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HomeMy WebLinkAbout06-2938Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclay@dzglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff V. TRACY K. REEDER, Defendant No. 2006 - CIVIL ACTION - LAW (In Divorce) (Civil Term) PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT is made this 1 Stkday of 4_s t , 2006, BY and BETWEEN Ronald L. Reeder of 105 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as Husband, A N D Tracy K. Reeder of 105 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania, hereinafter referred to as Wife. RECITALS R.1: The Parties hereto are Husband and Wife, having been joined in marriage on March 3, 2000 in Boiling Springs, Cumberland County, Pennsylvania; and R.2: No children were born of the marriage; and R.3: Differences have arisen between the Parties, in consequence of which they have lived separate and apart since on or about May 22, 2006; and RLR rz-? Page 1 of 17 TKR R.4: The Parties have resolved that it is not possible to continue the marital relationship between them for reasons known to them, in consequence of which they are living separate and apart; and R.5: Husband filed a Complaint for Divorce in the Court of Common Pleas of Cumberland County in the Commonwealth of Pennsylvania, to Docket Number 2006-2938, Civil Term; and R.6: It is the desire and intention of the Parties, after long and careful consideration, to amicably adjust, compromise and settle all property rights, and all rights in, to or against the property or estate of the other, including property heretofore or subsequently acquired by either Party, and to settle all disputes existing between them, including any claims or rights that they may have under the provisions of the Pennsylvania Divorce Code, as amended; and R.7: The Parties also desire to settle their issues of counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates; and R.8: The Parties desire to resolve all claims pending between them, including the settlement of all of their respective property rights and other rights growing out of their marriage relationship including, but not limited to, all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs; and RLR- Page 2 of 17 TKRLJO R.9: Husband and Wife declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Husband has been independently represented by Lindsay Gingrich Maclay, Esquire of Daley, Zucker & Gingrich, LLC, and that Wife, has been independently represented by Kara W. Haggerty, Esquire of Abom & Kutulakis; and R.10: Both Husband and Wife each covenant that they have made full and complete disclosure to the other of his and her respective property holdings and income; and R.11: Each Party has had an opportunity to verify the financial disclosure of the other. Discovery, if any, has been conducted to the satisfaction of each Party. Each Party has had the opportunity to investigate further the financial disclosure of the other, and has had access to any desired books and/or records to investigate further. Each Party had an opportunity to do an independent valuation of the assets, liabilities and income of the other party. To the extent either Party decided not to pursue further discovery and investigation, he or she did so voluntarily and specifically waives the right to challenge this Agreement based on the absence of full and fair disclosure. NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each Party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the Parties, intending to be legally bound, hereby agree as follows: RLR F Page 3 of 17 TKR ' (1) SEPARATION: It shall be lawful for each Party at all times hereafter to live separate and apart from the other Party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither Party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Neither Party shall disparage or discredit the other in any way, nor in any way injure his or her reputation; nor shall either of them act or permit anyone else to act in any way which might tend to create any disaffection or disloyalty or disrespect between the members of the family of either Party. Each Party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this Agreement and/or the terms of any Custody Agreement or Order. (2) DIVORCE: The Parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the expiration of the mandatory 90-day waiting period, the Parties shall execute and the Affidavits of Consent and Waiver of Notice Forms necessary to finalize said divorce. Said Affidavits and Waivers will immediately thereafter be filed in the Cumberland County Prothonotary's Office. If either Party fails or refuses to execute and file the foregoing documents, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other Party at his or her option to terminate this Agreement. RLR Page 4 of 17 TKRj4?