully requests this Court to enter an Order awarding each party half of the funds located as of December 1, 2006 in M&T Market Advantage account ending 8846. By Pamela L. Purdy Date: "*? 7 Zov-j- Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Petition for Interim Distribution are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Steph nie L. Krouse CERTIFICATE OF SERVICE The undersigned certifies that on the f1'4 day of March, 2007, a true and correct copy of the foregoing Petition for Interim Partial Distribution of Marital Property was served by first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 171 10 _&j?: ?' 10("? Pamela L. Purdy, Esquire Of Counsel for Plaintiff Lxhibi+ A MM&TBank 00 0 06129M NM 017 JEFFREY E KROUSE 153 GARLAND DR CARLISLE PA 17013-4226 STATZMENT PERIOD PAGE NOV.04-DEC.01,2006 1 OF 3 EZEeEn AcOcvT s?RY ACCOUNT ACCOUNT INTEREST EARNED MATURITY ENDING TYPE NUMBER YEAR-TO-DATE DATE BALANCE M&T SELECT WITH INTEREST 000000052902501 6.61 M&T MARKET ADVANTAGE 015004206188846 1,571.94 TOTAL DEPOSITS 4,485.38 51,022.99 55,508.37 ACCOUNT>, JEFFREY E KROUSE M&T SELECT WITH INTEREST TL'ILS ACCOUNT NO. 52902501 ACCC)TTNT SUMMARY CARLISLE WEST BEGINNING <• BAI?ANOE DEPOSITs & .. `'i >? : 'OTHER ADQfTIONS::. . ::.: ''-CHECtcS.- PA'ID.. O FtER,:>:... .. '? .. SU.$'?RAC'F'IONS. > : ?:CLIRRE[tT >Ihl'f'?k65'Y' PD ENDING . ,;> ,BALbI•NCB NO. AMOUNT NO. AMOUNT N0. AMOUNT 4,574.29 2 4,888.37 7 2,835.07 8 2,142.50 0.29 4,485.38 ACCOTTNT ACTTVTTY PS35TIfIG :: IIATL . i: ..... : TRANFSACTi:ON DES:CRtPt.I:bN EIEPQSITS; INTEREST & 0?`HEFt.>A6t1?1`IONS ;..: `•CHECKS.,&,: OTHER,<: .:`....SLtB?!RAC?'?ONS..: DAILY.. :: BAL,ANCE....:: 11-04-06 BEGINNING BALANCE $4,574.29 11-06-06 DISCOVER ARC PAYMENTS 000000000003103 753.64 11-06-06 WFHM MORTGAGE CHECKPAYMT 000000000003100 616.96 3,203.69 11-07-06 CAPITAL ONE ARC CHECK PYMT 000000000003108 240.81 11-07-06 CHECK NUMBER 3107 117.97 11-07-06 CHECK NUMBER 3105 50.67 2,794.24 11-08-06 CHECK NUMBER 3110 1,224.00 1,570.24 11-09-06 CHECK NUMBER 3109 32.45 11-09-06 CHECK NUMBER 3106 25.00 1,512.79 11-13-06 VZ WIRELESS ARC ARC 000000000003104 36.16 1,476.63 11-14-06 WEB XFER FROM SAV 15004206188846 1,200.00 2,676.63 11-16-06 ATM ENV-DEP 3,688.37 11-16-06 M&T ATM CASH WITHDRAWAL ON 11/16 200.00 STONEHEDGE,960 WALNUT BOTTOM RD,CARLISLE,PA 6,165.00 11-24-06 M&T ATM CASH WITHDRAWAL ON 11/23 200.00 MMOBank :STATEMENTPERIOD PAGE NOV.04-DEC.01,2006 2 OF 3 JEFFREY E KROUSE ACCOUNT ACTIVITY PASTING "DATE ` ,. TRANSACTION: DESCRIPTION. : DEPOSITS: INTEREST :& .OTEfER' All ITi0NS OHEeKS k.•.AIHER:; i .....U9TRACT!IONS''': D.AILX , ; $} f ANCE. ' DILLSBURG,4 N US HIGHWAY 15,DILLSBURG,PA 11-24-06 CANTOR ZIEGLER ORTHDNTCARLISLE 70.00 5,895.00 11-28-06 CHECK NUMBER 3113 1,199.52 11-28-06 CHECK NUMBER 3112 185.46 4,510.02 12-01-06 INTEREST PAYMENT 0.29 12-01-06 ZAZZLE,COM 600-980-9890 24.93 4,485.38 ENDING BALANCE $4,485.38 . >.•CHEC'SCS` SAID?:SUMMAR'Y . 3105 11-07-06 50.67 3106 11-09-06 25.00 3107 11-07-06 117.97 3109* 11-09-06 32.45 3110 11-08-06 1,224.00 3112* 11-28-06 185.46 3113 11-28-06 1,199.52 ANNUAL PERCENTAGE YIELD EARNED = 0,10 % M&T BANK HAS JOINED THE PLUS NETWORK, THE WORLD'S LARGEST ATM NETWORK - WITH MORE THAN ONE MILLION ATM LOCATIONS FOUND IN OVER 160 COUNTRIES. WHEN YOU TRAVEL AND NEED TO TRANSACT SOME BUSINESS AT A NON-M&T ATM WITH YOUR M&T CARD, SIMPLY LOOK FOR THE PLUS, STAR (R), AND VISA (R) NETWORK LOGOS. AS A RESULT OF OUR NEW AFFILIATION WITH PLUS, M&T BANK IS NO LONGER PARTICIPATING IN THE CIRRUS AND NYCE NETWORKS. FOR QUESTIONS, PLEASE CALL THE M&T TELEPHONE BANKING CENTER AT 1-800-724-2440. THANK YOU FOR BANKING WITH M&T. MM&TBank S:TATEMEN? PERIAD PAGE: NOV.04-DEC.01,2006 3 OF 3 JEFFREY E KROUSE AC.GO:UNTi;: JEFFREY E KROUSE M&T MARKET ADVANTAGE ACCOUNT NO. 15004206188846 CARLISLE WEST ACCOUNT SUMMARY $EGINHING BALANCE.:.: _ DEPOSITS .& . ..... OTHER ::ADDITIQNS:: WITHDRAWALS.-:& OTHER z>:•:''SUBTRACT10NS :.. CURRENT .. :; _ IN?EREST,:PAID'::... Ei3DING .. BAI;ANCE _ NO. AMOUNT NO. AMOUNT 52,100.78 0 0.00 1 1,200.00 122.21 51,022.99 AL:C:UUN'1" ACT i v 1'1'Y POSSI:NG > DEPOSITS .IItTERT: W1:?RAWALS.k;nEFtER DASI:Y DA'Z'E..:. TRANSACTLON`. flESCRIP.2ION ; &':O'fHER }aODS2'T6NS%? . -,. Sif9CRAGTZQNS.<' AAhAI4Lt 11-04-06 BEGINNING BALANCE $52,100.78 11-14-06 WEB XFER TO CHK 00000052902501 1,200.00 50,900.78 12-01-06 INTEREST PAYMENT 122.21 51,022.99 ENDING BALANCE 1 1 $51,022.99 ANNUAL PERCENTAGE YIELD EARNED - 3.14 t ** END OF STATEMENT ** ~? ? 7 ?/ __ .... 3 ?s N ' { ??? ? -. j?.J i _ _-«? ?4 r .. 1 ,?. `?. -.. '_?;, J ?? ?- - rv ?, ? :..J -^. Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AMENDED PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO 23 PA.C.S. -§ 3502(f) AND NOW comes the Plaintiff, Stephanie L. Krouse, by and through her attorney, Pamela L. Purdy, Esquire, and files the following Petition for Interim Partial Distribution of Marital Property, and in support thereof, avers as follows: 1. Stephanie L. Krouse (hereinafter "Wife") and Jeffrey E. Krouse (hereinafter "Husband") were married on July 13, 1992. 2. On May 2, 2006, Wife filed a Complaint in Divorce in this matter. 3. On June 8, 2006, Husband accepted service of the Complaint in Divorce. 4. On September 15, 2006, Wife filed a Petition Raising Economic Claims, including claims for equitable distribution, alimony pendente lite, alimony, and counsel fees. 5. Prior to separation, Wife had no access to or control of the parties' financial information or assets. 6. On November 15, 2006, Wife served Husband with Requests for Production of Documents and Interrogatories. 7. On January 25, 2007, Husband served Wife with his responses to Wife's discovery requests. 8. Husband disclosed in his discovery responses that the parties had $51,022.99 in an M&T Bank Market Advantage account as of December 1, 2006. A true and correct copy of Husband's December 1, 2006 M&T Bank Market Advantage account number ending 8846 statement is attached hereto as Exhibit "A" and incorporated herein as if fully set forth. 9. Said funds were earned during the marriage and, as such, are a marital asset. 10. Wife is not receiving alimony pendente lite and has no savings with which to pay her legal fees and establish a new residence. 11. In addition to the divorce litigation, the parties are engaged in custody litigation that is scheduled for trial on March 29, 2007. 12. Receiving an interim distribution of half of the balance of the M&T Bank savings account would allow Wife to pay her legal fees and establish a residence separate from her parents. 13. Section 3502(f) of the Divorce Code states that "[t)he 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." 14. No fudge has ruled on any other issue in this matter. judge Oler has been assigned to the parties' pending action in custody. 15. Counsel spoke about this Petition, but Counsel for Defendant did not state whether Defendant concurs with said Petition. WHEREFORE, Plaintiff Stephanie L. Krouse respectfully requests this Court to enter an Order awarding each party half of the funds located as of December 1, 2006 in M&T Market Advantage account in 8846. By Pamela L. Purdy Date: 3 (5 Attorney for Plaintiff VERIFICATION I, Pamela L. Purdy, the attorney for Plaintiff Stephanie L. Krouse, have read the foregoing Amended Petition for Interim Partial Distribution of Marital Property Pursuant to 23 Pa.C.S. §3502(f). I verify that the averments in this Amended Petition are true and correct and based upon the information provided to me by Stephanie L. Krouse, who is unavailable to sign this document at this time. I understand that I am to secure Stephanie L. Krouse's signature through a separate Verification when she is available; I then will submit said Verification via Praecipe to Attach with the Prothonotary's office. I further understand that any false statements herein are made subject to the penalities of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Dated: MWA meta L. Purdy, Esquire CERTIFICATE OF SERVICE The undersigned certifies that on the day of March 2007, a true and correct copy of the foregoing Petition for Interim Partial Distribution of Marital Property was served by first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 171 10 /" L' ela L. Purdy, Esquire Of Counsel for Plaintiff c? r-11 o . , -ems 3/19/200710:10:56 AM/AVL/smt SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V, Levin, Esquire ID #70259 4431 North Front Street, Yd Fir. Harrisburg, PA 17110-1778 (717) 234-2401 Ismigelna.sasl Ip. com alevin&sasllp.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY AND NOW, comes the Defendant/Respondent, Jeffrey K. Krouse (hereinafter "Respondent"), by and through his attorneys, SMIGEL, ANDERSON & SACKS, LLP, and files this Answer to Plaintiff's Petition for Interim Partial Distribution of Marital Property and in support thereof avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. It is denied that prior to separation Petitioner had no access to or control of the parties' financial information or assets. By way of further answer, a majority of any of the assets in which Petitioner has a marital interest are Respondent's pre-marital property. Further, Petitioner chose to leave the marital residence in April 2006. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 6. Admitted. 3/19/200711:02:43 AM/AVL/smt 7. Denied. Respondent served his answers to Petitioner's discovery requests on December 21, 2006. 