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Home My WebLink About02-3839 REAGER & ADLER, PC BY: Debra Denison Cantor, ESQUIRE Attorney LD. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorn~y for Plaintiff GLADYS BROWN DULL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, Od _ 3?3'1 GARY A. DULL, Defendant CIVIL ACTION - LAW 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 ease 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in th~ office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 REAGER & ADLER, PC BY: ,ESQUIRE Attorney LD. No. 2331 Market Street CampHiIl,PA 17011 Telephone: (717) 763-1383 Attornevs for GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. GARY A. DULL, Defendant CIVIL ACTION - LAW IN DIVORCE A VISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensaction reclamados par el demandante. Usted puede perder dinero, 0 sus propiedades 0 otros derechos importantes para usted. Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEV AR ESTE P APEL A UN ABOGADO DE INMEDIA TO. SI NO TIENE o NO PUEDO P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle. P A 17013 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney LD. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff GLADYS BROWN-DULL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. GARY A. DULL, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(0 OR (D) OF THE DIVORCE CODE L Plaintiff is GLADYS BROWN-DULL, ant individual who currently resides at 1300 Old Trial Road, Etters, York County, Pennsylvania 2. Defendant is GARY A. DULL, an adult individual who currently resides at 816 Belmont Avenue, Mechanicsburg, Cumberland County, Pennsylvania 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint 4. The Plaintiff and Defendant were married on June 19, 1999 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions ofthe Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there is no child of this marriage. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the eourt require the parties to participate in counseling. Plaintiff declines eounseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. I L In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. 12. The Plaintiff avers that the ground on whieh the action is based are: (A) That the marriage is irretrievably broken, or in the alternative; (B) That the Defendant has offered such indignities to the person of the plaintiff, the innocent and injured spouse, to render her condition intolerable and life burdensome, and that this action is not collusive. COUNT I EOUlTABLE DISTRIBUTION 13. Paragraphs one (I) through eleven (11) of this Complaint are incorporated herein by reference. 14. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 15. The parties have acquired marital debt during their marriage. 16. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt Respectfully submitted, Dated: 81\~O~ By: Attorney for Plaintiff VERIFICATION I, Gladys Brown- Dull, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: !#k'?/ ~~c-Wl1- ~ - GIallys Brown-Dull GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 02 ~ 3)".3Q GARY A. DULL, : CIVIL ACTION-LAW Defendant PETITION FOR SPECIAL RELIEF COUNT I: FREEZING OF ASSETS AND NOW COMES Plaintiff Gladys Brown-Dull by and through her counsel, Reager & Adler and seeks Special Relief as follows: L Petitioner is Gladys Brown-Dull and an adult individual with a residence of 1300 Old Trail Road, Etters, York County, Pennsylvania. 2. Respondent is Gary A. Dull an adult individual with a current residence of 816 Belmont Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant were married on June 19, 1999 in Cumberland County, Pennsylvania. 4. Concurrently filing with this Petition for Special Relief the Plaintiff has filed a Complaint in Divorce citing grounds for a no-fault divorce indignities and as Equitable Distribution. 5. Prior to the parties marriage, petitioner was owner of a 5th Wheel Camper which is currently located at Park Way Park Camp Grounds, Lot # 97. 6. On August 17, 1997 the parties executed the agreement attached hereto and marked Exhibit "A" indicating that Mr. Dull would not make any claims to any properties owned by Mrs. Brown-Dull, specifically including the 5'" Wheel Camper. 7. Certain incidents have occurred that resulted in the filing of a Protection from Abuse action. (The temporary order is attached hereto as Exhibit "BOO) 8. Despite the language in the Protection from Abuse Order, Respondent has listed the camper for sale in the newspaper and Petitioner fears that it will be sold prior to the final Equitable Distribution of this property. 9. In addition, the parties are owners of a Pontiac Grand AM GT 2000. Respondent has also placed this vehicle in the newspaper for sale without Petitioners consent. IO.Petitioner utilizes this Pontiac on a Grand AM on a daily basis as her primary vehicle. She has no other vehicle at her disposaL It is apparently by Respondents actions that he intends to transfer and dissipate marital assets pending the final Equitable Distribution. WHEREFORE,. Petitioner requests that this Honorable Court to enter an Order freezing the marital assets pending further Order of Court or Consent ofthe parties. COUNT II, EXCLUSIVE POSSESSION 1 L Paragraph I through 10 are incorporated herein by reference. 12. The entry of the Protection from Abuse Action, petitioner resided for a short time in homeless shelter. 13. Pursuant to the Protection from Abuse Order she was to protected at the residence at the camp ground at 1300 Old Trial Road, Etters, York County, Pennsylvania. 14. Subsequent to the entry of the Protection from Abuse Order it has been determined that the Respondent has changed the locks on the camper thus preventing Plaintiff from residing there. 15. Plaintiffs stay at the shelter expires this week and it is imperative that she obtain possession of the camper at 1300 Old Trial Road, Etters in order to provide her with a place to live. 16. Respondent is currently residing at another resident and has no need for this residence. 17.Further, Respondent is prohibit from going to this address pursuant to the Protection from Abuse Order attaehed herein. WHEREFORE, Petitioner requests that the Court enter an Order granting Petitioner exclusive possession of the Camper at 1300 Old Trial Road, Etters, York County, Pennsylvania. Respectfully submitted: gll~ 01/ 2331 Market Street Camp Hill, P A 17011 (717) 763-1383 Lawyers LD. # 66378 VERIFICATION I, Gladys Brown- Dull, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: g/f II? 2- ~a~ &o-WrL . (u;jJ Glailys Brown-Dull August 17, 1997 To Whom This May Concern: I Gary Dull will not lay any claims on any of the properties that Gladys Brown has owned prior to our relationship. That started in December of 1996 I also give up all my rights to any of the property that would be put in my name. during our relationship. EVEN IF WE WOULD GET MARRIED:: The properties include: 1- A Double Wide Mobile Home Located at Regency South Lot # 34 2- A Pontiac Car 3- A Fifth Wheel Camper Located AT Park Away Park Camp Ground Lot #97 THIS AGREEMENT WILL BE SIGNED BY 130TI-I PARTIES ON TIllS DATE OF AUGUST 17,1997 J3GYJ :i2dI Gary Dull jJa~6J~ Gladys Brown Exhibit "A" Wir MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Phone 717-243-9400 1-800-822-5288 FAX 717-243-8026 July 29, 2002 Newberry Township Police Department 1905 Old Trail Road Etters, PA 17319 Re: Brown-Dull v, Dull No. 02-3565 Civil Term Protection From Abuse To Whom It May Concern: Our office represents Gladys Brown-Dull, the Plaintiff, in the above-eaptioned action. A certified copy of the Temporary Protection From Abuse Order and Petition for Protection Prom Abuse with the attached Notice of Hearing is enclosed for your records. Ms. Brown-Dull has been advised to telephone 911 or your department directly for assistance if Mr. Dull violates the Order. The Temporary Protection Prom Abuse Order remains in effect for a period of 18 months from the date it was entered, through January 25, 2004, or until further Order of Court, whichever comes first. PLEASE NOTE: This paperwork is being sent to your department because Ms. Brown-Dull resides at 1300 Old Trail Road, Etters, PA. Please contact Attorney David A. Lopez if you have questions regarding this matter. Thank you. Sincerely, MidPenn Legal Services, e\'\\)J\..J\.t\...~ "\4.IlJU"1\.,l\.I\.. - ~ IlW~clil.l\, Hannah Herman-Snyder Legal Intern Enclosure cc: Gladys Brown-Dull Exhibit "B" jjlb LSC Q MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Phone 717-243-9400 1-800-822-5288 FAX 717-243-8026 July 29,2002 Camp Hill Borough Police 2199 Walnut Street Camp Hill, PA 17011 Re: Brown-Dull v. Dull No. 02-3565 Civil Term Protection From Abuse To Whom It May Concern: Our office represents Gladys Brown-Dull, the Plaintiff, in the above-captioned action. A certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse with the attached Notice of Hearing is enclosed for your records. Ms. Brown-Dull has been advised to telephone 911 or your department directly for assistance if Mr. Dull violates the Order. The Temporary Protection From Abuse Order remains in effect for a period of 18 months from the date it was entered, through January 25, 2004, or until further Order of Court, whichever comes first PLEASE NOTE: This paperwork is being sent to your department because Ms. Brown-Dull is employed at Panera Bread, 3025 Market Street, Camp Hill, P A. Please contact Attorney David A. Lopez if you have questions regarding this matter. Thank you. Sincerely, MidPenn Legal Services, '~Ov[\.JU\-A "\-\ ~1l)U~ -.::%. (~~Jl Hannah Herman-Snyder Legal Intern Enclosure cc: Gladys Brown-Dull nib LSC , DATE ::}.~jO ,J.-OQ, Mr. NAME J:-Ja.)(.;,,~ ~,1.~ ... STREET 1S'~q E0rn ~t.^~~ .~ O:c: CITY, STATE AND ZIP'--f\,Q.W \':wyH.,N 0... \ nOt 0 Dear NAME: ~ (l,"-i; This letter gives you official notice that you will be considered a DEFIANT TRESPASSER if you come to my residence at (ADDRESS) uninvited or without my consent \ SCO oQc\ ~ Rc::o-.c\ ~S \=>0..., \1';5\<1 The penalty for DEFIANT TRESPASS IS UP TO ONE-YEAR IN JAIL. Furthermore, if you continue to commit acts that alarm or seriously annoy me, and which serve no legitimate purpose, which includes phone calls to my residence, you could be prosecuted for the summary offense of HARRASSMENT. The penalty for HARASSMENT is up to 90 DAYS IN JAIL. A copy of this letter is being given to the LOCAL POLlCE. and Pennsylvania State Police of CITY. They will be called if you defy this request and come to my resid~nce and/or continue to harass me. r_ . .. . ~\ ~ ~ -\e; -XQ_bJ\J-.QJ ~'l, ~.uu ~ U"G -to-t...Q (}-LU-VYl,~ a'GJ--~ So ~ ~~ ~\ 0\.~~~~~t/{\'G~ . ~~ i\~ ~ 2:}~\j~ , " Jihipr3nc.u.:n.t1~ 1)'~ \'.30 QI('{\~~<t-\\ a -tiJJ. C1..00?m NAME ~(r \ ~~ . -SJ. ':3 F'1 'ffi Pi. , t fI'" \ j}..-\ e.~ ~ 0--'1; '3\ w'\ \_C)O~\'Y\ -\:) \d.. 0 -\:t_:~ >+.D-U.'U ~a. (]~\- ~ ~~ ,""&1)-1..0 c;&l:LtJ ~, \J \~ v-.r-- . Cc: File' LOCAL. P.O. Penna. State Police of CITY Gladys M. Brown-Dull, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 02- 3..5 /, 6 CNIL TERM Gary A. Dull, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HA VB BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled on the.3/-u-day of O,P.. ,2002, at 'f;(T(j,4 .m., in Courtroom No. -3 on the 4th Floor of the Cumberland Cou~house, I Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court afternotice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months injail under 23 Pa.C.S. 96114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.c. 92265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.c. 92261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. Gladys M. Brown-Dull, : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. Gary A. Dull, ./ : No. 0':<. 3S{,":) Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Gary A. Dull Defendant's Date of Birth is: May 30, 1948 Defendant's Social Security Number is: 191-40-9755 Name(s) of All protected persons, including Plaintiff and minor children: I. Gladys M, Brown-Dull AND NOW, on 25th Day of July, 2002 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: PIaintifrs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employment 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor child/ren. Defendant is enjoined from damaging, destroying or selling any property acquired during the parties marriage or property owned solely by Plaintiff. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Camp Hill Borough Police Department Newberry Township Police Department 6, The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER 8. TillS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JANUARY 25, 2004 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY TillS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation ofthis Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jaiL 23 Pa.C.S. g6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. g6113. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.c. gg2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 3 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior ineidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest BY THE COURT: A iln~ Q I!;F- ~t.IJ P. C)'~I :u. 2C7>.<- Judge Date Distribution to: Legal Services Faxed & Mailed to PSP Pennsylvania State Police Camp Hill Police Department Newberry Township Police Department T'R~E COPY FROM RECORD 1,~TestimoilY I'JlllJiOOf, I here unto 1:01 m)' han., :I,(! the sa:al 01 said CQ m ""''',0<1 0.. I hI ay' ,""'",,,.... ~;L, Prothonotary Gladys M. Brown-Dull, : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. Gary A. Dull, : No. Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM )illUSE 1. Plaintiffs name is: G1adys~.Brown-Dull 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. G1adys~. Brown-Dull 4. Plaintiffs address is confidential 5. Defendant's Name is: Gary A. Dull 6. Defendant is believed to live at the following address: 1829 Elm St" New Cumberland, PA 17078 7. Defendant's Social Security Number is: 191-40-9755 8. Defendant's Date of Birth is: May 30, 1948 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Spouse 11. . The facts of the most recent incident of abuse are as follows: On or about July 15, 2002, Plaintiff arrived at work and was called into the office regarding a package that had been delivered to her. Her employer had opened the package, per work policy. The package contained the following: a case of gun shells, a clip to a gun, and a note stating, "When you do it, don't miss." 12. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: On or about July 13, 2002, Plaintiff hired a constable to go with her to get her belongings out of the residence. Defendant had been notified. When Plaintiff and the constable arrived, Defendant was not present and they found a note on the front door stating, "Stay away until your time to be here or you may get a big hard surprise." On or about July 11, 2002 Plaintiff sent a letter to Defendant, notifying him that he was not to come to her residence or harass her by phone. Defendant has been calling Plaintiff approximately 7 to 10 times a day, every day. On or about June 28, 2002, Defendant tried to lure Plaintiff into going down the basement stairs. When Plaintiff eventually went down the first basement step, she realized Defendant had oiled the entire staircase. On or about June 6, 2002, Defendant threatened to torch the trailor in which Plaintiff resided on a camp ground. Because of these incidents, Plaintiff fears for her safety. 13. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Camp Hill Borough Police Department Newberry Township Police Department 14. There is an immediate and present danger of further abuse from the Defendant. 15. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor child/ren. c. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. , d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order Defendant to pay Plaintiffs reasonable attorney's fees. f. Order the following additional relief, not listed above: Defendant is enjoined from damaging, destroying or selling any property acquired during the parties marriage or property owned solely by Plaintiff. g. Grant such other relief as the court deems appropriate. h. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will infornl the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. R,"p',<fuIly Submitt,d by~ ~. oan Carey Attorney for Plaintiff MidPenn Legal Serviees 8 Irvine Row Carlisle, PA 17013 J // a VERlFICA TION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: fh95 -D ~ ~Ortw Yn i&6-071 ~ Glady;-M. 'Brown-Dull, Plainti~ 0 r::) 0 C r'~} -T1 ~:,. ...1 -n : .Q n I .. "-;") ri ~- < ,. e) -, --, '. ) ] -. , -<. N ~ () <:::> N c- r'", ~ C> ~Q) 7>> :u:: 0 ::.~[_._; ~ --" Zi:-'- ~ vi fi;~:, w 0 1'0 0(' vJ \)J ~ j;:~ u !;O >:>- t~. ~ :j ''-> '. <Jl ";> -+- ~ .., 9 '1 " r ";nl ,0 ')(L .j -"" :::..3 -() ) . -, ~ ., 'j..:. ~~ =< GLADYS BROWN-DULL, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GARY A. DULL, DEFENDANT 02-3839 CIVIL TERM ORDER OF COURT AND NOW, this /j day of August, 2002, a hearing on the within petition for special relief shall be conducted on Friday, August 23, 2002, at 8:45 a.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Debra Denison Cantor, Esquire For Plaintiff Gary Dull 816 Belmont Avenue Mechanicsburg, PA 17055 ~ ~ f./9-o.v 9-- :saa LL o -C',J >-. ':::'..... ,.- ~Z -..,) ..d .)~ l-S- - :":'-. J:2 :" Cf) -)Z ([:z L.'...1 LU 1;:(1 n.. -2 ::J o ;::.:, :;c: ":.=:.:; o. (~~; oc: 0..J e:::, GLADYS BROWN-DULL, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GARY A. DULL, DEFENDANT 02-3839 CIVIL TERM ORDER OF COURT AND NOW, this ...-z-o day of August, 2002, the hearing on the special relief petition currently scheduled for August 23, 2002, IS CANCELLED and rescheduled for Friday, August 30, 2002, at 8:45 a.m., in Courtroom Number 2. /[)ebra Denison Cantor, Esquire For Plaintiff f1 . o.J.J. ;> L ~ofl -y,~5 /Gary A. Dull 816 Belmont Avenue Mechanicsburg, PA 17055 :saa V\N\/t0,,\S~\N3d II ','r...... '~~.'^I(v"\ i\..J ~i \'.' 1."i~>" ~ IV 2 u ;,~ "..j 0 2 j:Y'J 20 l\t.\.'l.t-" ; 'I ~ GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW MOTION FOR CONTINUANCE AND Now, comes Gary Dull, by and through his attorney, Richard C, Gaffney, Esquire, who files this Motion for Continuance of the Special Relief Hearing that was scheduled for Friday, August 30, 2002 at 8:45 a.m. and who, in support thereof, avers the following: 1. The Plaintiff is Gladys Brown Dull, who is represented by Debra Denison Cantor, Esquire of Reager and Adler, PC. 2. The Defendant is Gary Dull, who is represented by undersigned counsel. 