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TIMOTHY CARLSON.
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYL VANIA
liS.
: NO 96-1191 CIVIL TERM
LEEANN C. CARLSON.
Defendant
: CIVIL ACTION - DIVORCE
ACCEPTANCE OF SERVICE;
I, Robert B. Macintyre, Esquire, do certifY that I accept service of the Diliorce Complaint
on behalf of my client. LeeAnn Carlson.
Date: /J)4''-/'" /1, lh:.
Robert B. Maclllfyre, Esquire ..'
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PRAECIPE
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NOTARIAL SEAL
ATTORNEY JAMES M. BACH. NoWy PublIc
CUmoorlAnd Ccunly
My Co,nm"sion E.pif9~ lA3y ". 1009
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.)u.t:$ M. BACH
Ano!\/jFY AT UW
352 S. Sf-Of. LNG HILL ~1).
MECHAN1CStlL:RC. PA 1105!
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'iEP 01 1998
. .
TIMOTHY CARLSON,
Plaintiff
.
.
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 96 - 1191 CIVIL
LEANN C. CARLSON,
Defendant IN DIVORCE
THE MASTER TOday is Tuesday, August 18, 1998.
This is the date set for a Master's hearing in the above
captioned divorce proceedings. Present are the Plaintiff,
Timothy Carlson, and his attorney James M. Bach, and the
Defendant, Leann C. Carlson, and her attorney Timothy J. Colgan.
A divorce complaint was filed on March 5, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. The Master has been provided affidavits of consent
and waivers of notice of intention to request entry of divorce
decree signed by the parties and dated today. Those documents
will be filed with the Pl'othonotary by tne Divorce Master's
Office. The divorce can then conclude under Section 3301(c) of
the Domestic Relations Code.
The complaint raised the e~onomic claim of
equitable distribution. The Master has been advised, however,
that part of an agreement reached between the parties involves a
claim for alimony; therefore, Mr. Colgan is going to file a
petition with the Prothonotary raising that claim of record.
Upon the Master being notified that the claim is filed and the
signed agreement being returned to the Master, the Master will
EXHIBIT A
prepare an order vacating his appointment so that counsel can
tile the praecipe to transmit the record to request a tinal
decree in divorce.
No claim has been raised tor counsel fees and
expenses by either party.
The Master has been advised that counsel and the
parties have reached an agreement with respect to the
outstanding claims ot equitable distribution and the claim to be
tiled ot alimony. An agreement is going to be placed on the
record in the presence of the parties. That agreement as placed
on the record will be considered the substantive agreement ot
the parties not subject to changes or modifications except for
correction ot typographical errors which may be made during the
transcription. The draft ot the agreement is going to be .ent
to counsel to review for typographical errors. Any corrections
will then be made and the Master will prepare a tinal dratt for
signatures by the parties. The signatures of the parties is
simply an affirmation of the agreement which is placed on the
record at this time. As indicated, the agreement as stated on
the record will be binding and is considered the substantive
agreement of the parties resolving all economic claims.
After the Master has been provided the signed
agreement and the alimony claim has been raised of record, the
Master will prepare an order vacating his appointment and
counsel can then file a praecipe transmitting the record to the
Court requesting a final decree divorce.
At the pre-hearing conference, the Master noted
that attorney Robert B. MacIntyre accepted the service of the
complaint on behalf of the Defendant. The Master felt that that
constituted an entry of appearance on his behalf in the action
and had requested that counsel obtain his withdrawal of
appearance. However, both counsel and Ms. Carlson have
indicated that they have been unable to get Mr. MacIntyre to
file the appropriate praecipe withdrawing his appearance in the
action. Nevertheless, we are satisfied that Mr. Colgan is
representing Ms. Carlson and we will proceed on that basis. Mr.
Bach.
MR. BACH: Mr. and Ms. Carlson, what I am going to
put on the record at this time is a proposed mutual agreement
between each of you. The purpose of the agreement is to divide
and distribute the assets and debts that you acquired during the
marriage. If we say something that is inappropriate or
incorrect or you do not understand, please stop me.
1. REAL ESTATE: The parties hereto, namely, husband and
wife, own as tenants by the entireties real estate
situate at 111 Salem Church Road, Mechanicsburg,
Cumberland County, Pennsylvania. The parties have agreed
and stipulated that the value of this real estate is
$90,000.00.
Presently, this property is encumbered by a first
mortgage in the approximate amount of $59,000.00 with
Chase Manhattan Mortgage Company and a second mortgage in
the approximate amount of $11,000.00 with Mellon Bank.
Husband will renounce all of his right, title, and
interest in the subject real estate and award his real
estate to wife by executing a deed within five (5) days
from the date the agreement is signed whereby the real
estate is transferred from husband to wife to wife
exclusively.
wife will be responsible for full and final payment of
mortgage No. 1 and mortgage No. 2 set forth above.
Further, wife will indemnify and hold husband harmless on
account of mortgage No. 1 and mortgage No. 2 as set forth
above.
All taxes due and owing as of this date or the date of
the signing of the agreement will be the responsibility
of wife. Expenses appended to the real estate as of the
date of the signing of the agreement will be the
responsibility of wife.
2. RETIREMENT PI,ANS OF THE PARTIES: Wite does not own or
possess a retirement account nor has she acquired one
during the course of the marriage. Husband does own
a retirement account and he acquired it during the course
of the marriage. This account is with his employer,
PP&L and it is known as a 401(k) account. This account
with an approximate balance of $25,000.00 is to be
transferred absolutely to wife. Husband agrees to
sign any and all documents necessary to transfer this
account balance to wife. This account balance may be
placed into another 40l(k) account that wife may set up
and designate to be her own or alternatively any other
account that she deems to be proper and appropriate for
said transfer.
Husband agrees to sign all documents immediately upon
presentation to him to accomplish the objective set forth
in this paragraph. All documents will be prepared by
attorney Colgan on behalf of wife and then transmitted
to attorney Bach for disposition and review by his
client.
Husband also has a retirement plan with PP&L which is
designated as an accrued monthly retirement benefit --
straight life payable at age 65. Wife waives, releases,
and renounces any and all right, title, and interest in
said retirement plan.
3. ALIMONY: Husband agrees to pay alimony to wife for six
(6) years at the rate of $877.00 per month. This alimony
will be paid by way of a payroll deduction through the
Domestic Relations Section of the Court ot Common Pleas
ot Cumberland County. Presently, there exists a support
order in the Domestic Relations. No. 540597 which
provides tor alimony pendente lite at the rate ot $877.00
per month. This order also contains a provision tor
child support in the amount ot $474.50 tor each ot the
two children per month.
The parties agree that they or their counsel will
immediately notity the Domestic Relations Section ot the
entry ot a tinal decree in divorce and that the alimony
would begin the month that the divorce is issued and stay
in ettect for the next 71 months. The total payment at
$877.00 per month is tor 72 months.
Wife has applied tor social security disability benetits
at the present time. Wite has not received a tinal
approval and/or disapproval trom the social security
administration.
In the event wife does receive benefits trom social
security for her disability, the obligation tor alimony
would be reduced by 1/2 of her disability payment. (An
example, if wite is awarded ~600.00 per month, $300.00
per month would come off the alimony required payment.)
Wife agrees to immediately notify her counsel as to the
results of the disability application and advise as to an
acceptance or rejection. Further, wite agrees to do all
those things necessary and required by social security to
see that the entire application process is completed.
The alimony will terminate automatically 72 months after
it begins without further crder of court. The alimony
will not terminate upon wite's remarriage, cohabitation,
or the death of Mr. Carlson, and upon death of husband,
if any alimony is remaining to be paid of the 72 months,
wife will have a claim against Mr. Carlson's estate. It
is further agreed that neither party will be able to
modify the alimony. The only modification being provided
herein is in the event that wife receivescdisability
benefits from social security.
4. VEHICLES OWNED BY THE PARTIES: Husband and wife have
divided and distributed any vehicles owned by them during
the course of the marriage and each party is now
responsible for the vehicle in their possession as well
as payment and license requirements of said vehicle.
5. HOUSEHOLD FURNISHINGS: Husband and wife have divided,
to their mutual satisfaction, all household furnishings.