8. Admitted in part and denied in part. It is admitted that Respondent's Market Advantage account at M&T Bank had a balance of $51,022.99 as of December 1, 2006. It is denied that the funds were earned entirely during the marriage. This is Respondent's account and it was funded with money from an account Respondent had prior to the date of marriage. Petitioner would only have a marital interest in the increase in value. The marital portion has not yet been determined. The tracing of funds has yet to occur and will be time consuming. 9. Denied. It is denied that all of the funds were earned during the marriage. By way of further answer, the account was funded with some money from an account that Respondent had prior to the date of marriage and therefore Petitioner only has a marital interest in the increase in value of the account. 10. Denied as stated. Petitioner has not requested a hearing on her claim for alimony pendente lite and is currently receiving child support. Respondent is without sufficient knowledge as to the amount of legal fees owed by Petitioner to her counsel and the amount of money Petitioner deems necessary to establish a separate residence. It is unknown to Respondent whether or not Petitioner has any savings account. By way of further answer, the fees related to the divorce action are minimal. There has been no protracted litigation. There are no complicated asset valuations. Furthermore, Petitioner earns income through her employment with Bobby Rahal Honda of approximately $38,348 in 2006. Petitioner has also taken two trips since Petitioner left the marital residence. Petitioner also unilaterally enrolled the parties' youngest child in daycare when Respondent had been providing this care. This is an unnecessary expense. 3/19/200710:10:56 AM/AVL/smt 11. Admitted. By way of further answer, it is believed and therefore averred that Petitioner is seeking payment of legal fees to assist in the custody action and not in the divorce action. Petitioner has minimal living expense and earns sufficient money to pay her own legal fees in the divorce action and the custody action. 12. Denied. Respondent is without sufficient knowledge or information as to the amount of legal fees due by Petitioner to her counsel. By way of further answer, it is Respondent's belief that the majority of fees due by Petitioner to her counsel are related to the custody matter which is set for trial on March 29, 2007. 13. No response required. By way of further answer, it would be inappropriate to assign any funds to Petitioner since the extent of the marital assets has not been determined. 14. Admitted in part and denied in part. It is admitted that counsel for Petitioner has attempted to contact counsel for the Respondent. It is denied that no response has been given. Counsel for Respondent has contacted counsel for Petitioner and requested answers to discovery to discern the extent of Petitioner's assets. Petitioner's discovery answers were due on or about February 26, 2007 and are still outstanding. WHEREFORE, Respondent Jeffrey E. Krouse respectfully requests that this Honorable Court deny Petitioner's request for interim partial distribution of Respondent's M&T Market Advantage account. Date: 3-11-0'? SMIGEL ANDERSON & SACKS, LLP By: 4SmigLeRvyel, , Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant/Respondent VERIFICATION I, Jeffrey E. Krouse, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: J E. Kro se 3/19/200710:10:56 AWAVL/smt SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3nd Mr. Harrisburg, PA 17110-1778 (717) 234-2401 IsmiEel a?saslip.com aievinna sasllp.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant/Respondent in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Answer to Plaintiff's Petition for Interim Partial Distribution of Marital Property on counsel for Plaintiff/Petitioner by placing same in the U.S. Mail, first class, postage paid on the _ 't day of March 2007, addressed as follows: PAMELA L. PURDY, ESQUIRE 308 NORTH SECOND STREET, STE. 200 HARRISBURG, PA 17101 SMIGEL ANDERSON & SACKS, LLP J By: LeR y Smigel, Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant/Respondent E) :3 i>C ' m ti ro ,?- rG STEPHANIE L. KROUSE,: Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2454 CIVIL TERM ORDER OF COURT AND NOW, this 26`h day of March, 2007, upon consideration of Plaintiff's Petition for Interim Partial Distribution of Marital Property and of Defendant's Answer to Plaintiff's Petition for Interim Partial Distribution of Marital Property, a hearing is scheduled for Thursday, April 12, 2007, at 10:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING SAID HEARING, neither party shall transfer or dissipate any marital assets. Z4(-nn Levin, Esq. 4431 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff Xmela L. Purdy, Esq. 308 North Second Street Suite 200 Harrisburg, PA 17101 Attorney for Defendant rc y BY THE COURT, 10 :C Wd 8Z o ld LOOZ Pamela L. Purdy PA ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 1] 544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdygverizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO SUBSTITUTE VERIFICATION TO THE CLERK: Please substitute the attached Verification for the Attorney Verification filed with the Plaintiff's Petition for Interim Partial Distribution. By C. . Pamela L. Purdy Date: ?Ck Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Petition for Interim Distribution are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. "UAJU 12 teph nie L. Krouse CERTIFICATE OF SERVICE The undersigned certifies that on the 41'` day of March, 2007, a true and correct copy of the foregoing Praecipe to Substitute Verification was served by first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 f - I& -,I ?.. pfmln Pamela L. Purdy, Esquire Of Counsel for Defendant Q -n t. , ` -'' ? r r; r? ? s-?? ?_4: -`- ? ? ?.? ? " ? - T3 ' - ?? O .G" C7 .ft STEPHANIE L. KROUSE, Plaintiff v JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 06-2454 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR INTERM PARTIAL DISTRIBUTION OF MARITAL PROPERTY ORDER OF COURT AND NOW, this 12th day of April, 2007, upon consideration of Plaintiff's Petition for Interim Partial Distribution of Marital Property, and pursuant to an agreement of the parties reached in open court, with the assistance of their counsel, it is ordered and directed as follows: 1. $10,000 shall be distributed to Plaintiff from the Money Market Advantage Account No. 8846. 2. Husband shall transfer money to his checking account and cause a check to be issued to wife, which would be forwarded through counsel for the parties. 3. The balance of this account may be transferred by husband into a Certificate of Deposit in order to obtain a higher interest rate. If that occurs, the Money Market Account Number 8846 would be closed. 4. In any event, the balance of the funds following the distribution to wife as set forth above shall not be used by either party, and the account shall be frozen. 5. Counsel for wife shall be copied on any statements transferring the money from the money market account to any Certificate of Deposit. 6. The $10,000.00 shall be considered an advance on equitable distribution for purposes of the pending divorce action, and wife shall be credited as having received said 1 V low amount. 7. All arguments regarding the nature of the account as marital or non-marital are preserved by both parties. By the Court, esley 01 Z,,- Ann Levin, Esquire 4431 North Front Street Harrisburg, PA 17110 For Plaintiff Pamela L. Purdy, Esquire 308 North Second Street Suite 200 Harrisburg, PA 17101 For Defendant :mae Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO 23 PA.C.S. § 3502(f) AND NOW comes the Plaintiff, Stephanie L. Krouse, by and through her attorney, Pamela L. Purdy, Esquire, and files the following Petition for Interim Partial Distribution of Marital Property, and in support thereof, avers as follows: 1. Stephanie L. Krouse (hereinafter "Wife") and Jeffrey E. Krouse (hereinafter "Husband") were married on July 13, 1992. 2. On May 2, 2006, Wife filed a Complaint in Divorce in this matter. 3. On June 8, 2006, Husband accepted service of the Complaint in Divorce. 4. On September 15, 2006, Wife filed a Petition Raising Economic Claims, including claims for equitable distribution, alimony pendente lite, alimony, and counsel fees. 5. Prior to separation, Wife had no access to or control of the parties' financial information or assets. 6. On November 15, 2006, Wife served Husband with Requests for Production of Documents and Interrogatories. 7. On January 25, 2007, Husband served Wife with his responses to Wife's discovery requests. 8. Husband disclosed in his discovery responses that the parties had $51,022.99 in an M&T Bank Market Advantage account as of December 1, 2006. A true and correct copy of Husband's December 1, 2006 M&T Bank Market Advantage account number ending 8846 statement is attached hereto as Exhibit "A" and incorporated herein as if fully set forth. 9. Said funds were earned during the marriage and, as such, are marital assets. 10. In April 2007, after Wife filed a prior Petition for Interim Partial Distribution of Marital Property, the parties agreed to distribute Ten Thousand Dollars to Wife as an advance on equitable distribution. 11. To date, Wife's legal fees and costs for custody, support and divorce matters total Thirteen Thousand Two Hundred Forty Three Dollars ($13,243). 