3. On August 12,2002, Defendant filed a Petition for Special Relief with this Honorable Court. 4. A Hearing on the Petition for Special Relief was subsequently scheduled for this Friday, August 30, 2002 at 8:45 a.m. 5. On Monday August 26,2002, undersigned counsel was informed by the Perry County Court of Common Pleas that a Protection from Abuse Hearing was scheduled, in an unrelated matter, for this Friday, August 30, 2002 at 8:30 a.m. PAGE 2 The Perry County Courts refused undersigned counsel's request to reschedule this PF A hearing due to time limits involved, 6. Attorney Deborah Denison Cantor was contacted by counsel and consents to this Request for Continuance, contingent upon undersigned counsel's consent to the Temporary Order attached for Your Honor's review. 7. Undersigned counsel consents to the Temporary Order. WHEREFORE, Plaintiff requests this Honorable Court to continue this hearing on the Petition for Special Relief. Respectfully submitted, LAW OFFICES OF RICHARD C. GAFFNEY Richard C. Gaffney, Esquire Attorney for the Plaintiff Supreme Court J.D. No. 63313 LAW OFFICES OF RICHARD C. GAFFNEY 2120 Market Street Suite 101 Camp Hill, Pennsylvania 17011 Telephone: 717-975-9033 GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I have duly served a true and correct copy of the Motionfor Continuance via First Class United States Mail postage pre-paid on the party whose name and address are listed immediately below: Deborah Denison Cantor Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 Dated: 0e/2.~ / c"2- . \L ~ Ju.U..~ ~~ -- Richard C. Gaffney, ESqU~ 08/29/2002 12: 48 FAX 783 '190~ __ REAGER&ADLER _.- ' ' ~002 REAGER & ADLER, PC AiTORNEYS AND COUNSEL.ORS AT LAW 2331 MARKET siREET CAMP HILL. pENNSYl V ANI" 17011-4642 711-763-1383 TELEFAX 711-130-7366 WiBSITE: R.,.gerAdlerPC.l:OIlI 'fHEOlXlRE p.. ADlER + DAVID W. REAGER CtlARlES E. ZAlESKI UNUS E. I'ENIcLE DEBRA DE1\ISON CAlllTOR THOMAS 0, WI~L1AMS SUSAN H. CON FAIR JOANNE HARRISON CLOUGH SUSAN J. SMITH DOUGLAS P. LEHMAN + CenlIIed Civil Trial s-;ar..t WriIo<'o ~Alldr-: _~nel August 29, 2002 VIA I'ACSIMIU Richard C. GaffiIeY. :Esq. 2120 Market Street Camp Hill. PA 17011 0: Bro....DaIl v. Brewa Oar File No.: 01-595 Dear Richard: It may be easier to respond to yom request fw a cootinuance via fax than to continue to play phone tag. I have DO objection to a continuance if we can agree that a TemporaIY Order freezing all m2rila1 assdS;md gtidlting my client excl\l$ive possession of the camper be entered without prejudice to your client As you may know. my client bas possession of the camper under the PF A which will be heard in a final hearing on September 23, 2002. I simply want this secondary order in case we do Dot bave a hearing prior to that time before Judge Bayley, In addition. the campa: is in your client's Dame alone and I am concemed that without this Comt Order he may attempt to sell the camper. Please advise if this is acceptable. If so, you may indicate my conseot to the continuance and attach the proposed Order for Judge Bayley' s signature. Your attention is appreciated. Very truly yours. Debra Denison Cantor DDCldls ~: Gladys BIowb-DulI (") ~ -oiJJ co fJ'" "'- _ ,) zr" 6'5'",0' --< ~< GL )':0 ~C ):>c.:: :z:: ~ Cl rv :r.- c: G-' W I=.> o -11 n ,-- ~rr .~6 ~:2~~ f.jrn _.-; 55 -< :r,. ::t.: - ., (1'\ \\Ntscrver\ntserver\R&A Family Law\Fonns-DDC\divorce\CERT.SER.geencard.wpd 8/28/02 GLADYS BROWN-DULL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. O~ - 3J' g'1 GARY A. DULL, Defendant CIVIL ACTION - LAW IN DIVORCE AFFTDA VTT OF SERVICE I, Debra Denison Cantor, Esquire ofREAGER & ADLER, P.C. do hereby certify that I served a certified copy of the Divorce Complaint on the Defendant, Gary A. Dull, by Certified Mail, Restricted pelivery on the 23rd day of August, 2002 as is evidenced by the signature of the Defendant on the Return Receipt card attached hereto as Exhibit A. Said Complaint in Divorce was mailed to Defendant by depositing a true and exact copy thereof in the United States mail, first class, Certified Mail, Restricted Delivery, Return Receipt Requested postage prepaid, addressed as follows: Gary A. Dull 816 Belmont Avenue Mechanicsburg, P A 17055 D,re4 71S! () 2- "'DEBRA DENISON CANTOR, ESQUrRE REAGER AND ADLER, P.C. 2331 MARKET STREET CAMP HILL, PA \?O~~ 4...-.- 0elMry? 3.S~-;;ce J-, "'1"'MI~y.. CERTIFIED I 2. Article Number 7111 1746 2100 0000 OD23 111111 1 11I1111 Illmllllllllllllll III I 2100 01Hl0 [}{]23 """GARY' A -.' DULL ::'816 EJELMONT AVENUE MECHANICSBURG PA 17055 ::-~=~ ,1,,1,,1,,",.rtt....~M,hH'rl/J'"~1 EXHIBIT" A" g c ". s:: (/) -om 1""1 mrn -:J Z:IJ zy . , o -~ .I --<....<IIt': r;;u -.- eC) 2:0 r',~' >c :z; , GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, : CIVIL ACTION-LAW Defendant ORDER AND NOW TillS LfC1\ day of ~ ,2002, upon the request of the parties, the Special Reliefhearing scheduled for August 30, 2002 shall be continued. Pending the hearing, the parties are prohibited from selling, transferring, encumbering or otherwise dissipating the martial assets. Plaintiff is granted exclusive possession of the camper located at 1300 Trail Road, Etters, Pensylvania 17319. The hearing is rescheduled for the Iq-tl day of ~ ,2002 in Courtroom No. ~ at the Cumberland County Courthouse,,<Vt ~,' ~() I? III. J. { ~ ~ -I:i;~ ~#7'~ ~ J.J, ~ , . '1, bfj. () 2; Cj-. VINVl17iSNN3d NN/7CX) OI'tfi'":l.f']8Wno "2 '1 :{Jf ~fV 7 - d3S ZO JU"'!(':'f"j'..:,,::, "', AU '. .:., ".-. "~'';li'.' "'~J ::]0 JO{;("iC""O:i7i'd REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP Hill, PENNSYLVANIA 17011-4642 717-763-1383 TElEFAX 717-730-7366 WEBSITE: ReagerAdlerPC.com THEODORE A ADLER + DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENIClE DEBRA DENISON CANTOR THOMAS O. WilLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH SUSAN J. SMITH DOUGLAS P. lEHMAN +Certified Trial Specialist Writer's E-Maii Address:ddenison@epix.net August 29,2002 VIA FAX-240-6462 The Honorable Edgar B. Bayley Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 RE: Brown-Dull v. Brown Our File No.: 02-595 Docket No. 02-3839 Dear Judge Bayley: This firm represents Gladys Brown-Dull in regard to the Petition for Special Relief filed in above-captioned matter. Richard Gaffney is now representing Mr. Dull, Mr. Gaffney and I came to a verbal agreement yesterday that this matter will be continued due to a conflict in his schedule. However, the continuance was contingent upon the execution of the attached Order granting my client the Relief the Requested without prejudice, pending a hearing, After a conversation with your chambers today, I learned that Mr. Gaffney has not forwarded this Order or the request for the continuance to your chambers. Therefore, I apologize for this last minute request and on behalf of the parties I am requesting a continuance of this matter and requesting that you execute the attached Order pending the rescheduling of the hearing. Your attention is appreciated. DDC/er cc: John Gaffney, Esquire Gladys Brown-Dull GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, : CIVIL ACTION-LAW Defendant STIPlJI,ATTON 1. Gladys Brown-Dull is an adult individual currently residing at 1300 Trail Road, Etters, Pennsylvania She is represented by REAGER & ADLER, P.C. 2. Gary A. Dull is an adult individual who is represented by Richard C. Gaffney, Esquire, of2120 Market Street, Camp Hill, Pennsylvania. 3. On or about August 28, 2002, Plaintiff filed a Petition for Special Relief which is scheduled for a hearing on September 19, 2002 at 2:30 PM. 4. The parties have reached an agreement as follows: a. Neither party shall sell, transfer, encumber or otherwise dissipate any marital assets without the written agreement of both parties or further order of this Court. b. Plaintiff shall have exclusive possession of the residence located at 1300 Trail Road, Etters, Pennsylvania. 5. The parties agree to have this Stipulation entered as an Order ofC () c ~ ~'.:" '-"'-^ SJ.~~ ?~t (f:! .'~ r> ~-:'- ;:.: \:'-.~ L.._ .r::, .--:; -. " o N c.1) rTl ""0 I.u} -11 u[ (...' Cr'l GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, : CIVIL ACTION-LAW Defendant STTPUT ,A TJON 1. Gladys Brown-Dull is an adult individual currently residing at 1300 Trail Road, Etters, Pennsylvania She is represented by REAGER & ADLER, P.C. 2. Gary A. Dull is an adult individual who is represented by Richard C. Gaffney, Esquire, of2120 Market Street, Camp Hill, Pennsylvania. 3. On or about August 28,2002, Plaintiff filed a Petition for Special Relief which is scheduled for a hearing on September 19, 2002 at 2:30 PM. 4. The parties have reached an agreement as follows: a. Neither party shall sell, transfer, encumber or otherwise dissipate any marital assets without the written agreement of both parties or further order of this Court. b. Plaintiff shall have exclusive possession ofthe residence located at 1300 Trail Road, Etters, Pennsylvania. 5. The parties agree to have this Stipulation entered as an Order ofC Jo Harrison 10 REAGER & ADLER, 2331 Market Street Camp Hill, P A 17011 Counsel for Plaintiff WHEREFORE, counsel for each party sets forth h's or her sign t 0 0 () S.:: rv " ':'...0') ~, 'rJ nl r- "0 i ~j , o. C r;: ".- ,,~'.- .J:.--~ -I - ~r> -q ( ~, -~ GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, : CIVIL ACTION-LAW Defendant ORDER AND NOW THIS Ie, day of S-~ 2002, upon review of the attached Stipulation, it is here by ORDERED and DECREED that the parties are prohibited from selling, transferring, encumbering or otherwise dissipating any marital assets without the written agreement of both parties or further order of this Court. Plaintiff is granted exclusive possession ofthe camper located at 1300 Trail Road, Etters, Pennsylvania 17319. The hearingiB .__A llttllaa for September 19, 2002 at 2:30 PM is canceled. 1. 'vlNViil,\Sf\fN3d )JNnCo ('~"'F"~i-:c;!\n:) S, :S ".1 6 I el3S ?CJ A!f'illC ; GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION ..LA W PETITION TO WITHDRAW ApPEARANCE AND NOW, COMES Richard C. Gaffney, Esquire and SMIGEL, ANDERSON AND SACKS (individually and collectively referred to herein as "Attorney"), counsel of record for the Defendant/Respondent, Gary Dull (hereinafter "Client"), who petition this Honorable Court under Pa.R.Civ.P. Rule 1012 for leave to withdraw appearance as counsel, and who, in support thereof, aver the following: 1. Attorney and Client have developed significant philosophical differences related to matters concerning the prosecution and handling of the case. 2. At this point in the attorney-client relationship, it is impossible for Attorney to adequately represent Client's interests. 3. Neither ofthe parties will be prejudiced by Attorney's withdrawal from this case. 4. Attorney contacted Counsel for the plaintiff, Joanne Harrison Clough of Reager and Adler, P.C., and Plaintiffs counsel consented to Attorney Withdrawal of Appearance as evidenced by he:r January 6, 2003 letter, which is attached to and incorporated in this Petition by reference thereto. WHEREFORE, Attorney respectfully prays this Honorable Court for leave to withdraw appearance in the above-captioned action. Respectfully submitted, ~..5l~~ Richard C. Gaffney, EsqUlre Supreme Court I.D. No. 63313 SMIGEL, ANDERSON, & SACKS 4431 North Front Street Harrisburg, PA 17110 (717) 234.2401 GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW CERTIFICATE OF SERVICE The undersigned counsel hereby certifies that on January~, 2003 the attached Petition to Withdraw Appearance was served on the Respondent, Gary Dull, in accordance with Pennsylvania Rules of Civil Procedure by postage prepaid United States Certified Mail, Restricted Delivery, Return Receipt Requested at the following address: Mr. Gary Dull 816 Belmont Street Mechanicsburg, P A 17055-4311 And also on counsel for the Plaintiff at the following address: Joanne Harrison Clough Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 "3!-.Q~ ~ Richard C, Gaffne, A, ~ire (") c ~ ;g C/.i ~[;. ;?;X' (0"'- -~...:. .~( !i:: E;: c- ;::: :< i"-'> ." , -~ ..,..,.Q :;:: , '..0 ~ c w o -"") " ...j :-rl ,-.::. .::-i _r...... ::J.J ""' GLADYS BROWN-DuLL, PLAINTIFF V. GARY A. DULL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. 02-3839 CIVIL ACTION -LAW ORDER AND NOW, this t6 day of January 2003, a Rule is issued upon the Respondent, Gary Dull, to show cause why the relief sought in the attached Petition to Withdraw Appearance should not be granted. Rule Returnable ~$ days after service. /1iL Rw~ ~1Abl9. ~Jt ~ CKMWlJ, ~~ M.t~k>~ . L~f~ ~RX~ OI-Ji,.o3 BY T!JE.-c6URT: ( ~ , J. VI M'i'II)'sNJ\l3d VfllnnJ nt,. :l-i"lU::'I;-.."j'V(l"" I 1\ '-". ''>., "., ,Y " tv g S =21 Hd 9 J fa )..tJ\iJ.O,' GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW PETITION TO MAKE RULE ABSOLUTE AND NOW, COMES Richard C. Gaffney, Esquire and SMIGEL, ANDERSON & SACKS (individually and collectively referred to herein as "Attorney"), counsel of record for the DefendantlRespondent, Gary Dull (hereinafter "Client"), who petition this Honorable Court under Pa.R.Civ.P. Rule 1012 for leave to withdraw appearance as counsel, and who, in support thereof, aver the following: 1. On January 8, 2003, Attorney filed a Petition to Withdraw Appearance. A time stamped copy of the Petition is attached hereto as Exhibit A. 2. On January 8, 2003, Attorney served a true and correct copy of the Petition on Respondent. Attorney's Certificate of Service is attached hereto as Exhibit B. 3. On January 16,2003, this Honorable Court issued an Order and Rule on Respondent, Client, to show cause why Attorney should not be allowed to withdraw appearance as counsel for Client. A true and correct copy of the Order and Rule is attached hereto as Exhibit C. 4. The Rule was returnable in 15 days. 5. On January 19,2003, Attorney served the Order and Rule on the Respondent. Attorney's Certificate of Service of the Rule is attached hereto as Exhibit D. 6. Fifteen days after service of the Rule was February 3,2003. 7. More than 15 days have elapsed since service of the Order and Rule on the Respondent. 8. On February 20,2003 Attorney called the Prothonotary's office to verify that Client did not file an Answer. Respondent has failed to file an Answer to the Rule within the time allowed by the Rule. 9. Pursuant to PA.R.C.P. 206.7 (Procedure after a Rule to Show Cause), if an Answer is not filed, all averments of fact in the petition may be deemed admitted and the Court shall enter an appropriate Order. 10. Client's case will not be prejudiced by Attorney's withdrawal from the case. WHEREFORE, Counsel for the Plaintiff prays this Honorable Court to make the Rule Absolute and grant Attorney Leave to Withdraw Appearance. Respectfully submitted, 12.Ul..MJ..~ Richard C. Gaffney, Esquire Supreme Court LD. No. 63313 Smigel, Anderson, & Sacks 4431 North Front Street Harrisburg, PA 17110 GLADYS BROWN-DULL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW CERTIFICATE OF SERVICE The undersigned hereby certifies that on March 6, 2003 the attached Petition to Mark Rule Absolute was served on the Respondent, Gary Dull, in accordance with Pennsylvania Rules of Civil Procedure by postage prepaid United States Certified Mail, at the following address: Mr. Gary Dull 816 Belmont Street Mechanicsburg, P A 17055-4311 And also on counsel for the Plaintiff at the following address: Joanne Harrison Clough Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 EXHIBIT A GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW PETITION TO WITHDRAW ApPEARANCE C) ~; -r)~7: ~~rC' --... C>l_ "~f --. ~~ c::; G..! ! .,() AND NOW, COMES Richard C. Gaffney, Esquire and SMIGEL, ANDERSO~g\ND SACKS (individually and collectively referred to herein as "Attorney"), counsel of ?e~~rd fb't' :~i .,.... ",1 the DefendantlRespondent, Gary Dull (hereinafter "Client"), who petition this Honorable Court under Pa.R.Civ.P. Rule 1012 for leave to withdraw appearance as counsel, and who, in support thereof, aver the following: 1. Attorney and Client have developed significant philosophical differences related to matters concerning the prosecution and handling of the case. 2. At this point in the attorney-client relationship, it is impossible for Attorney to adequately represent Client's interests. 3. Neither of the parties will be prejudiced by Attorney's withdrawal from this case. 4. Attorney contacted Counsel for the plaintiff, Joanne Harrison Clough of Reager and Adler, P.C., and Plaintiffs counsel consented to Attorney Withdrawal of Appearance as evidenced by her January 6, 2003 letter, which is attached to and incorporated in this Petition by reference thereto. WHEREFORE, Attorney respectfully prays this Honorable Court for leave to withdraw appearance in the above-captioned action. Respectfully submitted, -U:~~~ Richard C. Gaffney, EsqUlre Supreme Court LD. No. 63313 SMIGEL, ANDERSON, & SACKS 4431 North Front Street Harrisburg, PA 17110 (717) 234.2401 EXHIBIT B GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW CERTIFICATE OF SERVICE The undersigned counsel hereby certifies that on January~, 2003 the attached Petition to Withdraw Appearance was served on the Respondent, Gary Dull, in accordance with Pennsylvania Rules of Civil Procedure by postage prepaid United States Certified Mail, Restricted Delivery, Return Receipt Requested at the following address: Mr. Gary Dull 816 Belmont Street Mechanicsburg, P A 17055-4311 And also on counsel for the Plaintiff at the following address: Joanne Harrison Clough Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 n-.Q.....d.<:~ ~ Richard C. Gaffne, A, ~ire EXHIBIT C GLADYS BROWN-DuLL, PLAINTIFF V. GARY A. DULL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET No. 02-3839 CIVIL ACTION -LA W ORDER AND NOW, this ~ day of January 2003, a Rule is issued upon the Respondent, Gary Dull, to show cause why the relief sought in the attached Petition to Withdraw Appearance should not be granted. Rule Returnable J5 days after service. Th e. Protho rJ Ota.r:t 5hoJ I to f1,0 o..Rd a..nt O-nsweR ~(l..t. ma~:ibe. BY THE COURT: ~ \ eel -t 0 c.ho.JY\ be RS . TRUE COpy FROM RECORD In Testimony whereof, I here unto set my hand and the seal of s id Court at Carlisle, Pa. ...J~... da. f..