This agreement will act as a bill of sale from husband
and wife to each other for all household furnishings now
in their possession and each party, that is husband
and/or wife, may do whatever they deem necessary, fit and
appropriate with each item of household furnishings in
their possession.
6. CHECKING AND SAVINGS ACCOUNTS: The parties hereto
have divided and distributed their marital checking
accounts and savings accounts to their satisfaction
heretofore. Neither party will make any claim against
the other for any checking accounts or savings accounts
on account of this agreement.
7. STOCKS AND BONDS: The parties hereto, namely, husband
and wife have divided and distributed all marital stocks
and bonds to their mutual satisfaction heretofore.
Neither party will make any claim against the other for
any of the stocks and bonds acquired during the course of
the marriage.
8. HEALTH INSURANC~: Presently the father (husband) is
covering wife and the two children for health insurance
as provided by his employer. Husband and wite agree that
the parties will share in the costs of health insurance
for wife. Husband will cooperate with wife and wife's
counsel to obtain the necessary documents for signature
to obtain COBRA information and benefits so wife can get
a reduced rate for her health insurance which will take
place in her name post divorce. Post divorce those costs
and expenses for her health insurance under COBRA will be
shared equally by and between husband and wife. In other
words, if wife's obligation is $200.00 per month, husband
agrees to pay 1/2, $100.00 per month. Husband's
contribution as provided for herein will be tor a period
of two years.
9. VISITATION WITH THE MINOR CHILDREN: Husband and wite
both agree that they have exchanged between them a rather
liberal visitation schedule. Apparently, husband
provides wife with his work schedule and wite has been
agreeing to allow husband to have the children on hi.
scheduled days off. In addition to the times ott, they
have also agreed in the past to other times. It is
hopeful that they will continue to cooperate with each
other as to the visitation with the children in the
immediate near future.
,
Husband has been providing wite with a copy o~ his annual
schedule ot work so wite can calculate and husband c~n
calculate as to his days otf so they can make appropriate
adjustments to their schedule tor visitation, and husband
agrees to continue to provide wite with his schedule so
wite can see and he can know when he would have
visitation.
10. Except as herein otherwise provided, each party may
dispose ot his or her property in any way and each party
hereby waives and relinqui.he. any and all right. he or
she may now have or hereatter acquire under the pre.ent
or tuture laws ot any jurisdiction to share in the
property or the estate ot the other as a ~esult ot the
marital relationship including without limitation,
statutory allowance, widow's allowance, right ot
intestacy, right to take against the will ot the other,
and right to act as administrator or exacutor in the
other's estate. Each will at the request ot the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into ettect
this mutual waiver and relinquishment ot all such
interests, rights, and claims.
THE MASTER: Ms. Carlson, you've been present
during the statement ot the agreement by Mr. Bach on the record?
MS. CARLSON: Yes.
THE MASTER:
Do you understand what Mr. Bach has
stated on the record?
;)
MS. CARLSON: Yes.
THE MASTER: Do you have any questions about what
he stated?
MS. CARLSON: No.
THE MASTER: And are you satisfied that the
statement represents the agreement that you have reached with
respect to the claims of equitable distribution and alimony?
MS. CARLSON: Yes.
THE MASTER: You also understand that when you
leave here today, even though there is no signing or the
agreement, that you are bound by the terms or this agreement,
that the only changes that we can make would be correction or
typographical errors?
MS. CARLSON: Yes.
THE MASTER: Mr. Carlson, you have been present
during the statement or the agreement; is that correct?
MR. CARLSON: Yes.
THE MASTER: Do you understand the agreement?
MR. CARLSON: Yes.
THE MASTER: Do you have any questions about the
agreement?
MR. CARLSON: No.
THE MASTER: Are you satisfied that this agreement
represents your understanding of the settlement of the claims of
equitable distribution and alimony?
MR. CARLSON: Yes.
THE MASTER: You understand that when you leave
here today that the agreement is binding on you even though it
TIMOTHY CARLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VB. NO. 96 - 1191 CIVIL
LEANN C. CARLSON,
Defendant IN DIVORCE
THE MASTER Today is Tuesday, August 18, 1998.
This is the date set for a Master's hearing in the above
captioned divorce proceedings. Present are the Plaintiff,
Timothy Carlson, and his attorney James M. Bach, and the
Defendant, Leann C. Carlson, and her attorney Timothy J. Colgan.
A divorce complaint was filed on March 5, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. The Master has been provided affidavits of consent
and waivers of notice of intention to request entry of divorce
decree signed by the parties and dated today. Those documents
will be filed with the Prothonotary by the Divorce Master's
Office. The divorce can then conclude under Section 3301(c) of
the Domestic Relations Code.
The complaint raised the economic claim of
equitable distribution. The Master has been advised, however,
that part of an agreement reached between the parties involves a
claim for alimony; therefore, Mr. Colgan is going to file a
petition with the Prothonotary raising that claim of record.
Upon the Master being notified that the claim is filed and the
signed agreement being returned to the Master, the Master will
prepare an order vacating his appointment so that counsel can
file the praecipe to transmit the record to request a final
decree in divorce.
No claim has been raised for counsel fees and
expenses by either party.
The Master has been advised that counsel and the
parties have reached an agreemene with respect to the
outstanding claims of equitable distribution and the claim to be
filed of alimony. An agreement is going to be placed on the
record in the presence of the parties. That agreement as placed
on the record will be considered the substantive agreement of
the parties not subject to changes or modifications except for
correction of typographical errors which may be made during the
transcription. The draft of the agreement is going to be sent
to counsel to review for typographica1 errors. Any corrections
will then be made and the Master will prepare a final draft for
signatures by the parties. The signatures of the parties is
simply an affirmation of the agreement which is placed on the
record at this time. As indicated, the agreement as stated on
the record will be binding and is considered the substantive
agreement of the parties resolving all economic claims.
After the Master has been provided the signed
agreement and the alimony claim has been raised of record, the
Master will prepare an order vacating his appointment and
counsel can then file a praecipe transmitting the record to the
Court requesting a final decree divorce.
At the pre-hearing conference, the Master noted
that attorney Robert B. MacIntyre accepted the service of the
complaint on behalf of the Oefendant. The Master felt that that
constituted an entry of appearance on his behalf in the action
and had requested that counsel obtain his withdrawal of
appearance. However, both counsel and Ms. Carlson have
indicated that they have been unable to get Mr. MacIntyre to
file the appropriate praecipe withdrawing his appearance in the
action. Nevertheless, we are satisfied that Mr. Colgan is
representing Ms. Carlson and we will proceed on that basis. Mr.
Bach.
MR. BACH: Mr. and Ms. Carlson, what I am going to
put on the record at this time is a proposed mutual agreement
between each of you. The purpose of the agre~ment is to divide
and distribute the assets and debts that you acquired during the
marriage. If we say something that is inappropriate or
incorrect or you do not understand, please stop me.
1. REAL ESTATE: The parties hereto, namely, husband and
wife, own as tenants by the entireties real estate
situate at 111 Salem Church Road, Mechanicsburg,
Cumberland County, Pennsylvania. The parties have agree4
and stipulated that the value of this real estate is
$90,000.00.
Presently, this property is encumbered by a first
mortgage in the approximate amount of $59,000.00 with
Chase Manhattan Mortgage Company and a second mortgage in
the approximate amount of $11,000.00 with Mellon Bank.
Husband will renounce allot his right, title, and
interest in the subject real estate and award his real
estate to wife by executing a deed within five (5) days
from the date the agreement is signed whereby the real
estate is transferred from husband to wife to wife
exclusively.
Wife will be responsible for full and final payment of
mortgage No. 1 and mortgage No. 2 set forth above.
Further, wife will indemnity and hold husband harmless on
account of mortgage No. 1 and mortgage No. 2 as set forth
above.
All taxes due and owing as ot this date or the date of
the signing of the agreement will be the responsibility
of wite. Expenses appended to the real estate as of the
date ot the signing ot the agreement will be the
responsibility of wife.
