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06-6162
Dabis Camero, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, V. ) PENNSYLVANIA Colleen Camero, ) Defendant ) CIVIL ACTION -LAW No. 06-414J- CIVIL IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Since the ground for the divorce is irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the: Office of Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Dabis Camero, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, V. ) PENNSYLVANIA Colleen Camero, ) Defendant ) CIVIL ACTION -LAW No. O( -Ir! &;L CIVIL IN DIVORCE NOTICE REGARDING THE AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prepared By: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 717-4433 l )AN_REGAN@C OMCAST. NET Dabis Camero, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, V. ) PENNSYLVANIA Colleen Camero, ) CIVIL ACTION - LAW Defendant ) No. 04-4141 CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Dabis Camero, whose current residence is 511 Erford Rd., Camp Hill, PA 17011. 2. Defendant is Colleen Camero, whose current residence is 511 Erford Rd., Camp Hill, PA 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 14, 2003, in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or annulment between Plaintiff and Defendant. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. Count One: Request for Divorce under Section 3301(c) of the Divorce Code 7. Paragraphs 1 through 6 of this Complaint are incorporated herein by reference hereto. 8. The marriage between Plaintiff and Defendant is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require Plaintiff and Defendant to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(c). Count Two: Request for Divorce under Section 3301(a)(6) of the Divorce Code 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference hereto. 11. The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and his life burdensome. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(a)(6). Count Three: Request for Equitable Disposition of Marital Property Under Section 3502(a) of the Divorce Code 12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference. 13. The parties own various items of personal property acquired during the marriage which are subject to equitable distribution. WHEREFORE, Plaintiff respectfully requests the Court (1) after requiring full disclosure by Defendant, to equitably divide, distribute or assign the martial property between the parties, pursuant to 25 Pa.C.S. § 3502(a), in such proportion as the Court deems just after consideration of all the relevant factors. -2 - Count Four: Request for Primary Physical Custody Under Section 3323(b) of the Divorce Code 14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference. 15. Plaintiff seeks primary physical custody of the following children: Dabis CameroAge 3 born August 14, 2003 Dana Camero Age 1 born April 9, 2005 Both children currently reside at 511 Erford Rd., Camp Hill, PA 17011. 16. Neither of the children was born out of wedlock. 17. The children are presently in the custody of the parties. 18. Neither of the children is over five years old, and throughout their lifetimes they have lived at 511 Erford Rd., Camp Hill, PA 17011.. 19. The mother of the children is Colleen Camero, currently residing at 511 Erford Rd., Camp Hill, PA 17011. 20. The father of the children is Dabis Camero, currently residing at 511 Erford Rd., Camp Hill, PA 17011. 21. The relationship to the Plaintiff of the children is that of natural father. 22. The Plaintiff currently resides with Defendant and their two children. 23. The relationship to the Defendant of the children is that of natural mother. 23. The Defendant currently resides with Plaintiff and their two children. 24. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning either child in this or any other court. 25. Plaintiff has no information of a custody proceeding concerning either child pending in a court of this Commonwealth. 26. Plaintiff does not know of a person not a party to this proceeding who has custody or visitation rights with respect to either of the children. -3 - 27. The best interests of the children will be served by granting the relief requested because: A. Plaintiff has participated in the lives of each of the children since birth. B. Plaintiff can provide a loving home for the children. C. Plaintiff can provide a stable environment for the children. 28. Each parent whose parental rights to either of the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that, pursuant to 25 Pa.C.S. § 3401(a)(2), the Court enter an order granting primary physical custody of the children to Plaintiff. Respectfully submitted, DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements 'made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dated: 1Q ?e0? / abis Camero, n -4 - -7% 0 w 1^F v N ti ? U I p I Q O ? f + n ? fo C? ? Q CD - . - G3 s: ?a 5 r LAW OFFICES OF PETER J. RUSSO, P.C. SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 DABIS CAMERO, Plaintiff V. COLLEEN CAMERO, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 CV 6162 DV CIVIL ACTION - LAW PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE PURSUANT TO Section 3502(c) OF THE DIVORCE CODE AND NOW, comes Petitioner, Colleen Camero, by and through her attorneys, Law Offices of Peter J. Russo, P.C., who files the within Petition for Interim Exclusive Possession of Marital Residence, and in support thereof, avers as follows: 1. Petitioner is Colleen Camero, Defendant in the above-captioned divorce action. Petitioner currently resides at 17524 Hoskinson Road, Poolesville. Maryland, 20837 on a temporary basis. 2. Respondent is Dabis Camero, Plaintiff in the above-captioned divorce action. Respondent currently resides at 511 Erford Road, Camp Hill, Pennsylvania, 17011, the "marital home." 3. The parties hereto were married on January 14, 2003, in Carlisle, Pennsylvania. The parties are the parents of the following unemancipated children who currently reside with Respondent: (1) Davis Camero, II, born August 14, 2003 and (2) Dana Camero, born April 9, 2005. 4. On October 23, 2006 , Respondent filed a Complaint in Divorce against Petitioner in Cumberland County, Pennsylvania. 5. The marital home, where the parties' children have resided since January 14, 2003, is owned by Respondent. 6. Section 3502(c) of the Divorce Code states that "the court may award, during the pendency of the action or otherwise, to one or both of the parties the right to reside in the marital residence." 7. Section 3323(f) of the Divorce Code states that "[i]n all matrimonial causes, the court shall have full equity power and jurisdiction and may issue injunctions or other orders which are necessary to protect the interests of the parties or to effectuate the purposes of this part and may grant such other relief or remedy as equity and justice require against either party or against any third person over whom the court has jurisdiction and who is involved in or concerned with the disposition of the cause." 8. Unless Petitioner and the parties' children are permitted interim exclusive possession of the marital home, the mental and emotional health and welfare of Defendant and the children will be compromised. 9. Petitioner has been the primary caretaker and nurturer of the parties' children from the time of their births to the present and is currently breast-feeding the youngest child. 10. An award of interim exclusive possession of the marital home will avoid uprooting the parties' children from not only the marital home, but also the social and community setting in which they were thriving. 11. Petitioner has no family or friends in or about the area and has no means of support other than that of Respondent. 12. Respondent has during the course of the marriage maintained the financial accounts of the parties and has given Petitioner a modest allowance of $400 per month during the marriage to purchase diapers and food for the family unit. 13. Respondent has family in the area, a full-time job, and the means to provide himself housing during the pendency of the divorce action. 14. Respondent has taken steps to force Petitioner out of the family home knowing leaving her without shelter, job, and any means of support if he continues to live in the marital home with the children. 15. Defendant is not employed and has no family in Pennsylvania to assist her, thereby leaving her homeless if she is not granted interim possession of the marital home. 16. Plaintiff is gainfully employed and makes sufficient income to find safe and meaningful housing in the area. 17. Without a granting of interim possession of the marital residence, Defendant would be forced to live with family in Maryland until she has the means to obtain housing in the area or until litigation of the divorce is concluded, thereby N depriving the children meaningful relationships with their mother and causing tremendous harm to their mental and emotional well-being. WHEREFORE, Petitioner respectfully requests this Honorable Court grant her and the parties' children interim exclusive possession of the marital home until the conclusion of the divorce proceedings. Respectfully submitted, The Law Offices of Peter J. Russo, P.C. Scott A. Stein, Esquir ID # 81738 3800 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Date: /t - 3 - o C VERIFICATION I, Scott A. Stein, Esquire, verify that the statements made in the foregoing Petition for Interim Exclusive Possession of the Marital Residence are true and correct based upon my discussions with the Petitioner in preparing this petition. I am signing this verification on her behalf because she is currently forced to reside in Maryland with family as a result of having been evicted from her home by a temporary PFA order, and is, therefore, unable to personally sign this verification due to the urgency of the situation. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. l' 3 ' o Date: Scott A. Stein, Esquire for Colleen Camero, Petitioner ?':? ?:-? ??.., t--.-? =- ?Y q???, t..:J ?. Prepared By: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 717-4433 DAN_REGAN@COMCAST. NET Dabis Camero, Plaintiff V. Colleen Camero, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-6162 CIVIL IN DIVORCE EMERGENCY, VERIFIED PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE PURSUANT TO SECTIONS 3502(c) AND 33230 OF THE DIVORCE CODE AND NOW, this Third day of November, 2006, Petitioner, Dabis Camero, by and through his attorney, Dan Regan, Esq., files the within Petition for Interim Exclusive Possession of Marital Residence, and in support thereof avers as follows: 1. Petitioner is Dabis Camero, Plaintiff in the above-captioned divorce action. Petitioner and the parties' children reside at 511 Erford Road, Camp Hill, Pennsylvania [hereinafter, the "Marital Residence."] 2. Respondent is Colleen Camero, Defendant in the above-captioned divorce action. Defendant currently resides in the Marital Residence. 3. The parties hereto were married on January 14, 2003, in Carlisle, Pennsylvania. The parties are the parents of the following unemancipated children who reside in the Marital Residence with Plaintiff and Defendant: (1) -2- Dabis Camero, II (born August 14, 2003); and, (2) Dana Camero (born April 9, 2005). 4. On October 23, 2006, Petitioner filed a Complaint in Divorce against Respondent in Cumberland County, Pennsylvania. 5. The Marital Residence, where the parties' children have resided exclusively since birth, is owned by Petitioner. Petitioner purchased the Marital Residence prior to marriage, and Respondent does not appear anywhere in the chain of title. 6. Section 3502(c) of the Divorce Code states that "the court may award, during the pendency of the action or otherwise, to one or both of the parties the right to reside in the marital residence." 7. Section 3323(f) of the Divorce Code states that "[i]n all matrimonial causes, the court shall have full equity power and jurisdiction and may issue injunctions or other orders which are necessary to protect the interests of the parties or to effectuate the purposes of this part and may grant such other relief or remedy as equity and justice require against either party or against any third person over whom the court has jurisdiction and who is involved in or concerned with the disposition of the cause." 8. The marital residence is the only residence the parties' children have ever known. 9. Unless Plaintiff and the parties' children are permitted interim exclusive possession of the Marital Residence, the mental and emotional health and welfare of Plaintiff and the children will be compromised. For a substantial -3- period of time, and particularly over the past six weeks, Defendant has engaged in open and flagrant marital misconduct, thereby subjecting Plainitff to an atmosphere of tension, stress and conflict. Defendant has repeatedly been verbally (and, to an extent, physically) abusive towards Plaintiff. Defendant has also been repeatedly abusive toward Plaintiff's mother, who has been staying at the Marital Residence during an edxtended visit from her native Columbia. Defendant has engaged in this bevahior while the children are present, with no regard to the effect this bahavior has on the children. 10. The frequency and ferocity of Defendant's attacks prompted Plaintiff to file for a protection from abuse [hereinafter, "PFA'] order. On October 30, 2006, Judge Bayley issued an order dismissing Plaintiffs prtition to make the temporary PFA order permanent. As the order did not comment on the evidence presented, there are no findings as to Defendant's behavior (or, more specifically, whether Defendant's behavior warrants removal from the Marital Residence on equitable grounds). 11. On a number of occasions Plaintiff told Defendant that she wanted him dead and she wanted his mother dead, too. Plaintiff has also told Defendant that she would kill anyone - including him - if they tried to take her children from her. In Count Four of his divorce petition Plainitff seeks primary physical custody of the parties' children. 12. Given Defendant's prior behavior, there is every reason to believe Petitioner's custody filing and PFA filing will cause Defendant to be even more hostile, volatile and abusive if she returns to the Marital Residence. -4- 13. Plaintiff works full time, and to that extent Defendant has been the primary caretaker and nurturer of the parties' children. Even so, for the reasons stated below the children would be better off if Defendant were removed from the Marital Residence: a. Plaintiff is willing to make the necessary arrangements for the children to spend time with Defendant, and Plaintiffs mother is able and willing to offer maternal nurturing while the children adjust to Defendant's absence from the Marital Residence. b. Defendant has shown herself to be a poor mother. Defendant has been given to repeated, profane, abusive outbursts in front of the children. Defendant also abuses alcohol. Plaintiff once came home to find Defendant intoxicated to the point of incoherence, even as their toddler son was next to her and otherwise home alone. On another occcasion Plainitff found Defendant nursing their daughter even as Defendant smelled of alcohol. C. The temporary PFA kept Defendant out of the Marital Residence for one week, and during this time the children thrived. Bedtimes became more regular and the children's expressions became brighter while their residence was at peace. 14. Petitioner appreciates he will owe a duty of support to Defendant if she is removed from the Marital Residence. Peitioner further acknowledges that Respondent has filed a complaint with the Cumberland County Domestic Relations Section (PACSES Case No. 692108727) to obtain support. Petitioner -5- will cooperate as necessary to ensure Defendant is given the support she is entitled to under Pennsylvania law. JUSTIFICATION FOR EMERGENCY CONSIDERATION 15. As a result of Respondent's behavior, the relationship between Petitioner and Respondent has deteriorated to the point where they cannot remain under the same roof. If Respondent is allowed to return, the verbal abuse will escalate, the children will suffer, and there is a substantial likelihood that Respondent will retailiate for Petitioner's PFA filing by filing false claims of abuse. The need for relief is immediate and compelling. CONCURRENCE OF COUNSEL 16. Respondent, by her attorney, Scott A. Stein, Esq., does not concur with this petition. WHEREFORE, Petitioner, Dabis Camero, respectfully requests this Honorable Court to either (1) issue an order grant him and the parties' children interim exclusive possession of the marital residence until the conclusion of the divorce proceedings; or, (2) in the event the Court cannot make an ex parte determination on this petition, to issue a rule upon Defendant to show cause why the relief requested in this petition should not be granted. Respectfully submitted, DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: November 3, 2006 -6- 11/02/2006 18:49 7177370609 DAN REGAN ESO PAGE 11/11 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Camero, Plaintiff Dated: November 3, 2006 -5- Dabis Camero, ) IN THE COURT OF COMMON Plaintiff ) PLEAS V. ) OF CUMBERLAND COUNTY, PENNSYLVANIA Colleen Camero, ) Defendant ) CIVIL ACTION - LAW No. 06-6162 CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing document by first class mail, addressed as follows, upon: Scott A. Stein, Esq. Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011-4327 DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: November 3, 2006 DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 06-6162 CIVIL COLLEEN CAMERO, Defendant IN DIVORCE IN RE: PLAINTIFF'S EMERGENCY PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE AND DEFENDANT'S PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE ORDER AND NOW, this z A day of November, 2006, hearing in the above captioned matter is set for Thursday, December 7, 2006, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Dan Regan, Esquire For the Plaintiff Scott A. Stein, Esquire For the Defendant BY THE COURT, :rlm t q?} . n?l ij a0 NOV $1206 DABIS CAMERO, V. Plaintiff COLLEEN CAMERO, AND NOW, attached Custody follows: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6162 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY INTERIM ORDER OF COURT this day of November, 2006, upon consideration of the Conciliation ummary Report, it is hereby ordered and directed as 1. The parties, Dabis Camero and Colleen Camero, shall have shared legal custody of the minor children, Dabis Camero, born August 14, 2003 and Dana Camero, born April 9, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. All decisions affecting the children's growth and development including, but not limited to, choice of camp, if any; choice of child care provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the children directly or as a beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made with the parents jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the children's best interest. r 2. Physical Custody. This Order confirms the status quo prioth€-pa separation. Mother shall have primary physical custody of the minor children a o D. i P!i linW^,6'Y A. Commencing at 5:00 p.m. on November 10, 2006, and contV0 -uhM p.m. until Friday, November 17, Mother shall have custody of ft;:ChilOen. CA 1.?1 :.s S ?C, r4? ??.tu?v tiil t ? `'f ?. emu' :?, . ?._ _, r'::?ii:3 NO. 06-6162 CIVIL TERM B. Commencing November 17, 2006, Father shall have custody each Friday at 5:00 p.m. until Sunday at 5:00 p.m. C. Commencing November 19, 2006, Mother shall have custody each week from Sunday at 5:00 p.m. until Friday at 5:00 p.m. D. The custodial schedule indicated in this paragraph is structured to maximize Father's contact with the children during his non-work hours. Accordingly, it is expected that Father will be present throughout his periods of custody and that he will notify Mother if he is not able to participate in his periods of custody so that the children will not unnecessarily have to make a trip to Pennsylvania if Father will not be available. Nothing in this Order is contemplated to grant rights of partial custody to anyone other than the named parties in this matter. Following the hearing on the cross-petition for exclusive possession of the marital residence, if Mother is able to relocate to central Pennsylvania, Father will have partial custody of the children from 4:30 p.m. until 7:30 p.m. each Wednesday. If this occurs, Father shall be responsible for all transportation incident to Wednesday periods of custody. 3. Transportation. The parent relinquishing custody of the children shall provide transportation incident to the custodial exchange. The parties will meet at their respective residences to affect the exchange. At exchanges, both parents shall establish a no-conflict zone for their children and refrain from making derogatory comments about the other parent in the presence or earshot of the children and, to the extent possible, shall prevent third parties from making such comments in the presence or earshot of the children. 4. The following holiday schedule supercedes the regular schedule: A. Thanksgiving 2007 - Mother will have custody until November 24th at 10:00 a.m., provided that Father is able to be off work on that day. In the event that he is not able to be off work to meet Mother at 10:00 a.m., Father's custodial period will commence at 5:00 p.m. as usual, unless the parties agree on an earlier exchange time. B. Christmas 2007 - Father will have custody from December 24th from 5:00 p.m. until December 26th at noon. C. The 2007 holiday schedule above contemplates that this is an interim arrangement. Consideration to these holiday periods for 2007 will be factored into the appropriate holiday schedule in subsequent years, with a preference toward arranging for the children to be with the parent who did not have NO. 06-6162 CIVIL TERM holiday custody in the previous year when subsequent year holiday schedules are determined by the Court of further agreement of the parties. 5. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. For a period of twelve hours before and continuing throughout any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor possess or use non-prescribed controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 7. The children shall not be exposed to second-hand smoke in vehicles or in- door confined spaces. 8. The children shall be withdrawn from the daycare center in which Father enrolled them earlier this month, at the Pennsylvania State University. 9. The children shall not leave the United States in the absence of an agreement of the parties or further Order of this Court. 10. The Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. 11. Custody Evaluation. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Dr. Casey Sheinvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Each party shall be entitled to petition the Court to allocate the cost or otherwise determine the financial responsibility for this evaluation. 12. Each party's right to be heard with regard the custodial arrangement which would serve the best interest of the children is hereby reserved without prejudice and without regard to the recommendation of the Interim Order. NO. 06-6162 CIVIL TERM 13. A hearing is scheduled in Courtroom Number f the Cumberland County Courthouse, on the ? day of , 20W at 9,16 o'clock -.M., at which time testimony will be taken. For a purposes of the hearing, the Mother, Colleen Camero, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of anticipated testimony of each witness shall be filed at least twenty days prior to the hearing date. BY THE COURT: J. Dist: /0iel J. Regan, Jr., Esquire, 1300 Market St., Ste 1,`Lemoyne, PA 17043 colt A. Stein, Esquire, 3800 Market Street, Camp Hill, PA 17011 4 NOV $120 DABIS CAMERO, V. Plaintiff COLLEEN CAMERO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6162 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Dabis Camero August 14, 2003 Father Dana Camero April 9, 2005 Father 2. Father filed a Complaint in Divorce with a Count for Custody on or about October 23, 2006. Contemporaneously, he filed a PFA docketed to 06-6163. Following Hearing before Judge Bayley on October 30, 2006, the PFA Order was VACATED and the petition was dismissed. A Custody Conciliation Conference was held on November 9, 2006. Present for the conference were: the Mother, Colleen Camero, and her counsel, Scott Stein, Esquire; the Father, Dabis Camero, and his counsel, Daniel J. Regan, Jr., Esquire. 3. Father filed a petition for primary custody on or about October 23, 2006. His claim for custody was included as a court in a Divorce Complaint. Father is employed in the IT Department at Penn State Harrisburg. Father reports that his employer is flexible and that a typical work week for him is Monday through Friday, 40 hours, from 9:00 a.m. until 4:30 p.m. He reports that he does not work weekends, except in the event of an emergency, which may occur only once in every six months. He had also been taking classes there two evenings a week. However, he dropped out of all of his classes in October of 2006 in order to make himself more available for the children. The parties have been married three years. Although the custody count in the divorce complaint does not state the following information, Father alleges that Mother has an alcohol problem. In support of his allegation, Father claims that Mother had two DUI's before they were married and references two incidents where he claimed that he came home and found that Mother was passed out because she was drunk. These incidents NO. 06-6162 CIVIL TERM allegedly occurred in 2002 and 2004. Father further alleges that Mother has bulimia. He claims that her therapist may have inquired about whether she has ever considered taking medication. Father reports that Mother has trouble coping day-to-day and describes her as moody, and verbally abusive to him. He further complains that she makes racist comments regarding him. Father is a native of Columbia. But, through his marriage to Mother, is a resident alien and holds a green card. Father hastens to point out that had he not gotten a green card through his marriage to Mother, he believes he would have been able to get one through his sister, who is also in the United States. When we were exploring the options of reaching an agreement, Father indicated that he would not give up the children to someone who is mentally unstable. Father emphatically stated that he would not negotiate with liars. Throughout the conference, Father was extremely labile, and had difficulty maintaining an appropriate demeanor. He was extremely hostile and provocative to both Mother and her counsel. He seemed unable to accept the notion that his representations regarding Mother were not sufficient to completely restrict her contact with the children. Father has had custody of the children pursuant to a PFA filed on October 23, 2006. No portion of the petition made any allegations that Mother presents, or then presented, any danger to the children who are subject to this custody action. It is also notable that there are pending cross-petitions for exclusive possession of the marital residence, which are scheduled to be heard in coming weeks by Judge Hess. Father's comments regarding Mother were, without exception, negative and degrading. Since the PFA Order was vacated, Father has taken no apparent steps to facilitate any contact with Mother and the children. Father stated repeatedly that Mother should get a job. Father has arranged for his mother to come to the United States from Columbia on what he describes as an extended visit. She is apparently here to assist him with the care of the children. However, in addition, Father has unilaterally enrolled the children in a day care center at the Pennsylvania State University Middletown Campus. He has been informed by the undersigned that this is a direct violation of Mother's rights of legal custody. 4. Mother reports that she has been a stay-at-home mom throughout the marriage. She is presently residing with her mother and aunt in Maryland, in a town approximately an hour and a half away. Mother reports that she has been the primary caregiver throughout the children's lives as she was the stay-at-home mother while Father worked and went to school in the evenings. Mother reports that she takes to the children to swim lessons, gymboree and kindergym. Until the time that Father obtained custody by filing the Protection From Abuse petition, Mother was breast-feeding the parties' youngest child, who is approximately 18 months old. Although the PFA Order was vacatedupon advice of counsel, Mother did not return to the residence where it is clear that Father does not want her to reside. Mother has not seen the children since October 23, 2006. NO. 06-6162 CIVIL TERM Mother disputes everything Father alleges regarding abusing alcohol. Mother does acknowledge that she is receiving psychological care, along with the parties' son, through Guidance Associates of Pennsylvania. Her therapist is Jamie Orris, LSW. In regard to the allegations in the PFA petition, Mother reports that although she did not elect to file a petition for protection for herself, Father had pushed her. Mother describes Father as being very controlling. Mother reports that Father gave her an allowance of $400.00 per month to pay for diapers, and food for the family. She relates that she has no idea of the assets as he controls all of the family income. Mother has concerns about Father using the mother-in-law as an alternative caregiver because she is unable to lift the children for medical reasons, and is sometimes forgetful about locking doors. She is also concerned that she is not able to provide a safe environment for the children because the mother-in-law leaves cleaning supplies and sharp objects out where the children can reach them. Mother is concerned that without the doors being locked that the children might wander into the street. Both parties acknowledge that there is a view of parenting and significant tension between Mother and the paternal grandmother. 5. The parties reached agreements regarding legal custody, prohibitions against disparaging each other and drug and alcohol exposure for the children, as well an agreement that the children not be exposed to second-hand smoke. The parties were also able to reach an agreement with regard to Christmas and Thanksgiving custody for 2006. Both parties agreed that a custody evaluation would be appropriate under the circumstance. However, Father repeatedly asserted that he had no money with which he could pay for a custody evaluation. Father further represented that there were no marital assets which could be utilized to pay for these services pending an allocation of the cost by the Court, or subsequent agreement of the parties. Thus, the agreement to participate in a custody evaluation with Dr. Casey Sheinvold is unlikely to move forward until it can be determined how the evaluation might be paid for. The parties were not able to reach an agreement with regard to the schedule of physical custody. Neither party objected to the Cumberland Court of Common Pleas retaining jurisdiction. Because the parties were unable to reach an agreement in regard to custody, the Conciliator found it necessary to recommend an Interim Order, as the children have not had contact with Mother since October 23, 2006. A hearing in this matter will require one (1) day. Date :286756 Melissa Peel Greevy, Custody Conciliator DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 06-6162 CIVIL COLLEEN CAMERO, Defendant IN DIVORCE IN RE: PLAINTIFF'S EMERGENCY PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE AND DEFENDANT'S PETITION FOR INTERIM EXCLUSIVE POSSESSION OF MARITAL RESIDENCE ORDER AND NOW, this fl ' day of December, 2006, after hearing and review of the testimony adduced, the petition of the plaintiff, Dabis Camero, for interim exclusive possession of the marital residence is GRANTED. The cross-petition of the defendant, Colleen Camero, for interim exclusive possession of the marital residence is DENIED. BY THE COURT, Hess, J. Dan Regan, Esquire For the Plaintiff Scott A. Stein, Esquire For the Defendant :rlm ' VIA ?~ CASE NO: 2006-06162 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAMERO DABIS VS CAMERO COLLEEN DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon CAMERO COLLEEN the DEFENDANT , at 1823:00 HOURS, on the 23rd day of October , 2006 at 511 ERFORD ROAD CAMP HILL, PA 17011 COLLEEN CAMERO by handing to a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.20 Postage .39 Surcharge 10.00 R. Thomas Kline .00 41.59 ? 10/24/2006 I O q o (e DAN REGAN Sworn and Subscibed to By:?i before me this day Deputy Sheriff of A.D. DABIS CAMERO, V. Plaintiff : IN THE COURT OF COMMON : PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA NO. 06-6162 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY COLLEEN CAMERO, Defendant STIPULATED CUSTODY AGREEMENT THis AGREEMENT is hereby made and entered into this day of 2007, by and between Dabis Camero (hereinafter "Father") and Colleen Camero (hereinafter "Mother"). Witnesseth: Whereas, Dabis Camero is represented by Dan Regan, Esquire; Whereas, Colleen Camero, is represented by Scott Stein of The Law Offices of Peter J. Russo, P.C.; Whereas, the Parties have had adequate time and opportunity to consult with legal counsel; Whereas, both Parties acknowledge that they are satisfied with the legal advice they have received and understand the full importance of the Agreement they are entering into; and Now, therefore, the parties, in consideration of the foregoing promises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. Legal Custody. The parties, Dabis Camero and Colleen Camero, shall have shared legal custody of the minor children, Dabis Camero, born August 14, 2003 and Dana Camero, bom April 9, 2005. Each parent hall have an C r?/ D equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. § 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable times as to make the records and information of reasonable use to the other parent. All decisions affecting the children's growth and development including, but not limited to, choice of camp, if any; choice of child care provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the children directly or as a beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made with the parents jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the children's best interest. 