- (3) REAL PROPERTY: It is understood and agreed that the Parties are the joint owners of certain real property located at 105 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007 (hereinafter "Marital Residence"). Said Marital Residence is currently encumbered by a first mortgage through Northwest Savings Bank, which mortgage is in both Parties' names. As of May 1, 2006, the principal balance of the Parties' joint mortgage obligation with Northwest Savings Bank was One Hundred Sixty-One Thousand Two Hundred Seventy and 72/100 ($161,270.72) Dollars. A copy of the Northwest Savings Bank Mortgage Statement and cover letter is attached hereto as Exhibit "A" and is incorporated herein by reference. The Parties have agreed to list and sell the Marital Residence with Irene Whistler at ReMax. At the time of creation of this Agreement, the Parties had already met with and agreed to sign an exclusive listing contract with ReMax, with an asking price of Two Hundred Seventy-One Thousand ($271,000.00) Dollars. Until such time as the Marital Residence is sold, the Parties shall be equally responsible for any and all mortgage payments, repairs, taxes, homeowner's insurance, and private mortgage insurance associated with the Marital Home. The real estate broker shall advise the Parties whether the listing price shall be lowered in the event the Marital Residence is not sold within a reasonable period of time. The Parties shall cooperate and agree to lower the listing price until the price has been lowered by fifteen (15%) percent of the original listing price. Thereafter, the price shall not be lowered unless by agreement of the Parties or Order of Court. In the event that the Marital Residence needs improvements, whether capital or not, during the pendency of the sale, the Parties hereby stipulate and agree that they will be equally responsible for the cost of those improvements. RLR F4- Page 5 of 17 TKR 7 IZ The Parties specifically agreed that the net proceeds from the sale of the Marital Residence, after deduction of all expenses, fees and taxes in connection with the sale; then after satisfaction of the liens of any and all existing mortgages shall be divided equally between the Parties. (4) DEBT: A. MARITAL DEBT: Other than those debts enumerated within, Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement. i. Each of the Parties will pay all current bills and outstanding bills incurred on or before the date of separation of the Parties, May 22, 2006, to the same extent that he or she has been paying then in the past and neither Party shall incur any unusual bill which will bind the other Party. Husband hereby agrees to return to Wife any and all joint credit cards or charge plates that he may have in his possession, specifically including the Kohl's credit card, which was previously in joint names. The Parties further agree that any debts incurred on said joint credit cards or charge plates subsequent to the date of separation, shall be the sole and exclusive responsibility of the Party who incurred said debts and the debt-incurring Party shall save harmless the other party from any obligation or institutions of suit thereunder. B: POST SEPARATION DEBT: Except as otherwise herein provided, in the event that either Party contracted or incurred any debt since the date of separation on May 22, 2006, the Party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: FUTURE DEBT: Except as otherwise herein provided, from the date of this agreement neither Party shall contract or incur any debt or liability for which the other Party or his or her property or estate might be responsible and shall indemnify and save harmless the other Party from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other Party. RLR W- Page 6 of 17 TKR? (5) MOTOR VEHICLES: The Parties acknowledge that they individually hold titles to the vehicles in their individual possession. Husband hereby relinquishes any right, title or interest he may have in and to the vehicle currently in Wife's possession. Wife shall maintain separate insurance on and assume full responsibility for any encumbrance on the vehicle currently in her possession, and shall hold harmless and indemnify Husband from any loss thereon. Wife hereby relinquishes any right, title or interest she may have in and to the vehicle currently in Husband's possession. Husband shall maintain separate insurance on and assume full responsibility for any encumbrance on the vehicle currently in his possession, and shall hold harmless and indemnify Wife from any loss thereon. (6) TANGIBLE PERSONAL PROPERTY: The Parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each Party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the Parties hereto. This Agreement shall have the effect of an assignment or bill of sale from each Party to the other for such property as may be in the individual possession of the Parties hereto. RLR Page 7 of 17 TKR TL (7) INTANGIBLE PERSONAL PROPERTY: Except as otherwise provided herein, each Party hereto hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits, including retirement accounts, savings plans, pension plans, stock plans, 401 K plans, and the like. The Parties acknowledge that Husband has an IRA through Sentry Trust (hereinafter "Sentry IRA"). The Parties further acknowledge that Husband's Sentry IRA account had a stated market value of Two Hundred Four Thousand Two Hundred Ninety-Four and 43/100 ($204,294.43) Dollars as of May 16, 2006. A copy of the May 16, 2006 Sentry IRA account statement is attached hereto as Exhibit "B" and is incorporated herein by reference as if set forth fully herein. Wife acknowledges that she has been informed of her right to obtain an independent appraisal and/or valuation of Husband's Sentry IRA and any marital interest she may have therein, and notwithstanding same, Wife hereby forever waives and relinquishes any right, title interest or claim she might otherwise have in and to Husband's aforesaid Sentry IRA. The Parties acknowledge that Husband has a retirement plan through United Telephone/Sprint (hereinafter "Spring Retirement"). Said Sprint Retirement is a non-contributory retirement plan and therefore has no immediate cash value. Wife acknowledges that she has been informed of her right to obtain an independent appraisal and/or valuation of Husband's Sprint Retirement and any marital interest she may have therein, and notwithstanding same, Wife hereby forever waives and relinquishes any right, title interest or claim she might otherwise have in and to Husband's aforesaid Sprint Retirement. RLR f4k Page 8 of 17 TKR34?