2. RETIREMENT PLANS OF THE PARTIES: Wife does not own or
possess a retirement account nor has she acquired one
during the course of the marriage. Husband does own
a retirement account and he acquired it during the course
of the marriage. This account is with his employer,
PP&L and it is known as a 401(k) account. This account
had a separation balance of $19,324.79 and that amount is
to be transf,erred absolutely to wife. Husband agrees to
sign any and all documents necessary to transfer this
account balance to wife. This account balance may be
placed into another 401(k) account that wife may set up
and designate to be her own or alternatively any other
account that she deems to be proper and appropriate for
said transfer.
Husband agrees to sign all documents immediately upon
presentation to him to accomplish the objective set torth
in this paragraph. All docllments will be prepared by
attorney Colgan on behalf of wife and then transmitted
to attorney Bach for disposition and review by his
client.
Husband also has a retirement plan with PP&L which is
designated as an accrued monthly retirement benefit -_
straight life payable at age 65. Wife waives, relea...~
and renounces any and all right, title, and interest in
said retirement plan.
3. ALIMONY: Husband agrees to pay alimony to wife for six
(6) years at the rate of $877.00 per month. This alimony
will be paid by way of a payroll deduction through the
Domestic Relations section of the Court of Common Pleas
of Cumberland County. Presently, there exists a supp~rt
order in the Domestic Relations, No. 540597 which
provides for alimony pendente lite at the rate of $877.00
per month. This order also contains a provision for
child support in the amount of $474.50 for each of the
two children per month.
The parties agree that they or their counsel will
immediately notify the Domestic Relations section of the
entry of a final decree in divorce and that the alimony
would begin the month that the divorce is issued and stay
in effect for the next 71 months. The total payment at
$877.00 per month is for 72 months.
Wife has applied for social security disability benefits
at the present time. Wife has not received a final
approval and/or disapproval from the social security
administration.
4.
In the event wife does receive benefits from social
security for her disability, the obligation for alimony
would be reduced by 1/2 of her disability payment. (An
example, if wife is awarded $600.00 per month, $300.00
per month would come off the alimony required payment.)
Wife agrees to immediately notify her counsel as to the
results of the disability application and advise aa to an
acceptance or rejection. Further, wife agrees to do all
those things necessary and required by social security to
see that the entire application process is completed.
The alimony will terminate automatically 72 montha after
it begins without further order of court. The alimony
will not terminate upon wife's remarriage, cohabitation,
or the death of Mr. Carlson, and upon death ot hU~,..>
if any alimony is remaining to be paid of the 72 ~n~fw
wife will have a claim against Mr. Carlson's estat.. _I~~
is further agreed that neither party will be able to '.:--."
modify the alimony. The only modification being provldt4,
herein is in the event that wife receives disability
benefits from social security.
VEHICLES OWNED BY THE PARTIES: Husband and wife have
divided and distributed any vehicles owned by them durinq
the course of the marriage and each party is now
responsible for the vehicle in their possession as well
as payment and license requirements of said vehicle.
j' ~
^,"t.
. .
5. HOUSEHOLD FURNISHINGS: Husband and wife have divided,
to their mutual satisfaction, all household furnishings.
This agreement will act as a bill of sale from husband
and wife to each other for all household furnishings now
in their possession and each party, that is husband
and/or wife, may do whatever they deem necessary, fit and
appropriate with each item of household furnishings in
their possession.
6. CHECKING AND SAVINGS ACCOUNTS: The parties hereto
have divided and distributed their marital checking
accounts and savings accounts to their satisfaction
heretofore. Neither party will make any claim against
the other for any checking accounts or savings accounts
on account of this agreement.
7. ~KS AND BONDS: The parties hereto, namely, husband
and wife have divided and distributed all marital stocks
and bonds to their mutual satisfaction heretofore.
Neither party will make any claim against the other for
any of the stocks and bonds acquired during the course of
the marriage.
B. HEALTH INSURANCE: Presently the father (husband) is
covering wife and the two children for health insurance
as provided by his employer. Husband and wife agree that
the parties will share in the costs of health insurance
for wife. Husband will cooperate with wife and wife's
counsel to obtain the necessary documents for signature
to obtain ~OBRA information and benefits so wife can get
a reduced rate for her health insur.ance which will take
place in her name post divorce. Post divorce those costs
and expenses for her health insurance under COBRA will be
shared equally by and between husband and wife. In other
words, if wife's obligation is $200.00 per month, husband
agrees to pay 1/2, $100.00 per month. Husband's
contribution as provided for herein will be for a period
of two years.
9. VISITATION WITH THE MINOR CHILDREN: Husband and wife
both agree that they have exchanged between them a rather
liberal visitation schedule. Apparently, husband
provides wife with his work schedule and wife has been
agreeing to allow husband to have the children on his
scheduled days off. In addition to the times off, they
have also agreed in the past to other times. It is
hopeful that they will continue to cooperate with each
other as to the visitation with the children in the
immediate near future.
. .
Husband has been providing wite with a copy ot his annual
schedule ot work so wite can calculate and husband can
calculate as to his days ott so they can make appropriate
adjustments to their schedule tor visitation, And husband
agrees to continue to provide wite with his schedule so
wite can see and he can know when he would have
visitation.
10. Except AS herein otherwise provided, each party may
dispose ot his or her property in any way and each party
hereby waives and relinquishes any and all rights he or
she may now have or hereatter acquire under the present
or future laws ot any jurisdiction to share in the
property or the estate ot the other as a result ot the
marital relationship including without limitation,
statutory allowance, widow's allowance, right ot
intestacy, right to take against the will ot the other,
and right to act as administrator or executor in the
other's estate. Each will at the request ot the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into ettect
this mutual waiver and relinquishment ot all such
interests, rights, and claims.
THE MASTER: Ms. Carlson, you've been present
during the statement ot the agreement by Mr. Bach on the record?
MS. CARLSON: Yes.
THE MASTER: Do you understand what Mr. Bach has
stated on the record?
MS. CARLSON: Yes.
THE MASTER: Do you have any questions about what
he stated?
MS. CARLSON: No.
THE MASTER: And are you satisfied that the
statement represents the agreement that you have reached with
respect to the claims of equitable distribution ~nd alimony?
, -
MS. CARLSON: Yes.
THE MASTER: You also understand that when you
leave here today, even though there is no signing ot the
agreement, that you are bound by the terms ot this agreement,
that the only changes that we can make would be correction ot
typographical errors?
MS. CARLSON: Yes.
THE MASTER: Mr. Carlson, you have been present
during the statement ot the agreement; is that correct?
MR. CARLSON: Yes.
THE MASTER: Do you understand the agreement?
MR. CARLSON: Yes.
THE MASTER: Do you have any questions about the
agreement?
MR. CARLSON: No.
THE MASTER: Are you satistied that this agreement
represents your understanding of the settlement of the claims ot
equitable distribution and alimony?
MR. CARLSON: Yes.
THE MASTER: You understand that when you leave
here today that the agreement is binding on you even though it
o CMPi ley- & ~'flOX, P.J;.____________
Alt11fnt'Y'i oAt (-JW
Jan M. Wiley
David J. Lenox
Timothy J. Colg.n'
. Alia_mitral III 11_.. JUNY
o
Dawn Gladfelter
EJCdr. A.s"ur.nt
Janice Yocum
Real E.sttlc. Assl.St"nt
September 11, 1998
E. Robert Elicker, II
Divorce Master
Cumberland County Court of
COlDlllon Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: Carlson v Carlson
Docket No: 96-1191-CIVIL
Dear Mr. Elicker:
Enclosed please find the original settlement agreement in the
above captioned matter.
The document has now been signed by both parties and witnessed
by both attorneys.
Thank you for your ongoing cooperation.
Very truly yours,
WILEY & LENOX, P.C.
-JL-, ,,,a".J '), (/1 r..../pt--SOC
by Timothy J. Colgan, Esq.