2. Physical Custody. Mother shall have primary physical custody of the minor children subject to Father's periods of partial custody as follows: a. Alternating weekends beginning March 9, 2007 from Friday at 5:00 p.m. until Sunday at 5:00 p.m. b. Every Wednesday from 4:30 p.m. until 7:30 p.m. or at such D C C other days and times as agreed by the parties taking in to account Father's school schedule such that the intent of this paragraph is to give Father a weeknight that does not conflict with Father's schooling. 3. Transportation. The parent relinquishing custody of the children shall provide transportation incident to the custodial exchange. The parties will meet at their respective residences to affect the exchange. At exchanges, both parents shall establish a no-conflict zone for their children and refrain from making derogatory comments about the other parent in the presence or earshot of the children and, to the extent possible, shall prevent third parties from making such comments in the presence or earshot of the children. 4. The following holiday schedule supersedes the regular schedule a. Thanksgiving 2007 - Mother will have custody until November 24th at 10:00 a.m., provided that Father is able to be off work on that day. In the event that he is not able to be off work to meet Mother at 10:00 a.m., Father's custodial period will commence at 5:00 p.m. as usual, unless the parties agree on an earlier exchange time. b. Christmas - In odd years, Father shall have custody from December 24th at 5:00 p.m. until December 26th at noon. In even years, Mother shall have custody from December 24th at 5:00 p.m. until December 26th at noon. C. The 2007 holiday schedule above contemplates that this is an agreement. Consideration to these holiday periods for 2007 will be factored into the appropriate holiday schedule in subsequent years, with a preference D C CC toward arranging for the children to be with the parent who did not have holiday custody in the previous year when subsequent year holiday schedules are determined by the Court of further agreement of the parties. 5. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. For a period of twelve hours before and continuing through any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor posses or use non-prescribed controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 7. The children shall not be exposed to second-hand smoke in vehicles or indoor confided spaces. 8. The children shall not leave the United States in the absence of an agreement of the parties or further Order of Court. 9. The Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. NOW, THEREFORE, the parties hereto, each intending to be legally bound hereby, place their seal: D CC P rn to aid subscribe before me this a _ day of 2007,-, Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Linda M. Beezub, Notary Public Hampden Twp., Cumberland County My Commission Expires Oct. 21, 2009 Member, Pennsylvania Association of Notaries M41-W cc jU--- 2; Date: WITNESS Date: Sworn to and subscribe before me this 3or day of 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Troy Whner, Notary Public City Of Hartistxn, Dana * County My Commission E)ires March 22, 2011 Member, Pennsylvania Association of Notaries C7 0 A K _ -? rrt cn AUG 0 7 207 Q? DABIS CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-6162 CIVIL TERM COLLEEN CAMERO, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this P ` day of 2007, the terms of the attached Stipulation of the Parties is hereby made an Order of Court. BY THE COURT J. Distribution List: Sco . Stein, Esquire e Law Offices of Peter J. Russo, P.$o')'6z 3800 Market Street - mp 'll, PA 17011 an Regan, Esquire 1300 Market Street Lemoyne, PA 17043 k1`I!'VVAIM N. d °?mno C s .Zl wa 8.9nV LOOZ Aa?'1C?avu; id 3H130 Prepared By: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 717-4433 DAN_REGAN@COMCAST.NET Dabis Camero, Plaintiff V. Colleen Camero, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-6162 CIVIL IN DIVORCE Previously assigned to the Hon. Kevin A. Hess FATHER'S PETITION FOR PSYCHOLOGICAL EXAMINATION IN THE FORM OF CUSTODY EVALUATION AND NOW, Plaintiff, Dabis Camero ("Father'), by and through his attorney, Dan Regan, Esq., petitions the Court for an order directing a psychological examination in the form of a custody evalution. In support hereof, Father avers the following: 1. Father currently resides at 511 Erford Road, Camp Hill, PA 17011. 2. Defendant, Colleen Camero ("Mother") currently resides at Apartment B, 336 Spruce Street, Middletown, PA 17057. 3. Father and Mother are the parents of the following minor children: Dabis Camero, Age 4 (born August 14, 2003) and Dana Camero, Age 2 (born April 9, 2005). Currently, the children reside primarily with Mother at Apartment B, 336 Spruce Street, Middletown, PA 17057. Physical custody of the children is shared by Mother and Father, as described in a custody stipulation executed August 2, 2007, and made an Order of Court on August 8, 2007. Under the stipulation, Father has physical custody of -2- the children every other weekend, one weeknight evening each week and Thanksgving afternoon, with Christmas apportioned between Father and Mother on a split schedule. 4. This custody dispute came before this Court as a count in the divorce complaint Father filed in the Court of Common Pleas of Cumberland County, Pennsylvania, on October 23, 2006. 5. In response to the custody count of Father's divorce complaint, the Court ordered Mother and Father to attend a custody conciliaiton conference on Novermber 9, 2006, before Melissa Peel Greevy, Esq. In Paragraph 5 of her November 16, 2006, Custody Conciliation Summary Report, Ms. Greevy noted that both Mother and Father agreed that a custody evaluation would be appropriate. The issue was money: Both parties agreed that a custody evaluation would be appropriate under the circumstance[s]. However, father repeatedly asserted that he had no money with which he could pay for a custody evaluation. Father further represented that there were no marital assets which could be utilitzed to pay for these services pending an allocation of cost by the Court, or subsequent agreement of the parties. Thus the agreeemnt to participate in a custody evaluation with Dr. Casey Sheinvold is unlikely to move forward until it can be determined how the evaluation might be paid for. 6. This aspect of Ms. Greevy's concilation report appears in Paragraph 11 of the Court's November 22, 2006, interim custody order: Custody Evaulaiton. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Dr. Casey Sheinvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Each party shall be entitled to petition the Court to allocate the cost or otherwise determine the financial responsibility for this evaluation. For the Court's convenience, a copy of the interm custody order, which includes the conciliator's report, is attached hereto as Exhibit "A." -2- 7. The interim custody order set a custody hearing for February 21, 2007. Mother and Father then entered in to negotiations to reach a custody stipulation and avoid the February 21st hearing. The stipulation was reached in February, but for various reasons the final document was not executed and filed until August. 8. It is commonly understood that a custody evaluation by Dr. Sheinvold costs approximately $4,000. When the stipulation was being negotiated, Father did not have that kind of money and there was no reasonable prospect of obtaining it. In fact, in February, the same month Father exected the stipulation, Father filed for bankruptcy. 9. The parties' stipulation did not preseve the provision in the' interim order directing the custody evaluation. Father signed the stipulation not because he felt an evaluation was no longer `needed, but with bankruptcy staring him in the face Father saw no realistic chance of ever being able to pay Dr. Sheinvold's fee. 10. Subsequent to the bankruptcy Father's friends and family have provided Father with the money to pay Dr. Sheinvold. Father then attempted to schedule the evaluation, and while Mother has expessed a willingness to attend she has not committed to a schedule of appointments. 11. The stipulation notwithstanding, it remains in the best interest and welfare of the children that Mother, Father and the children be ordered to submit to the custody evaluation ordered last November. The mental and/or physical condition of Mother, Father and the children remains in controversy, and the issues, behaviors and concerns that prompted the custody conciliator and the Court to order a custody evaluation have persisted. In these circumstances, there is an affirmative duty, resting in the need to determine what serves the best interests of the children, to develop a record and to conduct a thorough investigation with the aid of outside experts. -3- t , . •- 12. While an apportionment of the related costs would be welcome, Father recognizes that Mother is unlikely to have resources necessary to make a meaningful contribution toward Dr. Sheinvold's bill (which must be paid in fulll in advance). Under the circumstances it is suffificent for the Court to direct that the cost of Dr. Sheinvold's examination shall be paid as ordered at a later date. CONCURRENCE OF COUNSEL 13. The undersigned broached this motion with opposing counsel in an effort to obtain concurrence. In the absence of a specific response, it is assumed that opposing counsel does not concur with this motion. WHEREFORE, Plaintiff Dabis Camero respectfully requests that this Honorable Court enter an Order of Court pursuant to Pa. R.C.P. 1915.8 directing Mother, Father and the children to submit to a psychological examination, in the form of a custody evaluation, to be conducted by Dr. Casey Sheinvold. It is further requested that Dr. Sheinvold shall deliver to this Honorable Court and to the attorneys of record copies of a detailed written report setting out the findings, results of all tests made, diagnosis and conclusions within ninety (90) days of the first scheduled appointment. Respectfully submitted, 'V?4? 4ti-s- DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Plaintiff, Dabis Camero Dated: September 4, 2007 -4- q . _. VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. Dated: September 4, 2007 -6- Dabis Camero, ) IN THE COURT OF COMMON Plaintiff ) PLEAS V. ) OF CUMBERLAND COUNTY, PENNSYLVANIA Colleen Camero, ) Defendant ) CIVIL ACTION - LAW No. 06-6162 CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing document by first class mail, addressed as follows, upon: Scott A. Stein, Esq. Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011-4327 Dated: September 5, 2007 DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 c `'- cry rn y Cil n? r -,ice Dabis Came 'o, Plaintiff V. Colleen Ca ro, sEP oazamed IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW No. 06-6162 CIVIL IN DIVORCE ORDER OF COURT ANQ NOW this /off day of , 2007, upon consideration of "Father's Motion for Psychological Examination in the Form of Custody Evaluation," a rule is issued upo Defendant to show cause why the P/llaai"ntiff is not entitled to the relief requested. Rule is ret mable at the hearing scheduled for [ ?.? .2007 rez -i Courtroom No. '-(of the Cumberland County Courthouse, Carlisle, Pennsylvania. at 9;m By the Court, For the Pl ntiff.• an Rega , Esq. 1300 Mark t Street, Suite 1 Lemoyne, A 17043 For the cott A. S in, Esq. Law Offi of Peter J. Russo, P.C. 3800 Ma t Street Camp Hill, PA 17011-4327 J VINVAIASNN-:W h Z: I I WV Z i d3S t00Z 33k Prepared By: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 D A N_R EGAN@C OM CA ST . NET Dabis Camero ) Plaintiff, ) V. ) Colleen Camero, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-6162 CIVIL IN CHILD CUSTODY DEFENDANT'S PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Plaintiff, Dabis Camero, by and through his attorney, Dan Regan, Esq., files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Dabis Camero [hereinafter referred to as "Father"]. Father currently resides at 511 Erford Rd., Camp Hill, PA 17011. 2. Defendant is Colleen Camero [hereinafter referred to as "Mother"]. Mother currently resides at 542 N Front Street, Steelton PA 17113. 3. The parties hereto are the parents of the following two minor children: Dabis Camero, 4, (date of birth: August 14, 2003); and, Dana Camero, 2, (date of birth: April 9, 2005). The children alternatively reside with Mother and Father at the residences identified above. 4. On August 8, 2007, the Court entered an Order dividing physical custody of the parties' children. A true and correct copy of this Order is marked Exhibit "A," attached hereto, and made part hereof. Under this order Mother has primary physical custody, with Father having physical custody alternating weekends and Wednesdays from 4:30 to 7:30 p.m. 5. The best interests and permanent welfare of the children will be served by a modification of the Court's Order: a. Father had custody of the children this past weekend (October 19 through 21, 2007). During this visit the parties' two and a half year old daughter, Dana, reported to Father and her aunt that "You would never see me again." Father asked Dana why she would say such a thing, and Dana responded that she overheard Mother saying as much over the telephone. b. Mother and her live-in boyfriend continue to be hostile to Father in front of the children. On a recent occasion, Mother and her boyfriend accused Father of brainwashing young Dabis. These accusations, peppered with obscenity, were made in front of the child. G. Mother has apparently attempted to steer young Dabis away from his cultural roots. Until recently young Dabis had begun speaking Spanish, the native language of Father and his family. This past weekend, for no known reason, young Dabis announced that he would no longer be speaking Spanish. d. Mother has withheld custody to express her irritation towards Father and her dislike of Father's family. On October 19, 2007, the children's paternal grandfather arrived from Mexico for a week's visit. This visit would mark the first time the children saw their grandfather. It may also well be the last time they see him, since he is 76 years old and experiencing health problems. Consistent with the circumstances, Father sent Mother an e-mail asking if he could have additional time during the grandfather's one-week visit. Mother did not bother to respond electronically, and in a subsequent telephone conversation Mother said, in effect, that she would grant additional time when and if she felt like it. e. The foregoing behaviors are the latest manifestations of longstanding and as yet unexplored custody-related psychological issues. The parties first appeared for a custody conciliation conference on November 9, 2007. The custody conciliator, Mellissa Peel Greevy, noted that "Both parties agreed that a custody evaluations would be appropriate under the circumstance[s]." A true and correct copy of the custody conciliation report is marked Exhibit "B," attached hereto, and made part hereof. The suggested evaluation was not conducted because the parties lacked the necessary funds. When the funds became available, Father asked Mother's cooperation in scheduling the now overdue evaluation. On several occasions Mother expressed her willingness to participation in the evaluation, but ultimately she reneged. The -2- psychological problems that were detected by Ms. Greevy last November persist, and it remains true that the children's interests are best served by going forward with a custody evaluation. WHEREFORE, Plaintiff respectfully requests that this Honorable Court modify its Order to grant Father primary physical custody of the two children and to grant Mother partial physical custody every other weekend and one weekday evening per week. In the alternative, Plaintiff respectfully requests this Honorable Court modify its Order to direct the parties to undergo a custody evaluation. Respectfully submitted, DAN REGA Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: October 23, 2007 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dated: -3- GRU•I^+ AUG 0 7 2OD7 15XKI 617 "Ah DABIS CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-6162 CIVIL TERM COLLEEN CAMERO, CIVIL ACTION - LAW Defendant IN CUSTODY ORDE OF COURT AND NOW, this 0 day of 2007, the terms of the attached Stipulation of the Parties is hereby ade an Order of Court. BY THE OURT, J. Distribution List: Scott A. Stein, Esquire The Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011 ?Ur CUr ? , ?+????? ._?•i9Ru Dan Regan, Esquire 14 ? y?r f, I Unto set my hint 1300 Market Street t C?fIfS??t'- Lemoyne, PA 17043 ?v DABIS CAMERO, V. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6162 CIVIL TERM COLLEEN CAMERO, Defendant CIVIL ACTION - LAW IN CUSTODY STIPULATED CUSTODY AGREEMENT 7 --r G'7 e, rlo C1'1 THIS AGREEMENT is hereby made and entered into this -! day of 2007, by and between Dabis Camero (hereinafter "Father") and Colleen Camero (hereinafter "Mother"). Witnesseth: Whereas, Dabis Camero is represented by Dan Regan, Esquire; Whereas, Colleen Camero, is represented by Scott Stein of The Law Offices of Peter J. Russo, P.C.; Whereas, the Parties have had adequate time and opportunity to consult with legal counsel; Whereas, both Parties acknowledge that they are satisfied with the legal advice they have received and understand the full importance of the Agreement they are entering into; and Now, therefore, the parties, in consideration of the foregoing promises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. Legal Custody. The parties, Dabis Camero and Colleen Camero, shall have shared legal custody of the minor children, Dabis Camero, born August 14, 2003 and Dana Camero, bom April 9, 2005. Each parent hall have an E-iz C) Ti S n??? 7m equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. § 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable times as to make the records and information of reasonable use to the other parent. All decisions affecting the children's growth and development including, but not limited to, choice of camp, if any; choice of child care provider, medical and dental treatment; psychotherapy,- or like treatment; decisions relating to actual or potential litigation involving the children directly or as a beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made with the parents jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the children's best interest. 2. Physical Custody. Mother shall have primary physical custody of the minor children subject to Father's periods of partial custody as follows: a. Alternating weekends beginning March 9, 2007 from Friday at 5:00 p.m. until Sunday at 5:00 p.m. b. Every Wednesday from 4:30 p.m. until 7:30 p.m. or at such ? 11 D ? v CC other days and times as agreed by the parties taking in to account Father's school schedule such that the intent of this paragraph is to give Father a weeknight that does not conflict with Father's schooling. 3. Transportation. The parent relinquishing custody of the children shall provide transportation incident to the custodial exchange. The parties will meet at their respective residences to affect the exchange. At exchanges, both parents shall establish a no-conflict zone for their children and refrain from making derogatory comments about the other parent in the presence or earshot of the children and, to the extent possible, shall prevent third parties from making such comments in the presence or earshot of the children. 4. The following holiday schedule supersedes the regular schedule a. Thanksgiving 2007 - Mother will have custody until November 24th at 10:00 a.m., provided that Father is able to be off work on that day. In the event that he is not able to be off work to meet Mother at 10:00 a.m., Father's custodial period will commence at 5:00 p.m. as usual, unless the parties agree on an earlier exchange time. b. Christmas - In odd years, Father shall have custody from December 24th at 5:00 p.m. until December 26th at noon. In even years, Mother shall have custody from December 24th at 5:00 p.m. until December 26th at noon. c.. The 2007 holiday schedule above contemplates that this is an agreement. Consideration to these holiday periods for 2007 will be factored into the appropriate holiday schedule in subsequent years, with a preference D CC toward arranging for the children to be with the parent who did not have holiday custody in the previous year when subsequent year holiday schedules are determined by the Court of further agreement of the parties. 5. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. For a period of twelve hours before and continuing through any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor posses or use non-prescribed controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 7. The children shall not be exposed to second-hand smoke in vehicles or indoor confided spaces. 8. The children shall not leave the United States in the absence of an agreement of the parties or further Order of Court. 9. The Cumberland County Court of Common Pleas shall retain jurisdiction of this matter. NOW, THEREFORE, the parties hereto, each intending to be legally bound hereby, place their seal: D?? CC N CAMERO Pd rn to and subscribe before me this a day of --C3c?5'-? 2007,, I \A ry Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Linda M. Beezub, Notary Public Hampden Twp... Cumberland County My Commiscion Expires Oct. 21, 2009 Member, Pennsylvania Association of Notaries cc Date: '4-z' 4 az6g' WITNESS Date: 7-90-07 AT Sworn to and subscribe before me this Y day of 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Troy Wihter, Notary Public City Of Harrlstxxg, Dauphin county My ComnikWort E)Ores March 22, 2011 Member, Pennsylvania Association of Notaries rxN(6t-r t'ga DABIS CAMERO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6162 CIVIL TERM V. COLLEEN CAMERO, Defendant CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME Dabis Camero Dana Camero DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Father Father August 14, 2003 April 9, 2005 2. Father filed a Complaint in Divorce with a Count for Custody on or about October 23, 2006. Contemporaneously, he filed a PFA docketed to 06-6163. Following Hearing before Judge Bayley on October 30, 2006, the PFA Order was VACATED and the petition was dismissed. A Custody Conciliation Conference was held on November 9, 2006. Present for the conference were: the Mother, Colleen Camero, and her counsel, Scott Stein, Esquire; the Father, Dabis Camero, and his counsel, Daniel J. Regan, Jr., Esquire. 3. Father filed a petition for primary custody on or about October 23, 2006. His claim for custody was included as a court in a Divorce Complaint. Father is employed in the IT Department at Penn State Harrisburg. Father reports that his employer is flexible and that a typical work week for him is Monday through Friday, 40 hours, from 9:00 a.m. until 4:30 p.m. He reports that he does not work weekends, except in the event of an emergency, which may occur only once in every six months. He had also been taking classes there two evenings a week. However, he dropped out of all of his classes in October of 2006 in order to make himself more available for the children. The parties have been married three years. Although the custody count in the divorce complaint does not state the following information, Father alleges that Mother has an alcohol problem. In support of his allegation, Father claims that Mother had two DUI's before they were married and references two incidents where he claimed that he came home and found that Mother was passed out because she was drunk. These incidents NO. 06-6162 CIVIL TERM allegedly occurred in 2002 and 2004. Father further alleges that Mother has bulimia. He claims that her therapist may have inquired about whether she has ever considered taking medication. Father reports that Mother has trouble coping day-to-day and describes her as moody, and verbally abusive to him. He further complains that she makes racist comments regarding him. Father is a native of Columbia. But, through his marriage to Mother, is a resident alien and holds a green card. Father hastens to point out that had he not gotten a green card through his marriage to Mother, he believes he would have been able to get one through his sister, who is also in the United States. When we were exploring the options of reaching an agreement, Father indicated that he would not give up- the children to someone who is mentally unstable. Father emphatically stated that he would not negotiate with liars. Throughout the conference, Father was extremely labile, and had difficulty maintaining an appropriate demeanor. He was extremely hostile and provocative to both Mother and her counsel. He seemed unable to accept the notion that his representations regarding Mother were not sufficient to completely restrict her contact with the children. Father has had custody of the children pursuant to a PFA filed on October 23, 2006. No portion of the petition made any allegations that Mother presents, or then presented, any danger to the children who are subject to this custody action. It is also notable that there are pending cross-petitions for exclusive possession of the marital residence, which are scheduled to be heard in coming weeks by Judge Hess. Father's comments regarding Mother were, without exception, negative and degrading. Since the PFA Order was vacated, Father has taken no apparent steps to facilitate any contact with Mother and the children. Father stated repeatedly that Mother should get a job. Father has arranged for his mother to come to the United States from Columbia on what he describes as an extended visit. She is apparently here to assist him with the care of the children. However, in addition, Father has unilaterally enrolled the children in a day care center at the Pennsylvania State University Middletown Campus. He has been informed by the undersigned that this is a direct violation of Mother's rights of legal custody. 4. Mother reports that she has been a stay-at-home mom throughout the marriage. She is presently residing with her mother and aunt in Maryland, in a town approximately an hour and a half away. Mother reports that she has been the primary caregiver throughout the children's lives as she was the stay-at-home mother while Father worked and went to school in the evenings. Mother reports that she takes to the children to swim lessons, gymboree and kindergym. Until the time that Father obtained custody by filing the Protection From Abuse petition, Mother was breast-feeding the parties' youngest child, who is approximately 18 months old. Although the PFA Order was vacatedupon advice of counsel, Mother did not return to the residence where it is clear that Father does not want her to reside. Mother has not seen the children since October 23, 2006. NO. 06-6162 CIVIL TERM Mother disputes everything Father alleges regarding abusing alcohol. Mother does acknowledge that she is receiving psychological care, along with the parties' son, through Guidance Associates of Pennsylvania. Her therapist is Jamie Orris, LSW. In regard to the allegations in the PFA petition, Mother reports that although she did not elect to file a petition for protection for herself, Father had pushed her. Mother describes Father as being very controlling. Mother reports that Father gave her an allowance of $400.00 per month to pay for diapers, and food for the family. She relates that she has no idea of the assets as he controls all of the family income. Mother has concerns about Father using the mother-in-law as an alternative caregiver because she is unable to lift the children for medical reasons, and is sometimes forgetful about locking doors. She is also concerned that she is not able to provide a safe environment for the children because the mother-in-law leaves cleaning supplies and sharp objects out where the children can reach them. Mother is concerned that without the doors being locked that the children might wander into the street. Both parties acknowledge that there is a view of parenting and significant tension between Mother and the paternal grandmother. 5. The parties reached agreements regarding legal custody, prohibitions against disparaging each other and drug and alcohol exposure for the children, as well an agreement that the children not be exposed to second-hand smoke. The parties were also able to reach an agreement with regard to Christmas and Thanksgiving custody for 2006. Both parties agreed that a custody evaluation would be appropriate under the circumstance. However, Father repeatedly asserted that he had no money with which he could pay for a custody evaluation. Father further represented that there were no marital assets which could be utilized to pay for these services pending an allocation of the cost by the Court, or subsequent agreement of the parties. Thus, the agreement to participate in a custody evaluation with Dr. Casey Sheinvold is unlikely to move forward until it can be determined how the evaluation might be paid for. The parties were not able to reach an agreement with regard to the schedule of physical custody. Neither party objected to the Cumberland Court of Common Pleas retaining jurisdiction. Because the parties were unable to reach an agreement in regard to custody, the Conciliator found it necessary to recommend an Interim Order, as the children have not had contact with Mother since October 23, 2006. A hearing in this matter will require one (1) day. Date Melissa Peel Greevy, Esqui Custody Conciliator :286756 Dabis Camero ) IN THE COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL ACTION - LAW Colleen Camero, ) No. 06-6162 CIVIL Defendant ) IN CHILD CUSTODY CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing document by hand delivery upon: Peter J. Russo, Esq. 3800 Market Street Camp Hill, PA 17011 DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: October 23, 2007 r.7 ? 4 DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 06-6162 CIVIL COLLEEN CAMERO, Defendant IN DIVORCE IN RE: FATHER'S PETITION FOR PSYCHOLOGICAL EXAMINATION IN THE FORM OF CUSTODY EVALUATION ORDER AND NOW, this Z t' day of October, 2007, following conference with counsel in Chambers, it appearing that there is no petition before the court seeking modification of the existing custody order, the father's petition for custody evaluation is DENIED without prejudice. BY THE COURT, an Regan, Esquire For the Plaintiff Xott A. Stein, Esquire For the Defendant A :rlm 147» r ?` o Luz 3? DABIS CAMERO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. COLLEEN CAMERO DEFENDANT • 2006-6162 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, October 26, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 20, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or pennanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinp.. FOR THE COURT, By: /s/ ac ueKhe M. Verne Es q. ji.m Custody Conciliator fj I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 ???j ? ?„M, „emu, ?p-dam o/ k-V 6z 1-39 luz I DABIS CAMERO, Plaintiff VI. COLLEEN CAMERO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-6162 : IN CUSTODY ORDER OF COURT CIVIL ACTION - LAW AND NOW, this 2 I' day of AV-6..4., , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated August 8, 2007 shall remain in full force and effect with the following additions. 2. The parties shall cooperate with a custody evaluation performed by Casey Shienvold to include the children and all of the adults in each household. Father shall be responsible for the cost of the custody evaluation. 3. The parties shall cooperate with counseling for the child, Dabis, with Jamie Orris. Either both parents are to be included in the counseling session or neither will be included, depending on the availability of the parents. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Either party may schedule another conciliation conference once the custody evaluation is completed. BY THE COURT, Kevin cc: Dan Regan, Esquire, Counsel for Fatl*r Peter Russo, Esquire, Counsel for Mother J. 11, -0-7 PIZ t ) ?t?N.E{7PrvH1:??'d ? ?o DABIS CAMERO, Plaintiff V. COLLEEN CAMERO, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-6162 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dabis Camero August 14, 2003 Mother Dana Camero April 9, 2005 Mother 2. A Conciliation Conference was held in this matter on November 20, 2007, with the following in attendance: The Father, Dabis Camero, with his counsel, Dan Regan, Esquire, and the Mother, Colleen Camero, with her counsel, Peter Russo, Esquire. 3. The Honorable Kevin A. Hess previously entered an Order of Court dated August 8, 2007 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends and every Wednesday evening. 4. The parties agreed to an Order in the form as attached. Date acq line M. Verney, Esquire Custody Conciliator DABIS CAMERO Plaintiff V. COLLEEN CAMERO Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 -6162 CIVIL 'kCTION -LAW 4 PRAECIPE FOR WITHDRAW OF APPEARANCE Please withdraw the appearance of the undersigned as counsel for the Plaintiff, DAIS CAMERO in the above-captioned matter. Respectfully submitted, DATE: is . rs . o z Dan Regan , quire 1300 Market Street, Suite 1 Lemoyne, PA 17043 PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for the Plaintiff, DABIS CAMERO in the above-captioned matter. Respectfully submitted, DATE: 1'z 1'3- c57 Sanford A. v y, Esquire 1101 North Fr eet Harrisburg, PA 17102 (717)234-4583 I.D. 15560 Distribution: Dan Regan, Esq. Sanford Krevsky, Esq. Peter Russo, Esquire 0 ?i I -V C"4 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 The Defendant, Colleen Camero, by and through her counsel, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. THE LAW R J. RUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Defendant 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Date: ?JJ tO$ Facsimile: (717) 591-1756 Y ?. LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mr. Otis Comstock 577 Broadway Hanover, PA 17331 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all documents regarding disputes, problems or concerns, including but not limited to all personal and business Tax Returns, K1's and Schedules relating to Dabis Camero of 511 Erford Road Mechanicsburg, PA 17050 and Colleen Camero of 542 North Front Street, Steelton, Pennsylvania 17113 from 2002 to the present date at 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 to the attention of Peter J. Russo, Esquire. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party r. -. making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the document or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. This subpoena was issued at the request of the following person: Judith Krebs by and through her counsel The Law Offices of Peter J. Russo, P.C. THE LAW OFFICE OF PETER J. RUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Defendant 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Date: BY THE COURT: By: Prothonotary Seal of the Court C` C3 r r? C LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) an objection to the subpoena has been received, and the attached Order of Court has been issued, and t (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. J. RUSSO, P.C. Peter J. Russo, Esqui Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Defendant 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Date: 31 (et to?) 4. LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Certificate Prerequisite to Service of a subpoena pursuant to Rule 4009.22, upon the following person, in the manner indicated: FIRST CLASS MAIL Sanford A. Krevsky, Esquire 1101 North Front Street Harrisburg, PA 17102 DATE: 3 ( 1910?) Peter J. Russo, Esquire . f CD ? To. Page 2 of 2 2008-05-05 13:51:40 (GMT) LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Rt"s o, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1'755 Facsimile: (717) 591-1756 Attonieys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CA_MERO, Defendant : No. 06-6162 CIVIL. TERM : CIVIL ACTION -LAW : IN CUSTODY NOTICE To: Mr. Otis Comstock 577 Broadway Hanover, PA 17331 You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Otis Comstock, certify to the best of any knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on n(?( CYO ? q d 2?bU c {date of subpoena) have been produced. ?- Date: --- ------- ------ ---- - ----- - ---- - ------------- Otis Comstock From: Aptela Inc IN THE COURT OF COMMON PLEAS OF CIJMBERLAND COUNTY, PENNSYLVANIA G/W415'X 4,1 COL LE,!5"N : NO o6 - 9'/ 6 2 VS. C,4A.1,E,e01 7)A ,?I1 : Civil Action- Law AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on ?? •?? ?o?? 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 rights concerning alimony, division of property, lawyer's fees or e=xpenses 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 unsworn falsification to authorities. ?C.?/1' C? v?1112/'? S zoo9' / Date: Plaintiff efendant dv-ftev 4a r 1 C7, e DABIS CAMERO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006 -6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant IN DIVORCE PLAINTIFF'S AMENDED ANSWER TO DEFENDANT'S PRODUCTION OF DOCUMENTS AND NOW this 1 sf day of , 2009, comes Plaintiff, Dabis Camero, by and through his counsel, Sanford A. Krevsky, Esquire, and submits the following amended information and or documents in response to Defendant, Colleen Camero's request for Production of Documents: 1) Tax Returns from 2004 through 2007. (already submitted) 2) Unemployment Compensation - payment history of all checks received by Plaintiff. (already submitted) 3) a) Straw Man Agency Agreement & Declaration; (already submitted) and a copy of the Business Entity Filing History listing Maria N. Alzate-Osorio as President, Secretary, and Treasurer; b) Limited Liability Company Agreement for La Terre LLC, naming Luisa Benion as President, Secretary, and Treasurer. c) Call and Waiver of Notice of Meeting of Incorporator of Netland, Inc., Unaninous Action of Sole Director Netland, Inc., and Business Entity Filing History for Netland Inc. 4) a) None; b) None; c) None; d) Retirement summary as of separation (already submitted). e) None; f) None; g) None; h) None; i) None; j) See #2; k) None; 1) None. 5) A-gg: None; 6) See # 4D; 7) Fulton Bank (checking account # 3622-22988) statements from January of 2003- November of 2006 (already submitted). 8) None. 9) None. 10) Mortgage and Note (2°d Mortgage), Settlement Sheet, Tax Assessment, letter from Luisa Benion outlining her loan to Plaintiff and Defendant. 11) None. 12) None. 13) None. DATE: / O Respectfully submitted, r f Sanfor A. Krevsky ID # 10625 Attorney for Petitioner 1101 North Front Street Harrisburg, Pa 17102 Phone: (717) 234-4583 Fax: (717) 234-3650 skrevsky@krevskyandrosen.com 05/01/2009 08:14 17172344582 DAUPHIN 7COUNTY BAR PACE 04 ..... ?.,.,? 'L?. U? r i r ?Jtoitsn PAGE 83 LIMITED LIABILITY;WMPANY AGREEMENT For La Terre LLC This Limited Liability Company Agreement (hereinafter referred to as the "Agreement") Is made on this 13 day of Jime,2004, to be effective as of the day of filing the Certificate of Formation with the Delaware Secretary of State, by and between Lulsa Senion(hereinafter referred to as the "Member") and La Terre LLC, a Delaware limited liability company (hereinafter referred to as "Company")- PREAMBLE A. Whereas, the parties to this Agreement desire to form a limited liability Company for the purpose hereinafter set forth; and 13. Wheress, by entering into this Agreement the parties desire to provide for (1) the purpose for which the Company is formed; (tt) the division of the Company's net profits and net losses; (Ili) the restrictions on the disposition of Company property and Company interests; (iv) the management of the Company's business, (v) the duration of the Company's existence; and (vl) various other matters relating to the Company. NOW, THEREFORE, In consideration of the premises and the mutual promises, covenants and agreements contained in this Agreement, the parties hereto, intending to be legally bound hereby, agree to form a limited liabilky.company under the laws of the State of Delaware in accordance with the following terms and conditions: ARTICLE i- FORMATION AND PURPOSE 1.1 !go flag 6ILW and Government FUMr-.,. The Company shall be formed in accordance with and shall be governed by the Delaware Limited Liability Company Act, (hereinafter referred to as the "Act"), except to the extent that the Act permits variation by agreement of the parties and this Agreement provides for such variations. On or after the execution of this Agreement, the Members shall cause a Certificate of Formation that complies with the requirements of the Act to be properly filed with the Office of the Secretary of State for the State of Delaware (hereinafter referred to as the "Certificate") and shall execute such further documents and take such further action as is necessary or appropriate from time to time to comply with the requirements for the fornlatlon and operation of a limited liability company in the State of Delaware and In all other jurisdictions where the Company conducts its business. 1.2 . The name of the Company shall be La Terre LLC 1.3 Pumose of the C..oms anv. The purpose and business of the Company shall be to engage in any lawful business activity agreed to by the Members and to conduct such other activities as may be necessary or appropriate to promote the business of the Company. The Company may exercise all the powers and privileges either granted or limited sander the Act. 1.4 Registered Office: R„ 0iV9r9d AM. The name of the registered agent for service of process on the Company in the State of Delaware Is Agents 05/01!2009 08:14 17172344582 DAUPHIN RTOUNTY BAR PAGE e5 ,.,a„ iWwa c..i. VA /A / I.7Lb1fJl7 PACE 04 and Corporations, Inc. The address of the registered agent of the Company and the address of the registered office of the.Company in the Sterte of Delaware is 1201 Orange Street, Suite 600, City of Wilmington, County of New Castle, and State of Delaware. 1.5 Pja7pa1 place of Businel. The Company's principal place of business shall be located at , or at such other place as the Members may select from time to time. 1.6 Expenses of Formetlon. The Company shall bear the expenses incident to its formation. Each Member shall bear his own personal expenses, If any, incurred In connection with his decision to enter into this Agreement. ARTICLE i1• T!`EN 2,1 Term. The tern of the Company shall commence on the effective date of the filing of the Certificate With the Office of the Secretary of State of the State of Delaware and shall be perpetual. MMLE III gM[T COAtTRIBUTIONS AND COMPANY INTERESTS 3.1 Cgmpany Cam. The Capital of the Company shall be the aggregate sum of the capital dontilbutions made by the Members to the Company in the manner provided for in this Agreement, Each Member shall own a share of the toted capital of the Company in proportion to that Member"s Company Interest. 3.2 Initial Capital Contrib=. The initial capital contribution of the Members to the Company shall be as follows: Name of Memo Amourltgj Contritwtion Luisa Benion $ 0 TOTAL: $ 0 3.3 payment of Contriby§2121. Esoh Member's capital contribution shall be made by delivering it to the Company within the thirty (30) day period immediately following the execution of this Agreement by that Member. 3.4 Cmpany i nterest. For purposes of this Agreement. the term "Company interest" shall mean each Member's share of the Company's net proitts and net losses, the right to receive distributions of Company property and the rights, powers and liabilities of a Member as defined and described in the Act and this Agreement. The nature of a Company interest shall be personal properly for all purposes. 3.5 P$r g= pf_oMpany Voting Intern. The Company interest of the Members shall be represented by a total of One Thousand (1,000) Company Units, divided as follows: Five Hundred (600) Company Voting Units (hereinafter referred to as the "Voting Units") and Fhre Hundred (500) Company Non-voting Units (hereinafter referred to as the "Nonvoting Units"). With respect to Voting Units of the Company each Member shall be entitled to one vote per Voting Unit owned. The Nonvoting Units shall have no voting rights attached to them and each member holding the Nonvoting Units shall 2 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 06 VY/ JV/ LU07 .4.1: nt rl i r.??biae NUMART PAGE 05 not be entitled to vote on any Company matter unless otherwise provided herein. Each Member's Initial Company interest shall be equal to the number of Units set forth below- Name o Member No -of V tin nits Luisa Benson TOTAL: Name of Member ,NQ. of NQ,ayng Units Luisa Benson TOTAL I Each Members Company interest at any given time shall be calculated on the basis of the number of Units owned by that Member to the total number of Units owned by all of the Members. The Members holding the Voting Units are hereinafter referred to as the "Votlng Member" and the Members holding the Nonvoting Units are hereinafter referred to as the "Nonvoting Members". 3.6 Pom of_Contributlons. Unless specified otherwise in this Agreement, all capital contributions made by a Member to the Company shall be made In the fonn of cash. No capital contributions shall be made by a Member to the Company in property other than cash, unless specifically agreed to In writing by a majority In Interest of the Members, which writing shall: (a) identify the property to be contributed; (b) state the fair market value of the property on the date of contribution. (o) state the amount and nature of all liabilities secured by the property and the extent, If any, to which the Company shall assume or take subject to any of those liabilities; and (d) state the adjusted basis of the properly for federal Income tax purposes in the hands of the c onbibuting Member immediately prior to its contribution. The Members hereby consent to the contribution by them of the property identified In Paragraph 1.3 of this Agreement. 3.7 Adgitlonsl Cauital Con ' ns. No Member shall be required to make any further or additional capital contributions to the Company, except as required by the Act or this Agreement. No Member shall have the right to make additional capital contributions to the Company, except with the prior written consent of a majority in interest of the Members. 3.8 ZMdrawal of CQoital_CoMdbutions. No Member shall have the right to withdraw or reduce his capital contributions to the Company, except with the prior written consent of a majority in interest of the Members, No Member shall have the right to demand and receive any distribution from the Company in any form other than cash- No Member shah be entitled to receive any interest on his capital conMbutions to the Company. 3.8 Use pfContributions. The aggregpte of all capital contributions made by the Members to the Company shall be available to the Company to cant' out the purposes of the Company. 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 07 Uw arjf LVV7 L.7: 01 11 i /yLbltie NETMAR PAGE 06 3.10 Owns, 3W of Property. All Company property, whether real or personal, tangible or intangible, shall be owned by the Company. No Member shall have any Interest in any specific Company property. 3.11 No R1ghtaLbaitiap. Each Member welves any right he may have to cause Company property to be partitioned or otherwise divided among the Members, or to file a complaint or institute any proceeding at law or equity to cause Company property to be partitioned or otherwise divided among the Members. 3.12 Comm of Genital Accounts. The Company shall establish and maintain a separate capital account for each Member. In accordance with applicable federal tax laws. Each Member's capital account shall be determined and maintained as follows: . a. ContrJb-.u , noes and Gains. Each Member's capital account shall be increased by: (1) the amount of money contributed by that Member, (2) the fair market value at the time of contribution of all property other than money contributed by that Member, reduced by any liabilities secured by that property which are assumed or taken subject to by the Company: and (3) that MemboWs share of Company income and gains, including incomes and gains which are exempt from or not recognized for federal income tart purposes, as computed for book purposes; and b. Distributions, goUctIQfrs ands. Each Membees capital account shall be decreased by. (1) the amount of money dlstrlbute3d to that Member, (2) the fair market value at the time of distribution of all property other than money distributed to that Member, reduced by any liabilities secured by that property which area assumed or taken subject to by that Member, and (3) that Members shame of Company lasses and deductions, including Company expenditures which are not deductible or rapitelizable for federal income tax purposes, as computed for book purposes. . 3.13 Traplb 's Capital AMI;&nt. In the event of a permitted transfer of a Company' interest as provided in this Agreement, the capital account of the transferor shall become the capital account of the transferee to the extent it relates to the transferred Company interest. 3.14 Compliance I i T . The manner in which the capital accounts Of the Members are to be maintained pursuant to this Article iII of this Agreement Is Intended to comply with the requirements of all applicable federal tax laws. If in the opinion of all of a majority In Interest of the Members the manner in which capital accounts are to be maintained pursuant to this Article III of this Agreement should be modified in order to comply with the applicable federai tax laws, then notwithstanding anything contained in this Agreement to the contrary, the Members shall alter the method in which the capital accounts are maintained and amend this Agreement to reflect any such change in the manner in which capital accounts are maintained; provided, however, that any change in the manner of maintaining capital accounts shall not materially alter the economic agreement between the Members. ARTICLE IV. ALLOCATIONS AND DISTRi6U]30N3 4.1 Allocation of Company Items. All items of income, gain, loss. 4 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 08 r,w? ?n? ?nny ZX 41 1117326180 NETMART PAGE 07 deduction orcredit of the Company shall be allocated among the Members in proportion to their Company Interests; provided, however, that for federal income tax purposes such items of income, gain, loss and deduction or credit with respect to property contributed by a Member to the Company shall be allocated between the Members so as to take account of the variation between the federal income tax basis of the property to the Company and its falr market value at the time of its contribution to the Company in accordance with applicable federal tax laws. 4.2 PriorityAmm ag Members. unless specified otherwise In this Agreement, no Member shall have priority over any other Member with regwd to the return of capital, the allocation of any Company items or the distribution of Company property. 4.3 BMocatQn_on Transfer. In the event that a Member's Interest is transferred in accordance with the provisions of this Agreeme4 the allocations provided in this Article IV of this Agreement shall be further reallocated between the transferor and the transferee In the same ratio as the number of days each of therm owned the Company Interest during the fiscal year of. the Company for which the allocation is being made, unless the books of the Company permit the allocation of items of income and expense to the periods of time before and after the transfer, In which case the latter allocation shall be made. 4.4 i WAbutlon of Net Cash. Following the and of each fiscal year of the Company and the adjustment of the Member's capital accounts for that fiscal year, the Company may distribute the Net Cash of the Company to the Members. Distributions of Net Cash shall be made among the Members in proportion to their Company Interests. The term "Net Cash" shall mean an amount which is equal to the net profits of the Company, plus the net proceeds from any refinancing of Company property, except that (a) depreciation of buildings, improvements, personal property and amortization of leasehold improvement, if applicable, shall not be considered a deduction, (b) payment of interest on and repayment of principal of, debts shall be oonsidered a deduction, (c) any amounts expended on behalf of the Company for capital improvements or new Investments shall be considered a deduction, and (d) any reasonable reserve of capital created to provide funds to be Invested In additional Company property, to provide funds for capital improvements for Company property, or to provide funds far any other contingency of the Company shall be considered a deduction. 4.5 Draws. With the prior written consent of a majority in interest of the Members, at the beginning of eogh fiscal year, a periodic draw In anticipation of the distribution of Net Cash to that Member for that fiscal year may be established for one or more Members. Any amounts so withdrawn during the fiscal year shall be credited against any Net Cash distributable to that Member at the end of that fiscal year. To the extent such withdrawals exceed a Member's Net Cash distribution for the same fiscal year, the exoeas shall be a liability of that Member to the Company payable upon demand but without interest. A periodic drawing right once determined may be terminated by the consent of all of a majority in interest of the Members at any time during the course of the Company's fiscal year if It appears unlikely that the Net Cash distributable to that Member for that fiscal year shall equal or exceed that Members withdrawals. ARTICLE COMPETrTION 5.1 Any Member may engage in any other business, whether or 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 09 04117of "ai Ztl; nl rt / 1JZb1W NETMART PACE 08 not the same or similar to the business of the Company, and whether or not such other business is competitive with the Company with the written permission of a majority in Interest of the other Members. Neither the Company nor the other Members small have any rights In the income or profits of that business, ARTIr'c r: Vt TAX. FINANCIAL AND ACCOUNTIMS MATTERS 61 l" Year a ccountWMethod. The fiscal your of the Company for both accounting and Income tax purposes shall be the calendar year, and for both accounting and income tax purposes the Company shall report Its operaftw and profits and losses in accordance with the wash method of accounting, unless a different method of accounting is required by applicable federal tax laws. 6.2 DMMI Tax Remand Financial emerb The accountant for the Company shall prepare all required tax returns for the Company as of 'e're end of each fiscal year, including the balance sheet and statement of Income and expenses slating to such fiscal year, and a statement of each Me:mbees distributIve share of the items of Inoome, gain, loss, deduction and credit of the Company for tax purposes for such We[ year. The Company shall furnish each Member with a copy of each such tax return and statement within thirty (34) days after the Company files its tax returns for such fiscal year. 6.3 Tax and AccounU09Matters, All elections with reaped to the preparation and filing of the Company tax returns, the reporting of.ttems of Company income, gain, loss, deduction and credit, and all other elections which the Company or Members are entitled to make with respect to Company matters, shall be made only bythe Company. shall be the tax Matter's Member for the Company for income tax purposes. All decisions as to awount ng matters shall be made In accordance with generally accepted accounting principles applied on a basis consistent with prior periods. 6.4 Books end Reogrds. The Company shall maintain a full and accurate set of books and records at its principal place of business. Each Member and his duty authorized representative shall have access to and may Inspect and copy any such books and records at all reasonable times. 6.5 Dank Aorount. The Company shall open and maintain a bank account or bank accounts in the name of the Company at such bank or banks as of a majority in Interest of the Members may determine from time to tkne. Ail funds of the Company not otherwise invested shall be deposited in and withdrawn from such bank account(s) as a majority in interest of the Members may determine. Any withdrawals from such bank account(s) shall require such signature or signatures as a majority in interest of the Members may from time to time determine. ARTICLE VII. MEM„ RERS 7.1 Manam9rmntAuthoritx of Members and OffrcW. A majority in interest of the Voting Members shall have the full and exclusive responsibility for the management of the Company, the operation of the business of the Company, and the Performance of the duties described in this Article VII of this Agreemeent. The majority in interest of the Voting Members have delegated their power and authority to the fo!lowing President, Secretary and/or Treasurer as officers of the Company, all of whom could be the 6 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 10 v ...4 , I(JAOICU NETMART PAGE 09 same person and who could be a Member of the Company and will have the power and authority provided herein. unless otherwise specified by a majority in interest of the Voting Members: President: tiy;. wi S a. fBGri'aw Secretary: i'v i J A. V e 7t r v,n-- Treasurer: OL Yf rips- 2. res a t. The President shall be the chief executive officer of the Company, shall preside at all meetings of the Members, shall have general and active management of the business of the Company, and shall execute bonds, mortgages, loans, leases and contracts far the Company, and is authorized to open and sign bank accounts and to authorle other officers or persons to open and sign such accounts. b. W yr . The Secretary shall record all the prooeedings of the meetings of the Members and notice of all meetings of the Members, and shall perform such other duties as may be prescribed by the President, under whose supervision he shall be. o. Try. The Treasurer shall have the custody of the corporate funds and securities and shall keep full and accurate accounds of receipts and disbursements In books belonging to the Company and shall deposit all moneys and other valuable effects in the name and to the credit of the Company in such depositories as may be designated by the President. The Treasurer shall disburse the funds of the Company as may be ordered by the President taking proper vouchers for such disbursements, and shall render to the President an account of all his transactions as Treasurer and of the financial condition of the Company_ The foregoing officers shall serve until their respective successors are chosen by a majority in interest of the Members or a majority in interest of the Members removes one or more of the officers so that a majority in interest of the Members may resume exeroising the power and authority previously delegated to such officer or offlcem. 7.2 Quties Qf j?oyalt,y and Care of Membgm. The Members shall devote such Qme to the operations of the Company as they, In their sole discretion, deem to be reasonably required to conduct the Company business and to operate and manage the Company property in an efficient manner. The Members shall use their best efforts to manage the business and affairs of the Company. The doing of any act orfailure to do any act which may result in a loss to the Company, If done In good faith and In a manner reasonably believed to b e I n t he b eat f nterest o f t he C ompany, s hail n of s ubject t he Members to any liability to the Company. 7.3 EgMEN of The rs_ The Members shall collectively, but not severally, have all of the powers of the Company and may exercise all of the rights and powers of a member under the Act. The prior written consent of a majority in interest of the Members with respect to any item of business shall be the act and decision of the Company; and the phrase "approved by the Members" as used in this Agreement shall mean such a decision and only such a decision. No Member shall have the right, privilege or power to perform any act on behalf of the Company, unless such act has been approved 7 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 11 ??.?+ ,irra?otoo NETWT PAGE 10 by a majority in interest of the Members. Subject to the terms of this Agreement, a m* in Interest of the Members shall have and possess the same powers and rights as a. member of a limited liability company underthe Act, including, but not limited to, the powE and right to: a. Manage the Company property, and enter into contracts with respect to such management, in whole or In part, by related or unrelated third parties; b. Execute such documents, certfficaters or instruments as they may deem necessary or appropriate for the Company's purpose; c. Sell, assign, convey, lease, mortgage or otherwise dispose of or deal with all or any part of the Company property, including, but not limited to, the power and right to utilize all or any part of the Company property 'as collateral for any indebtedness; d. Lend money to or borrow money from any person, including any Member; e. Perform or cause to be perfonned all of the Company obligations under any agreement to which the Company is a party or by which it is bound; f. Acquire property from any person, or employ or deal with any person. The fact that a Member is employed by or is directly or indirectly interested in, affiliated or connected with any such person shall not prohibit the Company from employing or otherwise dealing with such person; g. Adjust, compromise, softie or refer to arbitration any claim against or in favor of the Company and to institute, prosecute or defend any legal proceedings relating to the business and property of the Company; h. Enter into agreements with or employ such accountants and attorneys and contract for such other professional services as may be necessary and appropriate for the conduct of the Company'e business; and 1. Do any and all of the foregoing upon such terms and conditions as they may deem proper, and to execute, acknowledge and deliver any and all instruments, certificates or documents in connection with any or all of the foregoing and to take such further action as they may deem necessary or appropriate in connection with the management and business of they Company. 7.4 QomI ion for Members. The Members may be entitled to compensation for personal services rendered by them on behalf of the Company in thew capacity as Members. For purposes of this Sub Article, reimbursement for out-of-pocket expenses shall not be construed as waompansation". The Members shall be fully reimbursed by the Company for all out-of-pocket expenses incurred by them on behalf of the Company. 7.5 lndemnl§2@tion of Members, The Company shall appear, 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 12 /JL r IOLt)iNO NMNART PAGE 11 defend and Indemnify each Member from any and all claims, losses, expenses, costs, fines, penalties, judgments or damages, Induding reasonable attorneys' fees, which that Member may incur by reason of any act or a failure to act with respect to the Compeny or in furtherance of its interest, if done In good faith and in a manner reasonably believed to be in the best Interest of the Company. 7.6 P. argil t.i ity of Membm. No Member shall have any personal liability for the liablIitles or obligations of the Company, except to the extent of the capital contributions made or required to be made by such Member to the Company In accordance with the terms of this Agreement. ARIlCLE VIII. MISSION, REMOVAL AND Fa3JQ +IATIO N OF EIRS 8.1 Inifl mbgrs. All persons having executed this Agreem®nt as Members shall be admitted as Members without any further act on the part of the Company or the other Members. 8.2 Additional- Mem ers. Following the execution of this Agreement by the initial Members, persons acquiring a Company interest dire* from the Company (whether the Company Interests are being issued for the first time or being reissued as a result of a reacquisition by the Company) shall not be admitted as Members of the Company, except upon the written consent of a majority in interest of the Members. 8.3 Members. Any persons acquiring a Company interest by transfer from an existing Member shall not be admitted as a Member of the Company, except upon the written consent of a majority in interest of the Members. 8.4 PTAp ditions #Q,6dmisslon. In no event shall a Member consent to the admission of any person as a Member of the Company, unless and until: a: Such person agrees to execute this Agreement, as then amended, and such other instruments as may be required by the Act or which a majority in interest of the Members deem necessary or appropriate to confirm and record such person's undertaking to be bound by the terms of this Agreement; and b. Such pemon agrees to pay all the reasonable expenses, including attorneys fees, Incurred by the Company in connection with the transfer, if any, and the admission of such person as a Member. 8.5 &qjgnee of a Me . If s person acquiring a Company Interest is not admitted as a Member of the Company as provided in this Article Vill of this Agreement, then such person's interest in the Company shall be solely that of a rightful assignee of a Member as provided in the Act. 8.6 Reskination of embers, No Member shall resign from the Company prior to the dissolution and winding up of the Company, exoept upon the prior written consent of a majority in interest of the Members. Any resigning Member transferring his, Company Interest In conformity with the transfer provisions o1ArNde IX of this Agreement, whether to the Company, an existing Member or to a thlfd party, shall be deemed to have resigned from the Company without vitiating this Agreement upon and to 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 13 Vl rirrJZOA0u WTMART PAGE 12 the extent of the transfer, whether or not the transferee is admitted as a Member of the Company, and shell be entWed to payment for all amounts due to such Member under this Agreement in the same manner as provided for in Article IX of this Agreement. . 8.7 Payments to WrongWy Resicmina Member, In the event that a Member resigns from'the Company in violation of this Agreement, any amounts due to that Member under this Agreement, subject to offset for any damages caused to the Company as a result of such wrongful resignation, shall be paid to that Member in the same manner as provided in Article IX of this Agreement, but only if and when such amounts can be paid without causing the Company's liabilities, Including liabilities owed to Members other thanthe resigning Member, to exceed the value of the Company's assets and without causing the Company to be unable to most its current debts and obligations as they corm due after allowing for a reasonable reserve for capital needs and Improvements, the acquisition of additional Company property or for any other contingency of the Company. 8.8 Re=YAI Safe Member. A majority in interest of the Members by prior written consent may remove a Member with or without cause of the Company by purchasing or causing the Company to purchase all the Company Units owned by such member for the purchase price an the terms and conditions provided in Sub Article 9.5 and 9A of this Agreement. E IX. TRANSFER OF COMPANY I NTERl$TS . 9.1 . Transfers Rte. No Member shall transfer all or any part of his Company interest, except as provided in this Article IX of this Agreement. In the event that a Member or a transferee of a Member violates any of the provisions of this Article IX of this Agreement, such transfer shall be null and void and of no force or effect. 9.2 :jranafte Defined. The terns "transfer shall mean and include any distribution, sale, transfer, assignment, gift, creation of an encumbrance, pledge, hypothecation, grant of a s&mrity interest, lien or other disposition, either with or without consideration, whether voluntary or Involuntary, by operation of law or otherwise, Including, without limitaftlon, transfers incident to divorce or separation and all executions of legal process attaching to or affecting in any way the Company interest of a Member or a Member's beneficial interest therein. In addition to the foregoing, the following events shall be deemed transfers within the meaning of Article IX of this Agreement which shall be subject to the teams and conditions imposed upon transfers: a: in the case of a Memberwho is a natural person, his death or the entry by a court of competent jurisdiction adjudicating him incompetent to manage his person or his property; b. In the case of a Member that is a trust, the termination of the trust; c. In the case of a Member that is a partnership, the dissolution and commencement of winding up of the partnership; d. In themes of a Member that is an estate, the distribution by the fiduciary of the estate`s entire interest in the Company; and 10 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 14 ?...