_ The Parties further acknowledge that Husband is currently a participant in a non- contributory retirement plan through Commonwealth Telephone Enterprises (hereinafter "CTE Retirement"). The Parties further acknowledge and agree that the CTE Retirement has no cash value and is not payable until age 65, if Husband is still employed at that time. Wife acknowledges that she has been informed of her right to obtain an independent appraisal and/or valuation of Husband's CTE Retirement and any marital interest she may have therein, and notwithstanding same, Wife hereby forever waives and relinquishes any right, title interest or claim she might otherwise have in and to Husband's aforesaid CTE Retirement. The Parties further acknowledge that Husband participates in an employee contributory 401K under Guardian Retirement through his current employment with South Canaan Telephone Company (hereinafter "SCT 401 K"). The Parties further acknowledge that Husband's SCT 401K account had a value of Three Thousand Nine Hundred Twenty-Five and 28/100 ($3,925.28) Dollars as of May 16, 2006. A copy of the May 16, 2006 SCT 401K account statement is attached hereto as Exhibit "C" and is incorporated herein by reference as if set forth fully herein. Wife acknowledges that she has been informed of her right to obtain an independent appraisal and/or valuation of Husband's SCT 401K and any marital interest she may have therein, and notwithstanding same, Wife hereby forever waives and relinquishes any right, title interest or claim she might otherwise have in and to Husband's aforesaid SCT 401K. The Parties further acknowledge that Wife has a retirement plan through her current employer, Sprint/Embarq (hereinafter "Embarq Retirement"). The Parties further acknowledge that Wife's Embarq Retirement account had an account balance of .1 G 61 43-7. 1,3 (0, )066 A copy of Wife's Dollars ($(p5?, L137,13 ) as of Embarq Retirement account RLR OAL Page 9 of 17 TKR statement is attached hereto as Exhibit "D" and is incorporated herein by reference as if set forth fully herein. Husband acknowledges that he has been informed of his right to obtain an independent appraisal and/or valuation of Wife's Embarq Retirement and any marital interest he may have therein, and notwithstanding same, Husband hereby forever waives and relinquishes any right, title interest or claim he might otherwise have in and to Wife's aforesaid Embarq Retirement. (8) LIFE INSURANCE: The Parties hereto acknowledge that each have life insurance policies. Simultaneous with the execution of this Agreement, any and all policies in Wife's name shall become her sole and separate property. Wife shall be free to designate beneficiaries or encumber her life insurance policies. Simultaneous with the execution of this Agreement, any and all policies in Husband's name shall become his sole and separate property. Husband shall be free to designate beneficiaries or encumber his life insurance policies. (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 acquired by him or her after execution of this Agreement, 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) WAIVER of ALIMONY: The Parties acknowledge that each has income and assets satisfactory to meet his and her own reasonable needs. Each Party waives any claim he or she may have, one against the other, for alimony, spousal support or alimony pendente lite. (11) DIVISION OF BANK ACCOUNTS: The Parties acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of RLR Page 10 of 17 TKR- this Agreement. Husband's account balances are attached hereto as Exhibit "E" and are incorporated herein by reference as if set forth fully herein (12) TAX MATTERS: The Parties have negotiated this Agreement with the understanding and intention to divide their mutual property. The Parties have determined that such division conforms to a right and just standard with regard to the rights of each Party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the Parties to constitute in any way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. (13) ATTORNEY'S FEES: Except as otherwise provided herein, each of the Parties waives the right to receive a payment for counsel fees from the other, and each shall be responsible for his or her own counsel fees, costs and expenses, if such fees or expenses are incurred. (14) ADVICE of COUNSEL: The Parties hereto acknowledge and declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Husband has been independently represented by Lindsay Gingrich Maclay, Esquire, of Daley, Zucker & Gingrich, LLC, and Wife has been independently represented by Kara W. Haggerty, Esquire, of Abom & Kutulakis. Each Party acknowledges that they fully understand the facts and have been fully informed of their legal rights and obligations and each accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the RLRG? Page 11 of 17 TKR execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. (15) ADDITIONAL