Enclosure
TJC/gcl
cc: LeeAnn Carlson
James M. Bach, Esq. (wI enclosure)
On~ S.,urh <imoft Screet
Dill.\hur)l. Pt'nt1~yh-;Jn;.J /7019
(717) .Ul.C)(,(J(1
(HIN)) 6H!-WO
Fu (717) 432-0426
. ~n~b'41~.~~~cs
Jan M. Wiley
O",'d J. IAnol(
TImothy J. COlg.n'
.AIMI...m_,.ffow_,1 <>
Dawn Gladfelter
EJr.r, A.atstMlt
Janice Yocum
RHI Est." Assaf"",
April 7, 1998
lames Bach. Esq,
352 S. Sporting Hill Road
Mechanlcsburg, PA 17055
Re: Carlson v, Carlson
Docket No,: 96-1191
Dear 11m:
Per our discussion yesterday, I have heen retained 10 represent Lee Ann
Carlson in the above captioned maller,
Attached is a copy of her Pre-Trial Statement. I have sent same via first class
mail, however, I wanted to get this in your hands as soon as possible.
Should you have any questions, please contact me at the numhers listed below.
Very truly yours,
IAN M, WILEY & ASSOCIATES
tO~lf
by Timothy I. Colga,\
cc: E. Robert Elicker. Esq,
TIC/ar
fl.I/'R.-IC rrn 11~IR/SI)NII)II'II//l '1-1/.-1/1'\'411711'/'/)
an.. SoUlh &/,i"""" Sir..'
Di/bbur/l, I'm,".y/.,n;, /70/9
(71 n 4J2%ti6
(1100) 682-4210
Flit (7/7) 4J2-D426
TIMOTHY CARLSON, IN THE COURT OF COMMON PLEAS OF
plaintiff CUMBERLAND COUNTY, PENNSYINANIA
vs. NO. 96 - 1191 CIVIL
LEANN C. CARLSON,
Defendant IN DIVORCE
THE MASTER Today is Tuesday, August 18, 1998.
This is the date set for a Master's hearing in the above
captioned divorce proceedings. Present ar~ the plaintiff,
Timothy Carlson, and his attorney James M. Bach, and the
Defendant, Leann C. Carlson, and her attorney Timothy J. Colgan.
A divorce complaint was filed on March 5, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. The Master has been provided affidavits of consent
and waivers of notice of intention to request entry of divorce
decree signed by the parties and dated today. Those documents
will be filed with the Prothonotary by the Divorce Master's
Office. The divorce can then conclude under section 3301(C) of
the Domestic Relations Code.
The complaint raised the economic claim of
equitable distribution. The Master has been advised, however,
that part of an agreement reached between the parties involves a
claim for alimony; therefore, Mr. colgan is going to file a
petition with the Prothonotary raising that claim of record.
Upon the Master being notified that the claim is filed and the
signed agreement being returned to the Master, the Master will
EXHIBIT A
prepare an order vacating his appointment 80 that counsel can
file the praecipe to transmit the record to request a final
decree in divorce.
No claim has been raised for counsel fees and
expenses by either party.
The Master has been advised that counsel and the
parties have reached an agreement with respect to the
outstanding claims of equitable distribution and the claim to be
filed of alimony. An agreement i~ going to be placed on the
record in the presence of the parties. That agreement as placed
on the record will be considered the substantive agreement of
the parties not subject ~o changes or modifications except for
correction of typographical errors which may be made during the
transcription. The draft of the agreement is going to be sent
to counsel to review for typographical errors. Any corrections
will then be made and the Master will prepare a final draft for
signatures by the parties. The signatures of the parties is
simply an affirmation of the agreement which is placed on the
record at this time. As indicated, the agreement as stated on
the record will be binding and is considered the substantive
agreement of the parties resolving all economic claims.
After the Master has been provided the signed
agreement and the alimony claim has been raised of record, the
Master will prepare an order vacating his appointment and
counsel can then file a praecipe transmitting the record to the
Court requesting a final decree divorce.
At the pre-hearing conference, the Master notsd
that attorney Robert B. MacIntyre accepted the service of the
complaint on behalf of the Defendant. The Master felt that that
constituted an entry of appearance on his behalf in the action
and had requested that counsel obtain his withdrawal of
appearance. However, both counsel and Ms. Carlson have
indicated that they have been unable to get Mr. MacIntyre to
file the appropriate praecipe withdrawing his appearance in the
action. Nevertheless, we are satisfied that Mr. Colgan is
representing Ms. Carlson and we will proceed on that basis. Mr.
Bach.
MR. BACH: Mr. and Ms. Carlson, what I am going to
put on the record at this time is a proposed mutual agreement
between each of you. The purpose of the agreement is to divide
and distribute the assets and debts that you acquired during the
marriage. If we say something that is inappropriate or
incorrect or you do not understand, please stop me.
1. REAL ESTATE: The parties hereto, namely, husband and
wife, own as tenants by the entireties real estate
situate at 111 Salem Church Road, Mechanicsburg,
Cumberland County, Pennsylvania. The parties have agreed
and stipulated that the value of this real estate is
$90,000.00.
Presently, this property is encumbered by a first
mortgage in the approximate amount of $59,000.00 with
Chase Manhattan Mortgage Company and a second mortgage in
the approximate amount of $11,000.00 with Mellon Bank.
Husband will renounce all of his right, title, and
interest in the subject real estate and award his real
estate to wife by executing a deed within five (5) daye
from the date the agreement is signed whereby the real
estate is transferred from husband to wife to wife
exclusively.
Wife will be responsible for full and final payment of
mortgage No. 1 and mortgage No. 2 set forth above.
Further, wife will indemnify and hold husband harmless on
account of mortgage No. 1 and mortgage No. 2 as set forth
above.
All taxes due and owing as of this date or the date of
the signing of the agreement will be the responsibility
of wife. Expenses appended to the real estate as of the
date of the signing of the agreement will be the
responsibility of wife.
2. RETIREMENT PLANS OF THE PARTIES: Wife does not own or
possess a retirement account nor has she acquired one
during the course of the marriage. Husband does own
a retirement account and he acquired it during the course
of the marriage. This account js with his employer,
PP&L and it is known as a 401(k) account. This account
with an approximate balance of $25,000.00 is to be
transferred absolutely to wife. Husband agrees to
sign any and all documents necessary to transfer this
account balance to wife. This account balance may be
placed into another 401(k) account that wife may set up
and designate to be her own or alternatively any other
account that she deems to be proper and appropriate for
said transfer.
Husband agrees to sign all documents immediately upon
presentation to him to accomplish the objective set forth
in this paragraph. All documents will be prepared by
attorney colgan on behalf of wife and then transmitted
to attorney Bach for disposition and review by his
client.
Husband also has a retirement plan with PP&L which is
designated as an accrued monthly retirement benefit --
straight life payable at age 65. Wife waives, releases,
and renounces any and all right, title, and interest in
said retirement plan.
J. ALIMONY: Husband agrees to pay alimony to wife for six
(6) years at the rate of $877.00 per month. This alimony
will be paid by way of a payroll deduction through the
Domestic Relations Section ot the Court ot Common Pleas
ot Cumberland county. presently, there exists a support
order in the Domestic Relations, No. 540S97 which
provides tor alimony pendente lite at the rate ot $877.00
per month. This order also contains a provision tor
child support in the amount of $474.50 for each ot the
two children per month.
The parties agree that they or their counsel will
immediately notity the Domestic Relations Section ot the
entry ot a tinal decree in divorce ana that the alimony
would begin the month that the divorce is issued and stay
in eftect tor the next 71 months. The total payment at
$877.00 per month is tor 72 months.
Wite has applied tor social security disability benetits
at the present time. Wite has not received a tinal
approval and/or disapproval trom the social security
administration.
In the event wite does receive benetits trom social
security tor her disability, the obligation tor alimony
would be reduced by 1/2 ot her disability payment. (An
example, it wite is awarded $600.00 per month, $300.00
per month would come ott the alimony required payment.)
Wite agrees to immediately notify her counsel as to the
results of the disability application and advise as to an
acceptance or rejection. Further, wife agrees to do all
those things neces9ary and required by social security to
see that the entire application process is completed.
The alimony will terminate automatically 72 months atter
it begins without turther order ot court. The alimony
will not terminate upon wite's remarriage, cohabitation,
or the death ot Mr. Carlson, and upon death ot husband,
it any alimony is remaining to be paid of the 72 months,
wite will have a claim against Mr. Carlson's estate. It
is turther agreed that neither party will be able to
modify the alimony. The only modification being provided
herein is in the event that wife receives disability
benefits from social security.