-+ aWwa Z-... crx r 1 r ratotno NETMART PACE 13 e. in the case of a Member that is a corporation, the filing of a certificate of dissolution, o n is a quivalent, f or t he c orporation o r t he r evocation o f i is charter. 93 Transfer Not an Event of gissolution. Except as otherwise provided In Article X .of this Agreement, the transfer by a Member of his Company interest shall not cause the dissolution or termination of the Company and the business of the Company may be continued thereafter by and for the benefit of the remaining Members. 9-4 voluntary Tranafpc Mg?tory Cffer to comnat,?v. No Member may voluntarily transfer ail or any part of his Company interest, without first complying with the terms of this Sub Article: a. Offer fgr §alee. Any Member desiring to transfer his Company interest (hereinafter referred to as the "Transferring Membeel shall give written notice to the Company and all the other Members, stating his desire to dispose of some or all of his Company interest (hereinafter referred to as the "Company Interest proposed for sale") and shall offer for saw the Company interest proposed for sale to the Company Orst and then to all the other Members as provided herein. b. Acceptance 91 For a period ofthirty (30) days after delivery of said written notice to the Company and all the Members, or until rejected by the Company, whichever occurs first, the Transferring Member may not transfer the Company interest proposed for sale to anyone other than the Company in accordance with the terms hereof. In the event the Company does not elect or rejects to purchase such Company interest within such thirty (30) day period, then all the Members shall be entitled to elect to purchase such Company Interest either prora?tn among themselves or as they otherwise mutually agree In writing within fifteen (15) days thereafter. If the Company elects or subsequently the Members elect to purchase the Company interest proposed for sale, the Company or Members shall elect to do so by giving written notice of acceptance to the Transferring member. within the aforesaid periods, and in the event of such election, such sale shall dose at the Company's principal place of business within one hundred and twenty (120) days after the Transferring Member gave written notion do the Company as provided in Sub Article 9.4 (a) of this Agreement, c. Purchase Price and Payment Tams. The purchase price for the Company interest proposed for sale pursuant to Sub Article 9.4(a) of this Agreement shall be determined In accordance with Sub Article 9-5 of this Agreement and the temps and conditions for the payment of such purchase pride shall be determined in accordance with Sub Article 9.6 of this Agreement. d. RiW„ ht of First Refual. In the event that the Company or Members do not elect to purchase the entire Company interest proposed for sale by the Transferring Member as provided In Sub Article 9.4(a) of thle Agreement, the Transferring Membet may thereupon solicit offers from any other person (hereinafter referred to as the "third party') to purchase the entire Company interest proposed for sale within sixty (60) days thereafter, subject to the Company's and Member! right of first refusal as set forth herein. No offer to purchase a Company interest proposed for sale shall be valid unless It is bona fide, in writing and signed by the third panty and the Transferring Member (hereinafter referred to as the "third party offer"). In the event the Transferring Member obtains a third party offer to purchase the Company interest proposed for sale, the 11 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 15 b4/:ib/:M1J 1;x:91 7177326186 NETMART PAGE 14 Transferring Member shall deliverthe third party offerto the Company and altthe Members and shall reoffer the Company interest proposed for sale to the Company and subsequently to all the Members on the same terms and conditions as contained in the third party offer. The offer to the Company and the Members and the acoeptance of such offer by the Company or the Members shall be done as provided in Sub Article 9.4(b) of this Agreement. In the event the Company or the Members accepts the Transferring Member's offer to purchase the Company interest proposed for sale in aooordance with the terms and conditions contained in the third party offer, then settlement on the purchase of the Company Interest proposed for sale shall be held in sooordance with the terms and conditions of the third party offer. If the Company or the Members do not accept the third party offer, the Transferring Member shall be free to sell the Company Interest proposed for sale to the third party, but only in accordance with the exact same terms and conditions set forth in the third party offer. In the event the aforesaid sixty (00) day period expires or any of the terms or conditions of the third party offer is changed either by the Transferring Member and/or the third party, the Company and all the Members shall agaln'be offered the right to purchase the Company interest proposed for sale as aforesaid, e. Pu.?se of Entire Interest. In no event shall the Transferring Member be required to transfer less than the entire Company interest proposed for sale to the Company and the Members under this Sub Artide 9.4 of this Agreement; it being.understood that the Company must purchase the entire Company Interest proposed for sale or waive its rights under this Sub Article 9.4 of this Agreement. 9.5 Purchase Price. The purchase price for a Company interest proposed for sale in accordance with this Article IX of this Agreement shall be determined as follows: a. Capital Account Value. The Transferring Member's capital account shall be valued as per the books of account of the Company as of the Valuation Date and there shall be added to or subtracted from such amount the Transferring Member's proportionate share of the Company's net profits or net losses for the period up to and including the Valuation Date. b. Adius is to Capital Account. The amount determined in Sub Article 9.5(a) of this Agreement shall then be adjusted up or down to reflect the Transferring Member's proportionate share of the difference between the fair market value of the Company's real property, stocks, securities and equity interests in other entities, if any, and the book value of such Company property on the Valuation Date. If the parties cannot agree with respect to the fair market value of such Company property, the matter shall be settled by arbitration in the manner provided In Sub Article 11.12 of this Agreement with one (1) arbitrator to be selected by the Members other than the Transferring Member, one (1) arbitrator to be selected by the Transferring Member or his personal representative, as the case may be, and the third arbitrator, who shall be a person who is experfenoed In the appraisal of property of the kind being valued, shall be selected by the first two (2) arbitrators. The decision of the arbitrators as to the fair market value of such property shall be final and binding upon the parties- if the arbitrators cannot agree on the fair market value of such property, then the decision of the third arbitrator (i.e., the one selected by the first two (2) arbitrators) shall control. 0. Valuation 0111M. The term "Valuation Date" as used in this 12 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 16 04/30/2003 23:81 7177326180 NETMART PAGE 15 Sub Article 9.5 of this Agreement refers to the last day of the calendar month immediately preceding the date the Company intent proposed for sale Is offered for sale by the Transferring Member to the Company and the Members as provided in Sub Article 9A(a) of this Agreement. d. Third Party Offer. Notwithstanding anything contained In this Sub Article 9.5 of this Agreement to the contrary, if the purchase of the Company interest proposed for sale is the result of an exercise of a right of first refusal by the Company as provided In Sub Article 9.4(d) of this Agreement, then the purchase price shall be the price set forth in the third party offer. 9.6 Payment Terms and Condon. The payment of the purchase price pmvidead for in Sub Article 9.5 of this Agreement shall be paid by the Company to the Transferring Member as follows: a. Cash Payment. Ten percent (10%) of the purchase price provided for In Sub Articles 9.5 of this Agreement shall be paid in cash, oetrtlfied check. attorneys' check or other immediately available funds on the settlement date. b. Promissory Note. The balance of the purchase price provided for In Sub Article 9.5 of this Agreement shall be paid in the form of a promissory note for said sum (the "Promissory Note"), to be amortized with equal monthly payments of principal and interest over a term of five (5) years. The first payment on the Promissory Note shall be made on the first day of the second calendar month immediately following the settlement data, and payments of principal and interest shall continue on the first day of each calendar month thereafter for an additional W nine (59) calendar months, when the entire unpaid balance of principal, together with all accrued and unpaid Interest thereon, shall be fully due and payable. The interest to be paid on the Promissory Note shall be fixed at the lowest simple interest rate specified under Article 483 (or any successor Articles) of the Internal Revenue Code- of 1986, as amended, required to be charged in order to avoid the Imposition of "unstated interest". At the end of each. celwWar year during the term of the Promissory Note, the rate of Interest to be paid on the Promissory Note shall be adjusted for the new calendar year to be fixed at the lowest simple interest rate specified under Article 483 (or any successor Articles) of the Internal Revenue Code of 1986, as amended, required to be charged In order to avoid the imposition of "unstated interest". AiI or any part of the Promissory Note maybe prepaid at any time, and from time to time, without penalty. c. Additional Provision for Promissory Not,. In addition to the provisions set forth in Sub Article 9.6(b) of this Agreement, the Promissory Note shell also provide for the following: (i) if the maker of the Promissory Note is the Company, a provision requiring the joint and several personal guaranty of all of the Members otherthan the Transferring Member, (1I) If the marker of the Promissory Note are the Members, a provision requiring the guaranty of the Company; (iii) a provision for the Confeession of Judgment against the maker of the Promissory Note and the Guarantor(s); (Iv) a provision requiring the payment of the entire unpaid principal balance of the Promissory Note, and all accrued and unpaid interest thereon, in the event there Is a sale or exchange of substantially all of the Company property or substantially all of the Company interests of the Members, as the case may be; and (v) a provision requiring the payment of a five (5%) percent late penalty for any payment more than fifteen (15) days overdue. 13 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 17 04/30/2009 23:01 7177326160 hETMART PAGE 16 d. ftWft WE Nromis-M Note. The Promissory Note or the Guaranty, whichever Is made by the Company, shall be secured by (t) a mortgage on the real property of the Company, If any, subordinate only to mortgage lions outstanding at the time of the purchase of the Company interest proposed for sale and/or (H) a security Interest In the personal property of the Company, if any, subordinate only to security interests outstanding at the time of the purchase of the Company interest proposed for sale, as the case may be. The aforesaid mortgage lien and/or security interest shall be equal i n p rivrity to a ny I ion previously placed on such property as a result of a prior purchase of a Company interest proposed for sale under this Agreement. except that the Company shall not be required to grant a mortgage lien and/or security interest to any Transferring Member if that would cause a default under any existing mortgage, loan agreement, or security agreement to which the Company is a party or promissory note of which the Company Is the maker. The Company shall take all reasonable steps necessary to secure the approvals of all other parties to such instruments to permit It to mortgage its real property or grant a security interest in its personal property without causing a default under such instruments. e. Third Party ( rer_ Notwithstanding anything contained in this Sub Article 9.6 of this Agreement to the contrary, if the purchase of the Company interest proposed for sale Is the result of an exercise of a right of first refusal by the Company as provided in Sub Article 9.4(d) of this Agreement, then the terms for the payment of the purchase price shall be those set forum In the third party offer. 9,7 Involuntary Tra sfer, Option to urahase by may. In the event that a Member discontinues being employed by the Company or Membefs (hereinafter referred to as the "Transferring Member) interest is transferred other than as provided In Sub Article 9.4 of this Agreement (hereinafter referred to as the "Event of Transfer"), the Company shall have the option for a period of six (6) months after the date of the Event of Transfer to purchase all or any. part of the Company Interest owned at any time during such six (6) month period by the Transferring Member. In the event the Company does not elect to exercise its option within such six (6) month period, then all the Members shall be entitled to exercise such option either prorata among themselves or as they otherwise mutually agree in writing within an additional six (6) month period. The purchase prioe for the Transferring Members Company interest shall be determined in the some manner as set forth in Sub Article 9.5 of this Agreement, except that the "Valuation Date" shall be the last day of the calendar month Immediately preceding the date the Company exercises its option or the Members exercise their option to purchase the Transferring Members Company interest, and the terms and conditions for payment of this purchase price shall be determined in the same manner as set firth in Sub Article 9.$ of this Agreement. 9.8 Permitt.W 9rs_ Notwithstanding anything contained in this Agreement to the contrary, a Member shall have the right to transfer all or any part of his Company Interest to another Member or to a transferee that beers one of the following relationships to the transferring Member_ a spouse, a lineal descendant or a trust created for the exclusive benefit of the transferring Member, the transferring Member's spouse and/or the transferring Member's lineal descendant(s). 9.9 Per?centms of Limitations or Transfers. Notwithstanding any other provision of this; Agreement to the contrary, the Company shall not be required to recognize any transfer of a Company interest If the transfer, when considered with other 14 05101/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 18 04/3012009 23:01 7177326180 NETMART PAGE 17 transfers of Company interests made within the period of twelve (12) oansecutive calendar months prior thereto, would constitute a sate or exchange of fifty percent (60%) or more of the total Company Interest and result In the tax termination of the Company under Article 708(b) of the internal Revenue Code of 1988, as amended. 9.10 Costs and mesas of-Transfer. The Transferring Member shall pay all coeW and expenses incurred by the Company in connection with any transfer of a Company interest pursuant to this Article IX of this Agreement and/or another person's becoming a Member of the Company or an assignee of a Member of the Company, including, b ut n of I Imited to, a 11 f cling, recording a nd p ubiishing costs and reasonable attorneys' ides and disbursements. ARTICLE X. DI$_ OOL_`['ION 10.1 aivar. Each Member waives and, to the extent that a Member cannot waive, agrees not to exercise any right under the Act or any other law to dissolve the Company, except as primed In this Agreement. 102 ED* Qnsing gissolutign • The Company shall be dissolved upon the occurrence of the earliest of the following events: a. By the Wrl ten consent of a majority in interest of the Members; b. The death, insanity, retirement, resignation, removal, expulsion, bankruptcy or dissolution of a Member or the occurrence of any other event which terminates the continued membership of a Member In the Company, unless the business of the Company is continued by the written consent of a majority of Interest in the remaining Members within ninety (90) days following the occurrence of any such event; or c. Upon the occurrence of any other event causing a dissolution under the Act or this Agreement. 10.3 Windiag Ug Upon the dissolution of the Company, the last remaining Member(s) or, if none, the personal representative of the IW remaining Member, shall conclude the business of the Company, wind up its affairs, distribute its aeaate in liquidation, and file all certifica#ea or notices required by the Act to evidterrce such .dissolution, liquidation and termination. Except as otherwise expressly provided for in the Act, all decisions pertaining to the dissolution of the Company shall be made in the some manner as decisions made In the ordinary course of the Company's business. 10.4 Final Accountj ,g: Qeficft Capital Acsxtunts. Upon the dissolution of the Company, a final accounting shall be made of the capital wcount of each Member, adjusted up or down to reflect each Member's proportionate share of the Company's net profit or net loss from the time of the last previous accounting to the date of the dissolution. In the event a Member has a deficit balance in his capital account at the time of the dissolution of the Company, that Member shall be required to contribute sufficient capital to the Company within thirty (30) days of the date of the dissolution of the Company to eliminate the deficit balance In his capital account. 10.5 Priority of Distribu#j=. Distributions in liquidation of the X5 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 19 04/30/2009 23:01 7177326100 NETMART PAGE 18 Company shall be made in the following order: a. First, those owing to creditors of the Company, including Members who are creditors of the Company; b. Second, those owing to the Members other than for capital and piss; c. Third, those owing to the Members in respect of capital; and d. Fourth, those owing to the Members in respect of profits. 10.6 Paymft „of Cbaims Upon the dissolution of the Company, the Company shall pay or make reasonable provisions to pay all claims and obligations of the Company, Including all contingent, conditional or unmatured claims and obligations, known to.the Company and all claims and obligations which are known to the Company, but for which the identity of the claimant is unknown. If the Company has sufficient assets, such claims and obligations shall be paid in full and any such provision for payment made shall be made in full. If there are Insufficient assets, such claims and obligations shall be paid or provided for ac cording to their priority and, among claims and obligations of equal priority, ratably to the extent of the assaft available therefore. Any remaining Company assets shall be distributed as provided In Sub Article 10.5 of this Agreement. 10.7 DistribuU in Kind. No Member may demand or recehm property other than oath in return for his contributions, loans or advances to the Company or upon distribution or dissolution from the Company as provided herein; provided, however, that in the event that all of the Members at the time of dissolution so determine. It shall not be necessary to liquidate all of the property of the Company; but the property which shall not be required to be IlWidated to s,a#l* the categories of distribution described in Sub Article 10.5 of this Agreement may be distributed in kind, Including, but not limited to, undivided interests in such property, whether or not like property is distributed to each Member, ARTICLE XI. GUNEIRAL PROVIS10 S 11.1 Not . AN notices, claims, instructions, requests, demands, consents, or other communications which are required or permitted under this Agreement shall be In writing and shall be deemed to have been property given if and when sent by first class United States mail, registered or certified, postage prepaid, return receipt requested, addressed as follows: If to the company to: With a renuired copy to: r.: If to Lulea Benion to: 16 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 20 04/30/2009 23:01 7177326180 NETMART PAGE 19 or to such other address as the person to whom notice is to be given may give notice in the manner set forth above. 11.2 Egg ill The parties agree that the provisions of this Agreement shall be enforced to the fudest extent permissible under the laws and public policies applied in each jurisdiction In which enforcement is sought. Accordingly, N any particular provisions of this Agreement shall be adjudicated to be invalid, illegal or unenforceable, such provision of this Agreement shall be deemed amended to delete there from the portion thus adjudicated to be invalid, illegal or unenforceable, such deletion to apply only with respect to the operation of such provision of this Agreement in the particular jurisdiction in why such adjudication is made. 11.3 DnWpM Headings. The descriptive headings of the Sub Articles of this Agreement are Insetted for convenience of reference only and shall not control or affect in any way the meaning, construction, or interpretation of this Agreement- 11.4 . Cioveming Law. This Agreement has been executed In the State of Delaware and shall be governed. by, and construed, interpreted and enforced in accordance with, the laws of the State of Delaware In all respects. 11.5 Binding ffect. This Agreement shall be binding upon and inure to the benefit of the parties hereto'and their respective heirs, executors, administrators, personal representatives, successors and permitted assigns. 11.6 Entire Agreement. This Agreement contains the entire agreement between the parties hereto with respect to the subject matter hereof and supersedoes all prior agreements or understandings among the parties hereto with respect thereto- No representation, condition or understanding not expressed herein shall be binding upon the patties, unless subsequent to the date hereto and signed by all of the parties hereto. This Agreement may not be amended or modified except by a written instrument signed by a majority in interest of the Members. 11.7 Waiver of @ago. The waiver by any party hereto of a breach of any provislon of this Agreement by another party hereto must be in writing and shall not operate or be construed as a waiver of any subsequent breach by such other party. 11.6 Authorship. No questions of interpretation or construction oonoeming this Agreement shall be construed or Interpreted for or against any party based on the consideration of authorship. 11.9 Time of the Essence. Time is of the essence of this Agreement. 11.10 Gondor. When used in this Agreement, singular terms 17 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 21 94/39/2009 23:01 7177326189 NETMART PAGE 20 include the plural as appropriate in the oontwd, and masculine terms include the ferninine and neuter genders as appropriate in the context. i. +.: 11.11 Agreement Ln.Counteroarts. This Agreement may be executed in several counterparts and, as executed, shall constitute one Agrownent. binding on all the parties hereto. notwithstanding that all the parties are not signatory to the original or the same counterpart. . 11.12 Arbitration. Any dispute, claim, oontrovarsy arising out of or in connection with or relating to this Agreement or any breach or alleged breach hereof shell, upon the nest of any party involved, be submitted to and settled by three (3) arbitrators in the principal place of business, pursuant to the Commercial Arbitration Rules of the American Arbitration Association, but not subjett to its jurisdiction. The decision of the arbitratore shall be final and binding. Judgment may be entered in any court of record in the appropriate jurisdiction upon the decision of the arbitrators. The cost of the arbitration shalt be shared equally by the parties to the arbitration. Each of the parties shall pay their own attorneys' fees incurred in connection with the arbitration. 11.13 JAX Status. The parties to this Agreement intend that the Company shall be classified as a sole proprietorship or partnership or as the form of 'PI entity elected on Internal Revenue Service Form 8832, a copy of which is attached hereto, for federal, state and local income tax purposes and the parties agree that the provisions of this Agreement shall be construed and applied In a manner that will not Impair the qualification of the Company as such form of entity under the applicable provisions of the Internal Revenue Code, or the laws of any state or local tax authorities. IN WITNESS WHEREOF, thq parties hereto have signed, sealed and delivered this Agreement effeedve as of the -9!., dsy of Mhf.., .,, 2004, ' (SEAL.) Witnes Lulsa Benion Wi s CC?MPANY. La Terre By: VI ®L (SEAL) A ? !n Lu Benion, mbar is 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 29 04/30/2009 23:01 7177326180 NETMART PAGE 27 suoness aft Corporations Online Services I Corporations I Forms I Contact Corporations i Business Services Business Entity Date:4/30/2009 Filing History (Select the link above to view the Business Entity's . Rling History) Business Name. History Name . Name Type N ETMART CORP. Current Name PA Non Stock CorporStion - Domestic - infomiation Entity Number: 2878070 Stasbua: Active En ft Cmadon Date: 512411999 Slate of Business: PA RealiM ered Office Address: 3863 UMON DEPOSIT RD, 247 HARRISBURG PA 1710" Mailing Addresm No Address Officers Name: MARIA N ALZATE )MO Title; Proaident AddreM: P 0 BOX 1320 HANOVIE=R PA 17331-67 Name: MARIA ALZATE-OSORio Title: secrotary Address: P 0 BOX 1320 HANOVER PA 17331-e7 Nome: MARIA ALZALT11111-080RIO TM*., Treasurer Address: P 0 SOX 1320 ...suns.pe.ws/*"/soskb/Com,asa?17... 1/2 05/01/2009 06:14 17172344582 04/30/2009 23:01 7177326180 4/30/2009 Nome: Title: Addrew DAUPHIN COUNTY BAR NETMART Business Entity HANOVER PA 17331-67 MARIA ALZATE"C"o Vita Pr9gdent P 0 BOX 1320 HANOVER PA 17331-67 PAGE 30 PAGE 28 Home I Site Map I Site Feedbbek j bleN as Text Only Employment ?pi'?Yt1lls U• irwrt r•? CoPy„Oht 02002 PannWivania Depardnerrt of Stete. All Rights Reurded. Comm moealth of PA Pdwacy Statement ...stM e_pa.us/oorp/soskb/Carp.asp?17... 212 05/01/2009 08:14 17172344582 84/38/2989 23:91 7177326180 DAUTCOUNTY BAR NETMAR CALL AND WAIVER OF NOTICE OF MEETING OF INCORPORATOR OF NETLAND INC_ PAGE 23 PAGE 22 1, the underaianed, being the incorporator of the above captioned corporation, incorporated under the laws of the State of Pennsylvania, hereby waive notice of the time, place and purpose of the first meeting of this corporation and call said meeting as follows: [rate: 9-12-2001 Place: 4401 Packard Lane, Camp Hill PA 17011 1 do hereby waive all the requirements of the statutes of Pennsylvania, both as to notice of this meeting and pu0cattion thereof; and I do consent to the transaction of such business as may come before the meeting. Incorporator Date: 9-12-2001 BALLOT FOR DIRECTOR OF NETLAND CORPORATION Luisa F Benion -1- vote Votes in Person - I Secretary-. Date: 9-12-2001 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 25 U41311/20H9 23:b1 11(tJ2b18d hETMART PAGE 23 UNANIMOUS ACTION OF SOLE DIRECTOR The undersigned, being the sole director of NETLAND INCORPORATED pursuant to the provisions of the Pennsylvania General Corporation Law, agrees that the following action shall be deemed duly taken as if taken at a regularly called meeting and entered into the minutes of the corporations RESOLVED 1. The following persons are nominated officers of the corporation to serve until their successors are chosen and qualify: Luisa Benion - President Luisa Benion -Treasurer Wise Benion - Secretary 2. The form of stock certificate presented and read is hereby approved and adopted end the Secretary Is Instructed to insert a specimen thereof in the minute book. 3. The President is authorized to open a business bank account on behalf of the corporation until otherwise ordered, aid bank be and hereby is authorized and directed to make payment from such account on deposit to it with the checks of this corporation signed by the President. 4. The fiscal year of this corporation shall and the thirtieth day of December of each year. 5. The Board of Directors wishes to offer for sale and to issue 1500 shares of no per common voting stock as authorized by Its Certificate of Incorporation for S per share. The President and Secretary be and hereby authorized and directed to issue a stock certificate to Luisa F. Benion evidencing ownership of ISM shares of fully paid and unassessable no par common voting stock of Netland incorporated. 6. if, in the course of its operations, the corporation finds It necessary to obtain additional funds for operation or for capital expenditure, the President and Secretary are hereby authorized and directed to obtain on behalf of the corporation loans of such amounts and to agree to terms to such loans as 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 26 W itl/1btlu 13:91 7177326180 NETMART PAGE 24 appear appropriate to them at the time the loan is obtained and in the circumstances then prevailing. 7. The registered office of the corporation Is established and maintained at 1201 Orange Street, Suite 600, Wilmington, Delaware 19801, and the registered egent at that address Is Agents and Corporations, Inc. Meetings of the Board of Directors from time to time may be held either at than registered office or at such office as the Board of Directors shall elect from time to time. 8, For purposes of authorizing a corporation to do business in any state, territory or dependency of the united States or any foreign country in which It is necessary or expedient for this corporation to transact business, the proper officers of this corporation pre herby authorized to appoint and substitute all necessary agents or attorneys for service of process, to designate and change the location of all necessary statutory offices and, under the corporate seal, to make and file all necessary certificates, reports, powers of attorney and other instruments as may be required by the laws of such state, territory, dependency or country to authorize the corporation to transact business therein and whenever it is expedient for the corporation to cease doing business therein and withdraw there from , to revoke any appointment of agent or attorney for service of process, and to file such certificates, reports, *revocation of appointment, or surrender of authority as may be necessary to terminate the authority of the corporation to do business in any state, territory, dependency or country. t?,t ?.. ? ?"? 1 Zrri Lulsa Benion, President Dated: September 12, 2001 05/01/2009 08:14 17172344582 DAUPHIN COUNTY BAR PAGE 27 04/38/2009 23:01 7177326180 hETMART PAGE 25 BWIngS Entity Corporations Online Services' I Corporations i Forms I Contact Corporations I Business Services Business Entity DOW 4/30/2000 Filing History (Select the link above to view the Business Entity's Fling History) Buss nose Nam History Name Name Type NETLAN?I INC. Current Name Business Corpotation - Domsstio - ktvi tlon Entity limber: 3025081 8latua: Active Entity Creation Date: 9/12/2001 3:47:31 PM State of BtWnegm: PA Rogi#ered Office Address: (Mailing Addrea&- No Address Home i Site Map I Site Feedback I Vlewas Text Only i lmployment Home Copyright 02002 Pennsylvania Department of State. All RighglaNrvod. Commonwealth of PA Privacy Statement Yp?so,rKb/c.re?r?d; hf?p s /Wwh/, W/o 4"oW . s?dr VC, ...stabs.ps.us/tarp/soskb/CorD.asD719... 1/1 3/4/2009 Gma;? - letter far k &iJ11 D.-,Nis Camero <dabiscamero@gmail.com> G m i I letter for krevsky luisa benion <luisabenion@yahoo.com> Tue, Mar 3, 2009 at 6:10 PM Reply-To: luisabenion@yahoo.com To: Dabis Camero <dabiscamero@gmail.com> Dear I &. Krevsky. I would lice to walls you through the payments 1 haver (}e for niy bother from the time he obtained his mortgage at the house on 511 Erford rd in Camp 11LIL I lent my brother $15000.00 to use towards leis down pa rn,ent (1,e. used $14.650.00) and I agreed on making the payments for his house as a loan with no interest (si,f.,e lie is family). For the year 2002 I paid August-December his mortgag- of $588.87 per month That comes to $2944.35. For the year 2003, $588.87 was paid from Jan to Dec and the total amount was $5879.00 2004 I also paid. $5879.00 2005 I also paid $5879.00. During 2006 I continued making the payments and decided to formalized a guaranty of payment through a mortgage lien filed with attorney Dielh. We established an approximate amount of $35.000.00 (In reality my brother and Colleen owe rae more). As a sister I realized my brothers' hardship plus the fuc:t t)-ta.t Collc,;n was not providing with any financial help for their household. If I included what was owed for the mortgages paid fron -, _Y02 to 2008 and the down payment lent, my brother and Colleen would owe me: $35.274.00 plus $ 15000.00 = $50274.00 The above doesn't include the several payments I made for their vehicles: I paid for both cars during the years 2003 and 2004 which adds another $11614.08 for the Subaru and $7892.64 for the Suzuki, which I understand Colleen was drivir? and took the day they separated. As you can see, by no means I am trying to take advantage of my brother, on the contrary the idea was to try to help him (and Colleen at that tim-0 to rnect their Iln-ine al res:x?;-sibilities. I need to get paid for what was agreed on, though. Truly yours https:Hmail.google.com/.,na?'1/?ui=2&i... 1/2 3/4/2009 Gmail - letter for krevsky Luisa Benion 717 3798533 https:Hmail.google.com/mail/?ui=2&i... 2/2 DABIS CAMERO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006 -6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant IN DIVORCE VERIFICATION I, DABIS CAMERO, hereby verify that the information contained in the foregoing Interrogatories and Production of Documents are true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DATE: S % /A.