12. In addition, Wife paid One Thousand Five Hundred Dollars ($1,500) for her portion of a custody evaluation, which was requested by Husband. 13. Wife paid Three Hundred Fifty Dollars ($350) for Dr. Shienvold's appearance at the parties' custody trial. 14. In addition, in September 2007, Wife moved from her mother's home where she paid minimal rent and expenses to a townhouse in order to accommodate Husband's request that she move back into his school district and now pays approximately One Thousand Two Hundred Dollars ($1,200) in rent and utilities per month. 15. In addition to paying rent, Husband refused to give Wife any marital furniture, appliances, or utensils, and Wife had to purchase all new items for her and the children to use at their townhouse, which totaled approximately Twenty Thousand Dollars ($20,000). 16. Wife is not receiving alimony pendente lite and has no savings. 17. Wife has Thirty Five Thousand Dollars ($35,000) in credit card debt stemming from paying legal fees and buying items to furnish her and the children's new home. 18. Receiving an interim distribution of half of the remaining balance of the M&T Bank savings account would allow Wife to pay her legal fees and pay for the costs incurred in establishing a residence in Father's school district. 19. Wife has repeatedly asked Husband to negotiate a settlement of their marital assets and debts but, to date, Husband has refused to cooperate. 20. Section 3502(f) of the Divorce Code states that "[t]he 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." 21. judge Oler was previously assigned to this matter. 22. Counsel spoke about this Petition, but, to date, Counsel for Father has not responded as to whether Father concurs in this Petition. It is believed that Father does not concur in this Petition. WHEREFORE, Plaintiff Stephanie L. Krouse respectfully requests this Court to enter an Order awarding each party half of the remaining funds located as of December 1, 2006 in M&T Market Advantage account ending 8846. Respectfully submitted, ?i By- Date: fibew IK Pamela L. Purdy Attorney for Plaintiff ?.6C ?i2^z184©3 PURD1' LAW OFFICE PA E C E' VERIFICATION I verify that the statements made in the foregoing Petition for Interim Distribution are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn 'falsification to authorities. I I L h A -) 1, Stepha ie L. Krouse CERTIFICATE OF SERVICE The undersigned certifies that on the jf(A day of March, 2008, a true and correct copy of the foregoing Petition for Interim Partial Distribution of Marital Property was served by first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 171 10 P"?' Ya L P-1 Pamela L. Purdy, Esquire Of Counsel for Plaintiff ra C i crN ( } ITT G. ?-z I STEPHANIE L. KROUSE,: Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2454 CIVIL TERM ORDER OF COURT AND NOW, this 11`n day of March, 2008, upon consideration of Plaintiff's Petition for Interim Partial Distribution of Marital Property Pursuant to 23 Pa. C.S. §3502(f), a hearing is scheduled for Monday, May 12, 2008, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ? Pamela L. Purdy, Esq. 308 North Second Street Suite 200 Harrisburg, PA 17101 Attorney for Plaintiff ? Ann Levin, Esq. 4431 North Front Street Harrisburg, PA 17110 Attorney for Defendant :rc Co I i'e,5 m'-J-t `CCL jh x/v8 ."'=,n^ ?+ a rt /fo STEPHANIE L. KROUSE,: Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2454 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO 23 PA. C.S. V502(fl ORDER OF COURT AND NOW, this 9`h day of May, 2008, upon consideration of the attached letter from Pamela L. Purdy, Esq., attorney for Plaintiff, and of the praecipe to withdraw the above motion filed in the above matter, the hearing scheduled for May 12, 2008 is cancelled. ? Pamela L. Purdy, Esq. 308 North Second Street Suite 200 Harrisburg, PA 17101 Attorney for Plaintiff ? Ann Levin, Esq. 4431 North Front Street Harrisburg, PA 17110 Attorney for Defendant :rc ,i?s m2t 6-.'L P 44108 =/Y) BY THE COURT, r 1?& i'd? J., esley Oler, r., J. i' 4 'VINVA-tASNN3d OZ :Z Wd 6- IN 0001 AUVIO#dCii IOdd 311.40 30H4.0- 0 Pamela L. Purdy Attorney ID No. 85783 308 N. 2^d Street Suite 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 : IN DIVORCE PRAECIPE TO WITHDRAW PLAINTIFF'S PETITION FOR INTERIM PARTIAL DISTRIBUTION OF MARITAL PROPERTY PURSUANT TO 23 PA.C.S. 4 3502(f) TO THE COURT: Please withdraw the Plaintiff's Petition for Interim Partial Distribution of Marital Property filed on March 6, 2008. 0"', . /, -,, -/-) e f " Pamela L. Purdy Date: m 1? ?©? r CERTIFICATE OF SERVICE The undersigned certifies that on the 9111day of May, 2008, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Ann Levin, Esquire 4431 N. Front St., 311 floor Harrisburg, PA 17110-1778 Pamela L. Purdy, E quire Of Counsel for Plaintiff c4a C3 rn STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE , Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF DIVORCE MASTER Stephanie L. Krouse, Plaintiff, hereby moves this Honorable Court to appoint a Master with respect to the following claims: () Divorce (x) Distribution of Property () Annulment () Support (x) Alimony (x) Counsel Fees (x) Alimony Pendente Lite (x) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Plaintiff has appeared in this matter and is represented by the undersigned attorney. (3) The statutory grounds for divorce are mutual consent (3301(c)). (4) The divorce action is not contested. No agreement has been reached as to distribution of marital assets. No further claims are pending as of this date. (5) The case does not involve complex issues of law. (6) The hearing is expected to take less than one (1) day. (7) No additional information is relevant to this motion. /---a " pro Date: Pamela L. Purdy, Esquire Attorney for Plaintiff CERTIFICATE OF SERVICE A The undersigned certifies that on the day of August, 2008, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Ann Levin, Esquire 4431 N. Front St., 3rd floor Harrisburg, PA 17110-1778 The Law Office of Pamela L. Purdy 0"_ P 11VOL)Q Amanda P. Anderson, Paralegal -.r lJ Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI1 NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE INVENTORY OF PLAINTIFF, STEPHANIE L. KROUSE Plaintiff files the following Inventory and Appraisement 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 verifies that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unswom falsification to authorities. Date: ,J V o Ain I/1'0 ? OML, ep nie L. Kro se ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( x ) 1. Real property (x) 2. Motor Vehicles (x) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( x) 5. Checking accounts, cash ( x) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit 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, inventions, royalties (x) 14. Personal property outside the home ( ) 15. Businesses (list all owners, including percentage of ownership and officer/director positions held by a party with company) ( ) 16. Employment termination benefits--severance pay, workman's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) (x) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held -2- (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other -3- MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced. Item Number Description of Property 1 153 Garland Drive 5 M&T Checking Account 6 M&T Money Market Account 6 Savings bonds 2 2005 Ford Escape 2 1989 Ford F150 19 Federated IRA 19 Team Rahal 401(k) 25 Personalty Names of All Owners Husband Husband Husband Wife Husband and Wife Husband Husband Wife Husband and Wife -4- NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property 6 Savings Bonds 19 Team Rahai 401(k) 25 Personalty Reason for Exclusion Premarital Property Post-separation increase in value Post-separation property -5- PROPERTY TRANSFERRED Plaintiff lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: Item Description of Date of Consideration Person to Number Property Transfer Whom Transferred 2 1993 Honda Accord $2,000 Husband 6 $10,000 from M &T April 2007 interim dist. Wife Money Market Acct 6 $22,538 from M & T May 2008 interim dist '/2 to Wife, '/2 to Money Market Acct Husband 3 Savings Bonds May 2008 interim dist Wife 6 $5,000 from M & T interim dist Wife Money Market Account 6 $7,000 from M & T none Husband Money Market Account 6 $3,000 from M & T none Custody Evaluator Money Market Account -6- LIABILITIES Item Number NONE Description of Property Names of All Creditor Names of All Debtors -7- CERTIFICATE OF SERVICE The undersigned certifies that on the 13 day of August, 2008, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Ann Levin, Esquire 4431 N. Front St., 3`d floor Harrisburg, PA 17110-1778 The Law Office of Pamela L. Purdy tnAAL P Amanda P. Anderson, Paralegal C"? c ? C?. ? ? ? =r s 77 - i ? ? ? --'? C?7 __ -M _a ., '- :?, '`:, c_t'? .mac ?? ? Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff VS. JEFFREY KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-2454 CIVIL ACTION -LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF PLAINIFF. STEPHANIE L KROUSE INCOME (a) Wages/Salary Employer & Address Bobby Rahal Honda. Mechanicsburg. PA Job Title/Description Service advisor Pay Period (weekly, bi-weekl y, monthly) Bi-weekly Gross Pay per Pay Period $905.00 Payroll Deductions: Federal Withholding $31.94 Social Security $40.43 Local Wage Tax $10.43 State Income Tax $20.02 Retirement $25.00 Health Insurance $218.58 Unemployment $34.33 EMST/Occupation $100 Net Pay per Pay Period (b) Other Income Week Interest/Dividends ......................... 