4. VEHICLES OWNED BY THE PARTIES: Husband and wite have
divided and distributed any vehicles owned by them during
the course of the marriage and each party is now
responsible for the vehicle in their possession as well
as payment and license requirements of said vehicle.
5. HOUSEHOLD FURNISHINGS: Husband and wife have divided,
to their mutual satisfaction, all household furnishings.
This ag~eement will act as a bill of sale from husband
and wife to each other for all household furnishings now
in their possession and each party, that is husband
and/or wife, may do whatever they deem necessary, fit and
appropriate with each item of household furnishings in
their possession.
6. CHECKING AND SAVINGS ACCOUNTS: The parties hereto
have divided and distributed their marital checking
accounts and savings accounts to their satisfaction
heretofore. Neither party will make any claim against
the other for any checking accounts or savings accounts
on account of this agreement.
7. STOCKS AND BONDS: The parties hereto, namely, husband
and wife have divided and distributed all marital stocks
and bonds to their mutual satisfaction heretofore.
Neither party will make any claim against the other for
any of the stocks and bonds acquired during the course of
the marriage.
8. HEALTH INSURANCE: Presently the father (husband) is
covering wife and the two children for health insurance
as provided by his employer. Husband and wife agree that
the parties will share in the costs of health insurance
for wife. Husband will cooperate with wife and wife's
counsel to obtain the necessary documents for signature
to obtain COBRA information and benefits so wife can get
a reduced rate for her health insurance which will take
place in her name post divorce. Post divorce those costs
and expenses for her health insurance under COBRA will be
shared equally by and between husband and wife. In other
words, if wife's obligation is $200.00 per month, husband
agrees to pay 1/2, $100.00 per month. Husband's
contribution as provided for herein will be for a period
of two years.
9. VISITATION WITH THE MINOR CHILDREN: Husband and wife
both agree that they have exchanged between them a rather
liberal visitation schedule. Apparently, husband
provides wife with his work schedule and wife has been
agreeing to allow husband to have the children on his
scheduled days off. In addition to the times off, they
have also agreed in the past to other times. It is
hopeful that they will continue to cooperate with each
other as to the visitation with the children in the
immediate near future.
.
- ,
Husband has been providing wife with a copy of his annual
schedule of work so wife can calculate and husband can
calculate as to his days off so they can make appropriate
adjustments to their schedule for visitation, and husband
agrees to continue to provide wife with his schedule so
wife can see and he can know when he would have
visitation.
10. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or
she may now have or hereafter acquire under the present
or future laws of any jurisdiction to share in the
property or the estate of the other as a result of the
marital relationship including without limitation,
statutory allowance, widow's allowance, right of
intestacy, right to take against the will of the other,
and right to act as administrator or executor in the
other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect
this mutual waiver and relinquishment of all such
interests, rights, and claims.
THE MASTER: Ms. Carlson, you've been present
during the statement of the agreement by Mr. Bach on the record?
MS. CARLSON: Yes.
THE MASTER: Do you understand what Mr. Bach has
stated on the record?
MS. CARLSON: Yes.
THE MASTER: Do you have any questions about what
he stated?
MS. CARLSON: No.
THE MASTER: And are you satisfied that the
statement represents the agreement that you have reached with
respect to the claims of equitable distribution and alimony?
MS. CARLSON: Yes.
THE MASTER: You also undet'stand that when you
leave here today, even though there is no signing or the
agreement, t.hat you are bound by the terms of this agreement,
that the only changes that we can make would be correction of
typographical errors?
MS. CARLSON: Yes.
THE MASTER: Mr. Carlson, you have been present
during the statement or the agreement; is that correct?
MR. CARLSON: Yes.
THE MASTER: Do you understand the agreement?
MR. CARLSON: Yes.
THE MASTER: Do you have any questions about the
agreement?
MR. CARLSON: No.
THE MASTER: Are you satisfied that this agreement
represents your understanding of the settlement or the claims or
equitable distribution and alimony?
MR. C'RLSON: Yes.
THE MASTER: You understand that when you leave
here today that the agreement is binding on you even though it
(b) The Plaintiff reserves the right to call other witnesses should they becollle neccssilry
and will immediately adliise the Master and opposing counsel.
[41 A li.t of all nhiblu the party npects to offer Into evidence. each contlllnlnll In
IdentifyIng mark.
(a) ExhibIt" A" Inlientory and appraisal. marital a.ssets and marital debt.
(b) Exhibit "B" Income and expcnse statement.
[SI The parties gross Income from all sources. each payroll deduetllln. IInd the pllrtl.. net
Income. Including the parties most recent state and federal Ineom. ta, r.turns and pay
stubs.
(a) The Plaintiffs gross income pcr year is SS0,400.00
(b) The Plaintiffs net income pcr year is $41,820.00
(c) See F.XHIBIT "B" attached to this Pre-Trial Statement for !'I..inlin', payroll
deductions. and most current state and federal income tall Mums.
[61 If the party intends to offer any testimony as to his np.n.... a curr.nl np.n..
statement in the form required by the practice and procedure Ilonrnlna an action In
support.
(a) The Plaintiff will testifY in regards to his current expenscs. See t:xllllur "('" lor
Plaintiffs income and ellpense statement.
[71 The value of a pension or retirement benefiu. th. marUlI1 portion th.reof. and the racu
and documentation upon which the party relies to lupport the nluatlon.
(a) See Exhibit "A" attached to this ('re- I'rial Sllltement tilr !,Iaintill's pension and
retirement benefits,
[81 If there Is a claim for counsel fetl, the IImount of rllt. to be charlled, the basis for the
cbarge. and a detailed itemization of lb. Men In. rendered.
)
ASSETS OF PARTIES
The Plaintiff marks on the list below those ih:ms applicable to the case at bar and
itemizes the assets on the following pages, If an item has been appraised, a copy of the
appraisal report will be attached hereto,
1. REAL PROPERTY
2. MOTOR VEHICLES
3, STOCKS, BONDS, SECURITIES and OPTIONS
4. CERTIFICATES OF DEPOSIT
S. CHECKING ACCOUNTS, CASH
6. SAVING ACCOUNTS, MONEY MARKET, AND SAVING
CERTIFICATES
7. CONTENTS OF SAFE DEPOSIT BOX
8. TRUSTS
9. LIFE INSURANCE POLICIES (include face and cash values and
current beneficiaries).
10. ANNUITIES
II. GIFTS
12. INHERITANCES
13. PATENTS, COPYRIGHTS, INVENTIONS, and ROYALTIES
14. PERSONAL PROPERTY OUTSIDE OF HOME
(x)
( }t )
(x)
( )
(x)
( )
(x)
( )
( )
( )
( )
( )
( )
( )
( )
( )
( )
(x)
( x )
( )
IS, BUSINESS (list all owners, including percentage of ownership, and
officer / director positions held by party with company).
16. EMPLOYMENT TERMINATION BENEFITS (severance pay,
workmans comp,).