~Q..bl~...&. P thonotafY . 1 \l EXHIBIT D GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW CERTIFICATE OF SERVICE The undersigned counsel hereby certifies that on January~, 2003 the attached Petition to Withdraw Appearance was served on the Respondent, Gary Dull, in accordance with Pennsylvania Rules of Civil Procedure by postage prepaid United States Certified Mail, Restricted Delivery, Return Receipt Requested at the following address: Mr. Gary Dull 816 Belmont Street Mechanicsburg, P A 17055-4311 And also on counsel for the Plaintiff at the following address: Joanne Harrison Clough Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 3?-S).....d.t~ ~- Richard C. Gaffne, A, ~ire CJ L:'> (""'-, C (..., -n .<' :;~~ -- ..,! "1:) 1 ~~- -.'":.... ";:'i,a 1"'11 ;"(J Z U) ~. , -< "-" r" :< v ;,J::: ,-. ....,;..... ~ (", ):,~ c':~ r".,..) ...-:.~~ :..) --4 -C rv GLADYS BROWN-DULL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW ORDER AND NOW, this J$..- day o~~ 2003, upon consideration of Attorney's Petition to Withdraw Appearance, Respondent's failure to file an Answer thereto and Attorney's Petition to Make Rule Absolute, it is ORDERED that the Rule is made Absolute. Attorney is granted leave of court to withdraw appearance w~ll . - - days @f..1. 6leef ~11 p""'aDetJiRgIHG Etay HUM.:h:I", tv t r" .:I"R. ~pr\prlo...+ <>1"\~. ~ OPflCl...."-l~ t ~+~\~I.:J L.~mJl. ~~ ( (, , J. r ri. ? - l. i-Ip ~, ~ V1N\jt\lAS~!N~~ . - '"d', r ' ' '. '1"1""\"" 11r,lril"" l ""d"' ';"''"-'~,I (' 1\..Ll,~j <".~ \, ,.. ',' I V {)~ \ ~ l., '"' (~ '-'1 !! ~l ~.::J .(., .~ t,U "" \"f' i ~"""n . . U"" ,-, '. t. I .; r'f '; .,~~ GLADYS BROWN-DuLL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET No. 02-3839 GARY A. DULL, DEFENDANT CIVIL ACTION -LAW PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary of Said Court: Pursuant to Judge Bayley's March 13,2003 Order granting the undersigned counsel leave of Court to withdraw as counsel to the Defendant, Gary A. Dull, please withdraw my appearance as Mr. Dull's counsel. Respectfully submitted, \'-~~C~~ Richard C. Gaffney, E~i~ Supreme Court I.D. No. 63313 SMIGEL, ANDERSON, & SACKS 4431 North Front Street Harrisburg, PA 17110 (717) 234.2401 0 CJ 0 C W -'n ::~ :J: -u rJ; "':::-:;:a rn [, ::::J / <- N 2': , S2 ~ r.-= '-"' ~ ..-::... )> ::..,) "'V :i~ ~v C:) =< - GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 02-3839 GARY A. DULL, Defendant : CIVIL ACTIOK-LA W : IN DIVORCE RULE TO SHOW CAUSE: AND NOW, this a da~003, upon review of the attached Petition, a Rule is hereby issued against Respondent, Gladys Brown-Dull, and Defendant, Gary A. Dull, to show cause, if any, why Movant, Reager & Adler, P.C. 's Petition For Leave to Withdraw As Counsel should not be granted. Rule returnable within 2- days of date of service. BY THE COURT: J. I &-..l{~()~ ~. ~.:& ~ ~.~~ ........ .;1 . , \, '," 'VIN'V^lf..SNtBd IJt-ln08 C1tN18~ fie;;:6 \4'J 11llmr 80 \\1\.1110'1""1"" I.'.' 10 f\OV.L ~....)\-,..'\..}(i(l :;\"":11 :J 3;)\:J:1o-cB11:! :r GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 Defendant : CIVIL ACTION-LAW : IN DIVORCE GARY A. DULL, MOTION TO MAKE RULE ABSOLUTE AND NOW, this 25th day of July, 2003, come Movants, Joanne Harrison Clough, Esquire, and Reager & Adler, P.C., and in support of her Motion to Make Rule Absolute, respectfully represents as follows: I. On May 30, 2003, the above-named Movants filed a Petition For Leave To Withdraw As Counsel. 2. On June 24, 2003, the Court entered a Rule to Show Cause against Respondent Gladys Brown-Dull directing her to show cause why Petitioner should not be permitted to withdraw as counsel for Respondent. Said Rule was returnable seven (7) days after service thereof. 3. Service of said Rule was made on Respondent Gladys Brown-Dull by regular mail with cover letter on June 26, 2003. A true and correct copy of said cover letter, with address whited-out for privacy protection of Respondent, is attached hereto as Exhibit "A." 4. Service of said Rule was made on Defendant Gary A. Dull by regular mail with cover letter on June 26, 2003. A true and correct copy of said letter is attached hereto as Exhibit "'B." 5. More than seven (7) days have elapsed since the service of the aforesaid Rule to Show Cause. 6. Up to this point of time, no responsive pleading whatsoever has been filed by the Respondent or the Defendant. WHEREFORE, the Petitioners, Reager & Adler, P.c., and Joanne Harrison Clough, Esquire, respectfully request this Honorable Court enter an Order making its Rule absolute in the above caption. Respectfully submitted, REAGER & ADLER, PC DATE: /~ 'VP\----- 0 -'7 By: JO E HARRlSO LD. No. 36461 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individuals via United States First Class Mail, postage prepaid as follows: Gary A. Dull 816 Belmont Avenue Mechanicsburg, P A 17055 Gladys Brown-Dull Address withheld for privacy protection. Dated: l~ ~/Q7 EXHIBIT "A" THEODORE A. ADLER+ DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENICLE DEBRA DENISON CANTOR REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL. PENNSYLVANIA 17011-464,~ 717-763-1383 TELEFAX 717-730-7366 WEBSITE: ReagerAdlerPC.com THOMAS O. WILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH SUSAN J. SMITH DOUGLAS P. LEHMAN Writer's E-Mail Address:jclough@eplx.net + Certified Civil Trial Specialist Gladys Brown-Dull June 26, 2003 RE: Brown-Dull v. Dull Our File No.: 02-595 Dear Gladys: I am enclosing a copy of a Rule to Show Cause which was signed by Judge Bayley and entered by the Court on June 24, 2003. Please note that this Rule to Show Cause gives you ten (10) days from the date of service to show cause why our Petition For Leave to Withdraw As Counsel should not be granted. . JHC/dls Enclosures o;;~h~~ GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A DULL, Defendant : CIVIL ACTION-LAW : IN DIVORCE RULE TO SHOW CAUSE . . -r~ AND NOW, thiS!!Jf- day o~, 2003, upon review of the attached Petition, a Rule is hereby issued against Respondent, Gladys Brown-Dull, and Defendant, Gary A Dull, to show cause, if any, why Movant, Reager & Adler, P.C.'s Petition For Leave to Withdraw As Counsel should not be granted. Rule returnable within l days of date of service. BY THE COURT: t5lfhr/J ~ ftIJ! COPY Jl'ROM RS'XI8 11\ Tootlmony whereof, I here unte set my.... ~..41 t . of ".".1 CGlJ.Cf1t C~rIlSIe.. Pa.. .1- f" ....'1 ol~ a.IH)rJ . --- GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, Defendant : CIVIL ACTION-LAW : IN DIVORCE PETITION FOR LEAVE TO WITHDRAW AS COUNSEL (') 0 0 C <..) -n _:s::: :Jt ::::l vCIJ :<>0 '_ 92m -< rn.~ Gladys Brown-Dull retained Reager & Adler, P .C. to represent he~e l'AA>ve-:8e ~z 0 06 . . :<D ;:boo =t-r, referenced divorce actIOn. ~(") ::r ,::;~ ~o - gm c: .. ,....-t Pursuant to the terms of the Agreement for Representation, Plaintiff, ~adJffi ~ 1. 2. Brown-Dull, was to under certain terms and conditions of the regarding financial obligations for her legal representation. 3. Gladys Brown-Dull has failed to honor the terms and conditions of her financial arrangement with Petitioner, Reager & Adler, P.c. WHEREFORE, the Petitioners, Reager & Adler, P.c., respectfully request this Honorable Court to grant leave for them to withdraw as counsel for Plaintiff, Gladys Brown-Dull in the above caption. Respectfully submitted, REAGER & ADLER, P OUGH, ESQUIRE DATE: 5' o-/l \ ./ to J By: JO HA LD. No. 36461 2331 Market Street Camp Hill, PA 1701 (717) 763-1383 VERIFICATION: I, Joanne Harrison Clough, Esq., of Reager & Adler, PC, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: :) - L--\ ---0:5 Joanne Harrison Clou Esquire CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing Petition for Special Reliefe was served on the following individuals via United States First Class Mail, postage prepaid as follows: Dated: GaJY A. Dull 816 Belmont Avenue Mechanicsburg, P A 17055 Gladys Brown-Dull Address withheld for privacy protection. :f -" L\ --- IClI JOAN E HARRISON Attorney ill #36461 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 UGH, ESQUIRE EXHIBIT "B" REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AT LAW 2331 MARKET STREET CAMP HILL, PENNSYLVANIA 17011-4642 717-763-1363 TELEFAX 717-730-7366 WEBSITE: ReagerAdlerPC.com THEODORE A. ADLER+ DAVID W. REAGER CHARLES E. ZALESKI LINUS E. FENICLE DEBRA DENISON CANTOR THOMAS O. WILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH SUSAN J. SMITH DOUGLAS P. LEHMAN + Certified Civil Trial Specialist Writer's E.Mail Address: jclough@epix.net June 26, 2003 Gary A. Dull 816 Belmont Avenue Mechanicsburg, PA 17055 RE: Brown-Dull v. Dull Our File No.: 02-595 Dear Gary: I am enclosing a copy of a Rule to Show Cause which was signed by Judge Bayley and entered by the Court on June 24, 2003. Please note that this Rule to Show Cause gives you ten (10) days from the date of service to show cause why our Petition For Leave to Withdraw As Counsel against your wife, Gladys Brown-Dull, should not be granted. Sincerely, ~~o~~w mC/dls Enclosure cc: Gladys Brown-Dull GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 02-3839 GARY A. DULL, Defendant : CML ACTION-LAW : IN DIVORCE RULE TO SHOW CAUSE . , r~ AND NOW, this i!1f- day o~, 2003, upon review ofthe attached Petition, a Rule is hereby issued against Respondent, Gladys Brown-Dull, and Defendant, Gary A. Dull, to show cause, if any, why Movant, Reager & Adler, P.e. 's Petition For Leave to Withdraw As Counsel should not be granted, Rule returnable within l days of date of service. BY THE COURT: I~l( r{J ~~. ot8ly GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 GARY A. DULL, Defendant ; CIVIL ACTION-LAW : IN DIVORCE PETITION FOR LEAVE TO WITHnRA W AS COUNSEL 2 8 ~ ~. :E ::::I -"00 ". . ~' -< rn;;g 1. Gladys Brown-Dull retained Reager & Adler, P .C. to represent he - e cAA>ve~g9 -< ~ c::> 06 kG :-i-r; referenced divorce action. ~o ~ ~~ ~o om C .. "'-l 2. Pursuant to the terms of the Agreement for Representation, Plaintiff, ~ad~ ~ Brown-Dull, was to under certain terms and conditions of the regarding financial obligations for her legal representation. 3. Gladys Brown-Dull has failed to honor the terms and conditions of her financial arrangement with Petitioner, Reager & Adler, P.c. WHEREFORE, the Petitioners, Reager & Adler, P.C., respectfully request this Honorable Court to grant leave for them to withdraw as counsel for Plaintiff, Gladys Brown-Dull in the above caption. Respectfully submitted, REAGER & ADLER, I' ODGH, ESQUIRE DATE: 5' -./~ \./ () I By: JO J.D. No. 36461 2331 Market Street Camp Hill, PA 1701 (717) 763-1383 VEIUFICATION: I, Joanne Harrison Clough, Esq., of Reager & Adler, PC, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~ - LA ---0 I Esquire CERTIFICATE OF SERVICE I hereby certifY that on the date set forthbelow a true and cotrect copy of the foregoing Petition for Special Reliefe was served on the following individuals via United States First Class Mail, postage prepaid as follows: Dated: Gary A. Dull 816 Belmont Avenue Mechanicsburg, PA 17055 Gladys Brown-Dull Address withheld for privacy protection. :f ./ L\./ ICJ ? JOAN HARRISON Attorney ID #36461 2331 Market Street Camp Hill, P A 17011 (717) 763-1383 UGH, ESQUIRE -;, " ft:: ~ C1 ,: ~;... ~~. :: (1"' c.. ) . , () ;"1 ) ,.: GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 02-3839 Defendant : CIVIL ACTION-LAW : IN DIVORCE GARY A. DULL, ORDER OF COURT AND NOW, this "3 , day of July, 2003, upon consideration ofthe attached Motion to Make Rule Absolute, Movants, Joanne Harrison Clough, Esquire, and Reager & Adler, P.c., are permitted to withdraw as counsel for Respondent, Gladys A. Brown-Dull. BY THE COURT:' ./' J. o?'~ ~:~ o " , < .' \ .. 'v'II'Nf\'V\SNtBd IJ.Nr,Q~ 0'i':f1:r'\9~^1(\0 6'1: :n ~\\j \ 'i: l\\f \:,0 \\""0'\"" ' ..' -' .\lO "OilJ.. . i\"I..'d.:,-.,j~~,."" ,.. .,J 3'JI:l:\Q-{\:\ \1:1 GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 02-3839 GARY A. DULL, Defendant : CIVIL ACTION-LAW : IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel of record on behalf of Plaintiff Gladys Brown- DulL An Order of Court permitting my withdrawal is attached hereto as Exhibit "A." DATE: q- ~ /J / , ESQUIRE JOANNE HARRISON CL Attorney ID No. 36461 2331 Market Street Camp Hill, PA nOli (717)763 -13 83 EXHIBIT "A" GLADYS BROWN-DULL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 02-3839 GARY A DULL, Defendant : CIVIL ACTION-LAW : IN DIVORCE ORDER OF COURT AND NOW, this.JL day of July, 2003, upon consideration of the attached Motion to Make Rule Absolute, Movants, Joanne Harrison Clough, Esquire, and Reager & Adler, P.C., are permitted to withdraw as counsel for Respondent, Gladys A Brown-Dull. BY THE COURT: Is! tlfW .jJ . -Bolt: CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served on the following individuals via United States First Class Mail, postage prepaid as follows: Gary A. Dull 8 1 6 Belmont Avenue Mechanicsburg, P A 17055 Gladys Brown-Dull Address withheld for privacy protection. Dated: 1. '-" ~/Q:3 (i c- r., C L,. '11 Z- ,I> ~C; ......, ,. lp ~-U r::~. ;Z-' zC" 1 U~,):;' i', - ~#,'. (../ ~CJ; :r- ~ '~r1 ~C' (') ':PO '2 .,jl-n C _...t ~ .--.:> "'0 .-1 ::< "\. THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, Esa. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 GLADYS BROWN-DULL Plaintiff, GARY A. DULL, Defendant. CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff, GLADYS BROWN-DULL, moves this court to appoint a Master with respect to the following claims: Equitable Distribution of Marital Property and in support of her motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. Defendant, Gary A. Dull, is not represented by counsel in this action. 3. The statutory grounds for divorce in this matter are those set forth in section 3301 (D) of the Divorce Code. 4. The action is contested with respect to Plaintiff's claims for equitable distribution of the parties' marital property. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one (1) day. ... 7. Plaintiff, Gladys Brown-Dull, filed a complaint in divorce on August 12, 2002. For a period of three years the parties have negotiated in an attempt to amicably resolve the claims at issue. Said negotiations have proven unsuccessful. WHEREFORE, Plaintiff, Gladys Brown-Dull, respectfully requests that the court appoint a master with respect to her claim for Equitable Distribution of Marital Property. Respectfully Submitted, THE LAW OFFICES OF SHANE B. KOPE Dated: October 31, 2005 BY:C- ~~-=) Shane B. Kope, Esquire CC'--22-20D~ 82:40 PM , J.. l:, .i:' :\I~':J ,:,:,.:;:Ib ',/ 1eT 1M 'it i:,~ ;':)i~ '~~EP\.' 1 CES 76J.67-,4 F'.':;12 ~;Lj..'t: '_,:':;'i,1 f~'~ib i::;' lLERIFICATION I. Gladys Brown-Cull. tre Plaintiff :1 this matter. haw read !!'le foreg,l!'lg Motion for Appninfment of a Master. I verity that my a~ermenl$ tn tI1lS Motilln are true and co'-eel and basea upon my personal knowledge I undEll'$t3lld tnat any faise statements herel1 arc made suojocr to the oenalties of 18 Pa. C.S 49')4 relaling to on.wow ralslficallons to authOrities. D"ted (?: b~ J ~. .}OC<;. ,~ ,-J _/:11t41~.~M)YL . Cladj!l Br~;;Tn:Dull ,t". 'i, lv:!:,:ff r' . r= ""':4 ,~ "> :~ ;-'.... ci o 'T1 -l T rd-n r' --<:~m JO '-'-._~(S ,~;~~ ~~) rn i;! ~:U -< ...,,:..: I ...- :::? 1'-) ...,"" THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY LD. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkopeCOlcomcast.net Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3839 GLADYS BROWN-DULL Plaintiff, GARY A DULL, Defendant : CIVIL ACTION - LAW ORDER AND NOW, this ">~ I day of /J~,-" , 2005, E' ~kd ~ Esquire, is appointed master with respect to the following claims: Equitable Distribution of Marital Property. By the Court: 0{'0. rJ\3 ) I~~ 'A. "X ., ~. . >., "'-.) . u ,.(~~0' ~~ . -- ,....f'~(":J q \ '.S VJ L- h\J'r\SIJ'lL "'\ly.\\~\!):)j 1'r\i. :.0 N~ ' "-I~:;~~~~,:\O-cr~\\::\ .'N''''''''' SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-03839 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BROWN- DULL GLADYS VS DULL GARY A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT DULL GARY A but was unable to locate Him in his bailiwick. He therefore returns the MOTION , NOT FOUND , as to the within named DEFENDANT , DULL GARY A ARNOLD LOGISTICS 4410 INDUSTRIAL PARK ROAD CAMP HILL, PA 17011 PER HR. THERE IS NO SUCH EMPLOYEE AT ARNOLD LOGISTICS. Sheriff's Costs: Docketing Service Not Found Surcharge Postage So answers: 18.00 12.48 5.00 10.00 .37 45.85 .... :;!: :,..<":/ --"-7~"~:- R. Thomas Kline Sheriff of Cumberland County -<> SHANE KOPE 11/16/2005 Sworn and subscribed to before me this ;JI.AA- day of ~~ .J ./ ~tJV~ Pro THE LAW OFFICES OF SHANE B. KOPE BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@.comcast.net Attorney for Plaintiff GLADYS BROWN-DULL Plaintiff, vs. :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 GARY A DULL, Defendant CIVIL ACTIONI - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Shane B. Kope, do hereby certify that on this :mh day of December, 2005, I served a true and correct copy of the foregoing Motion for Appointment of Master and Order and Notice Setting Hearing via certified and regular U.S. First Class mail, postage prepaid, addressed as follows: Gary A Dull P.O. Box 1081 Carlisle, PA 17013 ~~ UJ-'~ANE B. KOPE ----".r- .C .----/ ) Shane B. ope, Esq. I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 1/'011 (717) 761-7573 (Attorney for Petlitioner ...., C.:J. ~~g Cl r-,"\ (~;. ...( N OJ q " -! ::'C-r'1 r.1p= -;; rE)' '-L'S- t<Sf'~ \-,.' "-~f~ -. :~ ~ 1"-"1 "'::'" '""-~ :< SHERIFF'S RETURN - REGULAR CASE NO: 2002-03839 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BROWN- DULL GLADYS VS DULL GARY A DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within MOTION FOR APPT OF MASTER was served upon DULL GARY A the DEFENDANT , at 0946:00 HOURS, on the 26th day of January 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to GARY A DULL a true and attested copy of MOTION FOR APPT OF MASTER together with ORDER & NOTICE SETTING HEARING and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 8.80 .39 10.00 .00 37.19 So Answers: /fl ?;Y''''- .f;J;;;,~,.",,,.,.>,": <(<~i"~":--R R. Thomas Kline 01/27/2006 SHANE KOPE Sworn and Subscribed to before By: of' v' ~'/~ V ,/ r .4/YI~~ Deputy Sheriff me this .., ':;0 ~ day of A.D. ... ,""10. Andrew H. Shaw, Esquire LD. No: 87371 61 W. Louther Street Carlisle, PA 17013 (717) 249-1177 Attorney for Defendants GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW GARY A. DULL, Defendant No. 02-3839 IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as counsel for the Defendant, Gary A. Dull, in the above- captioned matter. .