INSTRUMENTS: Except as otherwise herein provided, each of the Parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other Party, within ten (10) days of any request to do so, any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (16) INCOME TAX: The Parties hereby acknowledge that they plan to file separate federal, state, and local income tax return for the tax year of 2006 and all ongoing years. The Parties hereto agree to equally divide the mortgage interest paid prior to the sale of Marital Residence for purposes of claiming said deduction on their respective tax returns. (17) BANKRUPTCY: The Parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a Party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other Party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the Parties' marital assets and all other rights determined by this Agreement, including alimony, shall be subject to court determination the same as if this Agreement had never been entered into. (18) COMPLETE DISCLOSURE: The Parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her RLR Page 12 of 17 TKR_T?(L entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (19) WAIVER of APPRAISALS: The Parties acknowledge that they are aware of their respective rights pursuant to the Pennsylvania Divorce Code to obtain formal valuations or appraisals of the real estate, the personal property, the vehicles, and 401K's and IRA's, some or all of which were acquired during the marriage and therefore constitute marital property. However, the Parties have determined that they will not undertake the expense to have these items appraised and/or valuated, and that the division of property as set forth in this agreement, represents a fair and equitable distribution. (20) RIGHTS and RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (21) FULL SETTLEMENT: Except as herein otherwise provided, each Party hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either may have, or at any time hereafter have for past, present or future support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of any other jurisdiction, except and only except all rights, agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. Neither Party shall have any obligation to the other not expressly set forth herein. RLR ti- Page 13 of 17 TKRTX? I Except for any cause of action for Divorce which either Party may have or claim to have, and except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each Party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. (22) RELEASE of ALL CLAIMS: Except as otherwise provided herein, Each Party hereby absolutely and unconditionally releases and forever discharges the other and his or her heirs, executors, administrations, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the Parties or otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities or the other or by way of dower, courtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other country. It is expressly understood, however, that neither the provisions of this release nor the subsequent entry of a Divorce Decree are intended to defeat the right of either Party to receive any insurance proceeds at the death of the other of which she or he is the named beneficiary (whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the right of either Party to receive any legacy, bequest or residuary portion of the other's estate under his or her will, or to act as personal representative or executor if so named by the will of the other, whether such will was executed prior or subsequent to this Agreement. RLR (Lkr(- Page 14 of 17 TKR-D (23) SEPARABILITY of PROVISIONS: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall continue in full force, effect and operation. (24) GOVERNING LAW: All matters affecting the interpretation of this Agreement and the rights of the Parties hereto shall be governed by the laws of the Commonwealth of Pennsylvania. (25) INCORPORATION into DIVORCE DECREE: The Parties agree that this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the Parties. Upon entry of the Decree, the provisions of this Agreement may be incorporated by reference or in substance, but they shall not be deemed merged into such Decree. The Agreement shall survive any such Decree in Divorce, shall be independent thereof, and the Parties intend that all obligations contained in this Agreement shall retain their contractual nature in any enforcement proceedings, whether enforcement is sought in an action on the contact itself at law or in equity, or in any enforcement action filed to the Divorce Caption. (26) BREACH: In the event that either Party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other Party. In the event of breach, the other Party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. RLR Page 15 of 17 TKR (27) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the Parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (28) AGREEMENT BINDING on PARTIES and HEIRS: It is understood and agreed that not only the Parties hereto, but also their heirs, administrators, executors and assigns, shall be bound by all the terms, conditions and clauses of this Agreement. (29) DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the Parties if they have executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the Party last executing this Agreement. (30) PRESERVATION OF RECORDS: Each Party will keep and preserve for a period of four (4) years from the date