17. PROFIT SHARING PLANS
18. PENSION PLANS (indicate employee contribution and date plan vests)
19. RETIREMENT PLANS,INDlVIDUAL RETIREMENT ACCOUNTS
20. DISABILITY PAYMENTS
LIABILITIES OF THE PARTIES
The Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the liabilities on the tollowing pages,
SECURED
( x) I, MORTGAGES (Chase Manhattan, $55,000 First Mortgage, Mellon Bank,
$10,000 Second Mortgage)
( ) 2. JUDGMENTS
( ) 3, LIENS
( x) 4. OTHER SECURED LIABILITIES
UNSECURED
(x) 5. CREDIT CARD BALANCE (Beneficial $3,600, Benton $1,000, First Union
$6,100, Keystone Financial $600, PP & L $4,800, Pep Boys $1,200, Sunoco
$700)
( ) 6. PURCHASES
( ) 7, LOAN PAYMENTS
( ) 8. NOTES PAYABLE
( ) 9. OTHER UNSECURED LIABILITIES
CONTINGENT OR DEFERRED
( ) 10. CONTRACT OR AGREEMENTS
( ) 11. PROMISSORY NOTES
( ) 12, LAWSUITS
( ) 13. OPTIONS
( ) 14, TAXES
( ) 15, OTHER CONTINGENT OR DEFERRED LIABILITIES
MARITAL PROPERTY
The Plaintiff lists all marital property in which either or both spouses have a legal
or equitable interest individually or with any other person as of the date this action was
commenced:
ITEM DESCRIPTION NAMES OF DATE OF
NO. OF PJ:OPERTY AU. OWNERS ACQUISITION VALUE
J. Rtal Propeny Joint 1984 590,000
2. 1983 Ford Automobilt Joint 1994 5500
3. 1989 Subaru Automobilt Joint 1989 52,500
4. Stocks, Bonds Joint 198~ 53.500
5. Checking Accounts, cash Joint 1989 5100
6. Non-contributory, vested Husband 1980 5725.76
7, 40lK Husband 1980 520,000
8. Household furnishings Joint 198~ 53,000
TOTAL ASSETS: $120,325.76
LlABII.ITIES I DEBTS
The PlaintitT lists allliabilitil:s of l:ither or both spouses alone or with any person
as of the date this action was comml:nced:
Uem Amount 01 Nature 01 Effective Date Holder of
NIb Any Lien Any Lien 01 Lien tlen -
l. $55,000 Mungag. on house 1985 Chase Manhanan
2. $10,000 Home Equity loan 1995 Mellun Bank
ASSF.TS CW TifF. PARTIES
The Defendant marks on the list below those items applicable to the case at bar and
itemizes the assets on the following pagcs. Ifan itcm has becn appraiscd, a copy of the appraisal
report will be attached hcrcto,
( X ) I. Real Property
( X) 2. Motor Vehicles
( X) ), Stocks, Bonds, Sccurities, and Options
( ) 4, Certificates of Deposit
( ) 5. Checking Accouilts. Cash
( ) 6. Saliings Accounts, Money Market, and Saliing Ccrtificates
( X) 7, Contents of Safe Deposit Box
( ) 8, Trusts
( ) 9, Life Insurance Policies (includc face and cash lialues and currcnt beneficiaries)
( ) 10. Annuites
( ) II. Gifts
( ) 12. Inheritances
( ) 13. Patents. Copyrights, Inlicntions, and Royalties
( ) 14. Personal Property Outside ofUome
( ) 15. Busincss (list all owners, including percentage of ownership, and officer/director
positions held by party with company)
( ) 16, Employment Termination Bencfits (sclicrance pay, workman's comp.)
( ) 17, Profit Sharing Plans
Exhibit A-l
( X) 18. Pension Plans (indicate employee conlribution and date plan vests)
( X) 19, Retirement Plans, Indiliidual Retirement Accounts
( ) 20, Di:lllbility Payments
( ) 21, Litigation Claims (matured and unmatured)
( ) 22, MilitarylVA Bene Ii Is
( ) 23. Education Benefits
( 24. Debts Due (including loans, mortgages hcld)
( X ) 25, Household Furnishings and Personally (include as separate category and attach
itemized list if distribution of such assets is in dispute),
IJABII.ITIES 01. TilE P,\RTIF.S
SECURED
( X ) l. Mortgages [Chase Manhattan Mortgagc COfJXlratilln ( I sll, Mellon nank (2nd)/
( ) 2, Judgmcnts
( ) 3. Liens
( ) 4. Other Sccured liabilitics
UNSECtJRED
( ) 5, Credit Card Balances
( ) 6, Purchases
( X) 7, Loan Payments (auto loan from Kcystonc Financial)
( ) 8. Notes Payable
( ) 9. Other unsecured liabilities
CONTlNGF.NT OR DF.FF.RRED
( ) 10. Contracts or Agreements
( ) II. Promissory Notcs
( ) 12, Lawsuits
( ) 13. Options
( ) 14. Taxcs
( ) IS. Othcr cllntingcntllr dcfcrred liabilities
Exhibit A-2
MARITAl. PROPF.RTY
The Defendantlisls all marital property In which eilher or bOlh spouso:s haw a lellal or
equitable intero:st indiliidually or with any olho:r person as of the date Ihis action was
commenced.
Itum Descnpnon of Owner.l' Dale of
Number Property Nam... ACqUISition Value
I Home 1II1!! SlIIem Joinl 1984 $'10,000.00
Church Road,
Mechanic.burll
2 Stocks and Bonds Husbood 1'I8~ S.l,~OO,OO
1 Non-contributory, HushlUld 1980 572'16
vesled
4, 40!(k) Hu.hood 1'J80 $20,000,00
~ Household Joint !'J8~ 5J,ooo.00
fumishinllS
Tolals $111.US.76
Exhibit A-)
LlADII.lTIF.SIDF.RTS
The Defendontlists ollliahilities of either or hoth spouses individuolly or with ony other
person as of the dole this action was commenced.
Item Nalllr. of
Number AmounlofLien I..on note of lien Lien Hold.r
I 1",869 00 1st 1987 Chas. Manhallan
Mortllalle Mortllase Corp.
2, 110,892.00 2nd 1995 Mellon Bank
1\l0rtllBlle
Tot.l. 168.761.00
Exhibit A- 4
-
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LEi A. CARLSON ) Order Number 540 S n
Plaintiff )
v,. ) P ACSES Case Number nooooou
TIMO'l'HY R. CARLSON SR )
Defendant ) Otller Slale ID Number
ORDER OF COURT
o Final 0 interim 0 Modified
AND NOW,
17TH DAY Oil' MARCH, 1998
,based upon the Court's
determination that the Payee's monthly net income is $ 217 .00
and the Payor's
monthly net income is $ 4,090.00
, it is hereby ordered that the Payor pay to the
Domestic Relations Section, Court of Common Pleas,
BIGHTEBN KUNC~BD AND II'III'TY SIX DOLLARS
Dollars ($ 1,856.00
) a month ($1,826.00
for current support and $ 30.00
on arrears) payable
BIWllIIKL Y
as follows: $840. 3l/BIWEEKLY (CURRENTLY ZBRO ON
ARREARS I .
The effective date of the order is 01/20/98 .
Arrears set at $ -100.09
as of MARCH 17, 1998
are due in full
IMMEDIATELY. Contempt proceedings, credit bureau reporting and tax refund offset
certification will not be initiated and judgement will not be entered, as long as payor pays on
arrears on each payment date as specified above. Failure to make each payment on time and
in full will cause all arrears to become subject to immediate collection by all of the means
I isted above.
For the Support of:
LEE A. CARLSON
TIMOTHY CARLSON
ANDREW CARLSON
TIMOTHY R. CARLSON SR SERVICB II'EES/ANNUAL
TIMOTHY R. CARLSON SR
TIMOTHY R. CARLSON SR
$
$
$
$
$
$
877.00
474.50
474.50
26.00
0.00
0.00
Service Type M
Form OE-518
Worker ID 21004
,
TIMOTHY CARLSON,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96 - 1191 CIVIL
LEEAHN C. CARLSON,
Defendant
:
IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Monday, April 13, 1998
Present for the Plaintiff, Timothy Carlson, is
attorney James M. Bach, and present for the Defendant, Leeann C,
carlson, is attorney Timothy J. Colgan.
A divorce complaint was filed on March 5, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. The complaint raised the economic claim of equitable
distribution. At present no other economic claims have been
raised in the action; Mr. COlgan has indicated that he probably
will file a petition raising additional claims of alimony and
counsel fees and expenses.
With respect to any issues regarding marital
misconduct, we are going to allow counsel the opportunity to
present that testimony at the hearing on the other economic
claims without scheduling a separate hearing to take marital
misconduct testimony inasmuch as, according to attorney Bach,
the testimony will probably revolve around issues involving
wife's alleged alcohol abuse. Mr. Colgan, on the question of
martial misconduct, has indicated that although there has been
some mention about wife's alleged alcohol problem, that husband,
according to wife, also has an alcohol problem and that there
was also mutual drug use during the marriage which contributed
to the problems that the parties had in their marital
relationship.
The parties have indicated that they will sign and
file affidavits of consent so that the divorce can be concluded
under Section 3301(c) of the Domestic Relations Code.
The attorney who filed the complaint, Diane S.
Baker, has given Mr. Bach a praecipe withdrawing her appearance.