- DABIS CAMERO DABIS CAMERO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006 -6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this -A!4day of May, 2009, I, Aimee L. Paukovits, for the law firm of Krevsky & Rosen, P.C., hereby certify that I have this day served a copy of Defendant's Answers to Plaintiff's Interrogatories and Production of Documents in the above-captioned matter, via regular mail and facsimile on the following: PETER J. RUSSO, ESQUIRE 5006 EAST TRINDLE ROAD SUITE 100 MECHANICSBURG, PA 17050 imee L. Paukovits, Legal Assistant Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4583 Fax: (717) 234-3650 t '., t . T f k. DABIS CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6162 CIVIL ACTION - LAW COLLEEN CAMERO, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 14th day of September, 2009, neither party having requested another conciliation conference and ninety days having passed since the last conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, cq ine M. Verney, Esquire, C tody Conciliator FILEb OF THc P?,; I.1TY 2009 SEP 15 AH 9.2 4 CUM, u € ENt',1 rr t,; DABIS CAMERO : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006 CV 6162 N o c Q COLLEEN CAMERO CIVIL ACTION -LAW M zr _ - Defendant a s M r- .. TO: THE HONORABLE JUDGES OF SAID COURT C/ )r- -< - o a _ PETITION TO WITHDRAW =C:) M CD AND NOW this 29th day of December, 2010, comes counsel for Dabis E?tme% , Sanford A. Krevsky, Esquire of KREVSKY & ROSEN, P.C. : 1. Petitioner is counsel for Plaintiff, Dabis Camero, in the above- captioned matter. 2. Petitioner has exercised his best efforts on Plaintiff's behalf to advance his case for Divorce/Custody relative to the above-referenced matter. . 3. Plaintiff has advised Petitioner that he no longer wishes for Petitioner to represent him due to his current financial situation (see Exhibit A). 4. Much progress has been made in resolving the outstanding issues. The litigation has not advanced to the point where Plaintiff, if chosen to proceed pro se, or new counsel will find it unduly difficult: to enter his/her appearance. WHEREFORE, Petitioner asks Your Honorable Court to grant his Petition and Order that he be permitted to withdraw as counsel in the subject matter. Respectfully submitted: By: Sanford A. Krevsky, @quire Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 ID# 15560 (717) 234-4583 EXHIBIT A J Message http://ma il.krevskyandroserL corn/cgi-bin/inbox.exe?id=O l 17d4afe6f... j Read Message Previous Next Move To I Select One From: Dabis Camero <dabiscamero@gmail.com> [ add to contacts ] To: Sanford Krevsky <skrevsky@krevskyandrosen.com>, Aimee Rasheed <alr@krevskyandrosen.com>, Elisabeth Clough <eclough@krevskyandrosen.com> Cc: Date: Thursday, November 18, 2010 08:55 am Subject: Notice of Termination of Services Dear Sandy, This email is to let you know that due to my financial situation it is impossible to continue hiring you as a lawyer, therefore Pm regretfully terminating your representation. I need to talk about two things: 1) Notifying the courts you are not longer representing me. 2) Make an arrangement to satisfy any pending balances. Please contact me at your earliest convenience to talk about this items, resolve them, and make them effective. Kind Regards, - Dabis Camero Attachments: Text version of this message. (484B) j Previous __........_Next _.a 12/29/2010 10:46 AM DABIS CAMERO : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VII. NO. 2006 CV 6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE AND NOW, this 290i day of December, 2010, I, Aimee L. Paukovits, Legal Assistant for Kresvky & Rosen, P.C., attorneys for Plaintiff, DABIS CAMERO, hereby certify that I have this day served a copy of the Petition in the above-captioned matter, by First Class U.S. Mail, Certified Mail on the following: DABIS CAMERO 511 ERFORD ROAD CAMP HILL, PA. 17011 n ? n Aimee L. Paukovits 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 (7 ) - 1 c_ F m F -a - r n DABIS CAMERO IN THE COURT OF COMMON PLEAS OF - ' ?o Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA o V. N0.2006 CV 6162 oC COLLEEN CAMERO CIVIL ACTION -LAW __4 Defendant -< -c TO: THE HONORABLE JUDGES OF SAID COURT AMENDED MOTION TO WITHDRAW AND NOW this 17th day of January, 2011, comes counsel for Dabis Camero, Sanford A. Krevsky, Esquire of KREVSKY & ROSEN, P.C. : 1. A Motion for Withdraw as Counsel was filed with the Court on January 4, 2011. 2. Issues in the same or related matter were previously ruled upon as follows: a. Interim Order of Court relative to Custody was entered by The Honorable Kevin A. Hess on November 22, 2006; b. Order of Court on Plaintiff's Emergency Petition for Interim Exclusive Possession of Marital Residence and Defendant's Petition for Interim Exclusive Possession of Marital Residence was entered by The Honorable Kevin A. Hess on December 8, 2006; C. An Order relative to a Stipulated Custody Agreement was entered by The Honorable Kevin A. Hess on August 8, 2007; d. An Order relative to Father's Motino for Psychological Examination in the form of Custody Evaluation was entered by The Honorable Kevin A. Hess on October 25, 2007; e. A Custody Order was entered by The Honorable Kevin A. Hess on November 21, 2007. 3. Petitioner has contacted counsel for Defendant, Peter Russo, who indicated he has no objection relative to Petitioner's withdraw as counsel relative to this matter. WHEREFORE, Petitioner asks Your Honorable Court to grant his Petition and Order that he be permitted to withdraw as counsel in the subject matter. Respectfully submitted: By: Sanford A. Krevsky,tt-squire Krevsky & Rosen, P.C. 1101 North Front Street Harrisburg, PA 17102 ID# 15560 (717) 234-4583 DABIS CAMERO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VI. NO. 2006 CV 6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE AND NOW, this 17'' day of January, 2011, I, Aimee L. Paukovits, Legal Assistant for Kresvky & Rosen, P.C., attorneys for Plaintiff, DABIS CAMERO, hereby certify that I have this day served a copy of the Amended Motion in the above-captioned matter, by First Class U.S. Mail, on the following: DABIS CAMERO 511 ERFORD ROAD CAMP HILL, PA. 17011 J imee L. Pau ovits 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 JAN 062011 DABIS CAMERO IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VL NO. 2006 CV 6162 COLLEEN CAMERO CIVIL ACTION -LAW Defendant ORDER OF COURT AND NOW, this : day of :? AA O IWK -9201 , in consideration of the within PETITION FOR LEAVE TO WITHDRAW, it is HEREBY ORDERED AND DECREED that Sanford A. Krevsky, Esquire of Krevsky & Rosen, P.C. is hereby withdrawn from representing Plaintiff relative to the above-referenced matter. Distribution: Sanford A. Krevsky, Esquire, 1101 N. Front St., Harrisburg, PA 17102 d Dabis Camero, 511 Erford Rd., Camp Hill, PA 17011 W" Peter J. Russo, Esquire, 5116 East Trindle Rd., Suite 100, Mechanicsburg, PA 17050 d pblx? ?it ? 11a51 ply c") c n 3 --s V, c- Fn F - r- _> 71) C:3 C) _< Ln C? f.."D 01 y BY THE COURT, a DABIS CAMERO, Plaintiff V. COLEEN CAMERO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 CV 6162 CIVIL ACTION-LAW IN DIVORCE ORDER APPOINTING MASTER AND NOW, this day of , 2012, e. 77 Esquire is appointed master with respect to the following claims: 1 BY THE COURT: 9 i44. Distribution: Timothy Czekaj, Esquire, 315 N. Front Street, Harrisburg, PA 17101 Peter J. Russo, Esquire, 5006 East Trindle Road, # 100, Mechanicsburg, PA 17050 'E2 / w N 74 : -` cz: N) ?i;7 0 Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant IT., y, C' :S C0UNT kl'L,'t? JYLYANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff : No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, Defendant : CIVIL ACTION -LAW : IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate as Exhibit "A". (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. ICE OF P ER J. RUSSO, P.C. Peter--=. usso, E740M- Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Y f ( Attorneys for Defendant Date: t EXHIBIT "A" Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff : No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, Defendant : CIVIL ACTION -LAW : IN DIVORCE NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: ATTN: Linda McBeth Barrister Land Abstract Company 3310 Market Street Camp Hill, PA 17011 The Defendant, Colleen Camero, by and through her counsel, intends to serve a subpoena identical to the one that is attached to this notice. You have Twenty (20) Days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. ETER J. RUSSO, P.C. By(7a=ire Peter J. RusAttorne y I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant Date: U? a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER I hereby certify that I have on this day received a copy of the Subpoena to Produce Documents for Discovery pursuant to Rule 4009.22, Certificate of Compliance and Certificate Prerequisite to Service of a subpoena pursuant to Rule 4009.22 and hereby waive the twenty day (20) notice as I have no objections to this subpoena. Date: Timothy Czekaj, Esquire COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DABIS CAMERO Plaintiff . File No. 06-6162 CIVIL TERM vs. COLLEEN CAMERO Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Linda McBeth, Barrister Land Abstract Company, 3310 Market Street, Camp Hill, PA 17011 (Name of Person or Entity) , Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all checks issued in connection with the December 23, 2004 settlement of 980 Woodbridge Drive, Middletown, PA 17057; the Agreement of Sale for the subject property; any and all mortgages or notes held by the Sellers; a copy of the HUD for the subject property, and a copy of the photo ID secured during the notarization of Defendant's signature. at Law Offices of Peter J. Russo, P.C., 5006 East Trindle Road, Suite 100, Mechanicsburg, PA 17050 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Peter J. Russo, Esquire ADDRESS: tawOffices ofPeter J Russo.PC. 5006 East Tnndie Road, Suite I00 Mechanicsburg, PA 17050 TELEPHONE: 717.591.1755 SUPREME COURT ID # 72997 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court Deputy Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, . Plaintiff No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Certificate Prerequisite to Service of a subpoena pursuant to Rule 4009.22, upon the following person, in the manner indicated: Regular United States Mail to: Timothy Czekaj, Esquire 315 North Front Street Harrisburg, PA 17101 4 ? Date: erek . Strouphauer, gal Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant 21 P11 0 3 ERLAND COUNT`( "c "NS YLVA NIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff : No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, Defendant : CIVIL ACTION -LAW : IN DIVORCE NOTICE TO: ATTN: Linda McBeth Barrister Land Abstract Company 3310 Market Street Camp Hill, PA 17011 You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 ? "?4'/1 / , of Barrister Land Abstract Company, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on o? (date of subpoena) have been produced. Date: l5 ??' C? 4e: Title: p'j/i/v? 6 L /?, Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Email: prusso@pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedger@pjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717)-591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CAMERO, Defendant '~`1" i~j~ j ~t~TH~N~T~i"' .t ~~~~ Q(1~ 2$ ~~~ I1~ C~ "Ut~~~RtANO COUNTY ~~hNSYLVANlA No. Ob-6162 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached was mailed or delivered to each party at least twenty days prior to the date on the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to certificate as Exhibit "A", (3) no objection to the subpoena has been received, and opposing counsel has waived twenty (20) day notice requirement; a copy of the signed waiver is attached hereto Exhibit "B", and (4) the subpoena which will be served is identical to the subpoena which is attached the notice of intent to serve the subpoena. T FF TER J. R~JSSO, P.C. e Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Attorneys for Defendant Date: ~_ E~:HIBIT A Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, E~uire Attorney I.D. No. 72897 Email: prussoQa pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedget~Qpjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717)-591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CAMERO, Defendant No. 06-6162 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE The Defendant, Colleen Camero, by and through her counsel, intends to serve a identical to the one that is attached to this notice. You have Twenty (20) Days from the listed below in which to file of record and serve upon the undersigned an objection to subpoena. If no objection is made, the subpoena may be served. TH R J. RUSSO, P.C. By: Peter J. usso, Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Attorneys for Defendant Date: ~ ' f~c~ f ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DABIS CAMERO VS. File No. 06-6162 CIVIL TERM Plaimilr COLLEEN CAMERO Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Fulton Bank, Legal Department, ATTN: Steven R. Hord, Esquire, One Pam Square, I.anauaer, PA 17602 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to prodtnx the following documents or things: Any and all bank account statements and copies of any and all deposits and withdrawals for cash or checks, which include, but are not limited to, the following personal and business bank accounts held by Dabis Camera of S 11 Erford Road, Mechanicsburg, PA 17050 from January I, 2003 to the present date: 03622-22988 (excluding bank account statement from 01-27-2003 to 02-05-2003), 001371-3773, 3622-91881 (excluding bank account statement from 09-26-2006 to 10-25-2006). at Law Offices of Peter J. Russo, P.C., 5006 East Trindk Road, Suite 100, Mechanicsburg, PA 17050 (Address) You may deliver or mail legibk copies of the documents or produce things requested by this subpoena, toge~er with the certificate of compliance, to the petty making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the pally serving this subpoena may seek a court order compelling you to cornply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ~+~ ~• Rww. Esgrirc ADDRESS: ~...oiseeeorre~~.~.r.e. 5006 &rt True a0ed. Suite 100 MMdMipMra, M 17050 TELEPHONE: sir-s9i-~~ss SUPREME COURT ID # rtm ATTORNEY FOR: oe6eadru BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court ~PmY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, . Plaintiff No. 06-6162 CIVIL TERM vs. . COLLEEN CAMERO, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER I hereby certify that I have on this day received a copy of the Subpoena to Proc Documents for Discovery pursuant to Rule 4009.22, Certificate of Compliance and Certifi Prerequisite to Service of a subpoena pursuant to Rule 4009.22 and hereby waive the twenty (20) notice as I have no objections to this subpoena. Date: ~ ~~~/ 2 ~. ~~ . Timothy Czekaj, Esquire Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Email: prusso@pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedger@pjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717)-591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CAMERO, Defendant No. 06-6162 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Prerequisite to Service of a subpoena pursuant to Rule 4009.22, upon the following person, in manner indicated: Regular United States Mail to: Timothy Czekaj, Esquire 315 North Front Street Harrisburg, PA 17101 Date: ~ (a,~1 ~ l~ M. o. ~1- T}~~ p ~aN~` t~TA~y ~?0~2 AUG 2g A~ 11:22 cvMaFRL~NC covrrrY ~~NN$1'LVgNra 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717)-591-1756 Attorneys for Defendant Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Email: prusso@pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedger@pjrlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CAMERO, Defendant No. 06-6162 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA FURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached was mailed or delivered to each party at least twenty days prior to the date on the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to certificate as Exhibit "A", (3) no objection to the subpoena has been received, and opposing counsel has waived twenty (20) day notice requirement; a copy of the signed waiver is attached hereto Exhibit "B", and (4) the subpoena which will be served is identical to the subpoena which is attached is the notice of intent to serve the subpoena. IC~ PETER J. RUSSO, P.C. reier~usse-esquire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Attorneys for Defendant Date: ~}-~ 1 E~:HI~3IT A Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Email: prusso(a~pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedgerQpjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717591-1756 Attorneys for Defegclant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff vs. COLLEEN CAMERO, Defendant No. 06-6162 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE The Defendant, Colleen Camero, by and through her counsel, intends to serve a identical to the one that is attached to this notice. You have Twenty (20) Days from the listed below in which to file of record and serve upon the undersigned an objection to subpoena. If no objection is made, the subpoena may be served. TER J. RUSSO, P.C. By: Peter usso, uire Attorney I.D. No. 72897 Paul D. Edger, Esquire Attorney I.D. No. 312713 5006 E. Trindle Road, Suite i 00 Mechanicsburg, PA 17050 Telephone: (717591-1755 Attorneys for Defendant Date: /2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DABIS CAMERO Plaintiff File No.06-6162 CIVIL TERM V S. . COLLEEN CAMERO . Defendsnt SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 'I`~: MdcT Bank, ATTN: Legal Document Processing Department, 1100 Weivle Drive, WiOiatnsville, New York, 14221 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are orderod by the court to produce the following documents or things: Any and all bank account statements and copies of any and all deposits and withdrawals, including copies of checks, which include, but are not limited to, personal and business bank accounts held by Dabis Camera with a social security number ending in 4614 and an address of 511 Erford Road, Mechanicsburg, PA 17050 from January 1, 2003 to the present date. at Law Offices of Peter J. Russo, P.C., 5006 East Trindle Road, Suite 100, Mechanicsburg, PA 17050 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PaK ~. ~. tie ADDRESS: t... orr~. ~rt~ 1. ILww, r.c. 5006 t:W Trinit lto~d, soae 100 M~Irra-ur~, PA 17060 TELEPHONE: 717691-17ss SUPREME COURT ID # ~uv7 ATTORNEY FOR: oefan~m BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court Deputy E~:HIBIT B IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff No. Ob-6162 CIVIL TERM vs. . COLLEEN CAMERO, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER I hereby certify that I have on this day received a copy of the Subpoena to Documents for Discovery pursuant to Rule 4009.22, Certificate of Compliance and Prerequisite to Service of a subpoena pursuant to Rule 4009.22 and hereby waive the twenty (20) notice as I have no objections to this subpoena. Date: ~~~'l~ 2 Timothy Czekaj, squire - ~ -_t Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney I.D. No. 72897 Email: prusso@pjrlaw.com Paul D. Edger, Esquire Attorney I.D. No. 312713 Email: pedger@pjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717)-591-1755 Facsimile: (717)-591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, . Plaintiff No. 06-6162 CIVIL TERM vs. COLLEEN CAMERO, :CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Prerequisite to Service of a subpoena pursuant to Rule 4009.22, upon the following person, in manner indicated: Regular United States Mail to: Timothy Czekaj, Esquire 315 North Front Street Hamsburg, PA 17101 Date: $~~~ ~ I~ Law Offices of Peter J. Russo, P.C. By: Peter J. Russo, Esquire Attorney LD. No. 72897 Email: pn~sso a(~pjrlaw.com Paul D. Edger, Esquire Attorney l.ll. No. 312713 Email: pedger@pjrlaw.com 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (?l7)-591-1755 Facsicnile~: (7l7)-591-1756 Attorneys for Defendant ,.., ~,.. ,, f,~.~~ . ,~.}_' j~~~li S 1"'S r1 «._ f 7 r1 ''ti } r I1~ TIIE COURT OF COMMON PLEAS OF CUMDERLAND COUNTY, PEI'~'NSYLV A1ViA DABIS C'AMERO, - Plaintiff Flo. 06-6162 CIVIL TERM vs. COLLEEN CAMERO, :CIVIL AC'T'ION -LAW Defendant IN DIVORCE NOTICE TO: Fulton Bank Legal Department A"TTN: Steven R. Horst One Penn Square Lancaster, PA 17602 You are required to complete the following Certificate of Compliance when producing documents or thugs pursuant to the Subpoena. CEI2TIFIi;A'TE Ol' L®MI'LIAI'~tC1J '4~'ITIT SIJDT'OENA TO PRODI,rCE D~OC:I1dIENTS I, ~ ~,~_(l/~(,~(~ ~~(,~/~_, of Fulton Bank, certify to the best of my knowledge, information and belief that all dacume~ subpoena issued on. ~ ~JI ~ Date: ~ ~~~~ ~(~~a rts ar things required to be produced pursuant to the ` {date of subpoena) have been produced. ~~, ~/ ~~ ~ Marne: "Title: From.Ashley Malcolm Fax.+1(717)610-1639 To. Peter J.Russo Fax: +1(717)240.7890 Page 4 of 5 3P2812013 12:36 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C-) r- , DABIS CAMERO, a plaintiff No. 06-6162 CIVIL TERM rnw x• z ; • M VS. E COLLEEN CAMERO, : CIVIL ACTION -LAWS Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 1 _ Dater _24 Q - 1� ih � abis Came% Plamtr From.Ashley Malcolm Fax.+1(717)610-1639 To. Peter J.Russo Fax: +1 (717)240-7990 Page 5 of 5 3/2812013 12:36 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA W DABIS CAMERO, Plaintiff No. 06-6162 CIVIL TERMS --4 C:) ---r VS. -,o o COLLEEN CAMERO, : CIVIL ACTION -LAW ? ', Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER&3301(c)AND &3301(d)OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. r Date: J 2(?- 20/3 y abis Camero, Plaintiff From.Ashley Malcolm Fox.+1(717)610-1639 To: Peter J.Russo Fax: +1(717)240-7890 Page 2 of 5 312812013 12:36 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DABIS CAMIERO, Plaintiff No. 06-6162 CIVIL TERM CU 33P VS. C:) COLLEEN CAMERO, : CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. 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: Co1ILW&rnero, Defendant From.Ashley Malcolm Fax.+1(717)610-1639 To. Peter J.Russo Fax: +1(717)240-7890 Page 3 of 5 312812013 n IN THE COURT OF COMMON PLEAS OF cz CUMBERLAND COUNTY, PENNSYLVANIA -U:r DABIS CAMERO, Cr 7k) Plaintiff No.06-6162 CIVIL TERM -<> VS. COLLEEN CAMERO, : CIVIL ACTION -LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER I 3301(c)AND 4 3301(d)OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: _311.y ))* I f Coil t�Wer4j2gWdant DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 6162 CIVIL COLLEEN CAMERO, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 916-4 day of , 2013, counsel and the parties having entered into an agreement and stipulation resolving the economic issues on March 28, 2013, the date set for a four-party conference, the agreement and stipulation having been transcribed and signed by the parties, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent and waivers of the parties so that a final decree in divorce can be entered. BY THE COURT, K n A. Hess, P.J. CC: Timothy L. Czekaj �? Attorney for Plaintiff C- C= r' Z-, `--i Peter J. Russo M rn Attorney for Defendant N l..�l LL r . /'3 From:Ashley Malcolm Fax:+1 (717)610-1639'103 To: E.Robert Elicker,II Fax: +1(717)240-7890 Page 3 of 8 6119120134:34 DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 6162 CIVIL c -�3 COLLEEN CAMERO, rn ;_' Defendant IN DIVORCEr-� -<> •tr G �:.--r1 C"' :2-, THE MASTER: Today is Thursday, March 24 _. CD'`.,. cn 2013. This is the date set for a conference in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Dabis Camero, and his counsel Timothy L. Czekaj , and the Defendant, Colleen Camero, and her counsel Peter J. Russo. This action was commenced by the filing of a complaint in divorce on October 23, 2006, raising grounds for divorce of irretrievable breakdown of the marriage. The complaint also raised a count of indignities. With respect to the grounds for divorce, the parties are going to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree today. The affidavits and waivers will be filed with the Prothonotary' s office by the Master's office and the divorce will be able to conclude under Section 3301 (c) of the Domestic Relations code. The complaint also raised a claim for equitable distribution. Neither party has raised any claims 1 From:Ashley Malcolm Fax:+1 (717)610-1639'103 To.E.Robert Elicker,II Fax: +1(717)240-7890 Page 4 of 8 6119120134:34 q • for alimony or counsel fees and costs. The Master has been advised that the parties have, after considerable negotiations previously and today, reached an agreement with respect to the outstanding economic claim of equitable distribution. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties leave the hearing room today, they are bound by the terms of the agreement even though they have not subsequently signed the agreement affirming the terms of settlement. The agreement is going to be transcribed and sent to counsel for review for typographical errors; corrections will be made as necessary, and with the understanding that no substantive changes can be made; then the parties will be asked to sign the agreement affirming the terms of settlement as stated on the record. As noted, even though there is no signing, the parties are bound by the terms of the agreement when they leave the hearing room today. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe 2 From:Ashley Malcolm Fax:+1 (717)610-1639`103 To: E.Robert Elicker,II Fax: +1(717)240.7890 Page 5 of 8 6/19/2013 4:34 transmitting the record to the Court requesting a final decree in divorce. The parties were married on January 14, 2003, and separated October 23, 2006. They are the natural parents of two children. Both children are minors and primary custody is with wife and husband has partial custody with the children as agreed upon. Mr. Russo. MR. RUSSO: Thank you. 1. The parties have agreed that Dabis Camero shall pay onto Colleen Camero the sum of $28,500.00. This will constitute a complete distribution of all claims for marital assets and shall be paid as follows: Seven thousand six hundred dollars ($7, 600.00) shall be transferred to wife from husband's TIAA-CREF account by way of a QDRO provided by husband to wife. Husband shall provide this QDRO within sixty (60) days of today's date. Wife shall provide an account whereby the funds from the TIAA-CREF account of husband can be deposited. Additionally husband shall remit to wife $150.00 per month, each month, for the next five (5) years. Said payments shall begin May 1, 2013 , Further, husband shall provide to wife any federal tax refund he receives beginning with tax year 2012 through 2016. Finally, commencing in 2017, husband shall pay any balance remaining by providing wife his federal tax return refund or $1, 750.00, whichever is greater, in each tax year after 2017 until the balance is paid in full. 2. The parties agree that the terms of this agreement shall not be dischargeable in bankruptcy. 3. The parties further agree that they will execute a judgment note which documents the terms of this agreement as well as a mortgage which wife may file against husband' s real property located at 511 Erford Road, Camp Hill Pennsylvania 17011. 3 From:Ashley Malcolm Fax:+1 (717)610-1639 103 To: E.Robert Elicker,II Fax: +1(717)240-7890 Page 6 of 8 6119/20134:34 r The judgment note and the mortgage will be provided by wife's counsel and provided to husband's counsel for husband's signature. The mortgage and note will be signed by husband upon the documents being presented from wife' s counsel to husband's counsel, and upon signature by husband of the documents, the Master will be notified that he can then ask the Court to vacate his appointment and the parties can then file a praecipe transmitting the record requesting a final decree in divorce. 4. Husband agrees to secure the subordination of Luisa Benion's mortgage so that wife could be in a second lien position. Upon the payment in full of husband's $28, 500.00 obligation to wife, wife will satisfy the mortgage and mark the judgment note paid in full. 5. The parties further agree that all personal property has been distributed to their satisfaction. Those items in the possession of each party shall remain the sole and exclusive property of said party. 6. The parties acknowledge that neither have extended or opened any debt which is or can be imputed to the other from the date of separation until the date of this agreement. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow' s allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other' s estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. THE MASTER: Mr. Camero, you heard the agreement as stated on the record? MR. CAMERO: Yes, sir. 4 From;Ashley Malcolm Fax:+1 (717)610.1639 103 To: E.Robert Elicker,II Fax: +1(717)240-7890 Page 7 of 8 6119/20134:34 THE MASTER: You've been present while this statement has been made by Mr. Russo? MR. CAMERO: Correct. THE MASTER: Do you understand the agreement? MR. CAMERO: Yes, sir. THE MASTER: And are you satisfied that this agreement can be entered as of record, as a final agreement in resolving all claims in this divorce action? MR. CAMERO: Yes, sir. THE MASTER: And you understand that your counsel is going to get a transcribed copy and can review it for typographical errors, and then it will be presented to you for signature? MR. CAMERO: Yes, sir. THE MASTER: Mrs. Camero, do you understand the terms of this agreement? MS. CAMERO: Yes, sir. THE MASTER: You've been present during the statement of the agreement on the record? MS. CAMERO: Yes, sir. THE MASTER: You understand that the agreement is going to be presented to you, after your counsel has received it and any typographical corrections have been made, for signature? 5 From:Ashley Malcolm Fax: +1 (717)610.1639"103 To: E.Robert Elicker,II Fax: +1(717)240.7890 Page 8 of 8 6/19/2013 4:34 c MS, CAMERO: Yes, sir. THE MASTER: And are you satisfied that the agreement as stated concludes all matters in your divorce action? MS. CAMERO: Yes, sir. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations code. WITNESS: DATE: r r Timothy L. ekaj abis Camero Attorney `for Plaintiff Peter J. Russ 1 e Attorney for Defen 6 i DABIS CAMERO In the Court of Common Pleas of Cumberland County, Pennsylvania No.06-6162 Civil Term IN DIVORCE vs COLLEEN CAMERO r^ ,ter G) PRAECIPE To the Prothonotary: Please let the above-captioned docket reflect that I represent the Plaintiff, Dabis Camero, solely in regards to the divorce. I do not represent the Plaintiff in regards to the Custody matter at the same docket. David D. Buell, Prothonotary 20 Attorney Info: Timothy L. Czekaj,Esquire Attorne Plaintiff Czekaj Law Office 315 N Front Street Harrisburg,PA 17101 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW DABIS E. CAMERO, Plaintiff V. No. 06-6162 COLLEEN L. CAMERO, Defendant CD C3 CD Petition for Modification I. Petitioner is Plaintiff,DABIS E. CAMERO,who currently resides at 511 Erford Road,Camp Hill, Cumberland County,PA 17011. 2. Respondent is Defendant, COLLEEN L. CAMERO, who currently resides at 4085 Swatara Drive, Oberlin, Cumberland County,PA 17113. 3. Petitioner and Respondent are the natural parents of the following children: Name Age DABIS E. CAMERO-WELTZ, 11 9 years 11 months DANA E. CAMERO 8 years 4 months 4. A custody order was entered on 11/22/2006, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Petitioner seeks to modify the custody order because: It is in the best interest of our children Dabis E.Camero-Weltz and Dana E. Camera to have equal access to all parents, households and family settings. The children have the right as well as we do as parents to share equal time. They should have the opportunity to be enriched by accessing all that both sides of the family have to offer on a regular basis and not be limited to every other weekend from Friday evening to Monday morning(current time spent with father). Additional time should not be restricted to the parent with primary physical custody disposition at the time that is requested. The children are now 9 years 1.1 months and 8 years 4 months old respectively and have been consistently requesting to spend more time at father's home.Additional time should be provided, share and divided 50%-50%among both parties so that the best interest of the kids is served and they can continue to develop fully enriched by not being limited in their bonding,family, educational and leisure time with both parents/sides of the family.It is been 6 years and 8 Months since the last order came into effect(November 22,2006). 6. Petitioner believes the custody order should be changed as follows: Children should stay with each parent every other full week,Monday through Monday starting/finishing Monday 8:00 am if the kids are on school vacation time and/or Monday 4:00 pm during school time. During School time, when is the mother's turn to have the children,the children will arrive to her house via the school bus,and,when is the father's turn to have them,the children will be picked up by father or authorized adult. 7.Joint legal custody should remain in effect 50%- 50%decision capacity. WHEREFORE,Petitioner respectfully requests that this Court modify the Order as requested. Date: ABIS E. CAMERO,Plain x Verification I, DABIS E. CAMERO,Plaintiff,verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unsworn falsification to authorities. Date. DABIS E. CAMERO,Plaintiff - NOV 2120 DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO, 06-6162 CIVIL TERM V. CIVIL ACTION— LAW COLLEEN CAMERO, IN CUSTODY Defendant INTERIM ORDER OF COURT AND NOW, this K.42�' day of November, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as 1. The parties, Dabis Camero, and Colleen Camero, shall have shared legal custody of the minor children, Dabis Camero, born August 14, 2003 and Dana Camero, born April 9, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. All decisions affecting the children's growth and development including, but not limited to, choice of camp, if any; choice of child care provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the children directly or as a beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made with the parents jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the children's best interest, 2. Physical Custody. This Order confirms the status quo prior to the parties' separation. Mother shall have primary physical custody of the minor children as follows: A. Commencing at 5:00 p.m. on November 10, 2006, and continuing until 5:00 p.m. until Friday, November 17, Mother shall have custody of the children. NO. 06-6162 CIVIL TERM B. Commencing November 17, 2006, Father shall have custody each Friday at 5:00 p.m. until Sunday at 5:00 p.m. C, Commencing November 19, 2006, Mother shall have custody each week from Sunday at 5:00 p.m, until Friday at 5:00 p.m. D. The custodial schedule indicated in this paragraph is structured to maximize Fathers contact with the children during his non-work hours. Accordingly, it is expected that Father will be present throughout his periods of custody and that he will notify Mother if he is not able to participate in his periods of custody so that the children will not unnecessarily have to make a trip to Pennsylvania if Father will not be available. Nothing in this Order is contemplated to grant rights of partial custody to anyone other than the named parties in this matter. Following the 'hearing on the cross-petition for exclusive possession of the marital residence, if Mother is abi'e to relocateto central Pennsylvania, Father will have partial custody of the children from 4:30 p.m. until 7:30 p.m. each Wednesday. If this occurs, Father shall be responsible for all transportation incident to Wednesday periods of custody, 3. Transportation. The parent relinquishing custody of the children shall provide transportation incident to the custodial exchange. The parties will meet at their respective residences to affect the exchange. At exchanges, both parents shall establish a no-conflict zone for their children and refrain from making derogatory comments about the other parent in the presence or earshot of the children and, to the extent possible, shall prevent third parties from making such comments in the presence or earshot of the children. 