5--------- Pension/Annuity ............................ $--------- Social Security ................................ $--------- Rents/Royalties .............................. 5--------- Expense Account ........................... $--------- Gifts ............................................... $--------- Unemployment Comp ................... $--------- Workmen's Compensation .............. $--------- Total, Other Income S $512.26 Month $ ---------- $ ---------- $ ---------- $ ---------- $ ---------- $ ---------- $ ---------- $ ---------- Year $---------- $---------- $---------- $---------- $---------- $---------- $---------- $---------- S $ Household Child Household Child Week Week Month Month EXPENSES Home Mortgage/Rent ........................ ..... $-------- $-------- $700.00 $-------- Maintenance ........................... ..... $-------- $-------- $-------- $-------- Utilities (telephone, heating electric, etc.) ........................ ..... $-------- 5-------- $594.00 $-------- Employment (transportation, lunches) .................................... $-------- $-------- $120.00 $-------- Taxes Real Estate (annually) ................... $-------- 5-------- $-------- $-------- Personal Property ......................... $-------- 5-------- $-------- $-------- Income ......................................... $-------- $-------- $-------- $-------- Insurance Homeowners/Auto ....................... 5-------- Automobile .................................. $-------- Life/Accident/Health .................... $-------- Other ........................................... $-------- Automobile (payments, fuel, repairs). $ Medical Doctor, Dentist, Orthodontist ....... 5 Hospital ....................................... S Special (glasses, braces, etc.) ....... $ Education Private, Parochial School ............... $ College ........................................ $ Personal Clothing ....................................... $ Food ............................................ $ 5-------- $75.00 $-------- 5-------- $-------- $-------- $-------- $-------- $-------- $-------- $-------- $-------- $ -------- $405.00 $ -------- 5-------- $-------- $-------- $-------- $-------- $-------- $-------- $100.00 $-------- $-------- $-------- $ $-------- $-------- $ 5-------- $-------- $100.00 5-------- $ 500.00 $------- Other (household supplies, barber, etc) ............................... $-------- $-------- $-------- $ 50.00 Credit payments and loans........... $-------- $-------- $400.00 $-------- Miscellaneous Household help/child care ................. $-------- $-------- $-------- $-------- Entertainment (inc. papers, books, vacation, pay TV, etc.).... $-------- $-------- $150.00 $-------- Gifts/Charitable contributions ...... $-------- $-------- $-------- $-------- Legal Fees (accruing fees now) ..... $-------- $-------- $-------- $-------- Other child support/alimony payments .................................. $-------- $-------- $-------- $-------- Other (specify) ................................... $-------- $-------- $-------- $-------- Total Expenses .................................. $........ $-------- $3,044 INSURANCE Company Policy No. H Hospital ......................... ------------------- -------------- Medical .......................... ------------------- -------------- Health/Accident ......... ------------------- -------------- Disability Income............ ------------------- -------------- Other (dental, etc) .......... ------------------- -------------- (*H - Husband, W - Wife, J - Joint, C - Child) $150.00 Ownership* Coverage W C VERIFICATION I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: r I F 441 ('9V Dg vknAff--" Step a ie L. Krouse CERTIFICATE OF SERVICE -Nh The undersigned certifies that on the day of August, 2008, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Ann Levin, Esquire 4431 N. Front St., 31 floor Harrisburg, PA 17110-1778 The Law Office of Pamela L. Purdy Amanda P. Anderson, Paralegal C'? ?°? ?i ?._ .... y ? ..w. ? ? ?, .? "Y". I .. ;_7 ? , -=?, =y? ? . ,...r ...- ORDER APPOINTING MASTER And now / Q , 2008, ?• (0? ?/P/.? I? Esquire, is appointed master with respec to the following claims: Equitable Distribution. Alimony. Alimony Pendente Lite. Counsel fees and Costs and Expenses. By th ourt: vI o J MOVING PARTY Stephanie L. Krouse Attorney's Information Pamela L. Purdy, Esquire 308 North Second Street, Ste. P.O. Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 e?? NON-MOVING PARTY Jeffrey E. Krouse Attorney Information Ann Levin, Esquire 200 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 -2- 7 N q - 73 LL-T 8934-1-4/Plfs Pretrial Stmt/AVL/mes 10/2/2008 2:30:02 PM SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3`d Flr. Harrisburg, PA 17110-1778 (717) 234-2401 Ismiee1(i ,sasllp.com alevin(dsas11p.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION- LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF JEFFREY E. KROUSE INCOME STATEMENT INCOME 2008 Proiected Gross Income Estimated Taxes i-$-(12,000.00)7- I 2008 Projected Net Income $ 34,200.00 EXPENSES i -- Item Mont hly (or) Yearly HOME - Mortgage- $ 635. $ - 7,620 Maintenance $ 25 $ 300 Electricity - $ 151 $ 1,812 Oil (estimated) $ 200 $ 2,400 Telephone (home and eel) $ 115 $ 1,380 Water/Sewer $ 45 $ 540 EMPLOYMENT Lunches 40 $ 480 IN SU RANCE _ _ _ Homeowners Insurance $ _ 30 $ 358 Automobile Insurance $ 65 $ 780 Health Insurance TBD Other Insurance (specify) (Dental & Eye) TBD AUTOMOBILE Automobile Fuel $ 135 4 $ 1,620 Automobile Repairs(Reg., Insp., Mamt., etc.) $ 37 $ 440 MEDICAL Doctor (Copays, deductables, etc.) $ 6 $ 75 Dentist (Copays, deductables, etc.) $ 23 $ 270 Orthodontist (Sarah) $ 200 $ 2,400 Medicine (Copays, deductables, etc.) $ 10 $ 120 Special Medical Needs (specify) (Counselor) $ 150 $ 1,800 PERSONAL - Clothing - - - - - - $ - - 11 $ - 132 Laundry/Dry Cleaning $ - - 13 $ 159 Food (Grocery) $ 413 $ 4,950 Barber/Hairdresser $ 18 $ 211 Credit Payments/Charge Accounts: 25 $ 300 Memberships (specify) (swim Club) $ 26 $ 310 MISCELLANEOUS Entertainment $ 28 $ 330 Pay TV $ _- - - 57 r $- - __ - 684 Church - - $ 110 $ 1,320 Charitable Contributions $ 23 $ 275 Other Child Support $ 720 $ 8,640 Other Expenses (specify) (misc. household goods , supplies, children's items, restaurant, etc.) $ 80 $ 960 Self-employment expenses ; $ 109 $ 1,302 Legal fees Total Expenses $ 3,497 $ 41,968 I, Jeffrey Krouse, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: lmz;x,et?? J Y1 e 8934-1-4/Plfs Pretrial Stmt/AVL/mes 10/2/2008 2:30:02 PM SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3 d Flr. Harrisburg, PA 17110-1778 (717) 234-2401 IsmigeWsasllp.com alevin asasilp.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION- LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Income and Expense Statement of Jeffrey E. Krouse on counsel for Plaintiff by placing same in the U.S. Mail, first class, postage paid on the day of n &X? 2008, addressed as follows: PAMELA L. PURDY, ESQUIRE 308 NORTH SECOND STREET, STE. 200 HARRISBURG, PA 17101 SMIGEL, ANDERSON & SACKS, LLP By: Ann Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant ?? ,nom r_? ?? ??.? , ?? ° ?? : 4 "?1 1 W _? ?:.? ...1.. ..F.« ?+ SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3`d Fir. Harrisburg, PA 17110-1778 (717) 234-2401 IsmigelLa-sasllp.com a levinld:sasllp.com Attorneys for Defendant STEPHANIE L. KROUSE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2454 JEFFREY E. KROUSE, CIVIL ACTION-LAW Defendant IN DIVORCE INVENTORY OF DEFENDANT JEFFREY E. KROUSE ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. Real property (X) 2. Motor vehicles (X) 3. Stocks, bonds, securities and options () 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts O 9. Life Insurance policies (indicate face value and current beneficiaries () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company.) () 16. Employment termination benefits - severance pay, workman's compensation claim/award () 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts O 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. MilitaryN.A. benefits () 23. Education benefits () 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute (X) 26. Other I CI Iw ? ? ? f? ?w m c w 'I mo i ? I I l I I ' I ? I I G? ? I I? ? ' bd dl co o Fo vao ? ? 3 I ? f2o ° ? I ,9 O O 1 ? A ' ry 'I y < K I K j? ? < 'I A \ A i -, N ?.?n I?' (p '< .gyp IcD ? n '•? ?° ,9• ' I to a S° o!?n! cN ?r=r ?I I o '? c I ?a Q V,?I ? Ira Ivan ' w! I_ ' . . N I? ? ? n ' ? I I a ? I I ILO I I ? ' c I , . I I I ? I C I I w III I 0 c 00 ' I ? I ? I I ? 'I I I I I I I ? I ? ? x III ? x x x I I CL aI aI, ° n I ? ? ''dII I a II ? ?ro Ic ? III ? I I oo? ; ? O - - "° I I , II ; I I A m Ig '' 'r3 N ^+? I < I O I p? d p i , O t a p IIp O p O I i al n. a, ,a .al N? m o' . ?0 0 0 C> ° o. c c CL o a o f I I! l i I I, se, ,sn i.-1 ? I ? I I? I O ! li ' I I? Igo', ? I o ! I HA 69. 69 69 ,., o- oiol -01 C rn n Im o l .._. A i ? tc to I co ? ? ? I co ? ' N ?l 'I, tJ ? N '' N fD ?? N (D ? N ? O '. (D ? m I t-j o II oo rn ' n Ll 0. cc to I co I co I ? o co ' 0 N N O 0 N b 0 0 a 'O b w E3 O I CD CD ? ?, II i W U?Q ? ? N W I O I I I z 0 z x x x ' c I? CT• c c I Q, " C3'• cr Mc?J I I ? Ir 0 0 c o olo no o 00 o i ? 0 '0 O j r-: l J I O N N O O N 00 ?b?