^ , Date: 10 - J lOr:) ,;t...---' n rew H. Saw, . squire Supreme Ct. LD. No. 87371 61 W. Louther St. Carlisle, Pennsylvania 17013 (717) 249-1177 (717) 249-4514 (facsimile) Attorney for Defendant ..I, . -.. CERTIFICATE OF SERVICE r, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Praecipe To Enter Appearance, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Shane B. Kope, Esquire Law Offices of Shane B. Kope 4660 Trindle Road, Suite 20r Camp Hill, PA 17011 Attorney for Plaintiff Date: S - (I, 0 L ~ A drew H. haW, E Ulre sup. Ct. LO. No. 87371 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (phone) (717) 249-4514 (facsimile) N = ,-:::. c;,.... '"""'". -"'- "\~,,. ?:J -J ~ ::t:!] f11r-: en :9.10 " , ()C) -~'-i . :;:, ~3_~~ ':y :---\ In '-< -Q ::~ ~) \'-, (JJ Andrew H. Shaw, Esquire l.D. No: 87371 61 W. LoutherStreet Carlisle, PA 17013 (717) 249-1177 Attorney for Defendant GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W GARY A. DULL, Defendant No. 02-3839 IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT LIST OF ASSETS 1. REAL PROPERTY None. II. PERSONALTY A) Snowblower B) Excel Logistics Coat C) Dale Earnhardt Leather Coat D) Other miscellaneous items retained by Plaintiff NON MARITAL PROPERTY A) 1995 Kountry Star Camper (owned by Gary Dull) EXPERT WITNESSES None planned at this time. However, Defendant reserves the right to call an expert witness if necessary. WITNESSES I. Gary Dull Will testify as to truth of statements of parties, and other averments as to possession of personal property and nature of personal property. EXHIBITS 1. Copy of current title to camper. 2. Current Pay stub. GROSS INCOME Defendant's only source of income is through his employment with Excel Logistics. See attached pay stub. PENSIONS Defendant: 401(k) with Fidelity Investments through prior employer Exel (currently obtaining values for this account). COUNSEL FEES Defendant is not making a claim for attorney fees. 2 DISPUTES AS TO PROPERTY AND VALUES OF PROPERTY At this time, counsel for Defendant is not aware of any disputes as to the value of personal property. However, Plaintiff is in possession of the camper titled in Defendant's name alone. Defendant has been unable to make any estimate of fair market value of the camper because he is unable to locate the camper. Defendant is requesting fair rental value of the camper from the date that Plaintiff took sole possession of the camper. Fair rental value is calculated at $350 per month commencing on August 1,2002 through December 2005. The total for said rental value is $14,350.00. MARIT AL DEBTS None. PROPOSED RESOLUTION Plaintiff return to Defendant the two jackets listed above, and Defendant shall retain the snowblower. Plaintiff shall retain the remaining marital personal property of which Defendant is aware. Defendant retains value of 401 (k) as of date of separation. Plaintiff pay to Defendant the fair rental value of the camper and return possession of the camper to Defendant ;J~/J~ O~ Date: By: rew H. Iiaw PA Sup. Ct lD# 87371 Attorney for Defendant 61 West Louther Street Carlisle, P A 17013 717-249-1177 3 , . EXHIBIT 1 N --J .j::::. <.D N --J N N . ,- EXHIBIT 2 SHS STAFFING SOLUTIONS ~ I'I!:J '.li'~ ~:I \~ ", I'll r;';;~~'7~7ro;;:~';~":j Dull, Gary A , 'DESCRIPTION HOURS/UNITS RATE AMOUNT DESCRIPTION I HOURS/UNITS I RATE AMOUNT xel - 3/11 40.00 7.75 310.00 COMMENTS Dull, Gary A zz 3679012 03/11/06 03/17/06 SSN 191-40-975 EMPLOYEE NAME NUMBER PAID THROUGH .00 310.00 310.00 ., :OyERTIME .00 TO 'DATE 2,722.08 THIS CHECK OVERT1ME REGULAR FEO. W/H F.I.C.A. STATE WIH S.U.I. CITY WIH 31. 98 266.76 23.72 208.28 9.52 83.56 .28 2.45 5.27 46.29 OTHER EARNINGS I OTHER DEDUCTIONS I OTHER DEDUCTIONS DirDepost YTD OPT YTD 239.23 2,104.74 10.00 .. , , ., ,. .. .. rs.H~ Staf~in9 K. ... Solutions 4999 Jonestown Road, Suite 20' Harrisburg, Pennsylvania 17109 M& TBank 60,295 ~ ************* DEPOSITED TO YOUR BANK' ACCOUNT ******,*-*** PAYROLL ACCOUNT PAY TO THE ORDER OF 46652 r AMOUNT PA 17055 N 0 }~"~ ill SECURITY FEATURES INCLUDED, DETAILS ON BACK m ...,~,,!,:M~"1==I1:"1t:l.q;~eJ~fnafl~Wm:'l;llW~:I.~fz1mrlJ' DEPOSITED , i __~;ti!'t~'='Jill"~~'1:'W::l"':+--;\."IM;;~~'lm:::'-- Gary A Dull 967 W Trindle Lot 31 Mechanicsburg Rd THIS CHECK VOID IF NOT CASHED WITHIN 90 DAYS 11'000004 bb 5211' .:o:n:lo 2'155': BB'12 5b'1 7'1211' VERIFICATION I verify that the statements made in this Pre-Trial Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. I/;; )04 CERTIFICATE OF SERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following docwnent, Pre-Trial Statement, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Shane B. Kope, Esquire Law Offices of Shane B. Kope 4660 Trindle Road, Suite 20] Camp Hill, PA 17011 Attorney for Plaintiff JJ~7 /" / Date: "'"( ~.I J -' l) (p l ,'~ ~~~ Andrew H( Shaw, Esquire Sup. Ct LD. No. 8737] 61 West Louther Street Carlisle. PA 17013 (717) 249-1177 (phone) (717) 249-4514 (facsimile) r--"', " ~ - f ,,) C:_', , ;-.-', '--,'-, :~ . KOPE & ASSOCIATES BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0.92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 GLADYS BROWN-DULL Plaintiff, GARY A DULL, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT Plaintiff, Gladys Brown, by her attorney, Shane B. Kope, Esquire, files this Pre-Trial Statement TABLE OF CONTENTS SECTION DESCRIPTION PAGE - Informational Notes and Sanctions 2-4 I. Background Information 5-9 II. Listing of Marital Assets and Debts 10-15 III. Listing of Household Goods 16 IV. Listing of Non-Marital Assets and Debts 17 V. Pensions and Retirement 18 VI. Income and Expenses 19-22 VII. Expert Witnesses 23 VIII. Other Witnesses 23 IX. Proposed Resolution 24 X Proposed Exhibits 25 - Certificate of Service 26 - Exhibits Supp. Dated: ~3 ~oo c. INFORMATIONAL NOTES AND CODES, RULES & SANCTIONS NOTES AND CODES 1. "..r" following an entry denotes that the entry (value) is verified by a document. 2. "*" preceding an entry denotes the value of an asset or debt. 3. "H" preceding an entry denotes documents/information to be supplied by Husband. 4. "W" preceding an entry denotes documents/information to be supplied by wife. 5. "E" preceding an entry denotes documents/information to be supplied by either party depending on which party has access to the documents/information. 6. "." preceding an entry denotes an item or value about which a decision has been made. 7. "NM" preceding an entry denotes non-marital property not subject to equitable distribution. 8. "A" preceding an entry denotes an agreed upon value. 9. "~" preceding an entry denotes documents/information of general note. 1 o. "[t]" preceding an entry denotes documents/information of special note. 11. The values used in various Tables herein may, in some cases, be based on estimated values. Those estimated values are subject to adjustment upon appraisal or otherwise. 12. Any adjustment figures used in the various tables herein for illustration purposes only and are not to be deemed a representation on the part of the Plaintiff as to whether an adjustment should be made or the amount of the adjustment, if any is appropriate. APPLICABLE RULES 1. Rule 1920.33(b)(1) (i): The Pre-Trial Statement shall include a list of the assets which may be in chart form, specifying the marital assets, their value, the date of valuation, whether any portion is non-marital; and any liens and encumbrances thereon. 2. Rule 1920.33(b)(91: The Pre-Trial Statement is to include, where there is a disputer, the description and value of any items of tangible personal property, the 2 . , method of valuing each item, and the evidence, including documentation, to be offered in support of the valuation. 3. Rule 1920.33(b)(10): The Pre-Trial Statement shall include a list of the marital debts including the amount of each debt as of the date of separation, the date on which the debt was initially incurred, the initial amount of the debt and its purpose, the amounts and dates of payments made since separation, the evidence that will be offered in support of the claim. 4. Rule 1920.33(b)(7): The Pre-Trial Statement shall include the value of the pension or retirement benefits, the marital portion thereof, and the facts and documentation upon which the party relies to support the valuation. 5. Rule 1920.33(b)(5)(21: The Pre-Trial Statement shall include the party's gross income from all sources, each payroll deduction, and the party's net income, including the party's most recent federal and state income tax returns and pay stubs. If the party intends to offer testimony as to his or her expenses, the party must supply a current expense statement in the form required by the practice and procedure governing an action in support. 6. Rule 1920.33(b)(B): If there is a claim for counsel fees, the Pre-Trial Statement shall include the amount of the fees to be charged; the basis for the charge; and a detailed itemization of the services rendered. 7. Rule 1920.33(b)(2): The Pre-Trial Statement shall include the name and address of each expert the party intends to call at trial as a witness. The report of each expert shall be attached to the Pre-Trial Statement The expert report shall describe witness's qualifications and experience and state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds of each opinion. 8. Rule 1920.33(b)(3): The Pre-Trial Statement shall include the name, address and a short summary of testimony of each person, other than a party, whom the party intends to call at trial as a witness. 9. Rule 1920.33(b)(11): The Pre-Trial Statement shall include a proposed resolution of the economic issues. 10. Rule 1920.33(b)(4): The Pre-Trial Statement shall include a list of all exhibits a party expects to offer into evidence, each containing an identifying mark. All Exhibits that do not exceed three (3) pages shall be attached. All Exhibits over three (3) pages shall be described. 3 SANCTIONS 11. Rule 1920.33Ic}: If a party fails to file either an Inventory as required by subdivision (a) or a Pre-Trial Statement as required by subdivision (b), the Court may make an appropriate Order under Rule 4019(c) governing sanctions. 12. Rule 1920.33(d)(i): A party who fails to comply with the requirement of subdivision (b) of this Rule (the filing of a Pre-Trial Statement with the information set forth in subparagraph (b)) shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence in support of or opposition to the claims for the matters not covered therein. 13. Rule 1920.33Id)(ij): A party shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence that is inconsistent with or which goes beyond the fair scope of the information set forth in the Pre-Trial Statement 4 . , SECTION I. BACKGROUND INFORMATION Gary A. Dull Gladys M. Brown Name Chane Maiden Name Unknown 717-265-4619 Home Phone Work Phone 191-40-9755 205-44-8120 Social Securi Number Unknown Date Party Moved into this Residence Unknown Se tember 2002 Birth Date PA Residenc B an 57 51 A e Ma 30, 1948 Se tember 18, 1954 Date of Birth Sand Patch, PA Place of Birth Caucasian Caucasian Race Health Status Educational Back round No Panera Bread Company Williams Sonoma Domestic Violence Services No Current Milita Service Employer's Name and Address Sales Panera - October 2001 Williams-Sonoma - Feb. 2001 Domestic Violence Services - Jul 2005 Job Position Date Employment Commenced Unknown $32,000 5 Est. Annual Income . . TABLE #1-B MARRIAGE INFORMATION Date of Marriage Place of Marriage Date of Separation Statement of Marital Problems Leading to Se aration Grounds for Divorce Prior Divorce Action Between Parties Number of this Marriage for Wife Number of this Marriage for Husband ~h June 19,1999 Cumberland County June 28, 2002 Irreconcilable Differences 3301 (c) or 3301(d) None 3 2 TABLE #1-C CHILDREN OF THIS MARRIAGE TABLE #1-0 SUPPORT FOR THIS MARRIAGE Name of Pa ort None Beneficiaries of Su o'rt None Amount of Su ort None Allocation None A reement or Order None Date of A reement None Docket Number of Su ort Order None Comments: None 6 . , TABLE #1-E PRIOR MARRIAGES Wife Husband TABLE #1-F CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES TABLE #1-G SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP Name of Party Paying Support Beneficiaries of Support Allocation Agreement or Order Date of Agreement or Order Docket Number of Support Order Comments N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 7 TABLE #1-H PROCEEDINGS INFORMATION: lalnt Au ust 12, 2002 Date of Service Manner of Service T e of Divorce Re uested No Fault Petition for S ecial Relief Au ust 2, 2002 T e of Divorce Re uested Date of Plaintiff's 3301 c Affidavit N/A Date of FiJin of Plaintiff's 3301 c Affidavit N/A Date of Defendant's 3301 c Affidavit N/A Date of FiJin of Defendant's 3301 c Affidavit N/A Date of Plaintiff's 3301 c Waiver of Notice N/A Date of FiJin of Plaintiff's 3301 c Waiver of Notice N/A Date of Defendant's 3301 c Waiver of Notice N/A 8 TABLE #1-H PROCEEDINGS INFORMATION Date of In House Se aration June 28, 2002 Date of Ex iration of 2 Year Se aration Period June 28, 2004 Date of Plaintiff's 3301 d Affidavit N/A Date of Filln Plaintiff's 3301 d Affidavit N/A Date of Service of 3301 d Affidavit N/A Manner of Service of 3301 d Affidavit N/A Date of Plaintiff's Notice of Intent to Request Entry of Divorce Decree and Praeci e to Transmit Record N/A Date of Service of Plaintiff's Notice to Request Entry Of Divorce Decree and Praeci e to Transmit Record N/A Manner of Service of Plaintiff's Notice to Request Ent of Divorce Decree and 3301 d Counter-affidavit Has the case been bifurcated? No Date of Decree Grantin Bifurcation Issue #1 Resolution Issue #2 Resolution. 9 SECTION II. MARITAL ASSETS AND DEBTS The following Table #2 sets forth the listing of the marital assets and debts of the parties: TABLE #2 MARITAL ASSETS AND DEBTS DESCRIPTION OF PROPERTY OR LIABILITY DATE OF VALUE VALUE OF ASSET OR LIABILITY PROPOSED NET VALUE DISTRIBUTION TO WIFE PROPOSED DISTRIBUTION TO HUSBAND ITEM 1 (REAL ESTATE #1) None Comments: Wife's Kountry Star 5 Wheel Camper 3.15.06 Vehicle Loan None Net Value $13,200.00 $13,200.00 Comments: * 3.15.06 NADA RV $18.390 .{ * 3.15.06 NADA TIV $13,200.{ Wife is in possession of Vehicle but Husband's name is on title and registration. Plaintiff purchased and paid for the vehicle prior to marriage. 10 DESCRIPTION OF PROPERTY OR LIABILITY TABLE #2 MARITAL ASSETS AND DEBTS DATE OF VALUE OF VALUE ASSET OR LIABILITY PROPOSED NET VALUE DISTRIBUTION TO WIFE PROPOSED DISTRIBUTION TO HUSBAND Husband's Excel 401 K $9,228.41 $9,228.41 Comments: *6.28.02 @ $9,228.41..[ *3.26.03 @ $70.82 ..[ Husband liquidated 401 K between 7.28.02 and 3.26.03 This was in violation of a Court Order dated Se tember 19, 2002 ITEM 4 (RETIREMENT #2) Wife's Williams Sonoma 401 K Comments: *6.30.02 @ $528.98..[ $528.98 $528.98 II 528.98 $9,228.41 TABLE #2 MARITAL ASSETS AND DEBTS DESCRIPTION OF PROPERTY OR LIABILITY DATE OF VALUE VALUE OF ASSET OR LIABILITY NET VALUE PROPOSED PROPOSED DISTRIBUTION TO WIFE DISTRIBUTION TO HUSBAND ITEMS Wife's Persona It $9,800,00 $9,800,00 Comments: See Attached Exhibit.[ These items were Wife's prior to marriage, Husband took them at time of se aration and whereabouts are unknown $9,800,00 ITEM 6 Husband's Personalty TBD TBD TBD TBD TBD Comments: ITEM 7 DEBT #1 Civil Judgment Cumberland County Court of Common 4,2002 Pleas Comments: *4,2002 balance @ $937.00.[ ($937,00) ($937. 00) ($937,00) ITEM 8 (DEBT #2) A TT Wireless # 5363921 11.2002 Comments: *11,2002 balance @ $812,00.[ ITEM 9 (DEBT #3) UGI Corp, # 214168869023 8.2002 Comments: * 8,2002 balance @$433,00.[ 12 TABLE #2 MARITAL ASSETS AND DEBTS DESCRIPTION OF DATE OF VALUE OF PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR NET VALUE DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO WIFE TO HUSBAND . ITEM 10 /DEBT #4) GMAC ($251.00\ # 20469152834 3.2001 ($251.00) ($251.00) Comments: * 3.2001 balance @ $251.00.[ This is the liquidation fee for a lease returned vehicle ITEM 11 (DEBT #5) N. American Cable Company ($73.00) ($73.00\ ($73.00\ # 48108803 8.2002 Comments: * 8.2002 balance @ $73.00 { ITEM 12 /DEBT#6l PPL Utilities # 6604078011 11.27.2002 ($1,063.39) ($1,063.39) ($1,063.39) Comments: * 11.27.2002 balance @ $1,063.39 { ITEM 13 (DEBT #6) Account # I I Comments: 13 TABLE #2 MARITAL ASSETS AND DEBTS DESCRIPTION OF PROPERTY OR LIABILITY DATE OF VALUE VALUE OF ASSET OR LIABILITY NET VALUE PROPOSED DISTRIBUTION TO WIFE Comments: PROPOSED DISTRIBUTION TO HUSBAND Amount Due in 50/50 Division $29,188.00 Adjustment Figure for SO/50 $14,594.00 $4,343.41 NOTES AND COMMENTS: 14 $14,594.00 TABLE 1-A CALCULATION OF EQUAL DIVISION OF RETIREMENT PLANS ITEM 3 (RETIREMENT #1 ) Husband's Excel 401 K Comments: 6.28.02 $9,229.41 $9,229.41 $9229.41 ITEM 4 (RETIREMENT #2) Wife's William 6.30.02 Sonoma 401K Comments: $528.98 $529.98 $528.98 Totals From Above $9,758.39 $9,229.41 $4,879.20 $528.96 $4,879.20 Amount Due in 50/50 Division $4,350.21 15 SECTION III. LISTING OF HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY The fol/owing Tables #3-A and #3-8 sets forth the household goods and contents and other personal property of the parties: Table #3-A HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN WIFE'S POSSESSION TBD if necessa Comments: Total Items in Wife's Possession . Table #3-B HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY IN HUSBAND'S POSSESSION See Attached Exhibit Comments: Total Items in Husband's Possession 16 SECTION IV. NON-MARITAL ASSETS AND DEBTS The following Table #4 sets forth the non-marital assets and debts of the parties Wife is not aware of any non-marital property and, therefore, none is listed on the following table #4 TABLE #4 NON-MARIL TAL PROPERTY AND DEBTS 17 SECTION V. PENSIONS AND RETIRMENT BENEFITS TABLE #5 RETIREMENT PLANS DESCRIPTION OF PROPERTY OR LIABILITY DATE OF MARITAL VALUE VALUE OF BENEFITS TOTAL VALUE OF BENEFITS SUPPORTING FACTS OR DOCUMENTATION ITEM 1 Husband's Excel 401 K $9,228.41 TBD Comments: *6.28.02 @ $9,228.41 .[ *3.26.03 @ $70.82 .[ Husband liquidated 401 K between 7.28.02 and 3.26.03 This was in violation of a Court Order dated Se tember 19,2002 ITEM 2 Plan Statement Wife's Williams Sonoma 401 K Comments: *6.30.02 @ $528.98.