4. The following holiday schedule supercedes the regular schedule: A. Thanksgiving 2007 " Mother will have custody until November 241h at 10:00 a.m., provided that Father is able to be off work on that day. In the event that he is not able to be off work to meet Mother at 10:00 a.m., Father's custodial period will commence at 5:00 p.m. as usual, unless the parties agree on an earlier exchange time. B. Christmas 2007— Father will have custody from December 24 th from 5:00 p.m. until December 26"' at noon. C. The 2007 holiday schedule above contemplates that this is an interim arrangement. Consideration to these holiday periods for 2007 will be factored into the appropriate holiday schedule in subsequent years, with a preference toward arranging for the children to be with the parent who did not have NO. 06-6162 CIVIL TERM i holiday custody in the previous year when subsequent year holiday schedules are determined by the Court of further agreement of the parties. 5. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. For a period of twelve hours before and continuing throughout any period of supervised visitation or partial custody with the minor child, the parties shall consume no alcoholic beverages nor possess or use non-prescribed controlled substances whatsoever. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. ` 7. The children shall not be exposed to second-hand smoke in vehicles or in- door confined spaces. i 8. The children shall be withdrawn from the daycare center in which Father enrolled them earlier this month, at the Pennsylvania State University. 9. The children shall not leave the United States in the absence of an agreement of the parties or further Order of this Court. 10. The Cumberland County Court of Common Pleas shall retain jurisdiction of this matter-. 11. Custody Evaluation. The parties shall submit themselves and their minor children to an independent custody evaluation to be performed by Dr. Casey Sheinvold. The parties shall sign all necessary releases and authorizations for the evaluator to obtain medical and psychological information pertaining to the parties. Additionally, the parties shall extend their full cooperation in completing this evaluation in a timely fashion and in the scheduling of appointments. Each party shall be entitled to petition the Court to allocate the cost or otherwise determine the financial responsibility for this evaluation. 12. Each party's right to be heard with regard the custodial arrangement which would serve the best interest of the children is hereby reserved without prejudice and without regard to the recommendation of the Interim Order. NO. 06-6162 CIVIL TERM 13. A hearing is sVeduled in Courtroom Number of the Cumberland County Courthouse, on the day of ac– 2—ooy 7at o'clock ru-arLl/ _L.M., at which time testimony will be taken. For e purposes of the hearing, the Mother, Colleen Camero, shall be deemed to be the mov g party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsellparty a memorandum setting forth each party's position on custody, a list of exhibits, a list of witnesses who are expected to testify at the hearing, and I a summary of the anticipated testimony of each witness. These memoranda, lists of exhibits, lists of witnesses and summaries of,anticipated testimony of each witness shall be filed at least twenty days prior to the hearing date. BY THE COURT* "AIN Dist: Daniel J.Regan,Jr..Esquire, 1300 Market St.,Ste i, Lemoyne,PA 17043 Scott A.Stein, Esquire,3800 Market Street,Camp Hill,PA 17011 RECORD TRUE Ct�%n FP-,eN-, RD In Testimon. s set my hand gam��an e seaL, Pa. ho roio P ry COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION c') �, DABIS E. CAMERO, ) mr" � .-1 , Plaintiff ) V. ) No. 06-6162 -<> cn COLLEEN L. CAMERO, ) _� Defendant ) CO Certificate Of Service I, DABIS E. CAMERO, Plaintiff in the above matter, hereby certify that on n�G-- -01S, I mailed a true and correct copy of the Petition for Modification, by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: PETER J. RUSSO (Presumable Attorney of Colleen Camero) 5006 E Trindle Road Mechanicsburg, PA 17050 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The rg een recipient's receipt is attached; COLLEEN L. CAMERO signed the certified mail receipt on (ATTACH receipt.) [ ] The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: [ ] The regular mail has not been returned to me. [ ] The regular mail was returned to me, with the notation: I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Date: —igmature) DAB STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: Postal CERTIFIED MAILT. RECEIPT m (Domestic Mail Only;No Insurance Coverage Provided) For dellvery Information visit our website at www.usps.como ti ru i; t � 14L USE 1-13.66 0112 r%- Postage $ r` $3.10 1.2 Certified Fee Return Receipt Fee $2.55 Q (Endorsement Required) �C� Gj ti� C3 Restricted Delivery Fee $0.00 a A (Endorsement Required) D Ln 56 08 2/20P Co C3 Totat Postage&Fees $ .31 ++ v� � ru � Sent To b`fieef,it pt%JO.; J v P or PO Box No. J e � (/ ....................................... PS Form 3800,August ,,. See Reverse for Instructions f!tO For tracking or inquiries go to U;PS.nom or cal l 1-WjJ-222-1811. ):A t'XXro;XXXxY:%Xxx kX XX X:tXXXxat'xxxXxX xX xY'xxXX ):'Y.'RX)tt:XXi:xY:xXX7tXx KXY::tXXXXX'xXk XXXx)t X:t'xxxX BR[GH"EN SOMEONE'S MAILBOX. 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Sign up for Return Rcpt (Green Card) $2.55: a box online at usps.com/poboxes. U Certified $3.10 - ):tXXZxzxXZxxzxxzXxz�::tzxzz XZZZxxzxXXxxxX Label #f: 71123050000177422124 );Y:kxxxxX*xxxxxxxx KxY::lxxxx kxXxxxxxxxX'xxxX Customer Postage -$0.46 Issue PVI: $5,85 Bill1i: 1000601931065 clerk: 12 1tECHANICSBURG PA 17050 Zorie-1 $0.66 First-Vass Mail Letter All s0 es final on stamps and postage 1.60 oz. Refunds for guaranteed services only Schedulers Delivery Day: Sat 08/03/1.3 Thank you for your business Return Rcpt (Grean Card) $2.55 :li'kY('kXYf XkXY:%XX%:X'XKx'K:ty;7KX%C:1'X7iY;YfY(XkxYi%'xYtXit' 00 Certified $3.10 :xktYY;xxxYCXrxzvztrkzY:trXZxkxYZZYZZxzYxXZ>r Labe i #: 70123050000177422131 HELP US SERVE YOU BETTER Issue PVI:PVI: W$6.31- Go to: htips://postalexperience.com/Pos HARRISBURG PA 17113 2'one-1. $0.66 TELL US .ABOUT YOUR RECENT First-Vass Mail Letter POSTAL EXPERIENCE 1.50 oz. Scheduled Delivery Day: Sat 08/03/13 YOUR OPINION COUNTS )::t•X'XY.'):XX'kXY;XXx:kXxkXY:;tXxxxK'xX kXXXxXXA,'xXXX 18suo PVI: «.-$0.66 ):X-.tXX+:K*xYCx7kX:t'tY:XkX'Y.:kXkYCx�'X)YxxXfcXJCx%'xxXX MECHANICSBURG PA 17050 Zone-1 $0.66 Firs#-C1es5 Mail I-eater Customer Copy 1.50 oz. Scheduled Delivery Day: eat 08/03/13 =====Z== Issue PVI: $0 66 o.tal . $13.48 Paid by: MasterCard $13.48 Account #: XXXXXXXXXXXX1537 Approval #: B26516 Transaction : 343 23 903160612 815113 Gmait-Request of No Trespass A'{ Request of No Trespass Dabis Camero <dabiscamero @gmail.com> Sun, Aug 4, 2013 at 11:43 AM To: Jamie Zimmerman <himes5o@gmail.com>, Colleen Camero <colleenbirdie @gmail.com> Cc: Peter Russo <prusso @pjdaw.com>, Alexandra Carrasco <carrascolaw@gmail.com> Good Morning Jamie and Colleen, We have received your email dated 8-3-2013. The following needs to be clarified: 1. 1 don't know where this "Harassment" allegation is coming from and much less why Ms. Carrasco or me are being mentioned or included in such a false allegation/statement. 2. 1 am guessing that you are making such injurious statements due to the fact that 1, as Biological Father and in exercise my paternal and civil right and in attention to my children's request and feasibility presented a request to modify the current custody order on August 2, 2013 at the Cumberland County Court House (a copy of this time stamped document has been sent to Colleen and to Peter Russo as he still appears as her legal counselor at the court house). This is a legal right of my children and I not as you stated: "Harassment". 3. Dabis E. Camero-Weitz II and Dana E. Camera are the biological children of Colleen Camero and Dabis E. Camero-Alzate. Custody matters shall be discussed in front of Custody Conciliator with Mrs. Colleen Camero. Not with you and/or much less in front of our children. I am kindly asking both of you to refrain from making comments and having conversations in regards to this matter in front of the children. 4. In regards to: "you are no longer allowed on the property residing at 4085 Swatara Dr. Oberlin, PA 17113". We can comply with your request to pick up and drop off my children (Dabis 11 and Dana) at the Target Store Main Entrance located at: 4600 High Pointe Blvd Harrisburg while school calendar year start and when on school breaks. During school schedule I can pick them up from Target and they will be dropped off at school Monday morning as we have been continuously for about a year now either by Ms. Alexandra Carrasco or me. When it comes to this coming Monday, August 5, 2013 both children will come with me for our appointment in Doctors Roman's office at 9:15 am as previously scheduled. Per your request, I am kindly asking you to make arrangements for Dana E. Camero while we (Dabis E. Camero-Weitz 11, Mrs. Colleen Camero and Dabis E. Camero- Alzate) attend the appointment. The other Mondays, until school start the children can be dropped off by me (DAD) at Target Mondays mornings. 5. In regards to Tuesday and Thursday schedule for Kung-Fu Classes which are in the best interest of Dabis_11, Alexandra will continue to transport him as she has been doing to the majority of the classes; however on the same arrangements at the Target Store Main Entrance located at: 4600 High Pointe Blvd Harrisburg at 4:40 pm to pick up and 6:15 pm to drop off. 6. We (Colleen, Jaime and Dabis) had already agreed friendly and kindly to have a join htkps:l/mail.goog le.com/mail/u101?ui=2&ilrba2c47a6f8&\iew=pt&search=sent&msg=14049ff29ee9b604&dsgt--1 112 8/5/13 Gnmil-Request of No Trespass birthday party for Dabis-11 on August 10, 2013 at 3 pm at 4085 Swatara Dr. Oberlin, PA 17113. Dabis-11 is obviously looking forward to this special day. I am asking you to take Dabis-11 feelings into consideration and know that it will be in his best interest to continue with the plans as previously agreed upon. Let me know at your earliest convenience if you are agreeable to this. 7. This doesn't have to be a contest procedure and the goal is to reach an agreement that will benefit the children. 8. In regards to points: 4, 5 and 6 we are kindly asking you to reconsider if your position is in the best interest of the children. Let me know at your earliest convenience. Sincerely, Dabis Camero CC: Colleen Camero, Peter Russo, Alexandra Carrasco On Sat, Aug 3, 2013 at 7:55 PM, Jamie Zimmerman <h1mes50@gmail.com> wrote: Mr. Camero and Miss Carrasco, This is a request of No Trespass. This is requested per Carol A Zimmerman. Reason behind the request: Harassment Per the request you are no longer allowed on the property residing at 4085 Swatara Dr. Oberlin, PA 17113. Due to this notice, pick up and drop will need to made at a neutral location. If the request is not followed the request will be forwarded to the Swatara Township Police Department to be formalized, Regards, Jamie S Zimmerman son of Carol A Zimmerman https://niail.google.coriVrnail/u/0/?ui=2&ik--ba2c47a6f8&\Aevv=pt&search=sent&nisg=14049ff29ee9b6O4&dsqt=1 212 815113 GmaiI-Returning the children today,Sunday August 4th,2013 at 5:00pm r� K v_ 4__1111 _ Returning the children today, Sunday August 4th, 2013 at 5:00pm Dabis Camero <dabiscamero @gmail.com> Sun, Aug 4, 2013 at 11:56 AM To: Colleen Camero <colleenbirdie @gmail.com> Cc: Peter Russo <prusso @pjdaw.com>, Jamie Zimmerman <himes50 @gmaiLcom>, Alexandra Carrasco <carrascolaw @gmail.com> This is not a problem. We'll be there. Regards, -- Dabis Camero On Sun, Aug 4, 2013 at 11:31 AM, Colleen Camera <colleenbirdie@gmail.com> wrote: Dabis, Per our current custody order, I will meet you today, Sunday, August 4th, 2013, at The Capital Diner on Eisenhower Blvd. at 5:00pm to exchange the children. Failure to do so will result in a breach of the custody agreement, and I will notify my attorney. Colleen h tps:llmail.google.corNmaillu 101?ui=2&ik=ba2c,47a6f8Wew=pt&search=sent&msg=1404aOaf2c062c4a&dsqt=l 111 8/5113 Gmail-WednesdaW Current Custody Order Visits With the Children r Wednesdays Current Custody Order Visits With the Children Dabis Camero <dabiscamero @gmail.com> Sun, Aug 4, 2013 at 5:50 PM To: Colleen Camero <colleenbirdie @gmail.com> Cc: Jamie Zmmerman <himes50 @gmail.com>, Alexandra Carrasco <carrascolaw @gmail.com>, Peter Russo <prusso @pjrlaw.com> Colleen, Per our current custody order, I will meet you every Wednesday at 4:30 pm to pick up Dabis_ll and Dana and for drop off at 7:30 pm at The Capital Diner on Eisenhower Blvd. Failure to do so will result in a breach of the custody agreement, and I will notify the authorities and your attorney. Sincerely, Dabis Camero https://maiI.g oog le.cortVmai I/u/0/?ui=2&i k=ba2c47a6f8&\iew---pt&search=sent&th=1404b4f64f7bl edc 1/1 815113 Gmail-Continuing Dabis_II Kung Fu practice and transportation 4 Continuing Dabis_II Kung Fu practice and transportation _._. ._..__ .....__. _._.......__.....___..... .._, _- Dabis Camero <dabiscamero @gmail_com> Mon, Aug 5, 2013 at 11:30 AM To: Colleen Camero <colleenbirdie @gmail.com> Cc: Peter Russo <prusso@pjriaw.com>, Alexandra Carrasco <carrascolaw @gmail.com>, Jamie Zimmerman <himes50 @gmail.com> Colleen, In regards to Tuesdays and Thursdays schedule for Dabis_li's Kung-Fu Classes (5.00 pm through 6:00 pm)which are in the best interest of Dabis_I!, Alexandra is willing to continue transporting him as she has been doing to the majority of the classes. Based on our latest arrangements (via email in the past two days), Alexandra can meet you at The Capitol Diner on 800 Eisenhower Blvd Harrisburg PA 17111 at 4:40 pm and then return Dabis II meeting you at the same place at 6:15 pm. Please let me know at your earliest convenience what arrangements will be made. This Martial Art and Sport practice is in the best interest of our son. Kind Regards and looking forward to hearing from you, Dabis Camero CC: Peter Russo, Alexandra Carrasco, Jamie Zimmerman. https:Himit.google.conV mail/u`0/?ui=2&ik=ba2c47a6f8&\iev,=pt&search=sent&th=1404fla3O85afO25 111 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA., CIVIL DIVISION C_— -a a ZZ ; DABIS E. CAMERO, Plaintiff , V. u) No. 06-6162 r<• --r ^7 COLLEEN L. CAMERO, �' Defendant 5;c= =a N) Certificate Of Service 1, DABIS E. AMERO, Plaintiff in the above matter, hereby certify that on mailed a true and correct copy of the Petition for Modification, b certified mail, return receipt requested,restricted delivery, and another copy of the same document by first class mail,postage prepaid, to: COLLEEN L. CAMERO 4085 Swatara Drive Oberlin, PA 17113 I certify that(check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The gree n recipient's receipt is attached; COLLEEN L. CAMERO signed the certified mail receipt on (ATTACH receipt.) [ ] The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: [ ] The regular mail has not been returned to me. [ ] The regular mail was returned to me, with the notation: f . y I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4944, relating to unsworn falsification to authorities. Date: "'�------ Signature) DABIS E. CAMERO r STAPLE OR TAPE THE CERTIFIES! MAIL RECEIPTS BELOW: U.S. Postal Service'r. CERTIFIED y RECEIPT ru (Domestic Mail Only;No Insurance Coverage Provided) For delivery information visit our website at www.usps.comg (•u U �� t 11� U3 r`- Postage $ r- Certified Fee $3.10 i2�r READ tmark C ©� Retum Receipt Fee $2.55 "Q (Endorsement Required) Restricted Delivery Fee . w Q (Endorsement Required) .4 � �C Ln I C3 Total Postage&Fees $ 2013 IM FACIL�� ru To e Sent �f yen r� Q Street,Apt.No.; -° --- ----------- . � - lr or PO Sax No. (/O V ✓ - -- -° ...._ . City,State,.Z1P+4 ��� r 60W For• trucking or inquiries go to US .i om or call 1-.8ijJ-2221811. ):/,K'kx7[XK*xxXXXXXXkx'K:txxXx KZZZxxXxxXX'xxxX' . ):X'K**xXk**Xxx*itXX K7C X:txXXxx'xX*XxXkXXx'xxxX BR;IGH'.EN SOMEONE'S MAILBOX. Greeting cards availabier for purchase at select Post Offices. :x•xXxxXxxXxxXXXx*xxX:t*xzxkzxzXZx*XXxzxxr IM ����'����,_� ':X•kxzxxxxzxXxxzxxXZZXxxzz"'*zzzxXZXxX*zXx GUS YATRON MAIL FACILITY Reading, Pennsylvania 196129992 ..n a hurry? Self-service kiosks offer 4144060/12 -0094 quick and easy check-out. Any Retail 08/02/2013 (610)921-7068 04:14:01 PM Associate can show you how. „ mmnn� ��� Order stamps at usps.com/shop or call Product Sales Receipt Sale Unit Final ::800-Sta:mp24. Go to usps.com/clicknship description Oty Price Price :o print shipping labels with postage. For ------------ —_____-. __ other information call 1-800-ASK-USPS. HARRISBURG PA '17113 Zone-1 $0.66 x'KXXxxzxxxxX*xzXkwXXXxxxxXxzzxx*xzxxxzX FirSt•-Class Mail Letter ):x:tx Xxxx*xY:XxXxxX kXX:tXXxX*'xX xXxx xXxX'XxXX 1.60 oz, Get your mail when and where you want it Scheduled Delivery Day: Sat 08/03/13 with a secure Post Office Box. Sign up for Return Rcpt (Green Card) $2.55. a box online at Usps.com/poboxes. @4 Certified $3.10 - ):xXxxxxxXxxxxxxxxXxx*xx*xxxxxxxxxxxxxxXx Label #: 70123050000177422124 :Xxxxxxx*xXxzxXxz'kzXXxxzzkxxxxxxzxxxzxxz Customer Postage -$0.46 - - El i I 1#: 1000601931065 Issue PVI: $5.85 (;Ierk: 12 MECHANICSBURG PA 17050 Zone-1 $0..66 First--Class Mail Letter All Sales final on stamps and postage 1.60 oz. Refunds for guaranteed services only Scheduled Delivery Day: Sat 08/03/1.3 Thank you for your business Return Rcpt (Green Card) $2.55 >:XxxxxxXXxXxxXXxXkxxxXZxz*xx*xxzxxxx*xxx $4 Certified $3.10 ''X*zxxxzzzxxxXxxX'kXXXXXxXx'XxxxxxxXZX*xxX Label #: 70123050000177422131 HELP US SERVE YOU BETTER Issue PV'I: $631 Go to: https://Postalexperience.com/Pos HARRISBURG PA 17113 gone-1 $0.166 TELL US ABOUT YOUR RECENT Hl-st--Clatss Mail Letter POSTAL EXPERIENCE 1.50 oz. Scheduled Delivery Day: Sat 08/03/13 YOUR OPINION COUNTS :Xxxxxxx*xr:xxXxx*xXX*YCZxxXZxxXXXZ*xX;xxxX ISSUE' PVT: - $066 :X"kkxxxkxXx*xxxxx'xxX:txxXX*xxxXxxxXXxxXXX MECHANICSBURG PA 17050 Zone-1 $0.66 First--Class Mail Letter Customer Copy 1.50 oz. Scheduled Delivery Day: Sat 08/03/13 Issue PVT: $0.66 "otal: $13.48 i)ai d by: flasterCard $13.48 Account #: XXXXXXXXXXXX1537 Approval #: B26516 Transaction #: 343 23 903160612 8/5/13 Gmail-Request of No Trespass Request of No Trespass Dabis Camero <dabiscamero @gmail.com> Sun, Aug 4, 2013 at 11:43 AM To: Jamie Zimmerman <himes50 @gmail.com>, Colleen Camero <colleenbirdie @gmail.com> Cc: Peter Russo <prusso @pjrlaw.com>, Alexandra Carrasco <carrascolaw @gmail.com> Good Morning Jamie and Colleen, We have received your email dated 8-3-2013. The following needs to be clarified: 1. 1 don't know where this "Harassment" allegation is coming from and much less why Ms. Carrasco or me are being mentioned or included in such a false allegation/statement. 2. 1 am guessing that you are making such injurious statements due to the fact that 1, as Biological Father and in exercise my paternal and civil right and in attention to my children's request and feasibility presented a request to modify the current custody order on August 2, 2013 at the Cumberland County Court House (a copy of this time stamped document has been sent to Colleen and to Peter Russo as he still appears as her legal counselor at the court house). This is a legal right of my children and I not as you stated: "Harassment". 3. Dabis E. Camero-Weitz II and Dana E. Camero are the biological children of Colleen Camero and Dabis E. Camero-Alzate. Custody matters shall be discussed in front of Custody Conciliator with Mrs. Colleen Camero. Not with you and/or much less in front of our children. I am kindly asking both of you to refrain from making comments and having conversations in regards to this matter in front of the children. 4. In regards to: "you are no longer allowed on the property residing at 4085 Swatara Dr. Oberlin, PA 17113". We can comply with your request to pick up and drop off my children (Dabis ll and Dana) at the Target Store Main Entrance located at: 4600 High Pointe Blvd Harrisburg while school calendar year start and when on school breaks. During school schedule I can pick them up from Target and they will be dropped off at school Monday morning as we have been continuously for about a year now either by Ms. Alexandra Carrasco or me. When it comes to this coming Monday, August 5, 2013 both children will come with me for our appointment in Doctors Roman's office at 9:15 am as previously scheduled. Per your request, I am kindly asking you to make arrangements for Dana E. Camero while we (Dabis E. Camero-Weitz II, Mrs. Colleen Camero and Dabis E. Camero- Alzate) attend the appointment. The other Mondays, until school start the children can be dropped off by me (DAD) at Target Mondays mornings. 5. In regards to Tuesday and Thursday schedule for Kung-Fu Classes which are in the best interest of Dabis_11, Alexandra will continue to transport him as she has been doing to the majority of the classes; however on the same arrangements at the Target Store Main Entrance located at: 4600 High Pointe Blvd Harrisburg at 4:40 pm to pick up and 6:15 pm to drop off. 6. We (Colleen, Jaime and Dabis) had already agreed friendly and kindly to have a join https://mai I.g oog le.conVmai I/u/0/?ui=2&i Ir ba2c47a6f8&\A ew--pt&search=sent&msg=14049ff29ee9b604&dsq t=1 1/2 AI 8/5/13 Gmai I-R eq uest of No Trespass birthday party for Dabis-11 on August 10, 2013 at 3 pm at 4085 Swatara Dr. Oberlin, PA 17113. Dabis-11 is obviously looking forward to this special day. I am asking you to take Dabis-11 feelings into consideration and know that it will be in his best interest to continue with the plans as previously agreed upon. Let me know at your earliest convenience if you are agreeable to this. 7. This doesn't have to be a contest procedure and the goal is to reach an agreement that will benefit the children. 8. In regards to points: 4, 5 and 6 we are kindly asking you to reconsider if your position is in the best interest of the children. Let me know at your earliest convenience. Sincerely, Dabis Camero CC: Colleen Camero, Peter Russo, Alexandra Carrasco On Sat, Aug 3, 2013 at 7:55 PM, Jamie Zimmerman <himes50@gmaiI.com> wrote: Mr. Camero and Miss Carrasco, This is a request of No Trespass. This is requested per Carol A Zimmerman. Reason behind the request: Harassment Per the request you are no longer allowed on the property residing at 4085 Swatara Dr. Oberlin, PA 17113. Due to this notice, pick up and drop will need to made at a neutral location. If the request is not followed the request will be forwarded to the Swatara Township Police Department to be formalized. Regards, Jamie S Zimmerman son of Carol A Zimmerman 1,.ttps://mail.google,corn/niail/U/0"`/?ui=2&jk--ba2r-47a6f8&,.iew--pt&seareh=sent&nisg=14049ff29ee9b6O4&dsqt=l 2/2 8/5113 Gmail-Returning the children today,Sunday August 4th,2013 at 5:00prn Returning the children today, Sunday August 4th, 2013 at 5:00prn Dabis Camero <dabiscamero@gmail.com> Sun, Aug 4, 2013 at 11:56 AM To: Colleen Camero <colleenbirdie@gmail.com> Cc: Peter Russo <prusso@pjdaw.com>, Jamie Zimmerman <himes50@gmail.com>, Alexandra Carrasco <carrascolaw@gmail.com> This is not a problem. We'll be there. Regards, - Dabis Camero On Sun, Aug 4, 2013 at 11:31 AM, Colleen Camero <colleenbirdie@gmail.com> wrote: Dabis, Per our current custody order, I will meet you today, Sunday, August 4th, 2013, at The Capital Diner on Eisenhower Bl\(d. at 5:00prn to exchange the children. Failure to do so will result in a breach of the custody agreement, and I will notify my attorney. Colleen littps:l/ryia'il.google.con-i/mil/u/0���/?ui=2&ik-ba2c47a6f8&NAev,-pt&search=sent&msg=1404aOaf2cO62c4a&dsqt=I M ------- 815113 GmaiI-Wednesdays Current Custody Order Visits With the Children AU Wednesdays Current Custody Order Visits With the Children Dabis Camero <dabiscamero @gmail.com> Sun, Aug 4, 2013 at 5:50 PM To: Colleen Camero <colleenbirdie @gmail.com> Cc: Jamie Zimmerman <himes50 @gmail.com>, Alexandra Carrasco <carrascolaw @gmail.com>, Peter Russo <prusso @pjdaw.com> Colleen, Per our current custody order, I will meet you every Wednesday at 4:30 pm to pick up Dabis_II and Dana and for drop off at 7:30 pm at The Capital Diner on Eisenhower Blvd. Failure to do so will result in a breach of the custody agreement, and I will notify the authorities and your attorney. Sincerely, - Dabis Camero https://mail.g oog le.com/mai I/u/0/?ui=2&i Irba2c47a6f8&view=pt&search=sent&th=1404b4f64f7bledc 1/1 8!5/13 Gmail-Continuing Dabis-11 Kung Fu practice and transportation Continuing Dabis-11 Kung Fu practice and transportation Dabis Camero <dabiscamero @gmail.com> Mon, Aug 5, 2013 at 11:30 AM To: Colleen Camero <colleenbirdie @gmail.com> Cc: Peter Russo <prusso @pjrlaw.com>, Alexandra Carrasco <carrascolaw @gmail.com>, Jamie Zimmerman <himes50 @gmaii.com> Colleen, In regards to Tuesdays and Thursdays schedule for Dabis_II's Kung-Fu Classes (5:00 pm through 6:00 pm)which are in the best interest of Dabis-11, Alexandra is willing to continue transporting him as she has been doing to the majority of the classes. Based on our latest arrangements (via email in the past two days), Alexandra can meet you at The Capitol Diner on 800 Eisenhower Blvd Harrisburg PA 17111 at 4:40 pm and then return Dabis-11 meeting you at the same place at 6:15 pm. Please let me know at your earliest convenience what arrangements will be made. This Martial Art and Sport practice is in the best interest of our son. Kind Regards and looking forward to hearing from you, Dabis Camero CC: Peter Russo, Alexandra Carrasco, Jamie Zimmerman. https://mail.goog le.corn/mai I/u/0/?ui=2&ik-ba2c47a6f8&\iev�r-pt&search=sent&th=1404fla3O85afO25 1/1 DABIS E.CAMERO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA !E2 V. 2006-6162 CIVIL ACTION LAW r l0 COLLEEN L.CAMERO IN CUSTODY C DEFENDANT ' CD ORDER OF COURT AND NOW, Wednesday,August 07,2013 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M.Verney,Esq.,the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle - on Tuesday,September 17,2013 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ _&gguefine M. Verney,Es Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 ces 17b I LSL 32 South Bedford Street Carlisle, Pennsylvania 17013 0-la no Telephone (717) 249-3166 b rw C . QAMXO-6 �l ��3 DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI �A C= C= i -0:K V. fTt SM COLLEEN L. CAMERO, NO. 2006-6162 CIVIL ACTION LAW C) ' , Defendant IN CUSTODY ORDER OF COURT AND NOW,this Z. 0 -day of SticA,-w— 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I The prior Order of Court dated November 22, 2006 is hereby vacated. 2. The Father, Dabis E. Camero and the Mother, Colleen L. Camero, shall have shared legal custody of Dabis E. Camero-Waltz, 11, born August 14, 2003 and Dana E. Camero, born April 9, 2005. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 3. Mother shall have primary physical custody of the children. 4. During the school year, Father shall have periods of partial physical custody on alternating weekends, from Friday at 5:00 p.m. to Tuesday morning when he shall transport the children to school. Father shall also transport the children to school on Monday when he has physical custody. 5. During the summer,the parents shall share physical custody on a week on/week off schedule from Monday to Monday at 8:00 a.m. Father's week shall begin on the first Monday after school recesses. 6. The parties shall share holiday periods equally as agreed, except that Mother shall have physical custody on Mother's Day and Father shall have physical custody on Father's Day. 7. Father shall be responsible for all transportation. 8. The parties shall have liberal telephone contact with the children. 9. Neither party shall do nor permit a third party to do, or say anything that would estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 10. RELOCATION: No party shall be permitted to relocate the residence of the children which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the children consents to the proposed relocation or the court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C. S. § 5337. 11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: isab E. Camero, pro se 511 Erford Road amp Hill, PA 17011 Colleen L. Camero,pro se 4085 Swatara Drive Oberlin,PA 17113 li s 4' ors/i3 DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. COLLEEN L. CAMERO, NO. 2006-6162 CIVIL ACTION - LAW Defendant IN CUSTODY PRIOR JUDGE: Kevin A. Hess,P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8,the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Dabis E. Camero-Waltz, 11 August 14, 2003 Mother Dana E. Camero April 9, 2005 Mother 2. A Conciliation Conference was held in this matter on September 17, 2013, with the following in attendance: The Father, Dabis E. Camero, pro se and Mother, Colleen L. Camero, pro se. 3. The Honorable Kevin A. Hess entered an Order of Court dated November 22, 2006 providing for shared legal custody, Mother having primary physical custody and Father having alternating weekends, Friday to Sunday. 4. The parties agreed to an Order in the form as attached. Date: 7-1.3 /Ja eline M. Verney, Esquire Custody Conciliator O Law Offices of Peter J. Russo, P.C. Peter J. Russo, Esquire G I'JA Supreme Court ID: 72897 ho II: G Email: prusso@pjrlaw.com ��� ,- RSA"'o COUNT p @pj Paul D. Edger, Esquire YLV C,�O J Supreme Court ID: 312713 Email: pedger @pjrlaw.com 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, •• Plaintiff : No. 06-6162 CIVIL TERM vs. COLLEEN CAMERO, : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION TO COMPEL The Defendant, Colleen Camero, by and through her attorney, Peter J. Russo, Esquire, and the Law Offices of Peter J. Russo, P.C. (hereinafter "Counsel for Defendant"), files this Motion to Compel, and in support thereof, represents the following: 1. On March 28, 2013, a conference was held before Divorce Master Elicker at which time both the Plaintiff and Defendant came to an amicable agreement to end the outstanding issues regarding equitable distribution of the parties' assets. 2. On or around April 4, 2013, Counsel for Defendant received, via regular U.S. mail, a copy of the March 28, 2013 Agreement (hereinafter "Agreement") for each of the parties to execute. 3. Plaintiff executed the Agreement on April 12, 2013, and Defendant executed the Agreement on June 6, 2013. A true and correct copy of the March 28, 2013 Agreement is attached hereto as Exhibit "A." 4. Per the Agreement, Plaintiff was to pay Defendant the sum of Twenty-Eight Thousand Five Hundred and 00/100 ($28,500.00) Dollars, which was to be distributed as follows: a. Seven Thousand Six Hundred and 00/100 ($7,600.00) Dollars to be transferred from Plaintiffs TIAA-CREF account via the execution of a Qualified Domestic Relations Order (QDRO) (which was to have been provided by Counsel for Plaintiff within Sixty(60) Days from the date of the Agreement); b. One Hundred Fifty and 00/100 ($150.00) Dollars to be paid per month, each month, by Plaintiff, for the next five (5) years, with payments beginning on May 1, 2013; c. Plaintiff was to provide Defendant with any federal income tax refunds he received beginning with tax year 2012 and ending in tax year 2016; d. Finally, commencing in 2017, Plaintiff was to pay any balance remaining by providing Defendant with his federal income tax refund or One Thousand Seven Hundred Fifty and 00/100 ($1,750.00) Dollars, whichever is greater, in each tax year after 2017 until the balance is paid in full. 4. To document the terms of the Agreement, Plaintiff was to execute a Judgment Note and Mortgage, which was to be drafted and provided by Counsel for Defendant. 5. Counsel for Defendant provided Counsel for Plaintiff a copy of the Judgment Note and Mortgage for Plaintiffs signature on or around July 16, 2013. A true and correct copy of the July 16, 2013 letter, Judgment Note, and Mortgage are attached hereto as Exhibit "B." 6. On or around July 18, 2013, Counsel for Plaintiff emailed Counsel for Defendant stating that he had not met with his client to discuss the Judgment Note and Mortgage at that time, but that he had reviewed the Judgment Note and Mortgage himself, and found a number of issues he had with the Judgment Note and Mortgage. 7. On or around July 25, 2013, Counsel for Defendant followed up with Counsel for Plaintiff in regard to whether or not he had met with Plaintiff and discussed the Judgment Note and Mortgage. 8. On or around July 29, 2013, Counsel for Plaintiff responded to Counsel for Defendant's inquiry, to which Counsel for Plaintiff stated that Plaintiff was seeking the advice of Attorney Craig Diehl in regard to the Judgment Note and Mortgage. 9. Additionally, on or around July 29, 2013, Counsel for Plaintiff provided Counsel for Defendant a draft copy of the QDRO, which was roughly Sixty-One (61) Days late. 10. On or around August 7, 2013, Counsel for Defendant mailed and emailed to Counsel for Plaintiff a partially executed copy of the parties' QDRO, in addition to following up on the status of Plaintiff either signing the Judgment Note and Mortgage, or providing changes to said documents. 