/- iO CD CD CD CD CD fD < ?D'? d;d' C? C7 C7 C1 ? ? a p? 0 0 0 0 0 0 0- o a 0 . ..1 ' 0 'CD CD CD CD ' CD X 0 c L '; s o!o 00 00 00 00 00 ? 00 . . 0 00 m p bssS fA bO?? kA ?A V ko I N ?'? W t!i ?l N O O'O N C> O 0 ? C1 N O CL 0 j ?w V l 1?0 ?w V O 110 O O O O O O O a1 00 O O ..r C O 0 O 0 • O 0 O 0 O 0 O 0 w C*? 0 O GG c cc 4 Ic4r 6 aO a lc4r 6 6 6 LI, - 3 o a' ! CL LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED (X) 1. Mortgages O 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED (X) 5. Credit card balances () 6. Purchases () 7. Loan payments () 8. Notes payable O 9. Other unsecured liabilities CONTINGENT OR DEFERRED () 10. Contracts or Agreements () 11. Promissory notes () 12. Lawsuits () 13. Options () 14. Taxes () 15. Other contingent or deferred liabilities 0 O d ? d G ? ? n O O (D cn " ! l „TI:Z' ^. ?r O o I' 0-0 ? r I? cn sA O c& fn kA: 1 ll co N- p A i 00 "C -,j N? C1. N N O O 00 N a I, Jeffrey Krouse, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. llvelllk" Date: 10 1-2- 056 - - I Je y SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3`d Fir. Harrisburg, PA 17110-1778 (717) 234-2401 Ismigel(a,sasllp. com alevin c sasllp.com Attorneys for Defendant STEPHANIE L. KROUSE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2454 JEFFREY E. KROUSE, CIVIL ACTION-LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant/Respondent in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Inventory of Jeffrey E. Krouse on counsel for Plaintiff by placing same in the U.S. Mail, first class, postage paid on the ;2- day of 2008, addressed as follows: PAMELA L. PURDY, ESQUIRE 308 NORTH SECOND STREET, STE. 200 HARRISBURG, PA 17101 SMIGEL, ANDERSON & SACKS, LLP V By Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant/Respondent {"'? `? i ? ' ? + y y ?? .?? ?.. .. ? 4`:fi`? '; i?.) .,.? ?\} +;? 10/2/20082:30:40 PM/AVL/mes SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3`d Mr. Harrisburg, PA 17110-1778 (717) 234-2401 Ismigelksaslln corn alevin a sasllo.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 JEFFREY E. KROUSE, Defendant CIVIL ACTION - LAW IN DIVORCE PETITION RAISING MARITAL CLAIMS AND NOW, comes the Defendant, Jeffrey E. Krouse, by and through his counsel, SMIGEL, ANDERSON & SACKS, LLP, and files this Petition Raising Marital Claims and in support thereof avers as follows: 1. Plaintiff is Stephanie L. Krouse, an adult individual who currently resides at 317 West Ridge Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey E. Krouse, an adult individual who currently resides at 183 Garland Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were married on July 14, 1992. 4. A Complaint for Divorce was filed by Plaintiff on May 2, 2006 in Cumberland County, Pennsylvania. 5. Defendant hereby raises the following marital claims: 10/2/20082:30:40 PM/AVL/mes COUNTI COUNSEL FEES, COSTS AND EXPENSES 6. Defendant repeats and realleges the averments of paragraphs 1 through 5 which are incorporated by reference herein. 7. Defendant has incurred unnecessary counsel fees, costs and expenses due to Plaintiff's actions. WHEREFORE, Defendant respectfully requests that this Honorable Court award him counsel fees, costs and expenses. SMIGEL, ANDERSON & SACKS, LLP Date: C) By: Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant I, Jeffrey Krouse, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 10) Z,1 CR) Je o 10/2/20082:30:40 PM/AVL/mes SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3rd Mr. Harrisburg, PA 17110-1778 (717) 234-2401 IsmigelCasasllp.corn alevinnsasllo.com Attorneys for Defendant STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Ann V. Levin, Esquire, counsel for Defendant in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Petition Raising Marital Claims on counsel for Plaintiff by hand-delivery on the I day of October, 2008. SMIGEL, NDERSON & SACKS, LLP X4?D By:. (1 Ann V. Levin, Esquire I.D.#: 70259 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Defendant ???, l? ?'S't 2 +1 . ?'s ?5 ? ? ? . ? ??.? r3'.o. i«?::4 .. '-:;? ?±' ?; Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE PETITION TO WITHDRAW AS COUNSEL AND NOW COMES Pamela L. Purdy, Esquire, attorney of record for Plaintiff Stephanie L. Krouse, and respectfully represents the following in support of this Petition: 1. Petitioner is undersigned counsel, Pamela L. Purdy, Esquire, attorney of record for Plaintiff Stephanie L. Krouse in the above-captioned case. 2. Defendant is Stephanie L. Krouse, currently residing at 317 W. Ridge Street, Carlisle, Cumberland County 17013. 3. Plaintiff has requested that Petitioner withdraw as counsel in the above-captioned matter. 4. Plaintiff has represented that she does not intend to retain new counsel, but intends to represent herself going forward. WHEREFORE, Petitioner Pamela L. Purdy respectfully requests this Honorable Court to permit her to withdraw her appearance as counsel of record for Defendant in the above-captioned case. Respectfully Submitted, f laou'? Ile Pamela L. Purdy Date: ? 124 ck 2,3 c l Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that on th??ay of 2009, a true and correct copy of the foregoing document was served by facsimile upon the following: Stephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 Ann V. Levin, Esq. Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 &4 t i::::Y Pamela L. Purdy c`? ? :?? _; .. ":? -?- r .?: ?? ` f? ? CJ? ?'[ '? ??.. !'«?.? °?.~ ?,, Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE AMENDED PETITION TO WITHDRAW AS COUNSEL AND NOW COMES Pamela L. Purdy, Esquire, attorney of record for Plaintiff Stephanie L. Krouse, and respectfully represents the following in support of this Petition: 1. Petitioner is undersigned counsel, Pamela L. Purdy, Esquire, attorney of record for Plaintiff Stephanie L. Krouse in the above-captioned case. 2. Defendant is Stephanie L. Krouse, currently residing at 317 W. Ridge Street, Carlisle, Cumberland County 17013. 3. Plaintiff has requested that Petitioner withdraw as counsel in the above-captioned matter. 4. Plaintiff has represented that she does not intend to retain new counsel, but intends to represent herself going forward. 5. No judge has made a ruling in this matter previously. 6. Defendant concurs with this motion. WHEREFORE, Petitioner Pamela L. Purdy respectfully requests this Honorable Court to permit her to withdraw her appearance as counsel of record for Defendant in the above-captioned case. Date: A?? (/ 2x I I Respectfully Submitted, Pamela L. Purdy Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that on the ) (Sday of 2009, a true and correct copy of the foregoing document was served by facsimile upon the following: Stephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 Ann V. Levin, Esq. Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 P mela L. Purdy e FILB>O OF THE PROTH '`S+1oTAM 2009 APR -3 PM 1: 33 COMPLAINT UNDER SECTION 3301 (d) OF THE DIVORCE CODE DOCKET # 06-2454 1. The plaintiff is StEPHANIE KROUSE, who currently resides at 317 W. Ridge Street,'; Carlisle, PA 17013- Cumberland County 2. The defendant is JEFFREY E. KROUSE, who currently resides at 153 Garland Drive, Carlisle PA 17013 Cumberland County 3. Plaintiff and Defodant have been bona fide residents in the Commonwealth for at least six months immediately following the filing of this complaint. 4. The Plaintiff and efendant were married on July 13, 1992 at Snow Hill, Marylad; 5. There have been 0o prior actions of divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been; advised that counseling is available and that plaintiff may have the right td request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. 9. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties, relating to unsworn falsification to authorities. Stephanie L. Krouse' / Plaintiff/ No attorney-representing myself pro se April 7, 2009 ?'?sr?.vnNi MOTAF1iAL 8EAL We" IMPP, N&MY Pao sow SP" "C0*80M coufft My Gq ob-oddW31,2012 R C= 932 O STEPHANIE L. KROUSE,: IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JEFFREY E. KROUSE, : Defendant NO. 06-2454 CIVIL TERM ORDER OF COURT AND NOW, this 14'h day of April, 2009, upon consideration of Petition To Withdraw As Counsel and the Amended Petition To Withdraw As Counsel, a Rule is hereby issued on Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of the date of this order. BY THE COURT, tephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 X1 ramela L. Purdy, Esq. 308 North Second Street Suite 200 Harrisburg, PA 17101 Attorney for Plaintiff ,,.Kfin Levin, Esq. 4431 North Front Street Harrisburg, PA 17110 Attorney for Defendant :rc 0E : t t Nv 51 m 6Q0z h `.t i v .1rd,j6cl 3HI Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. JEFFREY E. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, this ?1a , ` day of April, 2009, Pamela L. Purdy, Counsel for Plaintiff, hereby files this Motion to Make Rule Absolute, and in support thereof avers the following: 1. On April 3, 2009, Pamela L. Purdy, Counsel for Plaintiff, filed a Petition to Withdraw as Counsel. 2. This Court entered a Rule to Show Cause on April 14, 2009, requiring both parties to show cause why the Petition to Withdraw as Counsel should not be granted within ten days of the date of service. 3. Neither party filed an answer to the Petition to Withdraw as Counsel. 