[ $528.98 TBD Plan Statement 18 SECTION VI. INCOME AND EXPENSES The following Table #6-A sets forth the incomes of the parties. TABLE #6-A INCOME OF THE PARTIES Gross Pa WIFE BIWEEKLY $1,569.00 HUSBAND FICA Medicare Federal Tax Slate Tax Local Tax Union Dues Grou Life Enhanced Medical Pre Tax Dental Pre Tax Vision Su lemental Life Grou Term Life 401K NET INCOME PER PAY PERIOD $1,153.89 $2,307.78 19 '. TABLE #6-B MONTHLY EXPENSES OF THE PARTIES HOME EXPENSES Rent $550.00 First Mort a e Maintenance and Re airs Electric $50.00 Gas Oil Tele hone $50.00 Water Sewer Trash EMPLOYMENT Public Trans ortation Lunches TAXES Real Estate Taxes Personal Pro ert Taxes Incomes Taxes Not Withheld ation Taxes INSURANCE Homeowners Insurance 20 TABLE #6-B MONTHLY EXPENSES OF THE PARTIES Automobile Insurance $100.00 Accident Insurance Health Insurance $57.00 Other Insurance AUTOMOBILE EXPENSES Pa ments $365.00 Fuel $50.00 Maintenance and Re air License and Re istration MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE Doctor o tical Dental Orthodontic Hos ital Medicine S eclal Needsrrhera EDUCATIONAL EXPENSES Private School Parochial School Colle eNocational 21 TABLE #6-B MONTHLY EXPENSES OF THE PARTIES PERSSONALEXPENSES Clothin Food $100.00 Barber/Hairdresser Membershi s Other Personal Ex enses MISCELLANEOUS EXPENSES Household Hel Child Care Entertainment Pa TV Vacations Gifts Le al Fees Charitable Contributions Other Child Su ort TOTAL EXPENSES 22 . . SECTION VII. EXPERT WITNESSES The following Table #7 sets forth the listing of the experts who the party intends to call to testify in this case: TABLE #7 EXPERT WITNESSES To be supplied as soon available ** Additional expert who may be called to testify are not known at this time. Wife reserves the right to call additional expert witnesses upon proper notification to the other party once those expert witnesses are identified and retained. SECTION VIII. OTHER WITNESSES The following Table #8 sets forth the listing of the anticipated witnesses other than the experts who will be called to testify in this case: TABLE #8 LAY WITNESSES ** Additional expert who may be called to testify are not known at this time. Wife reserves the right to call additional expert witnesses upon proper notification to the other party once those expert witnesses are identified and retained. 23 SECTION IX. PROPOSED RESOLUTION The following is Plaintiff's proposed resolution of the issues presented in this case. A. DIVORCE: A No-Fault Divorce Decree should be entered under either section 3301 (c) or (d). B. EQUITABLE DISTRIBUTION: The parties' marital assets and debts should be divided and distributed in accordance with the schedule set forth in Section II of this Pre-Trial Statement The Kountry Star 5th Wheel Camper's registration and title is released back to the Wife's name. 24 SECTION X. PROPOSED EXHIBITS The following Table # 10 sets forth Plaintiffs listing the proposed exhibits to be submitted at the hearing in this case. Exhibits are attached or to be supplied as indicated below. TOSE No. DESCRIPTION ATTACHED SUPPLIED 1. Wife's Income and Expenses Statement X 2. Wife's Pay Stubs X 3. Wife's 2005 Federal Income Tax Return X 4. NADA Value for Wife's 5 Wheel Camper X 5. Proof of Camper Purchase X 6. Husband's EXCEL 401 K Statements X 7. Wife's Williams Sonoma 401K Statement X 8. Wife's Personalty Listing X 9. PPL Electric Collection Notice X 10. UGI Collection Notice X 11. Wife's Credit Report Showing Other Debts X 25 KOPE & ASSOCIATES BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope(1i1comcast.net Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 GLADYS BROWN-DULL Plaintiff, GARY A. DULL, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire do hereby certify that on this 13th day of April, 2006, I served a true and correct copy of the foregoing Plaintiffs Pre-Trial Statement via regular U.S. First Class mail, postage prepaid, addressed as follows: Andrew H.Shaw, Esquire 61 W Louther St. Carlisle, PA 17013 KOPE & ASSOCIATES ~ ~- Shane B. Kope, sq. 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (Attorney for Petitioner) 26 . PART I. INCOME A. EMPLOYMENT INFORM EMPLOYER #1 PAN ERA BR ADDRESS CAMP HILL S POSITION SALES ASSO PAY PERIOD BIWEEKL Y (f EMPLOYER #2 WILLIAMS S ADDRESS 3025 MARKE POSITION SALES ASSO PAY PERIOD BIWEEKL Y (t EMPLOYER #3 DOMESTIC V ADDRESS POSITION PAY PERIOD BIWEEKL Y (H ATION EAD CIATES HOPPING MALL HOURLY SO HOURS AND PAY CHANGE ONOMA CIATES T STREET, CAMP HILL PA 17011 HOURLY SO HOURS AND PAY CHANGE 10LENCE SERVICES OURL Y SO HOURS AND PAY CHANGE ~ EXHIBIT " w ~ ~ /. '" ,j <i. B. EMPLOYMENT INCOME: DESCRIPTION WIFE BIWEEKLY $1,569.00 HUSBAND Gross Pa FICA Medicare Federal Tax State Tax Local Tax Union Dues Grou Life Enhanced'Medical Pre Tax Dental Pre Tax Vision Su lemental Life Grou Term Life 401K $1,153.89 $2,307.78 " C. EXPENSES: DESCRIPTION WIFE HUSBAND Rent First Mort a e $550.00 Maintenance and Re airs Electric Gas Oil Tele hone Water Sewer Trash $50.00 $50.00 Public Trans ortation Lunches Real Estate Taxes Personal Pro ert Taxes Incomes Taxes Not Withheld Homeowners Insurance DESCRIPTION WIFE HUSBAND Automobile Insurance Accident Insurance Health Insurance Other Insurance $100.00 $57.00 Pa ments Fuel Maintenance and Re air $365.00 $50.00 Doctor o tical Dental Orthodontic Hos ital Medicine Private School Parochial School- Colle eNocational " DESCRIPTION WIFE HUSBAND Clothin Food Barber/Hairdresser Membershi s Other Personal Ex enses $100.00 Household Hel Child Care azine/Books Entertainment Pa TV Vacations Gifts Le alFees Charitable Contributions Other Child Su ort TOTAL EXPENSES i iiil f ill i~ri ~ ,lila, it II -II ., -I l ~ ~. f S1 .~ ~ ~f(l "'".. ~~' ailii' '" '" '" '" ~ f f i ~. ... ~I~;;!!t ~~8iifl~:" \l If ~ '~ i~~ 0" ~ g , ;; R g " w ~ ~ i i :c~ ,;; m ',.. S:' o < ,~ ~. ,,0' s: I :' ~I ~ ! 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"0" ;.~\ :~ \11 \ ~~ \ , i \ . :; \ , \ Iii \ : \ \ ..~\ .\ 1m " 1 ...... ... .. i \ 0 n ..Ii '" , i. \ 'g'1l .. .. , ....0 , " ~ ..... ~~-o -t'" ~ : :s: ~ ",n ~\ 'a'!i -"/ft ..~ ;0 ...... ~~,. ~l i\ ..0 .ar" !!!n! ~~'O ~ \~~~i~ gg\ . .. . ....'5 ... ~ . fl ~..fl ~ . .. . .. .. fl . . fl ~ . . . . . "~dJti , . .. ~ . . ."tt"&ti . . . . . . . . , 8..~~~~ !In . , . . ~~Ui8 . . .. J9U , . ,,~.. . . . . ~r ~~ QIoOi,N l~-O '"~~ fD ~o~.... .... - ~~~ . ...... Fo<:'1040 Department of the Treasury" Internal Revenue Service U.S. Individual Income Tax Return 2005 IRS Use Only - Do not write or staple In this space ForlheyearJan. 1-Dec. 31, 2005, or olhertax year bagmning , 2005, ending .20 OMS No. 1545-0074 Label Your first name and initial Last name Your social security number (See instructions) L A 8 E L Gl.ad s M If ajoint return, spouse's first name and initial rown Last name 205-44-8120 Spouse's social security number Use the IRS label, Otherwise, please print or type. Presidential Election Campaign H E R E Home address (number and street). If you have a P.O. box, see instructions Apt. no Exemptions .... You must enter .. _ your SSN(s) abolle. _ Checking a box below will not change your tax or refund. .... Check here if you, or your spouse if filing jointly, want $3 to go to this fund (see instnJctions)'" 0 You 0 Spouse 1 IXJ Single 4 0 Head of household (with qualifying person) (See instructions) If 2 0 Married filing jointly (even if only one had income) the qualifying person is a child but not your dependent. enter 3 0 Married filing separately. Enter spouse's SSN above this child's name here. .. and full name here. ..... 5 D Qua\ifying "Widow{er) with dependent child (See instructions) 68 IV! Yourself. If someone can claim you as a dependent, do not check box 6a . .} Boxes checked _1 I,e.I on6a and 6b b Souse. No. of children c Dependents: (3) Dependent's (4)_X if ~al- on 6c who: (1) First name last name socl:l S~~i~~ber Telati~~ShiP to l~[g~~~Q. lived with you ~ . did not live with you due to divorce or separation 0 (see instructlonsl - City, town or post office, state. and ZIP code. If you have a foreign address, see instructions 2101 Cedar Run Drive 207 Filing Status Check Ollly one box. If more than four dependents, see instructions. Dependents on 6c 0 not entered above Add numbers on Q d Total number of exemptions claimed lines above ... 7 Wages, salaries, tips, etc. Attach Form(s) W-2 . 7 32 052. Income 8. Taxable interest. Attach Schedule B if required Sa 3. Attach Form(s) b Tax-exempt interest. Do not include on line 8a . I 8b I W-2 here. Also 9a Ordinary dividends. Attach Schedule B if required . . . 9. attach Forms b Qualified dividends (see instructions) . . . . ~ W-2G .nd 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) 10 1099.R if tax . . was withheld. 11 Alimony received . . . . . . . . . 11 12 Business income or (loss). Attach Schedule C or C-EZ . 12 If you did not 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here ~ 0 13 get a W-2, see instructions. 14 Other gains or (losses). Attach Form 4797 . 14 15. IRA distributiOllS . . . . . ~ I b TS)(able amount (see ins1ructions) 15b 16. b Taxable amount (see instructions) 16b Pensions and annuities .. 16a Enclose, but do 17 Rental real estate, royalties, partnerships, S corporations, trusts. etc. Attach Schedule E 17 not attach, any 18 Farm income or (loss). Attach Schedule F 18 payment. Also, 19 Unemployment compensation 19 please use Form 1040-V. 20. Social security benefits . I 20a I I b Taxable amount (seE! instructions) 20b 21 Other income. List type and amount (see instructions). 21 22 Add the amounts in the far right column for lines 7 through 21. Thts is our total int:ome ~ 22 32,055. 23 Educator expenses (see instructions) . . 23 Adjusted 24 Certain business expenses of reservists, performing artists, and Gross fee-basis government officials. Attach Form 2106 or 2106-EZ 24 Income 25 Health savings account deduction. Attach Form 8889 . 25 26 Moving expenses. Attach Form 3903 26 27 One-half of self-employment tax. Attach Schedule SE . 27 28 Self~employed SEP, SIMPLE, and qualified plans. 28 29 Self-employed health insurance deduction (see instructions) . 29 30 Penalty on early withdrawal of savings 30 31a Alimony paid b Recipient's SSN ... -- --..---- - 31. 32 IRA deduction (see instructions) . 32 33 Student loan interest deduction (see instructions) . 33 34 Tuition and fees deduction (see instructions) 34 . EXHIBIT 35 Domestic production activities deduction. Attach Form 8903 . 35 ~ ~ '" 36 Add lines 23 through 31a and 32 through 35 w 3 o. . . ~ 37 Subtract line 36 from line 22. This is your adiusted Qross income w 32 055. ~ 1! For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. "' Form 1040 (2005) ~ UYA ~ ~ Fo";"'040 (2005) G1advs M Brown 205-44-8120 Page 2 TaXi and 38 Amount from line 37 (adjusted gross income) 38 32 055. Credits 39. Check {D You were born before January 2, 1941, 0 Blind. } Total boxea W if: 0 Spouse was born before January 2, 1941, 0 Blind. checked .. 39a 0 Standa"" \_ b If your spouse itemizes 011 a separate relum or you were a dual-status alien, see Instruction.s 8.C\ct cneck here" 39b 0 Deduction ~40 Itemized deductions (from Schedule A) or your standard deduction (see left margin). 40 5 000. for~ 27 055. 41 Subtract line 40 from line 38 . . . 41 . People who 42 If line 38 is over $109,475, or you provided housing to a person displaced by Hurricane Katrina, checked any t.oxon line see instructions. Otherwise, multiply $3,200 by the total number of exemptions claimed on line 6d . 42 3 200. 39a or 3gb or 43 Taxable income. Subtract line 42 from line 41. If line 42 is more than line 41 , enter -O~ 43 23 855. who can be claimed as a 44 Tax (see instructions)_ Check if any tax is from: a 0 Form(s) 8814 b 0 Form 4972 . 44 3 216. dependent. 45 Alternative minimum tax (see instructions). Attach Form 6251 45 Seeinstr . . . All others 46 Add lines 44 and 45 . . ~ 46 3 216. Single or 47 Foreign tax credit. Attach Form 1116 if required . 47 Married filing 48 Credit for child and dependent care expenses. Attach Form 2441 . 48 separately, 49 Credit for the elderty or the disabled. Attach Schedule R 49 $5,000 . . Married filing 50 Education credits. Attach Form 8863 50 jointly or 51 Retirement savings contributions credit. Attach Form 8880 . 51 Qualifying 52 Child tax credit (see instructions). Attach Form 8901 if required . 52 widow(er), $10,000 53 Adoption credit. Attach Form 8839 53 Head of 54 Credits trami . 0 Form 8396 b 0 Form 8859 . 54 household, 55 Other credits. Check applicable box(es): . 0 Form 3800 $7,300 b 0 Form 8801 c 0 Form 55 -"'" -- 56 Add lines 47 through 55, These are your total credits 56 o. 57 Subtract line 56 from line 46. If line 56 is more than line 46, enter -O~ ~ 57 3.216. Other 58 Self-employment tax:. Attach Schedule SE. 58 59 Social security and Medicare tax on tip income not reported to employer. Attach Form 41:37 . 59 Taxes 60 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required 60 61 Advance earned income credit payments from Form(s) W-2 61 62 Household employment taxes. Attach Schedule H . 62 63 Add lines 57 throuah 62. This is vour total tax . . ~ 63 3 216. Payments 64 Federal income tax withheld from Forms W ~2 and 1099 . 64 3 613, ,_ 65 2005 estimated tax payments and amount applied from 2004 return 65 If you have a _66. Earned income credit (EIG) NO. fl' . . . 66. qualifying Nontaxable combat pay election .. 66b 1- child, attach b Schedule EIC 67 Excess social security and tier 1 RRT A tax withheld (see instr.) 67 68 Additional child tax credit. Attach Form 8812 . 68 69 Amount paid with request for extension to file (see instructions) . 69 70 Payments from: ill 0 form 2439 bD Form 4136 cO Form 8885. 70 71 Add lines 64, 65, 66a, and 67 throunh 70. These are your total oavments . ~ 71 3 613. Refund 72 If line 71 is more than line 63, subtract line 63 from line 71. This is the amount you overpaid 72 397. Direct deposit? 73. Amount of line 72 you want refunded to you . . . ~ 73a 397. See instructions ~b Routing number 1231382241 I ~ C Type: IXI Checking o Savings and fill in 73b, ~d Account number 12182195293 ] 73c, and 73d. ~ I 74 I 74 Amount of fine 72 you want applied to your 2006 estimated tax Amount 75 Amount you owe. Subtract line 71 from line 63. For details on how to pay, see instructions ~ 75 o. You Owe 76 Estimated tax penalty (see instructions) . I 76 I Third Party Designee Sign Here Joint return? See instructions Keep a copy for your records. Do you want to allow another person to discuss this return with the IRS (see instructions)? /XI Yes. Complete the following. D No Designee'S Phone Personal identification name ~ PREP R no. ~ number (PIN) ~ I Under penalties of perju~t~_ll: are that I have exarT1lned thiS return and accompanYing SChedules and statements. and to the best of my Knowledge and belief, \hey are lrue, cplTeet;an complete. Declaration of preparer (other than taxpayer) IS based on all Information of which preparer has any knowledge ~;) . Your signatur8.._'" '/ Date Your occupation Daytime phone number I ') \) Sales Associate 717-761-2984 ure, If a joint return, both must sign Date Spouse's occupation Paid Pre parer's Use Only Preparers lItrr... signature ,. Check if self-employed Preparer's SSN or PTIN 00417046 20-3984334 Firm's name (or Jason M. Harshbar yours;f,e/f-employedl. ~ 1510 Chatham Road address, and ZIP code Carn Hill PA 17011-6022 CPA EIN Phone no. UYA 717 506-0422 Form 1040 (2005) R. D, KENNEDY SALES & SERVICE, INC, 1394 Old York Road, DillsburgPA 17019 Phone 717-432-9741'" Fax 717-432-1400 March 15, 2006 To: Gladys Brown 1995 Kountry Star 5th Wheel Trailer. NADA Book Value is Retail $18.390; Wholesale $13,200. R. D. t . EXHIBIT <i '" w L( ~ ~ >-' '" ~ ~ ~ , v....~ rn--901 A ":AKE Of VEHICLE U STAEET ~ NOTE IF A CO PURCHASER, OTHER lHAN YOUR SPOUSE, IS LISTED ABOVE, CHECK ON OF THESE: BLOCKS IF NO BLOCK IS CHECKED, Tl1"lE WILL BE ISSUEO AS "'TENANTS IN COMMON". JOINT TENANTS WITH RIGHT OF SURVIVORSHIP A. 0 (ON DEATH OF ONE OWNER. TITLE GOES TO SURVl'IlNG OWNERj NOTE IF THE VEHICLE IS BEING LEASED, CHECK THIS BLOCK 0 3. RegeDc:ly So.~ TENANTS IN COMMON, . " 0 (ON DEATH OF ONE OWNER, INteREST OF OEGEASED OWNER GOES TO HIS OR HER HEIRS OR ESTATE.) .IF BLOCK IS CHECKED, COMPlETE AND ATTACH rDR,M MV-IL . ~ . ltouUt Star ':':l ~ GROSS VEHICLE WT f.1 ~ RAT!:~G 156 ~~ 00 :gFUH DO'EsEL 0 ELECTRIC 8 LAST NAME (OR FULL BUSINESS NAME) Brown CO-PURCHASER BrtIIm, c. 0 ACTUAL MIlEAGe DIFFERS FROM ODOMETER READING FOR 0 MILEAGE OVER 1': REASONS OTHER tHAN CALIBRATION ERROR AND ACTUAL 99,999 ' ~ i MILEAGE IS UNKNOWN I j ~ WARNING AN INACCURATE ODOMETER STATEMENT MAY MAKE YOU LIABLE FOR DAMAGES' TO YOUJ:l i; TFiANSF~REE PURSUANT TO f A09A OF THE MOTOR VEHICLE INFORMATION AND COST SAVINGS ACT OF 19n O. 1ST LIEN DATE: 7-5-95 .1i g 1ST LIE. NHOlDER :J ~ STREET " Z CITY ODOMETER READING ..,.. IF NO LIEN. CHECKl] 2ND LIEN DATE' lIENHQlotR . > TeNTHS 3 __!!./A __~ . ... IF NO LIEN, I;HECKD 4. AEGISTRATIClN OR PeocE~SlH<l 'EE TITLE 'EE ENCUMBRANce, 1 FEE 15.00 5. 00 ;..'- ,,, ,." 8. E~ MAKE OF VEHICLE ~ BODY TYPE {SON, BUS. TK, ETC,) f PASSENGER TAXI/BUS CONDITION OF VEHICLE STATE ZIP MODEL YEAR o POOR SEATING CI\PAC,rTY , REPLACEMENT 'FEE - . 9. TOTl\l PAlo ~ (ADO 1 'n-lR!J B) Send ()}e Ch8ck In Th/sAmolIJt ... 1099, 75 RE.Q REGISTERED GROSS COMBlNj\TION WT. GROSs COMBlN"TlON Wl. RATlNG o SELF-PROPELLED HOW AND WHERE!S vEHICLE USED? ONOT '3ELF-PROPEll.ED {lMPH ONl.Y) G ORIGINAL PLATE'; Chllck One o Pl.A'TE TO BE ISSUED BY BUREAU {PROOF OF INSURANCE MUST BE PinACHED,) o EXCHANGE Pl.ATE fO BE ISSUED BY BUREI\U Ci TRANSFER OF PREVK)USLY ISSUED PlATE o TRANSFERS REPLAcl:MENr OF PLATE o TRj\NSFER & RENEW,.,\.. OF Pl,.,lE O TnANSFER OF PLArE S REPLACEMENT O~ SHCKf=R REASON FOR REPLACEMENT EXPIRES DLOST V'_. 