11. On or around August 7, 2013, Counsel for Defendant received an out of office response from Counsel for Plaintiff. 12. On or around August 13, 2013, Counsel for Plaintiff responded to Counsel for Defendant by stating that Plaintiff had met with Attorney Thomas McGlaughlin (hereinafter McGlaughlin) of Craig Diehl's Office, who was to prepare documents regarding revisions and recommendations to the Judgment Note and Mortgage. 13. On or around August 16, 2013, Counsel for Plaintiff provided Counsel for Defendant a copy of McGlaughlin's August 15, 2013 letter regarding recommendations and revisions to the Judgment Note and Mortgage as well as Plaintiffs request that the Judgment Note and Mortgage be revised consistent with McGlaughlin's suggestions. 14. On or around August 16, 2013, Counsel for Defendant responded to Counsel for Plaintiff regarding McGlaughlin's August 15, 2013 letter, proposing that a conference with Master Elicker would be necessary due to the parties' inability to come to an agreement regarding the Judgment Note and Mortgage. 15. On or around August 23, 2013, Counsel for Plaintiff responded to Counsel for Defendant by stating that Plaintiff was unwilling to agree to anything other than those recommendations or revisions outlined in McGlaughlin's August 15, 2013 letter, and that a conference with Master Elicker would be necessary. 16. On or around August 23, 2013, Counsel for Plaintiff stated that he had placed a call with Master Elicker's Office and he was waiting on dates and times for scheduling the conference. 17. On or around August 30, 2013, Counsel for Plaintiff contacted Counsel for Defendant and stated that he spoke with Master Elicker's Office who confirmed that Master Elicker no longer had the authority to make any decisions in this matter as a final agreement had been placed on record before the Court and his appearance had been withdrawn. 18. Additionally, Counsel for Plaintiff stated that in lieu of a conference, Master Elicker suggested that Counsel for Plaintiff draft and submit a letter to him regarding the issues surrounding the Judgment Note and Mortgage, and he would try to assist with coming up with an amicable resolution. 19. On or around September 4, 2013, Counsel for Defendant agreed to the letter as long as the letter was provided to Counsel for Defendant for his input before submitting it to Master Elicker. 20. On or around September 16, 2013, Counsel for Defendant contacted Counsel for Plaintiff in regard to a status update on drafting the letter to Master Elicker. 21. On or around September 20, 2013, Counsel for Plaintiff stated that he would be drafting the letter on or around September 27, 2013, as requested by his client. 22. On or around October 14, 2013, Counsel for Defendant contacted Counsel for Plaintiff once again in regard to a status update on drafting the letter to Master Elicker. 23. To date, Counsel for Defendant has not received the draft copy of the letter to Master Elicker for Counsel for Defendant's input. 24. Although Counsel for Plaintiff and Counsel for Defendant are attempting to work out the issues regarding the Judgment Note and Mortgage, there should be no reason Counsel for Plaintiff should not be able to have his client execute the QDRO, submit the fully executed QDRO to the Court, and forward same to the Plan Administrator for approval. 25. Pursuant to Cumberland County Local Rule 208.3(9), after contacting Attorney Czekaj, he does not concur with the filing of this motion. 26. Pursuant to Cumberland County Local Rule 208.3(2), it is the assertion of undersigned counsel that the Honorable Kevin A. Hess is the only Judge to rule on this matter regarding Plaintiff's Emergency Petition for Interim Exclusive Possession of Marital Residence and Defendant's Petition for Interim Exclusive Possession of Marital Residence. WHEREFORE, Defendant respectfully requests This Honorable Court to grant the relief requested. Respectfully submitted, _ S R J. RUSSO, P.C. .� By: _.�� Peter . 'usso, Es. . Supreme Court ID: 72897 Paul D. Edger, Esquire Supreme Court ID: 312713 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone: 717-591-1755 Facsimile: 717-591-1756 Attorneys for Defendant Date: January 6, 2014 EXHIBIT "A" DABIS CAMERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06 - 6162 CIVIL COLLEEN CAMERO, Defendant IN DIVORCE THE MASTER: Today is Thursday, March 28, 2013 . This is the date set for a conference in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Dabis Camero, and his counsel Timothy L. Czekaj , and the Defendant, Colleen Camero, and her counsel Peter J. Russo. This action was commenced by the filing of a complaint in divorce on October 23, 2006, raising grounds for divorce of irretrievable breakdown of the marriage. The complaint also raised a count of indignities. With respect to the grounds for divorce, the parties are going to sign affidavits of consent and waivers of notice of intention to request entry of divorce decree today. The affidavits and waivers will be filed with the Prothonotary's office by the Master's office and the divorce will be able to conclude under Section 3301 (c) of the Domestic Relations Code. The complaint also raised a claim for equitable distribution. Neither party has raised any claims 1 for alimony or counsel fees and costs. The Master has been advised that the parties have, after considerable negotiations previously and today, reached an agreement with respect to the outstanding economic claim of equitable distribution. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when the parties leave the hearing room today, they are bound by the terms of the agreement even though they have not subsequently signed the agreement affirming the terms of settlement. The agreement is going to be transcribed and sent to counsel for review for typographical errors; corrections will be made as necessary, and with the understanding that no substantive changes can be made; then the parties will be asked to sign the agreement affirming the terms of settlement as stated on the record. As noted, even though there is no signing, the parties are bound by the terms of the agreement when they leave the hearing room today. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe 2 transmitting the record to the Court requesting a final decree in divorce. The parties were married on January 14, 2003 , and separated October 23, 2006. They are the natural parents of two children. Both children are minors and primary custody is with wife and husband has partial custody with the children as agreed upon. Mr. Russo. MR. RUSSO: Thank you. 1. The parties have agreed that Dabis Camero shall pay onto Colleen Camero the sum of $28,500.00 . This will constitute a complete distribution of all claims for marital assets and shall be paid as follows: Seven thousand six hundred dollars ($7, 600.00) shall be transferred to wife from husband's TIAA-CREF account by way of a QDRO provided by husband to wife. Husband shall provide this QDRO within sixty (60) days of today's date. Wife shall provide an account whereby the funds from the TIAA-CREF account of husband can be deposited. Additionally husband shall remit to wife $150. 00 per month, each month, for the next five (5) years. Said payments shall begin May 1, 2013 . Further, husband shall provide to wife any federal tax refund he receives beginning with tax year 2012 through 2016. Finally, commencing in 2017, husband shall pay any balance remaining by providing wife his federal tax return refund or $1, 750. 00, whichever is greater, in each tax year after 2017 until the balance is paid in full. 2 . The parties agree that the terms of this agreement shall not be dischargeable in bankruptcy. 3 . The parties further agree that they will execute a judgment note which documents the terms of this agreement as well as a mortgage which wife may file against husband' s real property located at 511 Erford Road, Camp Hill Pennsylvania 17011 . 3 -C The judgment note and the mortgage will be provided by wife's counsel and provided to husband's counsel for husband's signature. The mortgage and note will be signed by husband upon the documents being presented from wife's counsel to husband' s counsel, and upon signature by husband of the documents, the Master will be notified that he can then ask the Court to vacate his appointment and the parties can then file a praecipe transmitting the record requesting a final decree in divorce. 4. Husband agrees to secure the subordination of Luisa Benion's mortgage so that wife could be in a second lien position. Upon the payment in full of husband's $28,500.00 obligation to wife, wife will satisfy the mortgage and mark the judgment note paid in full. 5. The parties further agree that all personal property has been distributed to their satisfaction. Those items in the possession of each party shall remain the sole and exclusive property of said party. 6. The parties acknowledge that neither have extended or opened any debt which is or can be imputed to the other from the date of separation until the date of this agreement. 7 . Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow' s allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. THE MASTER: Mr. Camero, you heard the agreement as stated on the record? MR. CAMERO: Yes, sir. 4 THE MASTER: You've been present while this statement has been made by Mr. Russo? MR. CAMERO: Correct. THE MASTER: Do you understand the agreement? MR. CAMERO: Yes, sir. THE MASTER: And are you satisfied that this agreement can be entered as of record, as a final agreement in resolving all claims in this divorce action? MR. CAMERO: Yes, sir. THE MASTER: And you understand that your counsel is going to get a transcribed copy and can review it for typographical errors, and then it will be presented to you for signature? MR. CAMERO: Yes, sir. THE MASTER: Mrs. Camero, do you understand the terms of this agreement? MS. CAMERO: Yes, sir. THE MASTER: You've been present during the statement of the agreement on the record? MS. CAMERO: Yes, sir. THE MASTER: You understand that the agreement is going to be presented to you, after your counsel has received it and any typographical corrections have been made, for signature? 5 M MS. CAMERO: Yes, sir. THE MASTER: And are you satisfied that the agreement as stated concludes all matters in your divorce action? MS. CAMERO: Yes, sir. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: 12- 4/3 / - Timothy L: �ekaj •abis Camero Attorney `for Plaintiff • Peter J. Russ• C. e - • Attorney for Defen•aht`•.. 6 EXHIBIT "B" ( ) • LAW OFFICES OF PETER J.RUSSOPC. PETER J. RUSSO, ESQUIRE ATTORNEYS AT LAW ASHLEY R. MALCOLM. PARALEGAL KATHLEEN MISTURAK-GINGRICH, ESQUIRE** DEREK M. STROUPHAUER. PARALEGAL LINDSAY GINGRICH MACLAY. ESQUIRE** LAURIE L.WATSON. PARALEGAL PAUL D. EDGER. ESQUIRE THOMAS D. GOULD. ESQUIRE **ADMITTED IN PA&NJ Tuesday,July 16, 2013 Timothy Czekaj,Esquire 315 North Front Street Harrisburg,PA 17101 RE: Dabis Camero v. Colleen Camero Docket Number: 2006 CV 6162 Dear Tim, Per the parties' signed agreement, enclosed herewith,please find a copy of the Balloon Mortgage and Promissory Note for your client's signature. Upon signing the enclosed documents, kindly provide the originals to our office. Having spoken with my client, she stated that Mr. Camero provided her with a copy of the TurboTax cover letter, but neglected to provide her with the proper pages of his 2012 Federal Income Tax Return. Kindly have your client provide my client with the first two pages of his tax return information at your earliest convenience. Thank you for your attention to the enclosed. If you should have any questions or concerns, please feel free to contact me at my direct extension, 102, or via email at prusso@pjrlaw.com, or via my assistant, Derek M. Strouphauer, via his direct extension, 114, or via email at dstrouphauer@pjrlaw.com. Very trul ours, • Peter J.Russo PJR/dms Enclosures cc: E. Robert Elicker, II,Divorce Master(w/enclosures via regular U.S.mail) Ms. Colleen Camero (w/enclosures via email only) 5006 EAST TRINDLE ROAD. SUITE 203. MECHANICSBURG. PA 17050 PHONE: (717) 591-1755 FAX: (717) 591-1756 • 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011 East Pennsboro Township Parcel#09-17-1042-009 BALLOON MORTGAGE THIS IS A BALLOON MORTGAGE,THE FINAL PAYMENT OR THE PRINCIPAL BALANCE DUE ON MATURITY IS TWENTY-EIGHT THOUSAND FIVE HUNDRED AND 00/100(US $28,500.00) DOLLARS,TOGETHER WITH ACCRUED INTEREST,IF ANY,AND ALL ADVANCEMENTS MADE BY THE MORTGAGEE UNDER THE TERMS OF THIS MORTGAGE. THIS MORTGAGE("Security Instrument")is given on the day of ,2013. The mortgagor is DABIS CAMERO whose address is 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011,hereinafter called the"Borrower." This Security Instrument is given to COLLEEN CAMERO, whose address is 4085 Swatara Drive, Oberlin,Dauphin County, Pennsylvania 17113,hereinafter called the"Lender". Borrower owes Lender the principal sum of TWENTY-EIGHT THOUSAND FIVE HUNDRED AND 00/100 (US $28,500.00) DOLLARS. This debt is evidenced by this Security Instrument, which provides for monthly payments, with the full debt, if not paid earlier, due and payable upon default of said payment terms or the refinance or sale of the Property. This Security Instrument secures to Lender: (a)the repayment of the debt,with interest, and all renewals, extensions and modifications; (b) the payment of all other sums, with interest, advanced hereunder to protect the security of this Security Instrument; and(c) the performance of Borrower's covenants and agreements under this Security Instrument. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located at Cumberland County,Pennsylvania: Legal Description as shown on Exhibit "A" BORROWER COVENANT that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of records. Borrower warrants and will defend generally the title to the property against all claims and demands, subject to any encumbrances of records. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the interest on the debt and any prepayment and late charges due. 2. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraph 1 and 2 shall be applied; first, to any prepayment charges due; second, to amounts payable under 3.Charges; Liens. Borrower shall pay all taxes, assessments,charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay them on time directly to the person owed payment. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner applicable to Lender; (b)contests in good faith the lien by,or defends against enforcement of the lien in, legal proceedings which in the Lenders' opinion operate to prevent the enforcement of the lien; or(c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien, Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 4.Events of Default. The occurrence of any of the following events shall constitute events of default (hereafter, "Events of Default") under this Security Instrument and shall entitle the Lender to exercise all rights and remedies provided by applicable laws or as otherwise set forth herein: Failure to Pay. The failure of Borrower to make any payment whatsoever required under this Security Instrument after the expiration of the twenty day grace period provided. Failure to Perform. The failure of Borrower, after ten (10) days written notice thereof from the Lender, to perform or observe any of the terms,covenants,conditions and provisions in this Security Instrument. Insolvency or Bankruptcy. An Act of Bankruptcy (hereinafter defined) shall occur with respect to Borrower; provided, however, if a proceeding with respect to an Act of Bankruptcy is filed or commenced against Borrower, the same shall not constitute an Event of Default if such proceeding is dismissed within thirty (30)days from the date of such Act of Bankruptcy. The term"Act of Bankruptcy," as used herein, shall mean the filing of a petition in bankruptcy under the United State Bankruptcy Code, 11 U.S.C. § 101 et seq., and all future acts supplemental thereto or amendatory thereof,or the commencement of a proceeding under any other applicable law concerning insolvency,reorganization or bankruptcy,by or against the Borrower. Death of Borrower. The death of Borrower. Failure to Pay Real Estate Taxes, School Taxes and Other Assessments. The failure of Borrower to pay any and all real estate taxes, school taxes and other federal, state and local taxes and/or assessments which become a lien upon the subject property. Lenders' actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take this action,Lender is not required to do so. Any amounts disbursed by Lender under this paragraph shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 5. Condemnation. The proceeds of any award or claim for damages,direct or consequential,in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation,are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal,to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing,the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction:(a)the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fail to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument,whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 6. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment of otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower' successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 7. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower. Borrower' covenants and agreements shall be joint and several. Any Borrower who co-sign this Security Instrument: (a)are co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument;(b)are not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument without that Borrower' consent. Borrower shall not assign or otherwise divest themselves of any portion of the Security Instrument without securing the prior written consent of the Lender. 8. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges,and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge. 9. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designate by notice to Lender. Any notice to Lender shall be given by first class mail to Lenders'address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 10. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument are declared to be severable. 11. Borrower' Right to Reinstate. If Borrower meet certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a)pay Lender all sums which then would be due under this Security Instrument as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including,but not limited to, reasonable attorneys'fees;and(d)takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lenders'rights in the Property and Borrower' obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 12. Demand. By signing this Agreement, Borrower expressly acknowledge that the Lender reserves its overriding right to demand immediate repayment of all outstanding balances whether due or owing, actual or contingent under the Agreement without prior notice. Notwithstanding any provisions stated in this Agreement, the balance of this Security Instrument is repayable upon default by Borrower or the refinance or sale of the Property. The Lender have the overriding right at any time to require immediate payment of all principal, interest, fees and other amounts outstanding under this Agreement or any part thereof of all or any sums actually or contingently owing to it under the Agreement. Notwithstanding anything contained in this letter,the Agreement is subject to the Lender's overriding right of repayment on demand. 13. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument to Borrower. Borrower shall pay all recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under applicable law. 14.Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 15. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment in an action of mortgage foreclosure shall be the rate payable from time to time under this Agreement plus five (5%) percent. 16. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. 17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower are sold or transferred and Borrower are not natural persons) without Lenders's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. BY SIGNING BELOW, Borrower accept and agree to the terms and covenants contained in this Security Instrument and in any rider(s)executed by Borrower and recorded with it. Witnesses: DAUBIS CAMERO -Borrower COMMONWEALTH OF PENNSYLVANIA COUNTY On this, the day of , 2013, before me, the undersigned officer, personally appeared DAUBIS CAMERO, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument and acknowledged that they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: Notary Public Certificate of Residence I, , do hereby certify that the correct address of the within-named Mortgagee is 511 Erford Road,Camp Hill, Cumberland County,Pennsylvania 17011. Witness my hand this day of ,2013. Agent of Mortgagee Exhibit"A" ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County,Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the Westerly line of Erford Road, (West) which point is One Hundred (100) feet North of the Northwesterly corner of Stephen Road and Erford Road (West) and the Northerly line of Plan 5 of Ridley Park; thence along same South 86 degrees 30 minutes West a distance of One Hundred Sixty-two and Ninety-five One Hundredths (162.95) feet to a point; thence further along same North 82 degrees 53 minutes West, a distance of Sixty-six and Fifty One Hundredths (66.50) feet to a point at the Easterly line of property now or late of East Pennsboro Township; thence along same North 18 degrees 36 minutes East, a distance of Twenty-seven and Twenty-five One Hundredths(27.25) feet to a point at the dividing line between Lot Nos. 9 and 9X on the hereinafter mentioned Plan of Lots; thence along said dividing line North 86 degrees 30 minutes East a distance of Two Hundred Eighteen and Six One Hundredths(218.06) feet to a point on the Westerly line of Erford Road (West); thence along same South 03 degrees 30 minutes East a distance of Thirty-seven and Fifty One Hundredths (37.50) feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a semi-detached dwelling known as No. 511 Erford Road (West). 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011 East Pennsboro Township Parcel#09-17-1042-009 BALLOON MORTGAGE THIS IS A BALLOON MORTGAGE, THE FINAL PAYMENT OR THE PRINCIPAL BALANCE DUE ON MATURITY IS TWENTY-EIGHT THOUSAND FIVE HUNDRED AND 00/100 (US $28,500.00) DOLLARS,TOGETHER WITH ACCRUED INTEREST,IF ANY,AND ALL ADVANCEMENTS MADE BY THE MORTGAGEE UNDER THE TERMS OF THIS MORTGAGE. THIS MORTGAGE ("Security Instrument") is given on the day of 2013. The mortgagor is DABIS CAMERO whose address is 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011, hereinafter called the"Borrower." This Security Instrument is given to COLLEEN CAMERO, whose address is 4085 Swatara Drive, Oberlin,Dauphin County,Pennsylvania 17113, hereinafter called the"Lender". Borrower owes Lender the principal sum of TWENTY-EIGHT THOUSAND FIVE HUNDRED AND 00/100 (US $28,500.00) DOLLARS. This debt is evidenced by this Security Instrument, which provides for monthly payments, with the full debt, if not paid earlier, due and payable upon default of said payment terms or the refinance or sale of the Property. This Security Instrument secures to Lender: (a)the repayment of the debt, with interest, and all renewals, extensions and modifications; (b) the payment of all other sums, with interest, advanced hereunder to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located at Cumberland County, Pennsylvania: Legal Description as shown on Exhibit "A" BORROWER COVENANT that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of records. Borrower warrants and will defend generally the title to the property against all claims and demands, subject to any encumbrances of records. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the interest on the debt and any prepayment and late charges due. 2. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraph 1 and 2 shall be applied; first, to any prepayment charges due; second, to amounts payable under • paragraph 2;third,to interest due; fourth,to principal due; and last, to any late charges due. 3. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay them on time directly to the person owed payment. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner applicable to Lender; (b)contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lenders' opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien, Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 4. Events of Default. The occurrence of any of the following events shall constitute events of default (hereafter, "Events of Default")under this Security Instrument and shall entitle the Lender to exercise all rights and remedies provided by applicable laws or as otherwise set forth herein: Failure to Pay. The failure of Borrower to make any payment whatsoever required under this Security Instrument after the expiration of the twenty day grace period provided. Failure to Perform. The failure of Borrower, after ten (10) days written notice thereof from the Lender, to perform or observe any of the terms, covenants, conditions and provisions in this Security Instrument. Insolvency or Bankruptcy. An Act of Bankruptcy (hereinafter defined) shall occur with respect to Borrower; provided, however, if a proceeding with respect to an Act of Bankruptcy is filed or commenced against Borrower, the same shall not constitute an Event of Default if such proceeding is dismissed within thirty(30) days from the date of such Act of Bankruptcy. The term "Act of Bankruptcy," as used herein, shall mean the filing of a petition in bankruptcy under the United State Bankruptcy Code, 11 U.S.C. § 101 et seq., and all future acts supplemental thereto or amendatory thereof, or the commencement of a proceeding under any other applicable law concerning insolvency, reorganization or bankruptcy, by or against the Borrower. Death of Borrower. The death of Borrower. Failure to Pay Real Estate Taxes, School Taxes and Other Assessments. The failure of Borrower to pay any and all real estate taxes, school taxes and other federal, state and local taxes and/or assessments which become a lien upon the subject property. Lenders' actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take this action, Lender is not required to do so. Any amounts disbursed by Lender under this paragraph shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 5. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a)the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fail to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument,whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 6. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment of otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower' successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 7. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower. Borrower' covenants and agreements shall be joint and several. Any Borrower who co-sign this Security Instrument: (a) are co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) are not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument without that Borrower' consent. Borrower shall not assign or otherwise divest themselves of any portion of the Security Instrument without securing the prior written consent of the Lender. 8. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge. 9. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designate by notice to Lender. Any notice to Lender shall be given by first class mail to Lenders'address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 10. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security • Instrument conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument are declared to be severable. 11. Borrower' Right to Reinstate. If Borrower meet certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pay Lender all sums which then would be due under this Security Instrument as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys'fees; and(d)takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lenders' rights in the Property and Borrower' obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 12. Demand. By signing this Agreement, Borrower expressly acknowledge that the Lender reserves its overriding right to demand immediate repayment of all outstanding balances whether due or owing, actual or contingent under the Agreement without prior notice. Notwithstanding any provisions stated in this Agreement, the balance of this Security Instrument is repayable upon default by Borrower or the refinance or sale of the Property. The Lender have the overriding right at any time to require immediate payment of all principal, interest, fees and other amounts outstanding under this Agreement or any part thereof of all or any sums actually or contingently owing to it under the Agreement. Notwithstanding anything contained in this letter,the Agreement is subject to the Lender's overriding right of repayment on demand. 13. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument to Borrower. Borrower shall pay all recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under applicable law. ,14. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 15. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment in an action of mortgage foreclosure shall be the rate payable from time to time under this Agreement plus five (5%) percent. 16. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage"and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. 17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or • any interest in it is sold or transferred (or if a beneficial interest in Borrower are sold or transferred and Borrower are not natural persons) without Lenders's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. BY SIGNING BELOW, Borrower accept and agree to the terms and covenants contained in this Security Instrument and in any rider(s)executed by Borrower and recorded with it. Witnesses: DABIS CAMERO -Borrower COMMONWEALTH OF PENNSYLVANIA COUNTY On this, the day of , 2013, before me, the undersigned officer, personally appeared DABIS CAMERO, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument and acknowledged that they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: Notary Public Certificate of Residence I, , do hereby certify that the correct address of the within-named Mortgagee is 511 Erford Road, Camp Hill, Cumberland County,Pennsylvania 17011. Witness my hand this day of ,2013. Agent of Mortgagee Exhibit"A" ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the Westerly line of Erford Road, (West) which point is One Hundred (100) feet North of the Northwesterly corner of Stephen Road and Erford Road (West) and the Northerly line of Plan 5 of Ridley Park; thence along same South 86 degrees 30 minutes West a distance of One Hundred Sixty-two and Ninety-five One Hundredths (162.95) feet to a point; thence further along same North 82 degrees 53 minutes West, a distance of Sixty-six and Fifty One Hundredths (66.50) feet to a point at the Easterly line of property now or late of East Pennsboro Township; thence along same North 18 degrees 36 minutes East, a distance of Twenty-seven and Twenty-five One Hundredths(27.25) feet to a point at the dividing line between Lot Nos. 9 and 9X on the hereinafter mentioned Plan of Lots; thence along said dividing line North 86 degrees 30 minutes East a distance of Two Hundred Eighteen and Six One Hundredths (218.06) feet to a point on the Westerly line of Erford Road (West); thence along same South 03 degrees 30 minutes East a distance of Thirty-seven and Fifty One Hundredths (37.50) feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a semi-detached dwelling known as No. 511 Erford Road (West). Amount $28,500.00 July , 2013 Camp Hill, Pennsylvania PROMISSORY NOTE FOR VALUE RECEIVED, and intending to be legally bound, DABIS CAMERO (hereinafter collectively"Maker"), of 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011, hereby promises to pay COLLEEN CAMERO, an adult individual, (hereinafter"Holder"), of 4085 Swatara Drive, Oberlin, Dauphin County, Pennsylvania 17113, the principal sum of TWENTY- EIGHT THOUSAND FIVE HUNDRED AND 00/100 ($28,500.00) DOLLARS lawful money of the United States of America. Maker shall transfer to Holder SEVEN THOUSAND SIX HUNDRED AND 00/100 ($7,600.00) DOLLARS, which shall be transferred to Holder from Maker's TIAA-CREF account by way of a QDRO provided by Maker to Holder. Additionally, Maker shall remit to Holder ONE HUNDRED FIFTY AND 00/100 ($150.00) DOLLARS per month, each month, for the next five (5) years, with the first payment beginning May 1, 2013. Further, Maker shall provide to Holder any federal tax refund Maker receives beginning with tax year 2012 through 2016. Finally, commencing in 2017, Maker shall pay any balance remaining by providing Holder Maker's federal tax return refund or ONE THOUSAND SEVEN HUNDRED FIFTY AND 00/100 ($1,750.00) DOLLARS, whichever is greater, in each tax year after 2017 until the balance is paid in full. Maker does hereby empower the Prothonotary, clerk of court, or any attorney of any court of record in the Commonwealth of Pennsylvania, at any time before or after maturity whether or not any default has occurred, to appear for it and, with or without declaration filed, confess judgment against it for the above sum with costs of suit, release of errors, and with out stay of execution, and with (5%) percent added as part of the judgment for attorney's fees for collection. Maker fully understands and agrees to the attached Explanation of Rights which is incorporated herein by reference. THIS NOTE MAY BE RECORDED AS A JUDGMENT AGAINST THE MAKER WITHOUT PREVIOUS NOTICE TO MAKER AND MAY HAVE AN IMPACT UPON THE CREDIT HISTORY OF THE MAKER. The failure of Holder to declare this Note due and payable on the Maturity Date shall not constitute a waiver of any of Holder's remedies, and the same shall be available to Holder until such time as this Note is satisfied. The words "Holder" and "Maker" whenever occurring herein shall be deemed and construed to include the respective heirs, successors and assigns of Holder and Maker, and the term "Maker" shall be deemed and construed to include the singular, as well as the plural, and the masculine, feminine and neuter gender, or vice versa. This instrument shall be construed according to and governed by the laws of the Commonwealth of Pennsylvania. EXPLANATION OF RIGHTS A. I clearly and specifically understand that by signing the foregoing Promissory Judgment Note dated even date herewith in the principal amount of TWENTY-EIGHT THOUSAND FIVE HUNDRED AND 00/100 ($28,500.00) DOLLARS (the "Note") payable to Colleen Camero (hereinafter"Holder") which contains a confession of judgment clause: 1. I will authorize the Holder to enter a judgment against me in Holder's favor, which will give the Holder a lien upon any real estate which I may own, including my home. 2. I will give up the right to any notice or opportunity to be heard prior to the entry of this judgment on the records of the court. 