4. Pursuant to Pa.R.C.P. §206.7, if an answer is not filed, "all averments of fact in the petition may be deemed admitted... and the court shall enter an appropriate order." WHEREFORE, Defendant's Counsel, Pamela L. Purdy, respectfully requests this Honorable Court to enter an Order granting her Petition to Withdraw as Counsel. Respectfully submitted, AV , Pamela L. Purdy Attorney for Plaintiff Dated: 0(1?11 2 1701 a CERTIFICATE OF SERVICE The undersigned hereby certifies that on the ?- ?? day of April, 2009, a true and correct copy of the foregoing document was served by U.S. Mail on the following: Stephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 Ann Levin, Esq. 4431 N. Front Street Harrisburg, PA 17110 Pamela L. Purdy FILED-: TRICE OF THE P",-,%" -, ; ; pY 2009 MA Y -i Ail H: : 214 ,4 Pamela L. Purdy PA ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff STEPHANIE L. KROUSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. JEFFREY E. KROUSE, Defendant NO. 06-2454 CIVIL ACTION - LAW IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, this S-`' day of May, 2009, Pamela L. Purdy, Counsel for Plaintiff, hereby files this Motion to Make Rule Absolute, and in support thereof avers the following: 1. On April 3, 2009, Pamela L. Purdy, Counsel for Plaintiff, filed a Petition to Withdraw as Counsel. 2. This Court entered a Rule to Show Cause on April 14, 2009, requiring both parties to show cause why the Petition to Withdraw as Counsel should not be granted within ten days of the date of service. 3. Neither party filed an answer to the Petition to Withdraw as Counsel. 4. Pursuant to Pa.R.C.P. §206.7, if an answer is not filed, "all averments of fact in the petition may be deemed admitted... and the court shall enter an appropriate order." 5. Judge Oler has previously ruled in this matter. 6. Plaintiff concurs in this Motion. WHEREFORE, Defendant's Counsel, Pamela L. Purdy, respectfully requests this Honorable Court to enter an Order granting her Petition to Withdraw as Counsel. Respectfully submitted, Dated: Sf (S/ 01 Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that on the day of May, 2009, a true and correct copy of the foregoing document was served by U.S. Mail on the following: Stephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 Ann Levin, Esq. 4431 N. Front Street Harrisburg, PA 17110 LCV9 L 9:;?' - Pamela L. Purdy 0 ,? fr f }? ?,.Ji I .i 1 MAY 1 9 2009 STE V. JEFFREY IIE L. KROUSE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA NO. 06-2454 E. KROUSE, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER to Make granted NOW, this day of , 2009, upon review of the Motion Absolute, said Motion is hereby granted. Plaintiffs Counsel is hereby nission to withdraw as counsel. ?uismDUVOI Stephanie L : Krouse 317 W. Rid a Street Carlisle, PA 17013 ,- Ann V. Levin , Esq. 4431 North Front Street Harrisburg, A 17110 /Pamela L. P 308 North 2 urdy, Esquire d St., Suite 200 PO Box 115 44 Harrisburg, A 17108 watE,S ITI?LL&L I Io BY THE COURT: t ° . (` N Pamela L. Purdy, Esquire 308 North 2"d Street, Suite 200 P.O. Box 11544 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax Attorney I.D. #85783 STEPHANIE L. KROUSE, Plaintiff VS. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-2454 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw the appearance of Pamela L. Purdy, Esquire, as counsel for the Plaintiff in the above-captioned action. ZG Lon Date P" L Pamela L. Purdy CERTIFICATE OF SERVICE The undersigned hereby certifies that on the Z?day of May, 2009 a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Stephanie L. Krouse 317 W. Ridge Street Carlisle, PA 17013 Ann V. Levin, Esquire 4431 North Front Street Harrisburg, PA 171 10 P" t Pamela L. Purdy, Esquire 1 4; 2099 MAY 21 PH 2: t ,: STEPHANIE L. KROUSE, Plaintiff vs. JEFFREY E. KROUSE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2454 CIVIL ACTION -LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated in April 2006 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date:01 `4 V ?Le?ko?ue? Kn Q ? Stephanie L. Krouse, Plaintiff FILED-O FICE OF THE I ROT`0NOTARY 2009 JUN 10 AM 11: 2 3 AILED-,, ?F ?;?ICE '' THE Pr 4?rE.. ' P?`OT?RY STEPHANIE L.KROUSE, Plaintiff V. JEFFREY E. KROUSE, Defendant : IN DIVORCE 2010 MAR I ( &M 9: 06 IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY,I;SYLVAN Ty f!YA CIVIL ACTION - LAW NO. 06-2454 CIVIL TERM WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses 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 THATT EH STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. G I??c Date Stepha ie L. Krouse STEPHANIE L. KROUSE, Plaintiff VS. JEFFREY E. KROUSE, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 2454 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this 6-4 day of 2011, the economic claims raised in the proceedings having been resolved in accordance with a marriage settlement agreement dated April 6, 2009, and amendments dated November 12, 2009, and June 23, 2010, 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, /&/, nA'? • - evi A. Hess, P.J. John cc: J. Mangan Attorney for Plaintiff Ann V. Levin Attorney for Defendant , b !v !/ :c' ^a c 8934-1-4/MSA/AVL/mes/Draft #7 4/6/2009 1:43:12 PM MARRIAGE SETTLEMENT AGREEMENT AGREEMENT MADE this - day of 40 . I , 2009, by and 14 between Stephanie Krouse ("Wife") - A N D - Jeffrey Krouse ("Husband"), at Harrisburg, Pennsylvania. WHEREAS, the parties hereto are husband and wife having been married on July 13, 1992, at, Snow Hill, Maryland; WHEREAS, two (2) children were born of this marriage; said children being: Sarah Jane Krouse, date of birth December 29, 1993 and Hannah Katherine Krouse, date of birth January 24, 1998. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the foregoing premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. Divorce and Separation. Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint, or interference whatsoever by the other. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. The parties acknowledge that a divorce action has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania at docket number 06-2454. Within ten (10) days of signing this Agreement, Husband and Wife shall file Praecipes to withdraw their economic claims of record. Thereafter, Wife shal l proceed with the entry of a divorce decree pursuant to Section 3301(d) of the Divorce Code of 1980. 2. Division of Property. Husband and Wife agree that the following constitutes an equitable distribution of the marital property. A. Husband's Property. The following property shall become the sole and exclusive property of Husband: (1) Husband's pre-marital property and lot situate at 153 Garland Drive, Carlisle, Pennsylvania 17013, subject to all existing liens and obligations. If necessary, Wife shall sign a Quitclaim Deed transferring any and all marital interest to Husband; (2) The 2005 Ford Escape; (3) The 1993 Honda Accord (3) The M&T Bank Checking account, last four digits 2501; (4) The M&T Bank Money Market account, last four digits 8846; (5) The M&T Bank IRA, last four digits 1865, formerly the State 2 Street IRA, subject to a distribution to Wife as set forth Paragraph 2.13.5, (6) Any and all post separation checking and savings accounts opened by Husband will remain his sole and exclusive possession; and (7) All household goods and personalty in Husband's possession wherever situated. B. Wife's Proaerty. The following property shall become the sole and exclusive property of Wife: (1) The Members lst Checking account, last four digits 6794; (2) The Members 1 st Savings account, last four digits 6794; (3) The Team Rahal, Inc. 401(k); (4) Any and all pension or retirement accounts acquired by Wife through her employment with Ford; (5) Husband shall transfer Seventy-One (71 %) percent of his M&T Bank IRA #1865, formerly the State Street IRA, account balance as of December 31, 2008 subject to gains and losses from that date to the date of distribution, to Wife. This transfer shall be pursuant to a Qualified Domestic Relations Order substantially in the form of the document attached hereto as Exhibit A. Wife's share shall be distributed on a pro rata basis from all of the investments in Husband's account. Of the Seventy-One (71%) percent Wife receives, Wife plans to withdraw Thirty Thousand ($30,000) Dollars in cash and the balance will be paid in a roll over to Wife's Members 1St IRA # 116794- 10; 3 (6) Husband agrees to pay to Wife one-half (1/2) of the actual income tax incurred by Wife for her withdrawal of Thirty Thousand ($30,000) Dollars in Paragraph 2.B.5 above, up to a maximum of One Thousand Five Hundred ($1,500) Dollars. Wife will provide Husband with a copy of her 2009 Federal Income Tax Return on or before April 1, 2010. Husband shall make the payment, if any, to Wife on or before April 15, 2010; (7) Husband shall pay to Wife the lump sum cash payment of Twenty- Five Thousand ($25,000) Dollars within fifteen (15) days of the date of his refinance of the debt on the marital home; (8) Any and all post separation checking and savings accounts opened by Wife will remain her sole and exclusive possession; and (9) All household goods and personalty in Wife's possession wherever situated. C. Satisfactory Division of Marital and Non-Marital Propertv. Husband and Wife hereby acknowledge that they have divided, to their mutual satisfaction, all of their marital and non-marital assets, including but without limitation, business interests, partnerships, inheritances, jewelry, clothing, pensions, brokerage accounts, stocks, bonds, life insurance policies or other securities, individual retirement accounts, 401(k), employment benefits, checking and savings accounts, mutual funds and other assets, whether real, personal or mixed, tangible or intangible. 