The Master's office will file the praecipe. Attorney Robert B.
MacIntyre accepted service of the complaint on behalf of the
Defendant but has not entered a praecipe withdrawing his
appearance in the action. The question is whether or not his
acceptance of the complaint constitutes entering his appearance.
~
The Master believes that if he accepted a pleading, he, by that
action, was indicating that he was representing the Defendant.
Therefore, his withdrawal of appearanca should be entered.
The parties were married on May 30, 1983, and
separated in January 1996. They are the natural parents of two
children, Andrew, age 13 and Timothy, age 9.
Husband is 40 years of age and resides at 650 Sears
Run Road, Mechanicburg, Pennsylvania, where he lives alone.
Husband is a high school graduate and works at PP&L as a
troubleshooter. The support office computed his net monthly
income to be $4,025.00 based on an order of court entered July
16, 1997. Wife's income was computed by the support office to
be $548.00 net per month. Husband's W-2 for 1997, however,
shows an income of $70,225.00 annually. The Master has been
advised, however, that a new support order is pending and we
will take a look at the amount of the order and what income the
Court determined at that time for both parties in setting the
new order. Mr. Bach has indicated that his client has attention
deficit disorder and takes medication for that disorder. He is
currently paying child support and spousal support in the amount
of $1,625.00 monthly allocated $932.00 for children and $693.00
for wife..
Wife is 44 years of age and resides at 111 Salem
ChurCh Road, Mechanicsburg, Pennsylvania, where she lives with
the two children. She has a college degree but is currently
unable to work because of a health condition inVOlving her
liver. Mr. Colgan has provided a letter from Frank W. Jackson,
M.D. stating her current medical situation involving chronic
hepatitis C with cirrhosis, fibromyalgia, and depression. Mr.
Colgan has indicated that his client is appealing a denial of
SSI but it will probably be a year or so before that matter is
heard and a decision is made. Mr. Colgan indicated that
previously wife worked as a reseacher, a service representative,
and has a paralegal degree from HACC, which is the college
degree which she has attained. The Master raised a question
about the medical insurance benefits that wife would be entitled
to receive upon the entry of a divorce decree. It is a
· Mr. Bach has given the Master a court order dated March
17, 1998, showing wife's monthly net income at $217.00 and
husband's monthly net income of $4,090.00. The support order
entered using those incomes was $1,826.00 per month. The
allocation of the order is $877.00 for wife and $474.50 for each
of the children monthly,
~
certainty that she would be entitled to COBRA benefits through
PP'L; however, we need to know the cost of those benefits and
~he length of those benefi~s, and what would occur when those
benefits terminate. Because of wife's preexisting medical
condition, it appears as if she would have difficulty getting on
a direct pay plan with Blue Cross/Blue Shield.
The parties own real estate at 111 Salem Church
Road, Mechanic.burg, Pennsylvania, which counsel stipulate has a
value of $90,000.00. The property is SUbject to a mortgage in
favor of Chase Manhattan Bank ~ith a payoff of around
$55,000.00. The monthly payment, inclUding taxes and insurance,
is $5~0.00. The home is also subject to a lien ari5ing out of a
home equity loan in favor of Mellon Bank with an approximate
balance on that lien of $10,000.00. The monthly payment is
$338.00. Mr. Colgan has indicated tha~ he believes that most of
that home equity loan was charged by Mr. Carlson after the
separation; therefore, we need to know what the balance due on
that loan was at separation (January 1996) and who made the
charge. after that date, if any. Mr. Bach pointed out that the
account is in wife's name only so there may be some question as
to whether or not Mr. Carlson was able to make any charges on
that account after separation. In any event, counsel are going
to inquire about the status of this line of credit as indicated.
Wife has indicated that she would like to remain in the home.
There were two vehicles noted on the pre-trial
statement of husband but they do not currently exist; therefore,
we will not use any value for vehicles in this case in the
equitable distribubtion computation.
The pre-trial statement indicates that there was a
CheCking account of around $100.00 at date of separation and
some stocks and bonds with a value of around $3,500.00. Mr.
Colgan indicated that after separation, Mr. Carlson cashed in
the stocks and bonds. We will need to have an accounting as to
what existed at time of separation and what happened to the
assets representing tho value of those stocks and bonds.
Mr. Carlson has a pension and perhaps in addition a
401(k) with PP&L. Mr. Colgan is going to inquire as to the
existence of the pension and 401(k) plans and may decide to have
them valued. However, if we have a defined benefit plan and
since there does not appear to be offsetting assets, then we
will probably employ a QDRO to distribute the defined benefit
plan. with the defined contribution plan, which may be the
401(k), that money can be rolled out, after determination of
what interest wife may have in that plan, to her name only
without any tax consequences or penalty into a similar plan.
<-
The household tangible personal property has be.n
valued by husband at $3,000.00. The property essentially
remains in the possession of wife and Mr. Colgan is going to
determine if his client will agree with the value as placed on
the property by husband or whether he wants to have the property
appraised.
Mr. Bach has indicated that Mr. Carlson filed a
bankruptcy proceeding (Chapter 7) and has been discharged from
martial debt. Apparently there was a large debt owed to credit
card companies which was in Mr. Carlson's name only; therefore,
the discharge of husband completely resolves all issues
regarding that debt since wife was not an obligor. Mr. Bach
does indicate that he thought perhaps his client should get some
credit for the assumption of marital debt; however, the Master
indicated that he would need to know what, if any, sums of money
husband actually paid on account of marital debt before the
discharge. In any event, Mr. Bach stated that he believes he
may have a case that he can use to support his position of
credit and will provide any research he has on that issue to the
Master and to Mr. Colgan. The remaining debt, however,
apparently remains in the form of the mortgage and the home
equity loan, which are liens against the property which wife
would like to retain. Wife is an obligor on both of those debts
although husband has boen discharged from the mortgage and the
home equity loan.
Mr. Bach has indicated that the income that was
computed by the support office in assessing the support order
against Mr. Carlson included a large amount of overtime pay.
Apparently because of a consistency of overtime, the Court
included that overtime income but Mr. Bach wanted to note that
there is no guarantee that that income will be paid on a long
term basis and that if the overtime were eliminated, Mr.
Carlson's income would decrease substantially.
A hearing is scheduled for TueSday, August 18,
1998, at 9:00 a.m. Notices will be sent to counsel and the
parties.
E. Robert EliCker, II
Divorce Master
,
TIKYIllY CARLSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 1191 CIVIL
VB.
CIVIL ACTION - LAW
I.EE'.Ntl C. CARLSON,
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: T:Imothy Carlson , Plaintiff
Janes M. Bach , Counsel for Plaintiff
Leeann C. Carlson , Defendant
T:Imothy J. Colgan . Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street. Carlisle, Pennsylvania on the 18th day
of AUQUst . 1998, at 9:00 a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
t e ,~rt,
'Wh
. rge E: :Offt,
presiden t Judge.
Date of Order and
Notice: 4/13/98
By:
Divorce Master
IF YOU 00 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 ASSOCIATWN
2 l.lI3EIfI'Y AVENUE
CAI<LISl.E, PA 1"I0l:l
TEl.EPHONE (717) 24<J-1l66
Ill{ #211:;'>(,
I II ^NN ( (^ltI.SON.
1'l.^INTI!'!'
IN IlIE COllI{ r m COMMON 1'1 LAS OF
t'liMRIRI.^NIl COUNTY. PENNSYl.VANIA
VS
DOMES 1"It" RU.^ liONS SH.1I1 IN
CIVIL. ^CTION. SIII'POR r
IIMOHIY R. CARLSON. SR.