of their Divorce Decree all financial records relating to the marital estate, and each Party will allow the other Party access to those records in the event of tax audits. (31) WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. (32) NO WAIVER OF DEFAULT: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either Party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such Party hereafter to enforce the same, nor shall the waiver of RLR Ctf- Page 16 of 17 TKR? any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. (33) HEADINGS NOT A PART OF AGREEMENT: Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and year first above written. WITNESS: Lindsay ingric Maclay, Esqui Attorney for Plaintiff &A,/, ex Ro Id L. Reeder, Plainti f 14o Kara W. Haggerty, 2Eire Attorney for Defen Tracy K. ede , Defendant RLR Page 17 of 17 TKRTg Exhibit "A" SINOP-rij sqv,,V IIVjE ?oo Where Gs B'4NS? ??eERTY SIRE people make t K he difference 0 O E30 X 1>93 wgRREN PENNSYLV AN?q ? B, Ronald L Tracy Reeder 105 SK Reed r .y L Boiling Spn ngsne 17007 Dear PA Customers, Nlay 18, 2006 Asper your r s the cur, contac ent balanceo fpm sending YOU Tha meat (8141 728 7452 punt. If you egage stater, nk 'You, for ed further assistance, h will provide allowing Northwest to please feel fr you With serve YOU kith Your banking needs Sincerely nclosureL cc Deanna xoll aba Ugh Loan Servicing R eSentative I t erect: 1-877-672-5678 LE61qORTHWEST SAVINGS BANK MORTGAGE LOAN RONALD L REEDER AND TRACY K RE'EDER 105 SHIRLEY LANE BOILING SPRINGS PA 17007 NOTE NUMBER PRINCIPAL BALANCE INTEREST RATE -------------------- POST DTE TC1 DUE DATE TC2 01-03- 1805084488 16ip270.72 5.0000 ---------------HISTORY TRANS DESCRIPTION I-RATE ---------------- AMOUNT TYPE O6 . 01-01-06 080 REG PMT-DUE DTE 22 5 0000 766.99 0 688,07 321,38 01-03-06 AUTO-DEBIT ACCOUNT NO. 627070808 02-01-06 030 ESCROW DISBURSE 503.00 00-00-00 2 5.0000 11007 02-01-06 DONEGAL INSURANCE 02-01-06 080 REG PMT-DUE DTE 770.18 02-01-06 22 500000 684.88 301.95 OZ-01-06 AUTO-DEBIT ACCOUNT NO. 627070808 03-01-06 03-01-06 080 REG PMT-DUE OTE 22 5 0000 773.39 0 681.67 301.95 03-01-06 AUTO-DEBIT ACCOUNT NO. 627070808 04-03-06 080 REG PMT-DUE OTE 776.61 04-01-06 22 500000 678.45 301,95 04-03-06 AUTO-DEBIT ACCOUNT N09 627070808 04-17-06 00-00-00 030 ESCROW DISBURSE 2 576,54 5*0000 11914 0 05-01-06 080 REG PMT-DUE DTE 779 85 05-01-06 22 500000 . 675.21 301.95 05-01-06 AUTO-DEBIT ACCOUNT NO. 627070808 PRINCIPAL INTEREST ESCROW-2 ------------------ NEW BALANI ESCROW DISB ESCROW NBR PRINCIPAL INTEREST ESCROW-2 PRINCIPAL INTEREST ESCROW-2 PRINCIPAL INTEREST ESCROW-2 ESCROW D.ISB ESCROW NBR CHECK NUMBER CK GEN INDICATOR PRINCIPAL INTEREST ESCROW-2 164374, 164370. 163600, 162827.. 162050, 162050.'. 161270, Exhibit "B" Iq Q i `VVV °'?lnrol IIY V??6 IrV, ??Y7 - I . S-Cnt-ryT,,,-,t, Cofiora r t 785,p?? Cerztet A venom Eharnbersbttt PA 1 Fax: 717_26q_ 200?201 ax: 717-264-0225 Facsimik TO' From: /New, Date: ??, ages: Conti 4 A k, The docents 3rouoa1' T? Pa"yi'°9 rdbi not the inte, taf% rs in ?aDpy?s a '?re/ra,? ed n?,?en only for V)e msion ion. i ced to ?ne im°n the o°ntents You are hynoW use of U, . n in at. fiedi ty alec so oaf ! 'ateiy. to re9ab4 t?pred+nf ?18t and d entity lvtl)?h is den Mon is a a 8s for Xlu V e ? 1 ???hure, ibiteU On this oo l sh if return OF t? 0 9. distrfbuGo rssin sh 9?nat p ocu to e at no m mnb,,?se r? ment4 od bqy o to Ydu. y telephone An qffliQte o f Ome 8Q Financial C?porat . Ip? ,I V- I V, I I ? i V .11 u I I I- V I I I v v 1 -1 ,,,,- V T V ? L V Report Date. May 17, 1006 A3-of Chas i L-VM Pricing Data Mav 16, 2006 Mav 12, 2006 Asset Review - - .1 -- - Account: 14 00 7375 0 OF RONALD L. REEDER INVESTMENT MANAGEMENT IRA Inva6tment Estimated Una Cost Markel Annual C urrent Straraevr Market Berms Value 111MM -Yield par value CASH 0.00 0.00 INCOME CASH 0.00 0.00 PRINCIPAL CASH 0.00 0.00 TOTAL CASH CASH EQUIVALENTS MISC CASH EQUIV-TAXABLE 3.809.3900 FEDERATED PRIME.OBLIG 0.0 3,809.39 3,809.39 170.28 4.47 FUND.#396 TOTAL MISC CASH EQUIV•TAXABLE 3.809.39 3.809.39 170.28 4,47 TOTAL CASH EQUIVALENTS 3.809.39 3,809.39 170.28 4.47 FIXED INCOME SECURITIES BANK CERTIFICATES OF DEPOSIT 20.000.0000 ^ABBYBANK CD 0.0 20,000.00 20.000.00 810.00 4.05 05% 08/25{06 4 . 15.0.00.0000 BRANSON BANK CD 0.0 15.000.00 15,000.00 705.00 4.70 4.70%02/16/07 0 0 00 000 20 20,000.00 980 00 4,90 20,000.0000 CURRIE STATE BANK CD . . . 4.900A 0MZ107 0 0 000.00 20 20,000.00 780,00 3,90 20.000.000,0 FANNIN BANK C/D . , 3.90%s 5/19106 0 0 000 00 10 10,000.00 400.00 4.00 10,000-0000 FIRST-BANK OF HENRYLNTY CD . , 4.00% 11130/06 0 9 00080 24 20,040.00 0.00 20.1x)0.0000 FIRST REGENTS BANK CD . , 4,75% 2/2312007 U D 500080 5,000.00 150.00 3.00 _0000 GRANGE BANK CD 5,000 . _3%9/27/06 0 0 000.00 20 20,000.00 820.00 4.10 20.000.0000 INDEPENDENT BANK CD . . 4.10°G 10/31/08 20.000.0000 SECURITY BANK OF BIBB COUNTY 0.0 20,000.00 20,000.00 940.00 470 . 4.70% 11/28/06 0 0 00 000 20 20.000.00 820 00 4.10 20.000.0000 THE PARK AVENUE BANK CD . . . 