3. Taxes. Prior to 2006 the parties filed joint federal and state tax returns. Both parties 4 agree that in the event any-deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 4. Additional Documentation. The parties agree to execute any deeds, assignments, titles or other documents necessary and appropriate to accomplish the aforesaid division of property and to carry out the provisions of this Agreement. 5. Transfers Subject to Existing Liens. Notwithstanding any other provisions in this document all property transferred hereunder is subject to the existing lien or liens set forth above. The respective transferee of such property agrees to indemnify and save harmless the other party from any claim or liability that such other party may suffer or may be required to pay on account of such lien or encumbrance. 6. Representations and Warranties. The parties represent and warrant to each other that the property described in this Agreement represents all of the property in which they have any right, title and interest, and that such property is subject to no mortgage, pledge, lien, security interest, encumbrance or charge except those which are disclosed herein. 7. Equitable Division. By this Agreement the parties have intended to effect an equitable division of their jointly owned property. The parties have determined that an equitable division of such property conforms to a just and right standard, with due regard to the rights of each party. The division 5 of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as non-taxable. 8. Relinquishment of Rights. Except as expressly provided herein, Husband forever relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now or hereafter have in any tangible or intangible assets now belonging to Husband. 9. After-Acquired Property. Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were unmarried. 10. Debts & Liabilities. Husband and Wife shall each be solely responsible for all debts, contracts, obligations and liabilities in their respective names incurred at any time in the past unless and except as otherwise specifically set forth in this Agreement, including but not limited to personal loans, charge accounts and credit cards. Both parties represent and warrant to the other that as of the date of this Agreement they have not incurred, and in the future will not contract or incur, any debt or liability for which the other or the estate of the other might be responsible. 11. Counsel Fees, Costs and Expenses. Each party shall be responsible for his or her own legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their 6 marriage. 12. Health Insurance. Wife will maintain health insurance coverage for Husband at Wife's expense, until the entry of a divorce decree. Thereafter, Wife will cooperate with Husband regarding health insurance benefits available through Cobra. 13. Alimony. In exchange for and in consideration of the promises and representations made hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the other or the respective separate property of the other under the laws of the Commonwealth of Pennsylvania or any other governing state, country, territory or jurisdiction in the nature of spousal support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative, permanent or lump sum and right to seek equitable or community distribution or division or assignment of property or similar marital rights. 14. Full Disclosure. The respective parties do hereby warrant, represent and declare and do acknowledge and agree that each is and has been fully and completely informed of and is familiar with and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his or her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. 15. Releases. Each party does hereby remise, release, quitclaim and forever discharge the other and the estate of the other from any and every claim that each other may now have, or hereafter have or can have at any time, against the other, or in and to or against the other's estate, or any part thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of 7 dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take against each other's will, or for support or maintenance, or of any other nature whatsoever, except any rights accruing under this Agreement. 16. Indemnification. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. Husband and Wife agree to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 17. General Provisions. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no 8 representations or warranties other than those expressly set forth herein. 18. Fair and Equitable Contents. Husband and Wife acknowledge that he or she has had the opportunity to employ, consult with and to have the provisions of this agreement and its legal effect fully explained by independent legal counsel of his or her selection and acknowledge that he or she was not prevented in any way from obtaining independent counsel. Wife had been represented by Pamela Purdy, Esquire until March 16, 2009 when she decided to continue pro se. Wife has had the opportunity to receive independent legal advice from counsel of her selection and she fully understands the facts and has been fully informed as to her legal rights and obligations. Each party fully understands the facts and had an opportunity to be fully informed as to his or her legal rights and obligations. 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 with such knowledge and that execution of this agreement is not the result of any duress or undue influence nor the result of any collusion or improper or illegal agreement or agreements. 19. Breach. It is expressly stipulated that if either party fails in the due performance of any of his or her material obligations under this Agreement, the other party shall have the right, at his or her election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services rendered by the non-defaulting party's attorney in any action or proceeding to compel performance hereunder. 20. Modification. No modification, rescission or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 9 21. 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. 22. Applicable Law. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 23. Agreement Not to be Merged. This Agreement may be filed with the Court for incorporation into the 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 have set their hands and seals the day and year first above written. Witness: V A j. Al A 9 i'l ) Vh Ai AA JU I Stephanie Krouse J s' 10 AMENDMENT TO MARRIAGE SETTLEMENT AGREEMENT AGREEMENT MADE this ).Z day of /tJIN evy\? , 2009, by and between STEPHANIE L. KROUSE ("Wife") - A N D - JEFFREY E. KROUSE ("Husband"), at Harrisburg, Pennsylvania. WHEREAS, the parties hereto entered into a Marriage Settlement Agreement dated April 6, 2009; WHEREAS, Paragraph 1 of the Marriage Settlement Agreement provided that Wife would proceed with the entry of a divorce decree pursuant to Section 3301(d) of the Divorce Code of 1980; WHEREAS, Paragraph 2.B.5 of the Marriage Settlement Agreement provided Wife with a roll- over from Husband's M&T Bank IRA # 1865; WHEREAS, the parties hereto wish to modify the terms of Paragraph 1, Paragraph 2.13.5 and Paragraph 2.B.6 of their April 6, 2009 Marriage Settlement Agreement. NOW, THEREFORE, the parties intending to be legally bound, do agree as follows: 1. Incorporation of Preambles as Material Terms of the Agreement. The parties agree that the above referenced terms contained in the Whereas clauses of this Amended Agreement are material terms of the Amended Agreement and are incorporated by reference herein. 2. Paragraph 1. Husband acknowledges that Wife has already filed her 3301(d) Affidavit. Paragraph 1 of the Marriage Settlement Agreement dated April 6, 2009 shall be modified so that Wife shall not proceed with the entry of the divorce decree until she has provided Husband with an additional ninety (90) days written notice of her intent to do so. A divorce decree shall be entered no sooner than January 1, 2010. 3. Paragraph 2.13.5. Paragraph 2.13.5 of the April 6, 2009 shall be void. It will be replaced with: As part of the division of the estate of the parties, Husband shall transfer Seventy-One (71%) percent of his M&T Bank IRA 41865 account balance as of December 31, 2008 subject to gains and losses from that date to the date of distribution, to Wife. Of the Seventy-One (71 %) percent Wife receives, Wife shall be credited with already having received Thirty-Five Thousand Eight Hundred ($35,800) Dollars plus having received the gains and losses that the sum of Thirty-Five Thousand Eight Hundred ($35,800) Dollars incurred from September 11, 2009 to the date of distribution. The balance will be paid in a rollover to Wife's Members 1" IRA #116794-10. The Qualified Domestic Relations Order attached to the Marriage Settlement Agreement dated April 6, 2009 as Exhibit A shall not be filed with the Court. The Qualified Domestic Relations Order, substantially in the form of the document attached hereto as Exhibit A, shall be executed and filed with the Court upon entry of the divorce decree. 5. Paragraph 2.B.6. Paragraph 2.B.6 of the April 6, 2009 Marriage Settlement Agreement is void and unenforceable. 