3. I will agree that the Holder can enter this judgment without any proof of nonpayment or other default on my part. 4. I will subject all of my property, both personal property and real estate, to execution (and sheriff' sale) pursuant to this judgment prior to proof of nonpayment or other default on my part. 5. I will be unable to challenge this judgment, should the Holder enter it, except by a proceeding to open or strike the judgment; and such a proceeding will result in attorney's fees and costs which I will have to pay. 6. I know and understand that it is the confession of judgment clause in the Note. B. IF I DO NOT SIGN A NOTE WHICH CONTAINS A CONFESSION OF JUDGMENT CLAUSE, I UNDERSTAND I WOULD HAVE THE FOLLOWING: 1. The right to have notice and an opportunity to be heard prior to judgment. 2. The right to have the burden of proving default rests upon the Holder before my property can be exposed to execution. 3. The right to avoid the additional expense of attorneys' fees and costs incident to the opening or striking off a confessed judgment. C. I fully and completely understand these rights, which I have received prior to signing the Note and am clearly aware that these rights will be given up, waived, relinquished and abandoned if I sign the Note. Nevertheless, I freely and voluntarily choose to sign the Note, my intention being to give up, waive, relinquish and abandon my known rights (as described in Paragraph B above) and subject myself to the circumstances described immediately above. D. I hereby certify that I, a signatory to the Note, which has a confession of judgment clause, have earnings of$10,000.00 or more per year. I HAVE READ THIS ENTIRE FORM AND FULLY UNDERSTAND ITS CONTENTS Witness for Dabis Camero Dabis Camero Date: Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, • Plaintiff : No. 06-6162 CIVIL TERM vs. COLLEEN CAMERO, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Derek M. Strouphauer, Paralegal, hereby certify that I have on this day served a true and correct copy of the Motion to Compel upon the following persons, and in the manner indicated: VIA REGULAR U.S. MAIL: Timothy Czekaj, Esquire Czekaj Law Offices 315 North Front Street Harrisburg, PA 17101 Respectfully submitted, I&W OFFICES OF PETERUSSO, P.C. By: Derek- Strouphauer, Paralegal Date: January 6, 2014 t�� DABIS CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION—LAW : NO. 06-6162 CIVIL COLLEEN CAMERO, Defendant : IN DIVORCE IN RE: DEFENDANT'S MOTION TO COMPEL RULE TO SHOW CAUSE AND NOW, this /0! day of January, 2014, in consideration of the Defendant's Motion to Compel: 1. A rule is issued upon the plaintiff to show cause why the relief requested ought not to be granted; 2. the plaintiff shall file an answer to the petition within twenty (20) days of service; 3. the petition shall be decided under Pa. R.C.P. No. 206.7; 4. depositions shall be completed within forty-five (45) days of this date; 5. argument is set for March 12, 2014, at 11:00 a.m. in Courtroom Number 4; and 6. notice of the entry of this order shall be provided to all parties by the plaintiff. BY THE COURT, /9 AZ Kevi A. Hess, P. J. 11" m r-1-1 — ‘ Timothy Czekaj, Esquire ' r- r-- 4`. For the Plaintiff • c.- Peter Russo, Esquire For the Defendant ises /724,4 tc_ct, . 71/1 DAB1S CAMERO, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, V. : PENNSYLVANIA COLLEEN CAMERO, : NO. 2006 CV 6162 Z' rr eD Defendant '' a : CIVIL ACTION-LAW IN DIVORCE rvF STIPULATION Pursuant to the Property Settlement Agreement put on the record at the Divorce Master's Office on March 28, 2013,the parties hereby agree and stipulate that the Court may sign the attached Qualified Domestic Relations Order. , 2, 3 4r„.‘ gate Dabis Camero Date Timoth L. Czekaj, Esquire 503 Date • e-Camero∎ or Iftth Date Peter J. Russo, Esquire DABIS CAMERO, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, C V. PENNSYLVANIA .c- rTr c.., . COLEEN CAMERO, NO. 2006 CV 6162 N ; Defendant co ' CIVIL ACTION-LAW _Z) 'v C'^ IN DIVORCE C C:)},} ri STIPULATION FOR THE ENTRY OF A QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this 78* day of 114nno , 2014, upon consideration of the attached Stipulation, it is hereby ORDERED, ADJUDGED AND DECREED as follows: 1. Parties: The parties hereto are husband and wife and a divorce action is presently pending in this Court at the above-captioned docket. 2. Participant Information: The Participant's name, mailing address, social security number and date of birth are: Dabis Camero 511 Erford Road, Camp Hill,Pennsylvania 17011 SS # xxx-xx-4614 Date of Birth: October 24, 1972 3. Alternate Payee Information: The alternate payee's name, mailing address, social security number and date of birth are: Colleen Camero 4085 Swatara Drive, Oberlin, Pennsylvania 17113 SS # xxx-xx-6050 Date of Birth: September 3, 1973 The alternate payee is the wife of the Participant. 4. Plan Information: This Order applies to benefits under the Penn State University Alternate Retirement Plan, RA (TIAA D3927573) (CREF V3927570), "TIAA/CREF", retirement and annuity plan. 5. Assignment of Benefits: The Participant assigns to the Alternate Payee an interest in the Participant's TIAA-CREF plan. The Alternate Payee is entitled to a direct payment in the amount specified herein. 6. Effect of this Order as a Qualified Domestic Relations Order: This Court has personal jurisdiction over the parties. 7. State Domestic Relations Law: This Order is entered pursuant to the authority granted in the applicable Domestic Relations laws of the Commonwealth of Pennsylvania. 8. Provisions of Marital Property Rights: This Order relates to the provision of marital property rights in conjunction with the pending divorce action between the Participant and the Alternate Payee. 9. Amount of Alternate Payee's Benefit: Alternate Payee shall receive a one-time payment of Seven thousand six hundred dollars ($7,600.00) from Participant's account. The form of the payment shall be in a lump sum payment. The Alternate Payee shall have the right to roll over the benefits distributed to her pursuant to the terms and provisions of this Order to an eligible retirement plan such as an Individual Retirement Account or to an Individual Retirement Annuity. 10. Commencement Date: The Alternate Payee shall receive the benefit as prescribed in Paragraph 9 as soon as administratively feasible following the date this Order is approved as a QDRO by the Plan Administrator. 11. Savings Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: a. to provide any type or form of benefits or any option not otherwise provided under the Plan; b. to provide increased benefits to the Alternate Payee; C. to pay any benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a QDRO; or d. to make any payment or take any action which is inconsistent with any federal or state law, rule, regulation or applicable judicial decisions. 12. Certification of Necessary Information: All payments made pursuant to this Order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties. 13. Continued Qualified State of Order. It is the intention of the parties that this QDRO continue to qualify as a QDRO under Section 414 (P) of the Code, as it may be amended from time to time, and the Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at the time benefits become payable hereunder. 14. Tax Treatment of Distributions Made Under this Order: For purposes of Sections 402 (a)(1) and 72 of the Code, or any successor Code section, any Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the distribute of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate federal income tax on such distribution. 15. Parties Responsibilities in Event of Error: In the event that the Plan inadvertently pays the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall immediately reimburse the Alternate Payee to the extent that the Participant has received such benefit payments by paying such amounts directly to the Alternate Payee within ten (10) days of receipt of notice of said inadvertent payment. 16. Effect of Plan Termination: In the event of a Plan termination prior to the distribution of funds to the Alternate Payee,the Alternate Payee shall be entitled to receive his or her portion of the Participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries. 17. Continued Jurisdiction: The Court retains jurisdiction over this matter to amend this Order to establish or maintain its status as a Qualified Domestic Relations Order under Code Section 414 (p), as amended, and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as are necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein. By the Court, ,<,z J. Distribution: Timothy L. Czekaj, Esquire, Czekaj Law Office, 315 N. Front Street, Harrisburg, PA 17101, A/ttorney for Plaintiff Peter J. Russo, Esquire, Law Offices of Peter J. Russo, P.C., 5006 East Trindle Road, 4203, Mechanicsburg, PA 17050,Attorney for Defendant Co TIES 02.--u'U a,eyiy, �r� 0 DABIS CAMERO, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, v. : PENNSYLVANIA r-_- J w� COLEEN CAMERO, NO 2006 CV 6162c Defendant - j : CIVIL ACTION-LAW e`' IN DIVORCE . -:; cw STIPULATION r.3 cp Pursuant to notification from the QDRO Relationship Manager, the Court's Order of January 28, 2014 requires revisions to fully comply with TIAA-CREF QDRO requirements. Therefore, and pursuant to the Property Settlement Agreement put on the record at the Divorce Master's Office on March 28, 2013, the parties hereby agree and stipulate that the Court may sign the attached revised Qualified Domestic Relations Order. -// —20// _ • /% Date Dabis Camero — 2. /// //Y Date Ti y L. Czekaj, Esquire A ) / I Date 'n I! ldbidOf� L��� Date Peter . 'usso, squire . a. DABIS CAMERO, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, v. : PENNSYLVANIA COLEEN CAMERO, : NO 2006 CV 6162 Defendant : rn _ : CIVIL ACTION-LAW cnr- : IN DIVORCE > cp, <c) ;. STIPULATION FOR THE ENTRY OF A QUALIFIED DOMESTIC RELATIONS ORDER _' AND NOW,this 5 day of MBA , 2014, upon consideration of the attached Stipulation, it is hereby ORDERED, ADJUDGED AND DECREED as follows: 1. Parties: The parties hereto are husband and wife and a divorce action is presently pending in this Court at the above-captioned docket. 2. Participant Information: The Participant's name, mailing address, social security number and date of birth are: Dabis Camero 511 Erford Road, Camp Hill, Pennsylvania 17011 SS #xxx-xx-4614 Date of Birth: October 24, 1972 3. Alternate Payee Information: The alternate payee's name, mailing address, social security number and date of birth are: Colleen Camero 4085 Swatara Drive, Oberlin, Pennsylvania 17113 SS #xxx-xx-6050 Date of Birth: September 3, 1973 The alternate payee is the wife of the Participant. 4. Plan Information: This Order applies to benefits under the Penn State University Alternate Retirement Plan, RA (TIAA D3927573) (CREF V3927570), "TIAA/CREF", retirement and annuity plan. 5. Assignment of Benefits: The Participant assigns to the Alternate Payee an interest in the Participant's TIAA-CREF plan. The Alternate Payee is entitled to a direct payment in the amount specified herein. Nothing in this Order will prevent the Participant from changing the beneficiary designations on any accumulation retained after execution of this Order. 6. Effect of this Order as a Qualified Domestic Relations Order: This Court has personal jurisdiction over the parties. 7. State Domestic Relations Law: This Order is entered pursuant to the authority granted in the applicable Domestic Relations laws of the Commonwealth of Pennsylvania. 8. Provisions of Marital Property Rights: This Order relates to the provision of marital property rights in conjunction with the pending divorce action between the Participant and the Alternate Payee. 9. Amount of Alternate Payee's Benefit: $7,600.00 will be awarded as of the date the transfer is recorded by TIAA-CREF. This amount will not include any interim investment experience but will be limited to the accumulations available at the time of transfer. All amounts transferred are subject to the terms and conditions of the contracts, including applicable liquidity restrictions and: a. All ownership and interest in the balance of the accumulations not transferred in all annuities issued to the Participant by TIAA-CREF will belong to the Participant. b. All ownership rights in the newly issued annuities will belong to the Alternate Payee. c. The beneficiary designation of the Alternate Payee's annuities will be his or her estate, unless a beneficiary designation is submitted pursuant to the provisions of the contracts, and accepted by TIAA-CREF. The Alternate Payee must review the contracts at issuance for accuracy and inform TIAA-CREF of any change of address. d. The Alternate Payee's annuities will be issued with the same investment allocation as the Participant's applied pro rata. The Alternate Payee may change the investment allocation once his or her annuities are issued in accordance with the contributing employer's plan. 10. Commencement Date: The Alternate Payee shall receive the benefit as prescribed in Paragraph 9 as soon as administratively feasible following the date this Order is approved as a QDRO by the Plan Administrator. 11. Savings Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: a. to provide any type or form of benefits or any option not otherwise provided under the Plan; b. to provide increased benefits to the Alternate Payee; c. to pay any benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a QDRO; or d. to make any payment or take any action which is inconsistent with any federal or state law, rule, regulation or applicable judicial decisions. 12. Additional Terms: TIAA Traditional Retirement Annuities (RAs) do not allow single-sum withdrawals or transfers to alternate carriers. For other TIAA-CREF annuities, the Alternate Payee's right to receive single-sum withdrawals and/or transfer all or a part of the accumulation to an alternate carrier may be limited in accordance with the contributing employer's plan. • 13. Certification of Necessary Information: All payments made pursuant to this Order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties. 14. Continued Qualified State of Order. It is the intention of the parties that this QDRO continue to qualify as a QDRO under Section 414 (P) of the Code, as it may be amended from time to time, and the Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at the time benefits become payable hereunder. 15. Tax Treatment of Distributions Made Under this Order: For purposes of Sections 402 (a)(1) and 72 of the Code, or any successor Code section, any Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the distribute of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate federal income tax on such distribution. 16. Parties Responsibilities in Event of Error: In the event that the Plan inadvertently pays the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall immediately reimburse the Alternate Payee to the extent that the Participant has received such benefit payments by paying such amounts directly to the Alternate Payee within ten (10) days of receipt of notice of said inadvertent payment. 17. Effect of Plan Termination: In the event of a Plan termination prior to the distribution of funds to the Alternate Payee, the Alternate Payee shall be entitled to receive his or her portion of the Participant's benefits as stipulated herein in accordance with the Plan's termination provisions for participants and beneficiaries. 18. Continued Jurisdiction: The Court retains jurisdiction over this matter to amend this Order to establish or maintain its status as a Qualified Domestic Relations Order under Code Section 414 (p), as amended, and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as are necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein. By the Court, 114 - d J. Distribution: imothy L. Czekaj, Esquire, Czekaj Law Office, 315 N. Front Street, Harrisburg, PA 17101, Attorney for Plaintiff eter J. Russo, Esquire, Law Offices of Peter J. Russo, P.C., 5006 East Trindle Road, #203, Mechanicsburg, PA 17050,Attorney for Defendant acr I'E.S /CI.;LEcL 3/t,py :_--Tyl THO H 0 17A-', tliiR 2 I !J1 I1: Li 3 OUM3ERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff : No. 06-6162 CIVIL TERM VS. COLLEEN CAMERO, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. abis Camero, Plaintif p. PRO THOU() 2014 KAR 21 AM IT: 143 UMBERL AND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) AND 4 3301(d) 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 1 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. 1 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 unsworn falsification to authorities. Date: Dabis Camero, Pia LAW OFFICES OF PETER J. RUSSO, P.C. Peter J. Russo, Esquire PA Supreme Court ID: 72897 Email: prusso@pjrlaw.com 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) -591-1756 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE r F3 THONO '10 if fifiR2 1 ILI 11: 42 CUMBERL /AND COUNTY PENNS YLVANJA AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. 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: LAW OFFICES OF PETER J. RUSSO, P.C. Peter J. Russo, Esquire PA Supreme Court ID: 72897 Email: prusso@pjrlaw.com 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) -591-1756 Attorneys for Defendant 2r3R MAR 21 Ail 11:142 CUI.IBERLA.ND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant : No. 06-6162 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ,* 3301(c) AND § 3301(d) 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 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 unsworn falsification to authorities. Date: DABIS CAMERO, Plaintiff VS. COLLEEN CAMERO, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No.2006 -6162 PRAECIPE TO TRANSMIT RECORD CIVIL TERM 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)) and (Strike out inapplicable section.) 2. Date and manner of service of the complaint: October 23, 2006; Hand Delivery by the Sheriff of Cumberland County 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintifMarch 20, 2014 ; by defendant February 20, 2014 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: NA Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: March 21, 2014 Date defendant's Waiver of Notice was filed with the Prothonotary: March 21, 2014 Attorney for Plaint' /Defendant T0.% o /it y G. C) t /al6S : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DABIS CAMERO • V. COLLEEN CAMERO : NO. 2006-6162 DIVORCE DECREE AND NOW, Aps:/ Z 4 , Zow i , it is ordered and decreed that DABIS CAMERO , plaintiff, and COLLEEN CAMERO , 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, .� g___ ..sssrssssf";" - ••z ` cT ar = _ /7 `&it �'_ = Atte- J. .,, _ : s ,/_ I , - _' `� " - Prothonotary 00pies mailed 4o ct,i+q ezeKa I�ai ice #copy ma; led io af+trusso Mai 1661/ q/9-5 rr�c JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 ry 5000 Ritter Road, Suite 202 r— c Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2006-6162 CIVIL TERM COLLEEN L. CAMERO, : CIVIL ACTION - LAW Defendant : EMERGENCY CUSTODY PETITION PLAINTIFF FATHER'S EMERGENCY PETITION TO MODIFY ORDER OF CUSTODY AND NOW comes the Plaintiff, Dabis E. Camero, by and through his attorney, Jeanne B. Costopoulos, Esquire, and respectfully avers the following: 1. Petitioner is Plaintiff above, Dabis E. Camero, hereinafter referred to as Father, currently residing at 511 Erford Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Respondent is Defendant above, Colleen L. Camero, hereinafter referred to as Mother, who is currently detoxing at Community General Osteopathic Hospital, Room 417, 4300 Londonderry Road, Harrisburg, Pennsylvania, 17109. Prior to going to the hospital, Mother resided at 4085 Swatara Drive, Oberlin, Dauphin County, Pennsylvania, 17113. 3. There are two (2) dependent children from the relationship of the parties, namely Dabis E. Camero-Weltz, II, born August 14, 2003, and Dana E. Camero, born April 9, 2005, hereinafter referred to as the children. 4. The parties are subject to an Order of Court dated September 20, 2013. Said order is attached hereto as Exhibit A. 5. Father seeks an emergency modification of the September 20, 2013 order such that Father 41.83.00 PD 011/ l*30515 is granted sole legal and primary physical custody of the parties' children until such time as Mother addresses her severe alcohol problem. 6. Such an emergency modification would be in the best interests of the children for the following reasons: a. Mother has a long history of severe alcoholism such that she drinks to the point of unconsciousness. b. On January 14, 2013, Father and his wife found Mother drunk to the point of near unconsciousness while the children were in her custody in her basement apartment. She also had in her custody her 3 year old son who was writing on the TV was crayons with a full diaper and hungry. c. On September 9, 2014, Mother's boyfriend,Jamie Zimmerman, contacted Father and shared his concerns about Mother's alcohol issues. Mr. Zimmerman sent Father a text showing a picture of a bottle of alcohol that was in a hamper. Mr. Zimmerman informed Father that he had given Mother an ultimatum to either go to AA or lose custody of the children(both his child and Father's children). Mother admitted she has an alcohol problem and started attending AA. d. On September 23, 2014,Mother drove the parties' older child to and from the Harrisburg Kung Fu Academy and arrived home around 6:30 p.m. or 6:45 p.m. Shortly after 7:00 p.m., Mother's boyfriend called Father and told him to pick up the children due to Mother having problems. When Father arrived to pick up the children he was informed that Mother was drunk and that an ambulance was being contacted and that Mother's alcohol level was going to be tested. e. On September 24, 2014, Mother's boyfriend informed Father that according to medical personnel, Mother had a BAC of.41. He confirmed this information to undersigned counsel in a phone call and added that he is going to try to encourage Mother to enter an alcohol abuse rehabilitation facility. 7. Father fears that once Mother sobers up she may decide not to enter into the rehabilitation facility and she may attempt to obtain custody of the children again prior to addressing her issues. 8. As of now,the children are under the belief that Mother is sick and have not been made aware of the exact nature of Mother's illness. 9. Mother is currently not represented by an attorney and she is in the hospital detoxing as of now, so her concurrence was not requested by undersigned counsel. WHEREFORE, Plaintiff, Dabis E. Camero, respectfully requests this Honorable Court to modify the September 20, 2013 order such that he is granted sole legal and primary physical custody of the children until such time as Mother's alcoholism is under control and she is no longer a threat to the children. Respectfully Submitted: By: JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 V/Z/� Attorney for Plaintiff/Petitioner Date: VERIFICATION I, Dabis E. Camero, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: f/21/2,/,� iezZ dilzt -e--- abis E. Camero CERTIFICATE OF SERVICE I,Jeanne B. Costopoulos, Esquire,hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail, prepaid, and addressed as follows: Colleen L. Camero c/o Community General Osteopathic Hospital Room 417 4300 Londonderry Road Harrisburg, PA 17109 By: JE• • 'E B. COSTOPOUL ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: /zy Attorney for Plaintiff/Petitioner DABIS t ( A'v1FRO, : IN THE COURT OF COMMON PLA !"!,:intiff Ci iVflit+ AND COUNTY:, T ,I,L � T\'` PENNSYLVANIA 'lx Q-) V c,�t C: COLLEEN N 1.• CAM RO, : NO. 2006-6162 CIVIC. ACTION - I A Defendant : IN CUSTODY" ORDER OF COURT AND NOW, this / W, lice\ of .¢.. Yk _ 2013, upon consideration of the attached Custody C oncllii t�teportordered and directed as follows: [he prior Order of Court dated November 22, 200E is hereby vacated. The Father, Dap s F. Camera and the Mother, Colleen L. Camera..shall have shared legal custody of Df his };. Canaero-\Vail , 11. horn August 14. 2003 and Dana L. Camera, born April 9. 2005. Inch parent shall have an equal right, to be exercised jointly with the other parent, to make,all major non-emergency decisions affecting the Children': general ,A,e11-being meluding, but not Ioutted to, all decisions regarding 'hi health, education and religion, Pursuant to the terms of 23 Pa.C.S. X$309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent, Both parents shall be entitled to lull participation in fill educational imd medical/treatment pliii ung meetings and evaluations with regard to die minor children. loch parent shall he entitled to full and complete inicn•nianan from any physician,n dl ii istU.U.her oainiloriiy tit any reOut'a� ell to them iS ,,,=t,:ins including, but not limited to: medical records, birth ccrtifici.itts, school or educational attendaucc records or report cards. \dditionally, each parent shall be entitled to receive copies of any.notices which come from school with regard to school pictures. extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like, 3, Mother shall have primary physical ,'itstods of she children, 4, Durintt the school year; Father shall have periods of partial physical custody on alternating weekends, from Friday it S:00 p.m. to Tuesday morning when he shall'`transport the children_to_school. Father shall also transport the children to school on Monday when he has physical custody, 5. During the summer, the parents shall share physical custody on a week oniweek off schedule from Monday to Monday at 8:00 a.m. Father's week shall begin on the first v onlay oiler school recesses. 6. The parties shall share holiday periods equally as agreed, except that Mother shall have physical custody on Mother's Day and Father shall have physical custody on Father's Day. 7. Father shall he responsible for all transportation. 8. he parties shall have liberal telephone contact with the children. ve.ither party snail do nor permit a third party to do, or say anything that would estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 10. REl,OCATION: No party shall he permitted to relocate the residence of the children which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the children consents to the proposed relocation or the court approves the proposed relocation. A. person proposing to relocate MUST comply with 23 Pa, C. S. § 5337. 1 1. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify- the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. 1:31' "HIE COURT, i‘y V.(2J—J cc: l)abir; F. Camels , pro J 1 1 r..rtord 1', id Camp }_fill i� 170! I c Colleen i_. C.:amet o, pro se ._. 4085 S\vatara Drive Oberlin, PA 17113 TRUE COPY FROM RECORD In Testimony whereof,I here unto set my hand and the sef said Com,at Cad's*.Pa. This ©,d, a��l pp l .ray of ,20-4&-- ; 3 Protho j, f .2&1t r„„„ DAUBS E. CAMERO, : IN THE CO IRT OF COMMON PLEAS (H' Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. COLLEEN L. ('AMER(), : NO. 2006-6162 CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR:11..1107,11',.. Kevin A. Iless, (TSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE Wall CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915,3-8, the undersigned Custody Conciliator submits the following report: 1. 'Phe pertinent information concerning the Children who are the subject of this litigation is as follows: NA M DATE OF HIRTI C1.1RRENTLY 1N Cl 'STODY Or Dabis l . (amero-Waltz, 11 August Id, 2003 Mother 1...)ana F. ( amero April 4), 2.0 0,) Niother 2. A Conciliation Conference was held in this matter on September 17, 2013, with the following in attendance: The Father. 1){this I ( amero, pro se and Mother, Colleen L Caner°, pro Sc. 3. l'heilonorable Kevni A. I less entered an Order ot*Couri dated November 22, 2006 providing, Cor ;hared eirao,l , Mother having primary ohysicttl custody and Father haviiig,alternating weekends. Friday to Sunday. 1. -[he parties agreed to au Order in the loon as attached. Date: 7 Jau( elineM, Vernev. Esquire Custody Conciliator 0 • Cil r r- JEANNE B. COSTOPOULOS, ESQUIRE d Attorney I.D. No. 68735 _ 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2006-6162 CIVIL TERM COLLEEN L. CAMERO, : CIVIL ACTION - LAW Defendant : CUSTODY CRIMINAL RECORD /ABUSE HISTORY VERIFICATION I, Dabis E. Camero, hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges 18 Pa.C.S. Ch. 25 (relating to criminal homicide) 18 Pa.C.S. §2702 (relating _ to aggravated assault) 18 Pa.C.S. §2706 (relating to terroristic threats) [1 18 Pa.C.S. §2709.1 (relating to stalking) 18 Pa.C.S. §2901 (relating _ to kidnapping) i7 18 Pa.C.S. §2902 (relating to unlawful restraint) 18 Pa.C.S. §2903 (relating to false imprisonment) 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 (relating to rape) u 18 Pa.C.S. §3122.1 (relating to statutory sexual assault) 7 18 Pa.C.S. §3123 (relating - to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1 V (relating to sexual assault) 1 18 Pa.C.S. §3125 (relating to aggravated indecent assault) 18 Pa.C.S. §3126 (relating to indecent assault) 18 Pa.C.S. §3127 (relating to indecent exposure) 18 Pa.C.S §3129 (relating to sexual intercourse with animal) ❑ 18 Pa.C.S §3130 (relating to conduct relating to sex offenders) u 18 Pa.C.S.§3301 (relating to arson and related offenses) 18 Pa.C.S. §4302 (relating to incest) 7 18 Pa.C.S. §4303 (relating to concealing the death of child) rl 18 Pa.C.S. §4304 (relating to endangering welfare of children) 18 Pa.C.S. §4305 (relating to dealing in infant children) T1 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(c) or(d) p (relating to obscene and other sexual materials and performances) 18 Pa.C.S.§6301 (relating to corruption of minors) 1.7 18 Pa.C.S. §6312 (relating to sexual abuse of children) 18 Pa.C.S. §6318 (relating , to unlawful contact with minor) 18 Pa.C.S. §6320 (relating to sexual exploitation of children) ❑ 23 Pa.C.S.§6114 (relating to contempt for violation of protection order or agreement) Driving under the influence of drugs or alcohol Li Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct, or involvement with a Children& Youth agency, including the following: Check Self Other household Date all that member apply A finding of abuse by a Children& Youth LI Li Agency or similar agency in Pennsylvania or similar statute in another jurisdiction Abusive conduct as defined under the Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Involvement with a Children& Youth C7 Agency or similar agency in Pennsylvania or another jurisdiction. Where?: C Other: State the date and circumstance of the child abuse, the named perpetrator of the abuse and the jurisdiction or location where the abuse took place. 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child(ren): Identify all household members by name and age that currently reside with you, and were included in the responses to Questions l-2 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: 6. State whether you or any member of your household was provided services by a child welfare agency (eg., County Children, Youth & Families agency). If yes, please indicate: a. The individuals that received services: b. The type of services provided: c. The circumstances surrounding the provision of services: d. The time frame during which the services were or are being provided: e. The jurisdiction or location where services are being or were provided: VERIFICATION I, Dabis E. Camero, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: • �JP/ ' ,e/t �� .bis E. Camero CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos,Esquire,hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail,prepaid, and addressed as follows: Colleen L. Camero c/o Community General Osteopathic Hospital Room 417 4300 Londonderry Road Harrisburg, PA 17109 By: EANNE B. COSTOPOULO1SQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: .7/2y/1 Attorney for Plaintiff DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2006-6162 CIVIL TERM COLLEEN L. CAMERO, Defendant : CIVIL ACTION - LAW : EMERGENCY CUSTODY PETITIOISE -72 (..P .,...,. al I-- -a -(1 — — .--A ..4.",, Re: PETITION FOR EMERGENCY CUSTODY AND NOW, this INTERIM ORDER OF COURT 1141 day of , 2014, upon consideration - consideration of Plaintiffs Eipergency Peitioji or Custody, it is hereby Ordered that •-•t" sy I primary physical custody of the parties' minor children, Dabis E. Camero-Weltz, II, born August 14, 2003, and Dana E. Camero, born April 9, 2005. BY THE COURT: / Jeanne B. Costopoulos, Esq., 5000 Ritter Road, Suite 202, Mechancisburg, PA 17055 / Colleen L. Camero, c/o Community General Osteopathic Hospital, Room 417, 4300 Londonderry Rd, Harrisburg, PA 17109 /e0 AcIrnin —in Vie DABIS E. CAMERO PLAINTIFF v. COLLEEN L. CAMERO DEFENDANT - , • ; IN THE COURT OF COMMON PLEAS OF q _ ...,- , ;-_-; CD CUMBERLAND COUNTY, PENNSYLVAT\frAr;13 c--) ---i --„•,. --, 2006-6162 CIVIL ACTION LAW -<:-.:.- ..-- L---1 -0. (: --T1 , .. ..... IN CUSTODY -;,-..--(--) -- - -.. - c.., . -< ORDER OF COURT AND NOW, Wednesday, October 01, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 14, 2014 1:30 PM for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: is/ Jacqueline M Verney, Esq. 1/ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference orhearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Coes g.7&/ o beF1 o (0i1 -o, g- o VemeY1 hrf. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DABIS E. CAMERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-6162 CIVIL ACTION - LAW COLLEEN L. CAMERO, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 19th day of November, 2014, being advised that Mother is in a long term rehabilitation facility and that Father is satisfied with the current Order of Court, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 4acq ,-Sine M. Verney, Esquire, Custo. ,+ Conciliator