0 STOLEN DOEFACED 0 NEVER ~EC'D (lOST IN MAil) NOTE: If "NEVER RECEIVED" block is chsc:ked, applicant must complel" Form MV.44. VIN ~~ II 4522:5616401 SIGNATURE OF PERSON FROM WHOM PLATE IS BEING TRANSFERRED (IF OTHER THAN APPLICANT): lR1n3S20R0072719 O TEMPORARY PLATE lSSuEO 8'< fULL AG-E:NT SIGN HERE RELATIONSHIP m APPLICANt INSURANCE COMPANY NAME' POLiCY NO, (OR ATTACH BINDER) POLICY EXPIRATION DATE H I CERTIFY THAT ON MONTH 7 DAY 5 YEAA-95.. \s~m:~ c~€8~~~A,w ~11Ji~~"J.fIOlr~THfH~EHA~b\elS l~~~T,AN~ t, IS COMPLIANCE WITH AL.L APPL.lCABlE PROVISIONS OF THE VEHICLE CODE ' AND DEPARTMENT REGULATIONS. l/WE ACKNOWLEDGE THAT I/WE MAY lOSE MY/OUR OPERATING PRIVllEGE(S) OR VEHICLE REGISTRATlON(S, F R FAILU TO MAINTAIN FIN CURRENny REGISTERED VEHICLE FOR THE PERIOD OF REGISTRATION. I/WE FURTHER ACKNOWlEDGE THAT I/WE MAY. E SUBJECT TO A F E NOT EXCEEDING $6,000 AND IMPRISONMENT OF NOT MORE THAN TWO 121 YEARS fOR ANY FALSE STATfMENT THAT I/WE NlAkE ON THIS FORM, AND I/WE CERTIFY THAT I{WE HAVE EXAMtNEO ANO SIGNE.D ~ THIS FORM AHE.R I"TS COMPlETION; AND, THA'-, tf AN EXEMPTION FROM PAYMENT OF SALES TAX IS CLAIMED, I AM/WE ARE AUTHORIZED TO CLAIM THIS EXEMPTION. I/WE ~ SUB AIBED AND SWORN FURTHER CERTIFY THAT All STATEMENTS HEREIN ARE TRUE AND CORRECT AND MAkE APPLICATION ~ TO F ME: FOR CERTIFICATE OF TITLE FOR THE VEHICLE DESCRIBED IN BLOCK A. It , SIGNAT OF INOIVI AL 0 UTHOR EO SIGNER i o !i . ~ ,. EXHIBIT ISSUING AGENT INfORMATION \ MESSENG . ~ ~ '" w ~ w ~ l' "' ~ <i. 5 S E A L SIGN IN PRESENCE OJ: NOfAIlV R. D, KENNEDY SALES & SERVICE . Travel Trailers & Snowmobiles 1394 Old York Road OILLSBURG, PA 17019 SALlES ORDER ...-..---.... CUSTC'MER OPDEA NO. 4Q98 ~~~~~~~.~ (717) 432.9741 ""i~x E)~~MPTN()- SOLD TO, SHIP TO: TERMS /c /7/)/ ~ . ' ~ f7- /~/2- .....-~-- -., I CHARGE Ica a STOCK NUMB~ -~-~- , .r:~pC>NT. 'tM~ ....AMO(M...- CASH .IMaSERETt"~~T ISHPVIA ..... OESCFIIPTION OUANTm' ~ 95 ..'1J '" .€Kw?3 4:::':'o/.dt~,!;JJ ~ ,.i /N8,.f<~~";3 SQ'> 9'~{L'S 5-- ~.3.:s C> C> rJ- ~E~]) Z~ 7'i;;itL J\~!.,." /N ZEI< 35'20 tV 007 )'7/J / -I- Su 13, 'nIl-I. ~, o > t... ~79.7 0 () I me:- fkJ1fN3. floT7fLY ;..::r'<> .t/,~ 4 /(p C> '" -~p 7/fTE 74'1.. . tHJ . Ip ............... [/7(:~ I ~e.. II m..tl.1,(!.f, 1.~ 19,9o3 c-o 137$' ORIGINAL '. "h~ -I') 1. ",,' ':..,':::~,,___-J..":'_"':""';"" . .c,___ . "(2E:, c'- e. ," g/~ll.e .'Z!L ..... () I rrz ,r-- . .... f (,LI 7::> - RECEIVED BY TOTAL ""~ PPODUr;151(~!'",,G,"lo",Il...Olll1100rd,"Pll(}~ErOll'REE1!o:)-r.>563M .0A 40% Pre-Consumer Content '<.jj '0% Post-COOS\m"l9T ConIen\ '=-, -... . ._------:~'&~-. -,.--...........-----....,---.-..,. -.., ,,~:~'S',- ~i)\ y) :v i'\') ""-K.'''';'~? -j ::-----". r..,~. -S. <to . \' Y'-, '_>- 'l)0 ",' ,":) -\}, \ .\('<;;" , y.\- 06 ',;,-<' ~\.\,~,:,,, , ~ ')-b '-",./ i<_ -t.;. ",f,) / -4'Y ".... , '>-:, "'N~'(}) ~ . ^'. .h.. '1;iJ \i"""w!>""i..%>}...(Jj. \t;:'~':0'<:?_~~~\ .~_.. ,,,.' , ;"" '~"".' .,,~ 61: ~ 0fI ~ OEAlEfl'8lICENSE NO. AUTHORIZED SlGNA11..R Of CEALER , ....'" ' &.lng dUy twOrrI ~ otlh .ey. IhtIt 1M ,1M1&menl, < , HI Iortl.... truI ~ COIT4d, IlblCfibod and ~11 i --~iI'^ ...... L__.....~....'~.., '-' ._~ tdn1tbefortm.'lhIIi ,.,.,.... ' ' . ;,~" . ,,'~.('} '!:"~>~" ',<"/(i<{', ~)'oI, 1L-. '. """,!!i<!~'>!t.LO",...... . . , ~""'l1.L, """"",--.N>Io t ' ,;~ ' "..I.r ;',.'..;-~~?1. .'':~:':'t~: ';.f'j~,:,,..H6tMUA1'ICIiClJr(Y."~":"I1\fU~'~,';;, -' ~- " > ! ~ , I ~, F r ;? .~., , , , ( .," i ~. t " ~. ;! \ 1: II t .~ ;..~},~ , Union CoIPy of YOJ''<i '" FOR iJAllE AECfiIIIEO. I TtE t.H)ERSDS), TRANSfER TIt: VEtICt.E NAME OF '.' -. JI'lfOIMEA(SJ .~ ADOAES8 " AN)CER'TFt to llE BEST Of NY KNOWlEOOE, NCJff.AATlON /JH)BElEFlHlERPENALTY OF LAW THAT nil: ~1..ulS..NEW}H) HAS toIOT BEEN .', AeOlITfJlWH fttS OR NIV STATE JHJ A.T ne TIdE OF aiU\lERy ~ \'13iCLi WAS Il..8.ECT TO nE F'Otlowht ~Ql.hTYlIlrneST5 AM> NOtE .'+' O'tt$ AI'<<' WJIflIWiT TfTt,.e-TO Ttt!WttCll, ' , "..... ," ;,:. ~ .......~ ReQUfIJI you. TO "ATllHI ~.. "'IAU UPON "'ANSP'!F1 or OWNER" -"- .. ~ 1~""'''''~''~'''''''OCkIfNt'''f..d1ng'' Ind f.'iKt. the .c:lnlmn..... oftM ....hlel. IlIlI... one 01 .,.~....... ~ W...... 0 1 the .....,unt of ......,. ...IIICII. '" '.0'" cH 18,_ Of 0 I Th. lHtom.l... fNdlng. ftOt 1M .Clllll......". ~'.'JMOlMTOP~' ,""DATeOfLIN KNl OF' W' N FAVOR OF . I.BIl<X.OOl'S NJ;jAEM .:~ .',..... B"': NN.E OF OEALEAGHP TtnE Oft FOSITIQH DEALER'S LICENSe NO. AUTHOfIZEO SIONATlAE OF rlEALER =.~= ::'e::c."l:'::': ~I~~e::~ ~mlbeforerne" ..,01 ........ .. "'-- t..aolftfyPubIlc ~ NOTNlZAfK)H CH.Y F 1E0lH0 f\I Tmtil .lRStlCTION ,FOFI,~~l(~~~!,~ 1,tE~~ON TH6 fAG€ Of THSCEHTFICATE TO ~'/"'>i?,';';'" ..:. . .~~~"'td""""ft.lP ..v~.,*MW.11CIN OOBEI.I:F lNlEAPENM..TY OF lAW THAT Ti-E VEHClf ISrl:W,IJ() HAS NoT BEEN ...~::::.OftNft If. AtE _. .ATTtfi,TIoE OfDEI.IVERY TtE. VEttCLeWAS Sl.8..ECT TOTtE FOUOWNl SEClIVTV MEfESTSNDNOtE ~~~m;:;~'~An! '"' ~ ........ IM'OH "'ANSFER Of OWNER_ , I","" 10....... of,.. ~ 1tlt4 the OOclflM,t... f.adlng I. .nd f.'.cl.lh. .cll,lal mll.a,,' 01 Itl. ....hk:.. un.... on. of the...........-...t6.. ~ 0' t 1M amount 01 mil..". alat.d I. In I"C'" 01 eg,otD rA 0 2 Thl odom.l... f..dlng Ia nollh. .eluall'lln..gl "~"~':. DAreOF~ I<.N)OFlf;N liFAVOAOf ",.;'. ;,;') .....,- TInE OR POSITION ........... ~..;.:-:",_~h"';,~ \,,1 ~;XE~L_? ,Exel Re~irement Savings Plan Retirement Savings Statement GARY A DULL 816 BELMONT AVE MECHANICSBURG ,PA 17055- 'Ii' Customer Service: (800) 835-5095 Fidelity Investments Institutional Services Co. 82 Devonshire Street Boston, MA 02109 Your Account Summary Statement Periodi 6/2812002tc> 7/2512002 Beginning Balance Employee Contributions Employer Contributions Withdrawals Loan Repayments Fees Change in Market Value $9,228.41 $69.20 $27.69 - $1,000.00 $85.36 . $13,75 - $162.72 Ending Balance $8,234,19 Additional Information Vested Balance Outstanding Loan Balance Dividends & Interest Loans are an asset of your account but are not included in your ending balance or reflected in your asset allocation. $8,234.19 $600,42 $43.67 Your Personal Rate of Return This Period -1,7% Your Personal Rate of Return is calculated with a time-weighted formula, widely used by financial analysts to calculate investment earnings. It reflects the results of your investment selections as well as any activity in the plan account(s) shown. There are other Personal Rate of Return formulas used that may yield different results. Remember that past performance is no guarantee of future results. Your Asset Allocation Statement Periodi 6/28/2002 to 7/25/2002 . EXHIBIT ;J, I '" w ~ w Cp l< t; ~ ~ ~ A Bond/managed Income .$6,50444 (7899%) A Stock Investments .$1,348.61 (16.38%) A Short-term Investments .$381.13 (4.63%) Your account is allocated among the asset classes specified above as of 7/25/2002. Percentages and totals may not be exact due to rounding. The AdditIOnal FUlld Intormatlon section lists the underlying allocation of your blended funds, Market Value of Your Account Statement Period: 6/2812002 to 7/2512002 Displayed in this section is the value of your account for the statement period, in both shares and dollars. Shares Shares Price Price Market Value Market Value Investment as of as of as of as of as of 8s01 6/27/2002 7/2512002 6/2712002 7125/2002 6/2712002 7/2512002 ,,,,"",",,,,,,,,,,,",,,,,",",.,,,,. "''''''''.-'''''''' ""'''''''''''"'''''-.--'''" Blended Fund Investments $3.415.55 $2,931, n Janus Balanced Fund 181.292 166.012 $18.84 $17.66 $3,415.55 $2,931.77 Bond/Managed Income $5,812,86 $5,302,42 STABLE VALUE FID MGD INC Port 1,890.070 1,724.410 $1.00 $1.00 $1,890.07 $1.724.41 INCOME Fidelity Invst GR BO 532.265 484.169 $7.37 $7.39 $3,922.79 $3,578.01 Account Total $9,228,41 $8,234,19 Remember that a dividend payment to fund shareholders reduces the share price of the fund, so a decrease in the share for the statement period does not necessarily reflect lower fund performance. You have invested a portion of your account in Blended Funds. Blended Funds generally invest in a mixture of stocks, bonds and shorHerm investments, blending long-term growth from stocks with income from dividends and interest. Please refer to the Addlll:Jr1l"1 Func l'1tormatlOrl section to see how your blended funds are allocated across the three asset classes. /1 .:f ,'f Your Contribution Elections i's of 312712003 This section displays the funds in which your future contributions will be invested, All Eligible Sources ...",......".."",""""",._.,,,..,,,,,.,,,,,"",,..._.,,,,,,,,,,,,,"..._,,-,,,,,,,,,,,,-,,,,,,,,"'" Investment Option by Asset Class Percent Blended Fund Investments JANUS BALANCED FUND 40% Bond/Managed Income Stable Value FID MGD INC PORT 20% Income FIDELITY INVST GR BD 40% Total 100% Your Contribution Summary Statement Period: 6/2812002 to 7/2512002 Contributions Pre Tax Exel Company Match Exel Profit Sharing Period to date $69.20 $27.69 $0.00 Vested Percent 100% 100% 100% Total Account Balance $3,669.44 $1,671.93 $2,692.82 Total Vested Balance $3,669.44 $1.871.93 $2,692.82 Your Account Activity Statement Period: 6/2812002 to 7/25/2002 Use this section as a summary of transactions that occurred in your account during the statement period, ~Detailed Transaction History Activity Janus Belanced Fldellfy Invsf GR FID MGD IHC Totel Fund SD Pon """"""""_....,......"".,,,,,,""..,,"- """""''''''''''''-'''""''''''"'''-'''''''"'''''''"'' "'''"'''.'''''''"''''"'''''''.--".'''''''''' Beginning Balance $3.415,55 $3.922,79 $1.890,07 $9,228,41 Employee Contributions $27.67 $27.69 $13.84 $69.20 Employer Contributions $11.08 $11.07 $5.54 $27.69 Withdrawals - $356.32 - $436.61 - $207.07 - $1,000.00 Loan Repayments $34.16 $34.14 $17.06 $85.36 Fees - $5.04 - $5.87 - $2.84 - $13.75 Change in Market Value - $195.33 $24.80 $7.81 - $162.72 Ending Balance $2,931.77 $3.578,01 $1,724,41 $8,234.19 Dividends & Interest $21.76 $14.10 $7.81 $43.67 Your Account Information As of 03/2612003 General Information Status Terminated Payroll Deductions - y , . Use this section to verify that Fidelity's records of your information are up-to:date. Loan Loan Loan 10# Date Amount Balance as of 612712002 Principal Paid This Period Bllanee as of' Interest Paid 7/2512002 . Thla Parlod PD LOAN1 01/16/2001 $2,000.00 $680.54 .$80.12 $600.42 $5.24 Additional Fund Information As of 3/27/2003 Use this section to determine the asset allocation of your blended investments, Blended Investment Stocks Bonds Short Term JANUS BALANCED FUND 46.00 % 41,00 % '13,00 % Blended investments generally invest in more than one asset class. The blended investment asset allocation above reflects the stated neutral mix or, jf not available, the asset mix reported by Morningstar, Inc. for mutual funds or by investment managers for non-mutual funds. "IMPORTANT PRINTING INSTRUCTIONS" In order to print this statement, click anywhere on this statement screen and then press the print button in your browser. For more information or help, please click on Help or call (800) 835-5095. Copyright@ 1996-2003 FMR Corp. All rights reserved. AA=7 DC=42 HW=3 IA=6 MX=3 55=1 ~x~L.z . ' ,Exel Re,tirement Savings Plan Retirement Savings Statement GARY A DULL 816 BELMONT AVE MECHANICSBURG, PA 17055- 'Ii' Customer Servicei (800) 835-5095 Fidelity Investments Institutional Services Co. 82 Devonshire Street Boston, MA 021 09 Your Account Summary Statement Periodi 6/30/2002 to 3/26/2003 Beginning Balance Employee Contributions Employer Contributions Withdrawals Loan Repayments Forfeitures Fees Change in Market Value $9,233.97 $90,46 $36,19 - $9,926.41 $484.86 $62.33 - $85.00 $174.42 Ending Balance $70,82 Additional Information Vested Balance Dividends & Interest $70,82 $287.55 """"""",,,,,,,,,,,,,,,,,,,,",,,,",,,,,,,,,,,,,,,"''''''''''''''''"''-''" "''''""",,''''--"",," ",."""'_""""m"",,,"""''' YIOUirlP1!l!r:~{'uu!1l1 Rate of Return This Period 30.1 % Your Personal Rate of Return is calculated with a time-weighted formula, widely used by financial analysts to calculate investment earnings. It reflects the results of your investment selections as well as any activity in the plan account(s) shown. There are other Personal Rate of Return formulas used that may yield different results. Remember that past performance is no guarantee of future results. Statement Period: 6/3012002 to 3126/2003 Your Asset Allocation A Bond/managed Income .$53.92 (76.15%) A Stock Investments .$13.16 (1860%) A Short-term Investments .$3.72 (5.26%) Your account is allocated among the asset classes specified above as of 3/26/2003. Percentages and totals may not be exact due to rounding. The Additional Fund Information section lists the underlying allocation of your blended funds. Market Value of Your Account Statement Period: 6/3012002 to 3/2612003 Displayed in this section is the value of your account for the statement period, in both shares and dollars, Shares Shares Price Price Market Value Market Value Investment as of as of as of as of as of as Of 6/2912002 3126/2003 6129/2002 3/2612003 6/29/2002 3/2612003 ."""""""""'"".-'""""" Blended Fund Investments $3,426,43 $28,63 Janus Balanced Fund 182.451 1.603 $18.78 $17.86 $3,426.43 $28.63 Bond/Managed Income $5,807,54 $42,19 STABLE VALUE FIO MGD INC Port 1,890.070 14.090 $1.00 $1.00 $1,890.07 $14.09 INCOME Fidelity lnvst GR SO 532.265 3.698 $7.36 $7.60 $3,917.47 $28.10 Account Total $9,233.97 $70.82 Remember that a dividend payment to fund shareholders reduces the share price of the fund, so a decrease in the share for the statement period does not necessarily reflect lower fund performance. You have invested a portion of your account in Blended Funds. Blended Funds generally invest in a mixture of stocks, bands and short-term investments, blending long-term growth from stocks with income from dividends and interest. Please refer to the i\Gd",'O:'J; F: ~JI Id Illlorl)' allon section to see how your blended funds are allocated across the three asset classes. Your Contribution Elections As 01 3/27/2003 This ~ection Glisplays the funds in which your future contributions will be invested. All Eligible Sources Investment Option by Asset Class Percent ".,."""""""""""""",,,."-,,,",,,,,,",,,","'-"""'""'''''''''''' Blended Fund Investments JANUS BALANCED FUND 40% Bond/Managed Income Stable Value FID MGD INC PORT 20% Income FIDELITY INVST GR BD 40% Total 100% Your Contribution Summary Statement Periodi 6/30/2002 to 3/26/2003 Contributions Pre Tax Exel Company Match Exel Profit Sherlng Period to date $90.46 $36.19 $0.00 Vested Percent 100% 100% 100% Total Account Balance $0.00 $0.00 $70.82 Total Vested Balance $0.00 $0.00 $70.82 Your Account Activity Statement Periodi 6/30/2002 to 3/26/2003 Use this section as a summary of transactions that occurred in your account during the statement period. Dividends & Interest ~Detailed Transaction !History Janus Bslsnced Fidelity Invsl GR FIO MGO INC Total Fund SO Port "'""'","'""""''''-'"""""",,,, """'"""."'''"'.,.,.......- $3,426.43 $3,917,47 $1,890.07 $9,233,97 $36.18 $36.19 $18.09 $90.46 $14.48 $14.47 $7.24 $36.19 - $3,445.57 - $4,421.19 - $2,059.65 - $9,926.41 $193.94 $193.95 $96.97 $484.86 $24.94 $24.93 $12.46 $62.33 - $29.99 - $37.43 - $17.58 - $85.00 - $191.78 $299.71 $66.49 $174.42 $28.63 $28.10 $14.09 $70,82 $48.47 $172.59 $66.49 $287.55 Activity Beginning Balance Employee Contributions Employer Contributions Withdrawals Loan Repayments Forfeitures Fees Change in Market Value Ending Balance Your Account Information As of 03126/2003 General Information Status Terminated Payroll Deductions - y Use this section to verify that Fidelity's records of your information are up-to-date, Loan 10# Loan Date Loan Amount Balance .a 01 612912002 Principal Paid This Period Balance as 01 312612003 Intaraat Paid This Period "",,"'_.,,"""'"...._,,""'""'''''''''''''''''"_.,~''''''''''''"'''''"'''''''''",,'''''- PD LOANl 01/16/2001 $2,000.00 $680.54 -$680.54 $0.00 $21.24 Additional Fund Information As 013/27/2003 Use this section to determine the asset allocation of your blended investments, Blended Investment Stocks Bonds Short Term "",,,,,,,,,,,,,,,,,,,,,,",",,...,,.._,,,,,,,,,,,,,,,,,,,,,"-,."~,,,,",,,,,,.,,,,_.,,,,,,,, JANUS BALANCED FUND 46.00 % 41,00 % 13,00 % Blended investments generally invest in more than one asset class. The blended investment asset allocation above reflects the stated neutral mix or, if not available, the asset mix reported by Morningstar, Inc. for mutual funds or by investment managers for non-mutual funds. "IMPORTANT PRINTING INSTRUCTIONS" In order to print this statement, click anywhere on this statement screen and then press the print button in your browser. For more information or help. please click on Help or call (800) 835-5095. Copyright@ 1996-2003 FMR Corp. All rights reserved, AA=7 DC=42 HW=3 IA~6 MX=3 88=1 ~x~J_? , ' ,Exel Re,tirement Savings Plan Retirement Savings Statement GARY A DULL 816 BELMONT AVE MECHANICSBURG , PA 17055- . Customer Service: (800) 835-5095 Fidelity Investments Institutional Services Co. 82 Devonshire Street Boston. MA 02109 Your Account Summary Statement Periodi 1/1/2002 to 6130/2002 Beginning Balance Employee Contributions Employer Contributions Loan Repayments Fees Change in Market Value $7,195,06 $655,10 $838,10 $576,18 - $27,50 $18,94 Ending Balance $9,255.88 Additional Information Vested Balance $9,255,88 Outstanding Loan Balance $680.54 Dividends & Interest $157.25 Loans are an asset of your account but are not included in your ending balance or reflected in your asset allocation. YOur Personal Rate of Return This Period 0,3% Your Personal Rate of Return is calculated with a time.weighted formula, widely used by financial analysts to calculate ,nvestment earnings. It reftects the results of your investment selections as well as any activity in the plan account(s) shown. There are other Personal Rate of Return formulas used that may yield different results. Remember that past performance is no guarantee of future results. Your Asset Allocation Statement Period: 1/1/2002 to 6130/2002 Williams-Sonoma, Inc. Associate Stock Incentive Plan For the Period 04/01/2002 - 06/30/2002 Participant Name: Gladys M. Brown-Dull Before-tax Savings: 4% Birth Date: 09/18/1954 Beneficiary Name(s): Account Activity Stock Fund Williams-Sonoma Money Market Fund Vanguard Balanced Fund Dodge & Cox Totals Investment Elections 100% 0% 0% 100% Employee Account (100%) Balance as of 04/0112002 Your Contributions Transfers Dividends/Interest Fund Earnings Withdrawals 49.69 0.00 0.00 49.69 180.82 0.00 0,00 180.82 0.00 0,00 0.00 0.00 0.00 0.00 0.00 0.00 33,98 0.00 0,00 33.98 0.00 0.00 0.00 O.OC 264.49 0.00 0.00 264.49 Balance as of 06/30/2002 Company Match (20% ) Balance as of 0410112002 Company Contributions Transfers Dividends/Interest Fund Earnings Withdrawals Forfeitures 49.69 0.00 0.00 49,69 180.82 0.00 0.00 180.82 0.00 0.00 0,00 0,00 0.00 0,00 0.00 0,00 33.98 0.00 0.00 33.98 0.00 0,00 0,00 0,00 0.00 0.00 0.00 0,00 264,49 0,00 0,00 264.49 528,98 0,00 0,00 528,98 17.253 About Your Statement Balance as of 06/30/2002 Total All Accounts Equivalent Shares Williams-Sonoma, lnc, Common Stock was valued at 30.660 per share as of 06/30/2002. To track Williams-Sonoma, Inc. stock performance, check the New York Stock Exchange under WSM. ~ EXHIBIT '" i 7 ~ ~ ~ '. WIFE'S PERSONALTY Micro Convection Oven Two Night Stands to Bedroom Suite Two Lamps Bed, Box-spring and Mattress (full) Bathroom Scales Ceramic Paints Christmas Decorations Three Antique Fishing Poles and Gear Antique Step Stool 19" Zenith Television Craftsman Tools Craftsman Lawn Mower Pots & Pans Other $800,00 $800,00 $150,00 $800,00 $200.00 $200.00 $400.00 $2,000.00 $400.00 $400.00 $1,500,00 $500,00 $150,00 $1,500.00 Total: $9,800.00 ~ EXHIBIT '" w ~l \< i;i ~ ~ ~ POWELL, ROGERS & SPEAKS, INC. P.O. Box 61107 Harrisburg, Pennsylvania 17106-1107 (717) 896-2850 NATIONWIDE (800) 762-4697 November 27, 2002 E29759-012 227066 12651 1,,,111.,,111,,,,,,11,,,111,,,1,1,,1.1,1.1.1,,,1.1,1,,,1.,11,I Gladys M Brown 2101 Cedar Run Dr Apt 207 Camp Hill PA 17011-7459 CASE #: E29759 Creditor Ppl Electric Utilities Account # 6604078011 Regarding 1829 Elm St Amt Owed 1063.39 Total Due: $1063.39 Dear Gladys M Brown: You have failed to satisfactorily respond to our initial communications and have made no attempt to pay this bill placed against you. Ignoring this bad debt will not make it go away. Thi~) attitude serves no good cause, you must look closely at the gravity of your intentions. Similarly, we are being forced to seriously consider our options in this matter. I strongly suggest that you reconsider your posi tiOD and pay this bill today or contact our offices immediately to forestall any further collection efforts from occurring. We have enclosed a return envelope for your payment. #E29759 on your check or money order. Please include your CASE Sincerely, Powell, Rogers & Speaks This is an attempt to collect a debt by a debt collector and any information obtained will be used for that purpose. ESDPRSPIOl2 ~ EXHIBIT " w ~ ~ q ~~ ~ ~ Office Hours: Monday ~ Thursday 8:00 AM ~ 9:00 PM. Friday 8:00 AM ~ 5:00 PM . Saturclay 9:00 AM ~ 12:00 ,R/TURN SERVICE REQUEST[Jl Credit Plus Collection Services 2491 Paxton 5t . Harrisburg PA 17110-1010 (717) 664-7742 or (800) 814-6546 Phone Hrs: Mon Barn - 9pm, Tues, Bam - 5pm, Wed 8am - 9pm, Thur and Friday 8am - 5pm, Sat 8am - 12pm ESP Office Hours: 8:30am - 5pm ESP Mon - Fri " 1111111111111111111111111111111111111111 , . PO 80;'; 4:;8 'V!:lnheim f'A. 17545-0458 December 3.2002 Credit Plus Collc~tiol1 Services PO Box 458 Manheim PA 17545-0458 111111I1111.1.llllul.I.I.IIIIIIIIIIII.I.IIIIIII.I.I..I.11.1,1 244974-1 107299 648 111I11I1111111111I111I11111111111111111.1.1111111111.1,,111I11 Gladys M Brown.Oull 1300 Old Trail Rd E!tm P A 17319-8826 . -':.