4. Ratification of Prior Terms. In all other respects, the parties ratify and confirm all the terms of their Agreement dated April 6, 2009. The parties acknowledge that this Amendment to the parties' Marital Settlement Agreement shall become effective when actually signed by both parties. Witness: effrey E. ouse S phanie L. Krouse 2 My Commission Expires: I I - Z. y - 3 O pNN edroa?w,a IM? C+aw?n ?+? Non. ?? !01>} COMMONWEALTH OF PENNSYLVANIA {{ : ss. COUNTY OF ; "PH*N Cu nnl oc?.d Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, JEFFREY E. KROUSE, who being duly sworn according to law deposes and says that he is a party of the foregoing Agreement and he executed same for the purposes therein contained. Witness my hand and seal this 1 to day of C 0 q-.e-M ?,--? , 2009. 0j Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . SS. Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, STEPHANIE L. KROUSE, who being duly sworn according to law deposes and says that she is a party of the foregoing Agreement and yysrhe executed same for the purposes therein contained. Witness my hand and seal this 1 V?'-h day of N 0Uk M ?J,0( , 2009. i Notj4rv Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Nohriml Seal 3 JUb M trod, Wtwy P? Cadwe em 01ftaand ??Wj .55c,^ ,q l?ea peC k 2011 Paluay?vaMa Aasxhm" of Nowfts i ft SECOND AMENDMENT TO MARRIAGE SETTLEMENT AGREEMENT AGREEMENT MADE this g- day of 2010, by and between STEPHANIE L. KROUSE ("Wife") - A N D - JEFFREY E. KROUSE ("Husband"), at Harrisburg, Pennsylvania. WHEREAS, the parties hereto entered into a Marriage Settlement Agreement dated April 6, 2009 and an Amendment to Marriage Settlement Agreement dated November 12.2009; WHEREAS, Paragraph 2 of the Amendment to Marriage Settlement Agreement amended Paragraph 1 of the original Marriage Settlement Agreement; WHEREAS, Paragraph 3 of the Amendment to Marriage Settlement Agreement amended Paragraph 2.B.5 of the original Marriage Settlement Agreement; WHEREAS, the parties hereto wish to further modify the terms of Paragraph. I and Paragraph .B.5. of their April 6, 1009 Marriage Settlement Agreement. NOW, THEREFORE, the parties intending to be legally bound, do agree as follows: 1. Husband acknowledges that Wife has already filed her 3301(d) Affidavit. Paragraph 1 of the Marriage Settlement Agreement dated April 6, 2009 shall be modified so that Wife shall not seek the entry of the divorce decree prior to March 1, 2011. Wife sha11_ provide Ditishard ?xrth thirty (10} days notice prior to seeking the entry of a divorce decree- Paragraph 2 of the November 12, 2009 Amendment to Marriage Settlement Agreement shall be void. 2. Paragraph 3 of the November 12, 2009 Amendment to Marriage Settlement Agreement shall bl; modified as follows: As part of the division of the estate of the parties, Husband shall transfer the sum of Forty-Three Thousand, Five Hundred Fifty-One ($43,551) Dollars from his M&T Bank IRA 41865 account balance to Wife. Wife acknowledges already having received Thirty-Five Thousand Eight Hundred ($35,800) Dollars. Husband shall not be required to transfer, or cause to be rolled over, any additional funds to Wife under the April 6, 2009 Marriage Settlement Agreement or the November 12, 2009 Amendment to Marriage Settlement Agreement. Any remaining balance in the M&T Bank IRA with the last four digits 1865 shall solely belong to Husband. The Qualified Domestic Relations Order attached to the Marriage Settlement Agreement dated April 6, 2009 as Exhibit A for entry as a court order shall not be filed with the Court and is hereby void. The Stipulation signed by counsel for Husband and Wife dated November 12, 2009 for the entry of a Qualified Domestic Relations Order shall be void. The Qualified Domestic Relations Order attached as Exhibit A to the November 12, 2009 Amendment to Marriage Settlement Agreement shall not be executed and filed with the Court upon entry of the divorce decree. 3. Ratification of Prior Terms. In all other respects, the parties ratify and confirm all the terms of their Agreement dated April 6, 2009 and the Amended Marriage Settlement Agreement dated November 12, 2009. The parties acknowledge that this Second Amendment to the parties' Marital Settlement Agreement shall become effective when actually signed by both parties. Witness: U Jeffrey . Krouse A LL'X St hanie I.. l5ouse 2 COMMONWEALTH.OF PENNSYLVANIA ss. COUNTY OF 1DA44PH4N CU.M'66XJ-A1U & : Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, JEFFREY E. KROUSE, who being duly sworn according to law deposes and says that he is a party of the foregoing Agreement and he executed same forlhe purposes therein contained. Witness my hand and seal this a-b day of -fjC- 2010. COMMONWEALTH OF PENNSYLVANIA Notary Public NOTARIAL SEAL CAMELA J. MANGES, Notary Pub{k SoroofCadisle,CumbedandCounty My Commission Expires: ?UjI?e My Commission E*m June 21, 2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County-, STEPHANIE L, KROtaSE, who being duly sworn according to law deposesand saes that she is a party of the foregoing Agreement and she e}xxecuted same for the purposes therein contained. Witness my hand and seal this _ - =_ day of - June 2010. 11 ?-\A ' r0a Not Public My Ccn-Amission Expires: ) al (DI /I COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jule M. Good, NotM PuNic Carlisle Boro, CuntAOand Ccu* My Commission E)O!? i)e,,C. 6, 7f11 S I Member, Pennsvly?:!',? ?' ' •-•i yoterle= FILED-OFFIC:L Wr a "k _j 2011 MAY 12 P 1: 50 STEPHANIE L. KROUSE, o i C Cr r'„ tlE , , NN YLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY E. KROUSE, Defendant CIVIL ACTION - LAW NO. 06-2454 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT A complaint in Divorce under §3301(c) of the Divorce Code was filed on May 2, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree or by signing a Waiver of Notice. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. D 4 AV) 1A !11 15 x Date ep arid Krouse 'r.1?3 ??(1 2 ply STEPHANIE L. KROUSE, HE COU T` W COMMON PLEAS OF Plaintiff : !a PLICANP-QOUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JEFFREY E. KROUSE, NO. 06-2454 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT A complaint in Divorce under §3301(c) of the Divorce Code was filed on May 2, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree or by signing a Waiver of Notice. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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. --7 IZ4 // ate Jeffrey Krouse Pik I ! I MAY 12 STEPHANIE L.KROUSE, „..-.:.F IN THE COURT OF COMMON PLEAS OF `' ` CUMBERLAND COUNTY, PENNSYLVANIA A ` P!I . Nky V. CIVIL ACTION - LAW JEFFREY E. KROUSE, NO. 06-2454 CIVIL TERM Defendant : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ? MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Aku"11W-) I\AJUVIA-) Date ephanie L. Krouse FILE -OFFIG _ ??II M?? 12 P?? ff STEPHANIE L.KROUSE, : INIE COURT OF COMMON PLEAS OF Plainti BERLAND CLIG rMBERLAND COUNTY, PENNSYLVANIA PENNSYLVAH1 V. CIVIL ACTION - LAW JEFFREY E. KROUSE, NO. 06-2454 CIVIL TERM Defendant IN DIVORCE WAIVER OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 IN THE FOREGOING AFFIDAVIT 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 Jeffery E. Krouse STEPHANIE L.KROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JEFFREY E. KROUSE, NO. 06-2454 CIVIL TERI1rI, =" a Defendant IN DIVORCE = --i ? ' ors r PRAECIPE TO TRANSMIT RECORD -- r? Y C: w- 1 TO THE PROTHONOTARY: r'- Transmit the record, together with the following information, to the Court for entry of a dree-decr&i,: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: filed on May 2, 2006 and Acceptance of Service signed on June 8, 2006. Date of execution of the Affidavit Of Consent required by § 3301(c) of The Divorce Code: by the Plaintiff. April 4, 2011; by the Defendant: March 24, 2011. 4. Related claims pending: None Date Plaintiff's Waiver Of Intention To Request Entry Of A Divorce Under §3301(c) Of The Divorce Code was filed with the Prothonotary: on April 4, 2011; a copy of which is attached. Date Defendant's Waiver Oflntention To Request Entry OfA Divorce Under §3301(c) Of The Divorce Code was filed with the Prothonotary: on March 24, 2011; a copy of which is attached. Date: -. - John IA4aVan , III, Esquire BA.EY MANGAN 17 South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87000 STEPHANIE L. KROUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JEFFREY E. KROUSE, Defendant NO. 06-2454 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of May, 2011, upon consideration of Plaintiff's Praecipe To Transmit Record, and it appearing that both Plaintiffs and Defendant's affidavits of consent and waivers of notice were filed more than 30 days after their execution and are therefore stale, a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiencies and file a new praecipe to transmit record. See Pa. R.C. P. 1920.42(b)(2). BY THE COURT, John J. Mangan, III, Esq. 17 West South Street Carlisle, PA 17013 A Attorney for Plaintiff i A cC P's V L i E / A (P nn . ev n, sq. V 4431 North Front Street Harrisburg, PA 17110 rnw a Attorney for Defendant m x= ,,. -? -- , pa ;Of= :rc ? STEPHANIE L. KROUSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY E. KROUSE : NO. 2006 - 2454 DIVORCE DECREE AND NOW, j'csyt? 1 , L o , it is ordered and decreed that STEPHANIE L. KROUSE , plaintiff, and JEFFREY E. KROUSE , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, ----------- 6- /s-i/ eery V761 lea( tell ?(Vhr e Y ma/