4.10% 08/18/06 _ Page 1 IV[ 0 1 • 1 7 L V U V V- V U 11141 I I I 1 L V't V L L U Report Date! Afay 17, 2006 IVV • JVIt 1 r • U: J Avvi Grose Lest Pri" Date Asset Review May 16, 2006 I _May 12, 2006 i Account: 14 00 7375 0 OF RONALD L. REEDER INVESTMENT MANAGEMENT IRA Snares or Par-Value Unit Market Investment COO Basis Market Value TOTAL BANK CERTIFICATES OF DEPOSIT 170.000.00 170,000.00 TOTAL FIXED INCOME SECURITIES 170.000.00 170.000.00 MUTUAL FUNDS LARGE CAP STOCK 175.3980 "FIDELITY EXPORT 6 22.14 3,274.21 3.883.31 MULTINATIONAL 78.6610 'LEGG MASON VALUE TR INC 72.38 4,145.80 5.693.48 NAV VALUE TR 286.9150 'NEUBERGER 8 BERMAN EQ FD 23.95 5.186.47 6,871.62 SOC RESP 0342 252.7240 "VANGUARD EQUITY INCOME FUND 24.21 5,163.88 6,118.45 TOTAL LARGE CAP STOCK 17,770.35 22,566.86 MID CAP STOCK 176.5010 'WELLS FARGO ADVANT MID CAP 22.25 3,269.51 3.927.15 DISCIPLINED FDtt3255 TOTAL MID CAP STOCK 3.289.51 3.927.15 SMALL CAP STOCK 119.6440 'FIDELITY SMALL CAP GROWTH 20.57 1.752.99 2,461.07 72.0320 'SEI INSTL MANAGED TRUST 21.24 1.486.20 1,529.96 SML CAP YALU A TOTAL SMALL CAP STOCK 3.239.19 3.991.03 TOTAL MUTUAL FUNDS 24,279.06 30.485.04 GRAND TOTAL 198,088.45 204.294.43 Pending Trades Trod* Data Settlement-Date Trada Tvpe SaturityRame Shares/Par 05/19/2006 0511912006 Maturity FANNIN BANK CID -20000.0000 Totals -20000.0000 Estimaled Annual Currant Income Yield 6,405.00 3.77 6.405.00 3.77 10.52 0.27 0.po 40.75 0.59 179,44 2.93 230.71 9.02 8.48 0.22 8.48 0.22 0.00 4.46 0.29 4.46 0.11 243.65 0.80 8,818.93 3.34 Amount/Cast 20.000 00 20,000.00 Page 2 Exhibit "C" Balance Information 100. 00:s Employee Pre-Tax Account Value By Source Dollar Value Percentage Employee Pre-Tax $3,925.28 100.00 Total $3,925.28 100.00 'Represents combination of total plan assets less than 5% This account summary includes the full amount of contributions deposited on your behalf and does not reflect the percentage that you may be vested in the company contributions or any outstanding loan balance that you may have. Account Information Name Reeder, Ronald L. Address 105 Shirley Ln Boiling Springs PA 17007 Social Security Number Company Name South Canaan Telephone Company Company Address P.O. Box 160 Rt. 296 South Canaan PA 18459 Plan Trustee Debra Edwards Update Personal Information Page 2 of 2 https://www.guardianretirement.com/oweb/plbisapi2.dll 5/16/200( Balance i ormaiton rage 1 or z Click on an investment option in the table below for more information. 100. M Am Cen Strat Alloc: Con Invstr Account Summary Units Price Dollar Value Percentage Am Cen_Strat Alloc_Con Invstr 286.5782 $13.697071 $3,925.28 100.00 Total $3,925.28 100.00 https://www.guardianretirement.com/oweb/plbisapi2.dll 5/16/2006 Exhibit "D" 06/02/2006 FRI 16:07 FAX 7t' 45 6157 • 2002/003 File Edit View Favorites - Tools . HOP .. .. . ./ Back j Search Favorites ' .. ;i?etbenefits na';+,tctionJna;igatigr? Address https;//•,vorkplaceservices 300,fidelity corn ,y,,.3 t <y Loci Out I Meld 14 ".0 Home ?t T I 'M311111111111 Welcome to NerSenefPrs5' Savings & Retiremetit Savings Plan Etv1BARQ' Sr-.:INGS ` R I f'dT FC PJ E: F c'RINT r'CS ES NE SP'UNT f'•IEXTEL E_ 5 Your Profile 'Hid t, f lanagc your pei'5rnai inFrs•mAticn. ic;'v'Uodate E hiwail add°5s Your Profile SO-00 $0.00 534.54 other plans/Accounts tilt other ?lansr'a:caunta Total $65,437.13:4' Planning Resources Tcclf, & 1-t-irring, Access the latest online nnrkshops, tools, calculators; and educational content. Savings _?x Retirement 06/02/2006 FRI 16:07 (f.rnnt 1 ictin tr FAX 745 6157 • 2003/003 Page: i of i atigroup..i 5ti•,rrr?f??v?vk?,Y ;, Benefit Access" o Your Account , Calculators - Exercise a Customer Service Home Stock Option View Your Options Account TRACY REEDER i, r?s? 7;"4 µr atA' ''?'t°a pn ?ly4tf "•7 !rm`G??I.J'frryry??to yy,?•Yi''r1%'?tln i, r?'?.w ?1ti'v?.!.?:'•, "?:1'JY':;?,•:;f, tJR',i??;,?ll?:'7Y'?rji7'LY7f?"?11J•4 4 r ? b ?? n? , g.•,..,,•? {?VC, "W ??ya ;tq?; , y?ly I r ti , t ?1A tc ?i?r" 'L r ""/pt'??``'t{•3• ?? S?u ,; ,;r? f;?'%i1l,S ? J ?, ? ,, Mr ??•??„f 1.7,,m??,??,¢(r ???r??,M,*,? r ??,,? P!p; L (yy ,4f??.?o, h f "'t y?:Y fit' r ,? ?yY 9 F ?cG J c c 1 y 1 f r} {t'" iK?f''ln;n)cvT"iLS:^JS?'sAr.rw:xrn1r•1?;•>i?,'n'?Y7a.'?li?n!`?uvtr'nL`:?lcv?dlw7'?;'Of ti?f1'µ1/J?d. n. 4 Vi Account Summar Grant Date View ACCOttnt: Ac ? Y ? Sort by: IV Expiration Grant Date Grant Grants Grants Date (mmldd/yyyy) Type Granted Grant Price Outstanding Lxercisable (mm/dd/yyyy) 05/18/2006 NQ 5 $190.7700 5 5 02/08/2010 05/18/2006 NQ 27 $120,3900 27 27 02/08/2010 Total 32 32 32 View Your Account Documents Click here to view your account documents online. Please note that documents are only available online if your company has elected to use this feature. Therefore, if you participate in multiple companies' plans, you will only have access to the documents of the companies that have elected this feature. 1o ohtain ,.t dcerinitiocl on flow Smith Barney define's the torn'Js iirtcd on thi; pagr! click Oil tho rohirnn hcending far ftrrtfx>r rJc'trul:;. The expiration date noted above is the date your Company has provided SB as the last day in which you may exercise your grants. In order to exercise your qrants prior to expiration, SB must enter your order prior to the close of the U.S. market ("Market') on which your Company's stock trades (The NASDAQ, NYSE and AMEX hours are currently 9:30 am to 4:00 pm ET). Therefore, please leave enough time for (i) you to contact S13, (ii) you to provide SB with appropriate instructions and (iii) 813 to process the trade. If your expiation date falls on a day the Market is closed, you must exercise before the expiration day and on a day in which the Market is open. Please note: Your order (whether a market order or limit order) will be filled in accordance with the priority rules of the appropriate market. Therefore, there is no guarantee that your order will be filled. Please reference the specifics of market and limit orders to determine