~ __~_~ ~ _ _. ,_ __" _ .~. Past.Due Bal-ance ~-- -- Re: Ugi Utilities In(: Harrisburg Account #i 244974310442 Client ID#: 2]4168869023 .... ***Plcase Detach And RctUlll The Tup Portion Of The Notice With Your Payment. *"'* Re: Account #: Client lD Hi For; Tots! Balance: Ugi Utilities ]nc Harrisburg 244974310442 214168869023 ] 829 Elm St $433.31 The account listed above has been referred to this office for collection, It is to your benefit to pay this claim. Do not neglect your obligation. AH payments must be made directly to this office for p;ompt credit to your account or call (800) 814-6546 to make anangements. Unless you notify this office within thirty-days after receiving this notice that you dispute the validity of the debt or any portion thereot; this office will assume this debt is valid. If you notify this office in writing within thirty-days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of a judgment and mail you a copy of such judgment or verification. If you request this office in writing thirty-days after receiving this notice, this office will provide you with the name and address or the original creditor, if different from the current creditor. This is an attempt to collect a debt and any infonnation obtained will be used for that purpose. This communication is from a debt collector. I f requesting a receipt, please enclose a self addressed stamped envelope. All payments must be made direetly to the address above, If your check is rerunted for insufficient funds or closed account, a $25.00 charge will be added to your account. (~.--l Enclosed is payment in full. ( __~ Enclosed is my 0 VISA or 0 MasterCard number: If you wish to pay by VISA or MasterCard, fill in the infonnation below and return the entire letter to us. At.:count Number Payment Amount I $ Expiration Date ---1- I Card Holder Name lDNPll:S011 Signature of Card Holder Date Credit Plus Collection Senices . 2491 Paxton SI Harrisburg PA 17111-1010 . Telephone: (717) 664-7742 or ( . EXHIBIT ~ ~ '" w ~ ~ /0 >" "' ~ ~ < File Number: Page: Date Issued: 134959167 1 of 7 03/09/200, " : :~: : ,_';:1 TransUnion Pers'onall nformation Name: GLADYS M, BROWN SSN: XXX-XX-8120 Date of Birth: 09/1954 Telephone: 761-2984 Your SSN is par1ially masked for your protection Other Names; DUll,GLADYS,M DULLBROWN.GlADYS,M You have been on our liles since 06/1970 CURRENT ADDRESS PREVIOUS ADDRESS Address: 2101 CEDAR RUN DR 207 CAMP HilL, PA 17011 Date Reported: 10/2004 Address: 1829 ELM ST NEW CUMBERLND. PA 17070 Date Reported: 10/2004 Address: 34 REGENCY SOUTH, CARLISLE, PA 17013 EMPLOYMENT DATA REPORTED E.mployer Name: Date Reported; WILLIAM SONOMA 03/2005 Position: Hired: Employer Name: Date Reported: PANERA BREAD & WILLIAMS SONOMA 02/200~ Position: Hired: Employer Name: Date Reported: WILLIAM SONOMA 09/2003 Position: Hired: frnplOYE'cr N~n:e: Date Reported: COVENCO 10/1990 P(}<",ition: Hired: Special Notes: Your Social Security number has been masked for your protection. You may request disclosure of the full number by writing to us at the address found al the end of this report. Also, if any ilem on your credit report begins with 'MED1', it includes medical inform.ltion and the data following 'MEn1' is not displayed to anyone but you except where permitted by law. Public Records The following items obtained from public records appear on your report. You may be required to explain public record items to potential creditors, Any bankru- ptcy informalionwill remain on your report for 10 years from the date oUBing. Unpaid lax liens may generally he reported for an indefinite period of time depending on your slate of residence. Paid tax liens may be reported for 7 years from date of payment. All other public record information, including discharged chapter 13 bankruptcy, remains for up to 1 years. COMMON PLEAS Docket#i 00200001779 CUMBERlAND (OUNlY Type, CIVIL JUDGMENT ROOM 203 Court Type: COMMON PLEAS HARRISBURG, PA 17103 (717) 240~6195 Estimated date that this item will be removed: 03/2009 Date Filed: Responsibility: Plaintiff: Amount: 04/2002 INDIVIDUAL DEBl AGWAY ENERGY PRODUCTS $937 PENNSYLVANIA FEDERAL COU Docket#: 00174 228 WALNUT SlREH Type, CHAPTER 7 BANKRUPTCY DISCHARGED HARRISBURG, PA 17101 Court Type: FEDERAL DISTRICT (717) 901-2840 Date Paid: 06/1998 Assets: $0 Estimated date that this item will be removed: 12/2007 Date Filed: 01/1998 Responsibility: INDIVIDUAL DEBT Plaintiff,l\ttomey: LEE ERIC OESTERllN Liabilities: $0 - . ~ ~ '" w ~ w ~ "' ~ ~ ~ J/- EXHIBIT 03102005000000022 COft5U~er Credit report for GlADYSM.. BiOWtl File Numbero 134959167 Page, 2 of 7 Date Issued, 03/09/2005 cm CARDS #559002240740 8725 W SAHARA AVE MC02-02-03 ll-lE LAKES, NV 89163-7802 Phone number not available Btllance: D.te Upd.ted, High a.fOli,e, Cred~ Limit, P.st Due. Loan Type, CHARGE ACCOUNT Rem.rks. >PROAT AND LOSS WRITEOFF< Estimated date that this item will be removed: 03/2006 COLUMBUS BANK AND TRUST #4146750000862232 PO 80X 1 05555 a.~n'e' . A llANTA, GA 30348 Dilte.UP.~led' (800) 348-8783 Hlghlt'~I"", CreditLliillt, Lo.n Type, CREDIT CARD Rem.rks' PURCHASED 8Y ANOll-lER LENDER Estbn.ted d.te th.t this item will be ~mo..d, 02/2011 $2.458 01/2005 $2,458 $2,200 >$2,458< P~ Status: >CHARGED OFF AS 8AD DEBT< '"it\,diliiil$e;.RtVd~illfAaOUNT Rerpon$lblUty. INDMDUALACCOUNT D.teOpened, 03/1990 D.te Closed, 04/1999 $0 01/2005 $1,101 $460 P.y.Status: ,CHARGED OFF AS BAD DEBT< AccounHype, REVOLVING ACCOuta:. Re$ilonslbility' INDIVIDUAL ACCOUNT Date Opened' 04/2003 Date Closed, 11/2004 Date P.Ul. 03/2004 CREDIT PLUS COLLECnONS #8010260007558497 PO 80X 67533 . . aa..""." $4~3 HARRISBURG, PA 17106-7533 Oat. Updated' 62/2005 (800)344-3125 Original Amount, $433 Ori(ln.lcredltoro 10 UGI UTILITIES INC Past Due, >$433< Loan Type, COLLECTION AGENCY/ATTORNEY Rem.rks, >PlACED FOR COLLECTlON< . D.te pla'ed!ot'_o~tll!~' 11/2002 Estimated d".lI!.tlhl. ~em will be removed, 07/2009 f1RSTPR~.__K #5178007243004140 900 W DELAWARE ST . a.lan'e, SIOUX FALLS, SO 57104-0347 D.'e Updated, Phone number not avaUa_ble High Balance: Credit L1m~, Past Due: Loan Type, CRWIT CARb" Rem....'>PROA'rAND tdS$WRITEOFF< Estimated date that this Item wi" be ~mo..d, 10/2010 FMS INC #1028470 PO 80X 707600 TULSA, OK 74170-7600 (918) 747-4884 Pay Status, 'COLLECTION ACCOUNT< ACtollnHype, OPEN ACCOUNT Re$ilonslbllity' INDIVIDUAL ACCOUNT \'v-<' $535 07/2004 $544 $4~ >$';35< Pay Status: >CHARGED OFF AS BAD DEBT< A,~~u~t Type, REVOLVINGI\Ccl?\!.I!T,' ReSponsibility, INDIVIDUAr A<COUNT Date Opened, 06/2003 DateClo,ed. 12/2003 Balance: $184 Date Upd.ted. 09/2000 Original Amount, $184 Ori(lnalCredlton FMS INC FORMERLYSUNOCO Past Due: >$184< Pay Status: >COLLECTION ACCOUNT< Account type: OPEN ACCOUNT Responsibility, INDIVIDUAL ACCOUNT Date Closed: 09/2000 Remarks. >PLACED FOR COLLECTION< Date placed forcoUectlon: 08/2000 Esthnated date that this Item will be removed: 01/2007 031020050000000228 4/14 DT (onsumer(redit report for GLADYS M. BROWN PROVIOIAN #4559542600710535 POB 9007 PlEASAHTON, CA 94S66-4122 Phone number not available Balance: Dale Updaled: Nigh Balance: Credit lImil, Loan Type: CREDIT CARD Remarks: PURCHASED BY ANOTHER LENDER Esllmaled date Ihalthls ilem will be removed, 04/2009 SUNRIsECREOITSERVICES #5363921 260AIRPOtlT: PLAZA BLVD FARMIN6DALE. NY 1173S-3946 (516) 785-BOO Loan TYP"' COLLECTION AGENCY/ATTORNEY Remarks: ,PLACED FOR COLLECTION, Date plac.ed for collection: 11/2002 Estimated date thaHllisitem will bOTemoved: 06/2009 Filelll/lllbe" 1349591~7 Page: 4of7 Datelssued, 03/09/200S $0 OS/2003 $1.063 $$00 Pay Status: >CHARGEO Off AS BAD DEBT' Accounl Type: REVOlVING ACCOUNT Responsibility: INDIVIDUAL ACWUNT Date Opeoed, 07/2001 Ollte CI.sed, 11/2l$2 Batanc.e~ $812 Dale Updated: 0SI/2003 OrlclnalAnwun" $766 OrighialLtWdIIOli Art WlR~s.ElIYfCES CENT PA Past Due: ,$812' U:G I CORP OF READING'#2'141688690 23 PO BOX 13009 READiN6, PA 19612-3009 Phone number not available Balance: Dale Updaled, Nigh Iblante: Past DUe: Loan Type, UTILiTY COMPANY Remarks: >PRom AND LOSS WRITEOFF, Estimated date that this Item wlU be removed: 03/2009 Pay Slatus: ,COLLECTION ACCOUNT< Aceount~ OPEIfAOCOUNT Responsibility: INDIVIDUAl; ACCOUNT ::',_.1 '">;. $433 02/2005 $171 '$433' Pay Slatus, >CHAAGEDOff AS BAD DEBT, Account Type: OPEN'ACCOUNT ResponsllllUty: INOMOUAL ACCOUNT Dil(I~If!"111~0Il1 Dall!'C"'slid!.' 08'/:1002 ; ;\>.~tb~.'Ti;,.. $6r,!13 ,.. li!'A1~,'!,,,<.~> '," $llll'911.,.>"."""""",,; 6Q;;MQNniii*1:~'\- _iiQltU€U#25543062.00 20 5I\IlRTINGlIlRfE~ DR IIIECHAllICSBURG; PI'170S0-2392 Phone number not available Balance: Dete Updated: High Balance, Tenns: Loan Type, AUTOMOBILE Rema"'" ClOSED ..'ji>>~~,B:1I#2554306100 2~nNG;6REEN DR MECHANjC$BURG, PA 170S0-2392 Phone number not available 8a,.oce: Date \lpdated: Hl&Ii Balance, Terms: Loan Type: AUTOMOBilE Remarks: ClOSED $0 08/1996 $18,066 MONTHLY $364 Pay Status, . PAIIH)IIcPAYI86 AS AGREED ActounHype' INS~TACCOUNT R......iilMUtylIllli~'A\1€ll\!IIT Date Ope~<>d' 11(199$" Oat.,.........., 07/1_ $0 12/1995 $15,255 MONlHlY $300 Pay Status: PAID OR.PAYiNG AS AGREED AceounHype, INSTALLMENT ACCOUNT ResponslblUty: INDIVIDUAL ACCOUNT Date Opeeed, 10/1994 Dale Closed, 11/1995 03102005000000022B 6/14 DT (onsumer(redit report for GLADYS M. BROWN ',' G~C #20469152834 PO BOX 105677 ATLANTA, GA 30348 (866) 814-8548 loan Type: AUTOMOBilE Remarks, ,PRo.FIT AND LOSS WRlTEo.FF< Estimated date that this item will be removed: 02/2008 I C SYSTEMS COLLECTIONS #4235244710 Po. BOX 64378 SAINT PAUl, MN 55164-0378 (651) 481-6333 Remarkso ,PLACED Fo.R COLLECTION< Date placed for collection: 04/2004 Estimated date that this item will be removed: 08/2009 File Number: Page: [late Issued: 134959167 30f7 03/09/2005 ~.". ';::r'....' .," . ::::,:-. :;':...:., TransUnion. Balance: Date Updated: Tenns: $251 OS/2003 24 MONTHLY $253 Pay Status, ,CHARGED OFF AS BAD OEBT< Account Type, INSTAllMENT ACCOUNT Respnnsibllity, PARTICIPANT ON ACCo.UNT Date Opened, OS/2000 Date Closed, 03/2001 Balance: $1.694 Date Updated, 09/2004' OriginalAmoun" $1#'" OrillriaIC"'dkor: REAGERADlER P C Pay Statuso 'COllECTION ACCOUNT< Account Type, OpmACCOUNT Responsibility, INDIVIDUAL ACCOUNT JEFFERSON CAPITAL SYSTEM #0199234868003 16 MCLELANO RO Balance, $1,101 SAINT CLOUD, MN 56303 Date Updated, 02/2005 (320) 229-8669 OriginaIAm..n" $1,101 OriglllalCreditor: 12 ASPIRE VISA loan Type, FACTORING COMPANY ACCOUNT Past Due, >$1,101< Rema,llso ,PLACEO FOR COllECTION< Date placed for collection: 11/2004 Estimated date that this item will be removed: 02/2011 LANE BRYANT MAllORDER #746649276 PO BQX182121 COLUMBUS,OH 43218-2121 (800) 888,9265 loan Type, CHARGE ACCOUNT ~~.Jl<s"PRom ANBJOSS WRITEOFFc<; '" Li EStimated date that this item will be removed; 02/2006, .- N AMERICAN CABLE COll #48108803 PO BOX 827 EDGEMONT, PA 19028-0827 Phone number not available loan Type, COllECTION AGENCY/ATTORNEY Remarks, ,PLACED FOR COllECTION< Date placed for collection: 08/2002 Estimated date that this item will be removed; 06/2009 PN€ BANK #6002006006832067 2730 lIBERlY AVE PITTSBURGH, PA 15222-4704 PhoneblJmber not available Pay Stat&sl >(OElECUONACCOUNT< AccountType: OPEN ACCOUNT Responsibility: INDIVIDUAL ACCOUNT Date Closed, 11 / 2004 Balance: Oate Update'" fti~}l~,tanc~: Credltllmft, $353 01/200S<. $353 $0 Pay Status: >CHARGED OFF PS BADDEBT< Account Type, REVOLVING ACCOUNT Responslbility:INOIVIDUAI ACCOUNT Date Opened, 01/1990 Date Closed, 03/1999 Balance, $73 Date Updated, 11/2002 Original Amount, $73 OriginalCredftor: COMCAST Past Due: >$73< Pay Status, >COllECTION ACCOUNT< Account Type: OPEN ACCOUNT Responsibility: INOIVIDUAIACCOUNT z Balance: Date Updated: High Balance: TeRnS: $0 11/2001 $30,644 180 MONTHLY Pay Status: >90 DAYS PAST DUE< AccountTyPe, INSTIIltMEN<T'ACCo.UNT Responsibility, INDIVItlOAL ACCOUNT Date Opened, 06/1996 Date Closed, 11 / 2001 10a1lJl'!>e' MANUFACTURED HOUSING Remarks, CLOSED )Maximum delinquency of 90+ days occurred in 06/2001 for $1,121< Estimated date that this item will be removed: 07/2007 - - - 031020050000000228 5/14 OT (!;)nsumer Credit report for GLADYS M. BROWN file Number: 134959167 Page: 5 of 7 Date Issued, 03/09/2005 '~f:'; 1~: TransUnion. , GEM'BI/C PENNY #677801177 PO BOX 981400 El PASO, 1)( 79998-1206 Phone number not available Balante: Date Updated; High Balance, $0 02/2005 $369 PaySta!us; PAID OR PAYING AS AGREED AccountType, REVOLVING ACCOUNT Responsibility: INDIVIDUAL ACCOUNT Date Opened: 01/1978 Date Closed: 01/1998 HECHTCO#18557600 PO BOX 8079 lORAIN, OH 44055 (800) 495-7855 Balance: Date Updated; Hip 1Ialance, $0 04/2004 $207 Pay Status; PAID OR PAYING AS AGREED AccountType, REVOLVING ACCOUNT ResponsibiUty,INDIVIDUAlACCoUNT Date Opened, 03/1996 Date Paid, 04/1997 HSBC NV#5488975025037139 PO BOX 98706 !AS VEGAS, NV 89193-8706 (800) 477'6000 BiI~nc.e: Date Updated, HllilIlf.12'..,e, C"'dltLIIltit< Pay Status, PAID OR PAYIIIG AS AGREED AccountType, REVOLVING ACCOUNT Responsibility, INDIVIDUAL ACCOUNT Date Opened, OS/2003 MEMBERS tSTfEDC U 5000 LOUISE DR MECHANICSBURG , PA 17055 (717) 697.1161 RequestedO", 02/28/2005 InquilyType, INDIVIDUAL FINANCIAL REf:OVERVSERV P.O. BOX 385908 MINNEAPOLIS, MN 55438 (888) 852-6023 RequestedOn, 11/15/2004 InqllhyType, INDIVIDUAL Permissible Purpose: COLLECTION BENEFICIALjHFC 961 WEIGEL DR ELMHURST,Il60126 Phone number not available RequestedOn, 09/25/2004 InqulryType, INDIVIDUAL SEVENTH AVE 00 1112 7TH AVENUE P.O.BOX 2816 MONROE, WI 53566 Phone number not available RequestedOn; 09/13!2()04 InqlllryType, INDIVIDUAL SEVENTH AVE 01) 11127THAVENUE P.O.BOX 2816 MONROE, WI 53566 Phone number not available RequestedOn: 06/01/2004 fnquiryType: INDIVIDUAL GATEWAYjCBUSANA PO BOX 9714 GRAY, TN 37615 Phone number not available Requested On; 04/09/2004 Inquiry Type, INDIVIDUAL - - - 031020050000000228 7/14 DT Consumer Credit report for GlADYS M. BRQWII file Number. 134959167 Page, 6 of 7 Date Issued, 03/09/2005 CHASE MANHAlTAN BANK 4915 INDEPENDENCE TAMPA, Fl33634 Phone numbel not available Requested On, 02/22/2004 Inquil'fType, INDIVIDUAL CHASE MANHAlTAN BANK 4915 INDEPENDENCE TAMPA, Fl33634 Phone number notavailable Requ..tedOn, 10/16/2003 Inquil'fType, INDIVIDUAL NATIONAL CITY CARD SERV 4653 E MAIN:ST COlUM~US,()~ 43251 (614) 856.8961 RequestedOn, 09/27/2003 Inqull'fType: INDIVIDUAl FINANCIAL RECOVERY SERV Plfilox''3S'S90S' MjNlIEAA!)tJS,MN 55438 (8$8) 857'~23 R~edP!l>'08/.1,2/2003 InquhyType, INDIVIDUAL Pelll!.I~I"Purpo$e: COllECTION T -MOBILE 3407W DR MARTIN lU KING IR BlVD TAMPA, &336>07 (800) 937.8'197 Request"dOn, 08/09/2003 Inqulw.lypl!< INDIVIDUAL CHASE MANHAlTAN BANK 4915 INDEPENDENCE TAMPA, Fl33634 Phone' nllrn~~J Mtilv"itabte Reque~,o..O~()4/2003 Inquiry TyPe, INDIVIDUAL RRST PREMIER BANK 900 W DElAWARE PO BOX 5114 SIOUX fAllS, SO 57117 (605) 357- 3440 Requested~e: 06/19/2003 Inqu!ryType, INDIVIDUAL CHASE MANHATTAN BANK 4915 INDEPENDENCE TAMPA, Fl 33634 Phone number not available RequestedOn, 05/30/2003 Inquiry Type, INDIVIDUAL FLEEllll:C POBOX 1568 HORSHAM, PA 19044 Phone nup#i~,~o~vai~~ble Requested qif - Q5/i912"Qo.3 ">~1fii,7:\!;,J,.';i:i,-_-,_;~- 1'!9~I~XM"I\4QI";\iluAl ' i':<;2!'i\'~,S;)>:.~~~)\;'~-L';fZl: /;';\':!~"{', - ~,;:: - :" fm CA!Ul5 E:BSDNA P.O. BOIUOOO-'. ' SIOUX fAlLS,S{).57117 p;~o~~i'tm~e~not ~~,~i1~b~e R..,~l8iIOil: 04104/2003 Fe.".,' Inq~lryType; INDIVibuAl MEMBERS 1ST FED C U RequesfedQD>02/28/2005 Identifying information they provided: -. GLADYS M_ BROWN 210lCEDAlI RUN DR CAMP HILL. PA 17011 1829 ELM ST NEW CUMBERlAND, PA 17319 (7m 215-5986 &nptoyer: PANERA BREAD & WilliAMS SONOMA THE HARTFORD Requested On, 12/2004 8 ~ARM SPRINGS RD fARMINGTON, CT 06032-2526 Phone number not available PROGRESSIVE INSURANCE Requested On, 11i2004 6300 WILSON MILLS RD CLEVElAND, OH 44143-2109 (800) 937-77()4 THE HARTFORD Requested On, 11/2004 8 fARM SPRINGS RO fARMINGTON, CT 06032-2526 Phone number not available mE HARTFORD Requested On' 11/2004 8 fARM SPRINGS RD fARMINGTON, CT 06032-2526 Phone number not available 031020050000000228 8/14 DT r~ } 031020050000000228 r ~, -, (~I I __J ., 10/14 nT . f .f KOPE & ASSOCIATES BY: SHANE B, KOPE, ESQ, ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkoDe@comcast.net Attorney for Plaintiff vs, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO, 02-3839 GLADYS BROWN-DULL Plaintiff, GARY A. DULL, Defendant. CIVIL ACTION - LAW THIS AGREEMENT made this the 18th day of May, 2006, by and between Gladys Brown-Dull, hereinafter referred to as 'Wife", and Gary A. Dull, hereinafter referred to as "Husband", WITNESETH: WHEREAS, the parties hereto are husband and wife, having been married on June 19, 1999 and separated on June 28, 2002. WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as . , , ~ between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates, NOW, THEREFORE, in consideration of the promises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: " .' GLADYS BROWN-DULL Plaintiff, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 GARY A. DULL, Defendant. CIVIL ACTION - LAW SECTION I GENERAL PROVISIONS 1,01, INCORPORATION OF PREAMBLE, The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 1.02. DIVORCE DECREE, The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent no-fault Divorce Decree in the above captioned divorce action. If either party has filed a counterclaim, counter-affidavit, or any claim for economic relief, he or she agrees that any such claims have been fully resolved by virtue of this Agreement, and he or she shall withdraw any such claims and, if necessary, shall take such further steps as may be necessary to allow for a prompt finalization of any divorce action between the parties. 1.03. EFFECT OF DIVORCE DECREE. INCORPORATION AND MERGER. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them, This Agreement shall not, however, merge with the Divorce Decree, but rather, it shall continue to have independent contractual significance and each party shall maintain their contractual remedies as well as Court remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. This Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties, 1,04. DATES, The "date of execution", "execution date" or "date of this Agreement" shall be defined as the date of execution by the party last executing this Agreement. .' 1.05. ADVICE OF COUNSEL, The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Shane B, Kope, Esquire for Wife, and Andrew Shaw, Esquire, for Husband, The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fUlly informed as to their legal rights and obligations, They acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements, 1.06. FINANCIAL DISCLOSURE, The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and each party acknowledges that there has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective incomes, which has been provided to each party. 1.07. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 1.08. BANKRUPTCY, The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein, In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to Court determination the same as if this Agreement had never been executed by the parties. 1.09, MUTUAL RELEASES. Except as other wise expressly provided in this Agreement, Wife and Husnband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from the following: A. Claims Aaainst Property or Estate: Any and all right, title, interest and/or claims in or against the other party, the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other party, the estate of such other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. 8, Life Time Convevances: The right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (i) the Commonwealth of Pennsylvania, (ii) State,. Commonwealth or Territory of the United States, or (iii) any other country; C. Marital Riahts: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise. D. Breach Exception: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 1,10. WAIVER OR MODIFICATION. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. " 1.11. MUTUAL COOPERATION. Each party shall, at any time, and from time to time hereafter, and within five (5) business days of request, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 1,12. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns, 1,13. INTEGRATION, This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 1.14. BREACH. If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies: A. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 PA. C.S.A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. 8, Damaaes: The right to damages arising out of breach of the terms of this Agreement, which damages shall include reimbursement of all reasonable attorney's fees and costs incurred as the result of the breach and in bringing the damage action. C, Other Remedies: Any other remedies provided for in law or in equity, D, Considerations for Reasonable Attornevs Fees: Any award of "reasonable attorney's fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered, Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching .' party. E, Breach Notice: In the event of an alleged breach of any term of this Agreement, the aggrieved party shall provide written notice to the breaching party and his or her counsel of his or her intent to take action to enforce his or her rights under the Agreement and to remedy such breach. The breaching party shall have a period of fifteen (15) days from the mailing of such notice to cure the alleged breach prior to the institution of any proceedings of any nature for enforcement of this Agreement. 1.15, INCOME TAX MATTERS. With respect to income tax matters regarding the parties the following shall apply: A. Prior Returns: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them arising out of such joint filing, each will be responsible for payment of half of such tax and any interest, penalty or other expense arising therefrom and shall indemnify and hold harmless the other from and against any loss or liability as a result thereof. B. Current Returns: The parties shall file individual tax returns for the current tax year and for every tax year hereafter. C. Preservation of Records: Each party will keep and preserve for a period of three (3) years from the date of their divorce all financial records relating to the marital estate, and each party will allow the other party access to those records as may be reasonably necessary from time to time. 1,16. EFFECT OF RECONCILIATION, This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as Husband and Wife or otherwise, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. SECTION DISTRIBUTION OF II PROPERTY 2.01. FINAL EQUITABLE DISTRIBUTION OF PROPERTY. The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division, 2.02. DISTRIBUTION OF PROPERTY AND DEBTS, The parties' marital assets and debts shall be divided and distributed as follows: A, Personal Property: The parties' tangible personal property including, but without limitation with specific reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property ("the Personal Property") shall be divided and distributed as follows: 1, To Wife: All items of personal property in the possession of Wife, not otherwise distributed to Husband herein, 2, To Husband: All items of personal property in the possession of Husband, not otherwise distributed to Wife herein, 8, Vehiclelsland Vehicle Loanlsl: The parties' vehicles, boats, snowmobiles, motorcycles, trailers, campers and the like owned by one or both of the parties, or the trade in value thereof if the Vehicles have been sold or traded in prior to the date of this Agreement ("Vehicles"), and loans associated therewith, shall be divided and distributed as follows: 1, To Wife: 1995 Kountry Star 5th Wheel Camper 2. To Husband: None c. Monetary Distributions: 1. To Wife: One Hundred Dollars ($100.00) per month for five (5) months starting June 1, 2006 payable by money order. 2, To Husband: None D. Investments: The parties shares of stock, brokerage accounts and other investments (the "Investments") shall be divided and distributed as follows: 1, To Wife: None 2, To Husband: None. E, Life Insurance: The parties' life insurance policy and the cash value thereof shall be divided and distributed as follows: 1. To Wife: None 2. To Husband: None F, Retirement Plans: T he parties' Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any employee benefit plan and/or any other retirement type plans (the "Retirement Plans") shall be divided and distributed as follows: 1. To Wife: None 2. To Husband: None G. Debts: The parties' marital debts, loans, credit cards and other obligations, not otherwise divided and distributed herein, shall be divided and distributed as follows: 1. To Wife: Wife shall be solely liable for and shall timely pay the following debts: A. Any credit cards, loans, debts and liabilities incurred in Wife's individual name. 2. To Husband: Husband shall be solely liable for and shall timely pay the following debts: A, Any credit cards, loans, debts and liabilities incurred in Husband's individual name. H, Title Transfer: Title transfer for the 1995 Kountry Star 5th Wheel Camper will be made within fifteen (15) days of the signing of this Agreement. The transfer will take place at the office of the Husband's attorney, Andrew H. Shaw, Esquire located at 61 West Louther Street, Carlisle, Pennsylvania whereas the Husband will sign over the title to the Wife and the Wife will pick up the Title, All costs of the title transfer will be the responsibility of the Wife. 2.03. MISCELLANEOUS DISTRIBUTION PROVISIONS: The following miscellaneous provision shall apply to the distribution of the parties' marital assets and debts: A. Final Eauitable Distribution of ProDertv: The division and distribution of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts, It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division, B, As Is Condition: Except as otherwise specifically herein provided, and with respect to the transfer of any tangible assets provided for in this Marital Agreement, the parties acknowledge that he or she have had the opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate property and he or she is fully aware of the condition of such tangible asset and is receiving those assets in "as is" physical condition, without warranty or representation by or from the other party. .' C. Personalty Transfer: if either party is entitled to any items of personal property in the possession of the other party as of the date of this Agreement, the parties shall promptly make arrangements so as to permit that party to remove the items of property from the other party's possession no later than fifteen (15) days from the date of this Agreement. 0, Waiver. Each of the parties specifically waives, releases, renounces and forever abandons whatever right, title and interest they may have in any property that is to become the sole and separate property of the other party pursuant to the terms of this Agreement. E. Liens: In the event any asset is subject to a lien or encumbrance the party receiving the asset as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible and liable therefore. F. Debt Balances and Prior Payments: Any debt herein described shall be deemed to include the current balance owed on the debt. Unless otherwise herein specifically provided, there shall be no adjustment in the distribution provisions for the payment of any portion of the marital debts prior to the execution of this Marital Agreement, whether or not that debt or the prior payment thereof is specifically referenced in this Paragraph, said payment having been taken into consideration in determining the distribution of marital assets and debts herein provided, H, Indemnification: Any party assuming an obligation pursuant to the terms of this Agreement shall indemnify, protect and hold the other party harmless from and against all any and all liability thereunder, including, but not limited to, any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this indemnification, Cancellation of Joint Debts: Any joint debt shall be canceled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. J. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. ,. K. No Further Joint Debt: From the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is individually and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. L No Additional Debt: Each party represents and warrants to the other party that since the separation he or she has not, and in the future he or she will not, contract or incur any debt or liability for which the other party or the other party or the other party's estate might be responsible, , SECTION III CLOSING PROVISIONS AND EXECUTION 3.01 COUNTERPARTS. This Agreement may be executed in counterparts, each of which shall be deemed to be an original, but all of which shall constitute one and the same agreement. 3.02 FACSIMILE SIGNATURE. Each party agrees to accept and be bound by facsimile signatures hereto. 3.03 BINDING EFFECT. By signing this agreement, each party acknowledges having read and understood the entire agreement, and each party acknowledges that the provisions of this agreement shall be binding upon the parties as if they were ordered by the Court after a full hearing, IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have signed sealed and acknowledged this Agreement the day and year below written, which Agreement has been executed in various counterparts, each of which shall constitute an original WITNESS: d#lL )J}(joip O)Kw}YI Gladys Brown-Dull Date: S / /q/Oh . (SEAL) ?' ..;0 Lv - ~ Q, .-,,(J J,/ ;9 ..(lg_ (SEAL) Gary A. Dull Date: & 1.2 3 /0 c ,. .. COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ) On this, the \ C\ day of \Yl ()t...0( , 2006, before me, a Notary Public, the undersigned officer, personally appeared Gl~wn-Dull, known to me (or satlsfactonly proven) to be the person whose name is subscribed to the foregoing Marital Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL COMMONWEALTH OF PENNSYLVANIA . Notarial Seal Amanda J, lavis, Notary Public Hampden T~., Cumberland County My ConvnlSSlOn Expires Afx. 6. 2010 Member, Pennsytvania ASSociation 01 Notarl.. Notary Public: ~/'LA & ~ AIY\()..nCW J 1-0. viS COMMONWEALTH OF PENNSYLVANIA ) / / )SS: COUNTY OF C"'k<'/~ ) On this, the :2 S ",j day of :r:.... ~, , 2006, before me, a Notary Public, the undersigned officer, personally appeared Gary A, Dull, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marital Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public: d L~/If!~__;) Notarial Seal Andrew H, Shaw, NOW)' NlIic City of HarrisbtJrs, Dauphin C'lliInty My Commission Expires Oct. 24, 2006 '.' '. RECEIVED JUI1 2 4 2006 c'~," --n KOPE & ASSOCIATES, LLC BY: SHANE B, KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkopeliilcomcast.net Attorney for Plaintiff V5. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3839 CIVIL ACTION - LAW GLADYS BROWN-DULL Plaintiff, GARY A. DULL, Defendant. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 12,2002. 2. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 3, I consent to the entry of a final decree 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. Section 4904 relating to unsworn falsification to authorities, Date: {gc}&-D& G~~UP~~ JL>> cJ(j5 -tfL./-8/ ~O Social Security Number C'~, -h .-..~ r-i''i j';,-, 1".("'> ~: (,..) CJ.._~ LC KOPE & ASSOCIATES, LLc BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0,92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@.comcast.net Attorney for Plaintiff vs, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3839 : CIVIL ACTION - LAW GLADYS BROWN-DULL Plaintiff, GARY A DULL, Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unsworn falsification to authorities, Date: tp-&I.J"Ofp -~~s~ 6JHtM- ,()~ Gladys Brown- ull r::; OS - 4'-/ - f? / (1 0 Social Security Number ~~1 (',) ,,0 (.') c,:J [,,;1 GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW GARY A, DULL, Defendant No. 02-3839 IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under !l3301 (c) of the Divorce Code was filed on August 12, 2002, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final decree 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, !l4904 relating to unsworn falsification to authorities, Dated: & JJ.)/oG )j II OL// Gary ~Ull, Defendant ~ C) C;:) --n L1.... ,- c: r...) 8 --, (;': c,:> \"'<J GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW GARY A. DULL, Defendant No, 02-3839 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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. Section 4904 relating to unsworn falsification to authorities, DATE:& h 3 /0 (p J0 ;I 2ltt Gary A~, Defendant C) ......:~- , ,..." c::;;; C..::.:;) ""' C) +-n ,-'l ," :',~- ....:~,I ~? (..) (......" GC GLADYS BROWN-DULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 02 - 3839 CIVIL GARY A. DULL, Defendant IN DIVORCE ORDER OF COURT AND NOW, this l:l~ day of ~1A , the proceed gs laVing been 2006, the economic claims raised in resolved in accordance with an agreement dated May 18, 2006, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, cQSM~~ Edgar B. Bayley, P.J. cc: Shane B, Kope Attorney for Plaintiff Andrew H, Shaw Attorney for Defendant ~~ 7-/2 -o~ C)... tAti -Ii f\-t~ :Jc i !:l ',' I (, AU GLAO'-(5 8e.nw,J Dvl..L VS, C-f+-~I..( A, OVLL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. Od- 3taCj CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: 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) OSA" {. J){1) ..r II -f II U~ OOd6. (Strike out inapplicable section). 2, Date and manner of service of the complaint: 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 plaintiff ~ /;;?-(p 10(0 , ; by defendant (P !.;}3)Ofc . (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 affidavit upon the respondent: 4. Related claims pending; tJotJ~ 5, 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 of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: (p 1 dq /010 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: CR Ie; '7 / Db ~ Attorney r Plaintiff / Defendant r~.} c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, Gladys Brown-Dull NO. 02-3839 VERSUS Gary A. Dull . . DECREE IN DIVORCE . . AND NOW, ~ ~, IT IS ORDERED AND . . . DECREED THAT Gladys Brown-Dull , PLAINTIFF, AND Gary A. Dull , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ("'}'?P ?~ ~ 'It' ~.$ ~ ~ 1 ~ 4v.f"iJ 'JO- ,J-s