which is appropriate for you. Account Summary This list includes all exercises completed through the end of the previous day, If you believe any of this information is incorrect or incomplete, please contact your Customer Service Representative at 212 818 0800, 888.723-3392 or 212-503- 1676. i)ttpS:??hea7G11t,,.3riiittibai-ney.ei)iii/,,top-bitl/baweb/o l)(iratltSet-Viet?optiotis=Accotlt)t°I'?lttnl)lill 6/2/2006 Exhibit "E" Financial Holdings - Ron Reeder as of 5/19/2006 Institution Approximate Balance Bank of Landisburg - Savings $10,250 Cornerstone FCU - Savings 1,225 Total Savings $11,475 t_- 1-_n; -n r . cry °- r ; - rl r -_ ki _n N J 'T' _ a __ t Lindsay Gingrich Maclay, Esquire DALEY, ZUCKER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006-2938 (Civil Term) V. TRACY K. REEDER, Defendant CIVIL ACTION-LAW (In Divorce) AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of the Notice of Intention to Request Entry of a Divorce Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904 relating to un m falsification t a thorities. Date: 183 i 10G L Ronald L. Reeder, Plaintiff Sworn to and subscribed before me this 31 aL day of A9 ?_ 2006. COMMONWEALT OF PENNSYLVANIA NOTARIAL SEAL JANET M. FISHER, NOTARY PUBLIC LOWER PAXTON TOWNSHIP. DAUPHIN COUNTY MY COMMISSION EXPIRES OCTOBER 19, 2008 n Lindsay Gingrich Maclay, Esquire DALEY, ZUCKER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 lmaclayndzglaw corn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006-2938 (Civil Term) V. CIVIL ACTION-LAW TRACY K. REEDER, Defendant (In Divorce) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVOCE 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 I further understand that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made su 'ect to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsi tion to the autho Date: 8 3 I to G L. ti Ronald L. Reeder, Plaintiff r-7 TJ Kara W. Haggerty, Esquire ABOM & KUTULAKIS, LLP 36 S. Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006-2938 (Civil Term) V. TRACY K. REEDER, Defendant CIVIL ACTION-LAW (In Divorce) AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of the Notice of Intention to Request Entry of a Divorce Decree. I "Trifv that the statementsmade in this Affidavit are true and correct to the best of-my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904 relating to unsworn falsification to authorities. Date:- or?a ?- gAgd..?? Tracy K. Ree r, D endant Swoo and subscribed before me this day of AA_1mblir2006. awmilm"MMMAM dm"" f4?wioa ?Jnibr?? C- ° V "' F= jsi7 C1 l?F 'n ?le finJ + E45 'we --ivq vvllft-'? v ?4 Kara W. Haggerty, Esquire ABOM & KUTULAKIS, LLP 36 S. Hanover Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006-2938 (Civil Term) V. CIVIL ACTION-LAW TRACY K. REEDER, Defendant (In Divorce) + =i? ii?l\ 11V1\ V KL+ u??1' 1''.NTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVOCE 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 I further understand that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to the authorities. Date:gr/ S`b1P K ' 1?/ ? d Tracy K. Ree er, Def ndant ? C? ? n C, y cr ?, ? . v ? j'am' ., (? ' ? ? -.: -? ? - -. Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Imacla dzglaw com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006 - 2938 (Civil Term) V. CIVIL ACTION - LAW TRACY K. REEDER, Defendant (In Divorce) To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1 • Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service signed by Kara W. Haggerty, Esquire, Attorney for Defendant, on May 30, 2006. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff, August 31, 2006; by Defendant, September 15, 2006. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: September 26, 2006. Date Defendant's Waiver of Notice was filed with the Prothonotary: September 26, 2006. Respectfully submitted, , ZUCKER & GINGRICH, Date: A By: --r-LiuNay v ng n Marla Esqu: Supreme C rt # 87954 1029 Scenery rive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorney for Plaintiff f C,? ra y? 4? i 6 -c'1 ???? ? __ ?? i f _ , ?? r,?.`- '[-a? ..,? G:a ?? -'rj ?11 ??-- C;- 5 ` T ?.1. --i i ?'t ? r7 ---? SJ ..-C Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Imaclay0clzglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006 - a9 (Civil Term) V. TRACY K. REEDER, Defendant CIVIL ACTION - LAW (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 may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High & Hanover Streets, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF 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 Date: At la ( to D EY, ZUCKER QNGRim, LL By: n say GiVA-M I Esquire upreme C ID # 954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Imaclav[o dzalaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006 - (Civil Term) V. TRACY IC REEDER, Defendant CIVIL ACTION - LAW (In Divorce) NOTICIA Le ban demandado a usted en Is corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir de la fecha de la demands y la notificacion. Usted debe presentar una apariencia escrita o en persona o par abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se deftende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso a notificacion y par cualquier queja o alivio que es pedido en la peficion do demands. Usted puede perder dinero o sus propiedades o otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 Date: At 1 A `m D EY, ZUCKER & GINGRICH, LLC C By: in say Gin I acl , Esquire japreme CO# 87 54 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff Lindsay Gingrich Maclay, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Imaclav0dza law. corn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD L. REEDER, Plaintiff No. 2006 - a43P V. CIVIL ACTION - LAW TRACY K. REEDER, Defendant (In Divorce) COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT I - DIVORCE (Civil Term) AND NOW, this 1q%- day of May, 2006, comes Plaintiff, Ronald L. Reeder, by and through his attorneys, Daley, Zucker & Gingrich, LLC, and avers as follows: 1. Plaintiff is Ronald L. Reeder, who currently resides at 105 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Tracy K. Reeder, who currently resides at 105 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania. 3. The Parties hereto have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 3, 2000 in Boiling Springs, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant are both citizens of the United States of America. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither Plaintiff nor Defendant is a member of the Armed Services of the United States of America or any of its allies. 8. Plaintiff has been advised of the availability of marriage counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. See Plaintiffs Affidavit attached hereto as Exhibit "A" and incorporated herein by reference. 11. The marriage is irretrievably broken. The foregoing facts are averred under Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. WHEREFORE, Plaintiff requests Your Honorable Court enter a Decree in Divorce, thereby divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT II - EQUITABLE DISTRIBUTION 12. The allegations in Paragraphs One through Eleven, inclusive, are made a part hereof and incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their mamage. WHEREFORE, Plaintiff requests this Honorable Court determine the extent of the marital assets and liabilities and order an equitable distribution thereof. Respectfully submitted, DALEY, ZUCKER & GINGRICH, LLC Date: IA( 2A By: L' ay Gin c acla Esquire upreme Co # 87954 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff AFFIDAVIT I, Ronald L. Reeder, being duly sworn according to law, depose and say: (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 Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. Dated: Jr l Oho n? L. a&, Ronald L. Reeder, Plainti VERIFICATION I, Ronald L. Reeder, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Dated: S ( 0G eat-j- L. &d,, Ronald L. Reeder, Plaintiff r +1 ?Q Ul) IJ) ? ? Y'? CJ '.pG RONALD L. REEDER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. NO. 06-2938 CIVIL TERM TRACY K. REEDER, CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this 30T' day of May, 2006, I, Kara W. Haggerty, Esq., hereby certify that I did receive and accept service of the Complaint in Divorce in the above captioned matter on behalf of the Defendant, Tracy K. Reeder, and I further certify that I am authorized to do so. Respectfully submitted, DATE 05 D OLP AB0M & KU7VL4A7s, L.L.P Kara W. Haggerty, Es 36 South Hanover Str Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Defendant ID #86914 a 0 ?, 0 ?? ?? ? ? °" ? ??-c C ? C;? l ? G ` cT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Ronald L. Reeder Plaintiff VERSUS Tracy K. Reeder AND NOW, or 5 , z, IT IS ORDERED AND No. 2006-2938 (CIVIL TERM) DECREE IN DIVORCE DECREED THAT AND Defendant Ronald L. Reeder Tracy K. Reeder ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Parties' Property Separation and Settlement Agreement dated August 15, 2006, is herein incorporated but not merged. BY THE i COURT: AT T: U J PROTHONOTARY t w 01© - Ql RONALD L. REEDER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW : NO. 2006-2938 TRACY K. REEDER Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Tracy K. Reeder, the defendant in the above matter, having having been granted a final decree in divorce on October 5, 2006, hereby intends to resume and hereafter use the previous name of Tracy K. Wertz, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. ?J'Il Tracy K. Reeder TO BE KNOWN AS: "47 J? tt+ ? . Tracy K. Wertz L/ FLONVER & LINDSAY 26 West High Strect CarlWc, PA COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. ON this, the /0 day of 'SEA7Z-7M "X , 2007, before me, a Notary Public, personally appeared Tracy K. Reeder, known to me or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary is NOTARIAL SEAL. KANDI L LENKER, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES MARCH 10, 200 OT - z N t.? h 1 1 N IN THE COURT OF COMMON PLEAS OF CD CUMBERLAND COUNTY, PENNSYLVANIA c .03: w � RONALD L. REEDER, M Plaintiff No. 2006 - 2938 (Civil Terror' tvc .�3? C) x V. CIVIL ACTION - LAW ° vr7 � TRACY K.REEDER, ►: _- Defendant (In Divorce) -< PRAECIPE TO THE PROTHONOTARY: Kindly withdraw the appearance of Daley Zucker Menton Miner & Gingrich, LLC, as counsel for Plaintiff in the above-captioned matter. Daley Zucker Meilton Miner& Gingrich, LLC Date: 9020/ P icia Carey Zu er, E quire ttorney I.D. N . 373 635 N. 12th Stree , uite 101 Lemoyne, PA 17043 (717) 724-9821 pzucker @dzmmglaw.com Kindly enter the appearance of Lindsay Gingrich Maclay, Esquire as counsel for the Plaintiff in the above-captioned matter. Law Offices of Peter J. Russo, P.C. Date: i 2013 ' i dsay ich a ay, E uire `5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 (717) 591-1755 lgmaclay @pjrlaw.com