DEFENDANT
NO. 54ll S 97
ORDF.R (n' COllRT
^ND NOW,Ihis 161h day of 1Y.!:L, 1997. based upou the Courl's delerminalionlhal
I'lainlifl's I1\llnlhly net income/earn in!! capacity is $ 5.lS.00 . and Deli:ndanl's n1llnlhly nel
II1cllmc/carninl:t capacity is $ 4015.0ll . it is hereby ordered thllllhe Defendanl pay to the
1l0l1\esllc Relali<1lls Section, ('ourt of Common Picas. $ 1625.0ll IIlllonth payable
$750.00/biweekl;y effeCliye, 8/1/97. Arrears set al $.Q.IIS Ill' 71) 1/97 (with Ihe lasl pllymellt
date of _ I. arc due in full IMMEDIATELY. ('onlempl proceedin!!s. credil bureau reportinl:t and
la.\ rcfund oflset certilicalion and cnlrance of a judllelllenlmay be held in abeyance as lonll as
Deli:ndanl pays $JlliL on arrears each payment date. Failure 10 make each paymenl onlillle and
in full will cause all arrea., 10 become subjeclto immediate collection by all of the means lislCd
aho\lc.
For the support of wife and two children. This order is based Iln an agree'llellt. Till
order takes into considernlionthe defendant will DaY directly 10 Ihe DlainlifT July I <)97's SUllllorl
Ilbligation. This order is allocaled $931.00 ocr month child SUDDorl and $6'lJ.00 ocr ml1nlh
sllousal SUDoort.. The delimdanl shall pay the cosls ofS 27.0ll. which sum includes Ihe pm-
raled service Ice of$ 12.00, payable wilhin 90 days.
Said money 10 be turned over by Ihe Domeslic Relalions Section Ill: olllinliff. Paymcllls
l1\usl be made by cash. check or money order. ('ash paYlllellls musl be made in person. ^II
chccks alld money orders must be made payable 10 Dllmeslic Relations Seclio" and deliyered or
mailed 10 Domestic Relations Section. 13 North Hanoyer Streel. P. 0. !io" no. Carlisle.
Pennsylvania 17013. Each paymen! must bear your Domeslic Relations number in ordcr t" be
pnu:csscd.
I !Ilrennhursed medical e.\pcnses arc I" he pllid 2!L% h) Ilcli:lldalll and 50 % hy
PlailllitT. Ilcfcndill1t to provide medical insurance 'l1verage as availahle throlll!h his prescHt
cmpl",mcnl.. Within 30 days alier Ihe enlry oflhis urder.lhc Dcfcndanl shall submill" Ihe
person having custody of the chilu(rc.:n) written pnloflhat medicill insuran+..:c cuverage IHI~ hccl1
mauc. Proof nf cll\lcrage shall consist. al a minimum uf: (I) the name of the hcallh care
c"yerage pruvider(sl; (21 any applicable identificalionnumhers; (3) any cards evidencinl:t
,,,,erage; (411he address 10 which claims should he madc: (5) a "cscripli"n of any restrictIons "n
lI'iilge. ~lU.:h as u priur nppnwal fur hO!ipilnllldm issiul1s. ;.uuJ the mal1l1er of llhlaining approvaL
I r>) a CI'P) "I' lhe henefit hook lei or ClIyeral:te contract: 17) a """'pli,,nor alf dcduClihlC\ and co.
I"'ymcnh. all" (S) fiye copies "I' allY claim limns.
IMPORTANT LEGAL NOTICE
i :j i I Ii"' , i i-: "t. ii!, l';l!t"i r! i i il'i
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5. COrlE< 11'IEi.! ~Imj r Hit I'Ji' I I ",ulI'li. :
6. PROI"'ORT IOrhHE F ..EEI'IC [ ri 'ldO,
7. 8A'':;[C CHILD 'oIIFH1F'T,
8. ?',OD [T IUN>)I SUFFOF, f,
9. TorAL SUPPORf,
PERCENT(,GE OF CUI-IHII'lFD l'IFf [1'11'(11.".'
EACH FARE~T'S OS[LGArrON:
MONTHLY CHILD CiiF'F' EXFE'i"I:JE':
1'10NTHLy CH1LD C(,F:E tlSl,lGIHIOH,
TOTAL ~IIJI'ITHI.Y CHIl.D :'jUFF'flF,'T OPI [(',(,T[,,1i'I,
TOTAL CHILD SUPPORT PEP PAY peRIOD,
OBI. [GOfi 'S i'lmlTHI '( I'IF r I I'IUWII',':
LESS OBL I GEE' '; I"'IO"~THL. { ~1F.' r r 1\I(,:CH~lL:
LE:S~'; OEtL [I]OR 'c; 1"101'1 fHI., f CH [I,D SUFFOF'r 081.,113,', r r 111'-1,
DIFFERENCE:
MULTIPLY BY:
At-IOUNT OF ~IOI'rrHL '( SFIJUSI'd.. c;u" F-rJ[-" r :
TOTAL ~IONTHL( SUfPOF r,
TO f?'.L SUF'F'IJPT ORL [IJA r I ml PEP Fr. (:
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CALCUL,AT IONS 8AHFO ON ~ UICI DFT!'I.
ASSETS OF Tilt PAR.f1ES
The Defendant marks on the list below those items applicable to the case at bar and
itemizes the assels on the following pages. Ifan item has been appraised, a copy of the appraisal
report will be attached hereto.
( X ) 1. Real Property
( X) 2. Motor Vehicles
( X) 3. Stocks. Bonds, Securities, and Options
( ) 4. Certificates of Deposit
( ) 5. Checking Accounts, Cash
( ) 6. Savings Accounts, Money Market. and Saving Certificates
( X) 7. Contents of Safe Deposit Box
( ) 8. Trusts
( ) 9. Life Insurance Policies (include face and cash values and currenl beneficiaries)
( ) 10. Annuiles
( ) II. Gifts
( ) 12. Inheritances
( ) 13. Patents, Copyrights, Inventions, and Royalties
( ) 14. Personal Property Outside ofllome
( ) 15. Business (list all owners. including percentage of ownership, and officer/director
positions held by party with company)
) 16. Employment Termination Benefits (severance pay, workman's comp.)
( ) 17. Profit Sharing Plans
Exhibit A-l
( X) 18. Pension Plans (indicate employee conlrihution and date plan vests)
( X) 19. Retirement Plans. Individual Retirement Accounts
( ) 20. Disahilily Pay men Is
( ) 21. Litigalion Claims (matured and unmalured)
( ) 22. MilitarylV.A. Benefits
( ) 23. Education Benefits
( ) 24. Debts Due (including loans, mortgages held)
( X) 25. Household Furnishings and Personalty (inelude as separate category and attach
itemized list if distribution orsuch assets is in dispute).
I.IADIUTIES OF TilE P,\RTIF.S
SECtJRED
( X ) I. Mortgages [Chase Manhattan Mortgage Corporation (I st). Mellon Bank (2nd)}
( ) 2. Judgments
( ) 3. Liens
( ) 4. Other Secured Liabilities
UNSECURED
( ) S. Credit Card Balances
( ) 6. Purchases
( X ) 7. Loan Payments (auto loan ffilm Keystone Financial)
( ) 8. Notes Payable
( ) 9. Other unsecured liabilities
CONTINGF.NT OR nF.FERRF.D
( ) 10. Contracls or Agreemenls
( ) II. Promis50ry Notes
( ) 12. Lawsuits
( ) 13. Options
( ) 14. Taxes
( ) 15. Other contingent or deferred liabilities
Exhibit A- 2
MARITAl, PROPF.RTY
The Defendant lists all marital property in which either or hoth spouses have a legal or
equitahle interest individually or with any other person as or the dale this action was
commenced,
Ilem Oascriplion or Owners' nal. or
Number Property Namas AClluisilion Value
J. lIome II III Salem Joinl 1984 S90,OOO.00
Church Road,
Mechanicshurg
2. Slocks and Dnnds lIusband 1981 SJ,IOn.OO
J. Non-contribulory. Ilusband 1980 572'-16
vesled
4. 401(k) Husband 1980 S20,OOO.00
I. Ilousehold Joinl 1981 U,OOOOO
fUmishinll5
Tolal. S 117,115.76
Exhibit A-J
IJADllJIIESillE.D:r5
Thc Defcndontlists all liabilities of either or both spouscs individually or with any olher
person as of thc dote this action was commenced.
'lam Non",. or
Numher AmounlofLien Lien Palll onien Lien lIolder
I. S~7,869.00 IsI 1987 Ch.... Munho"on
Mortgage Mortglge Corp.
2. SIO,892.00 2nd l'l'l' Mellon 8B11k
Mortglg_
Telals
568,761.00
Exh ihit A- 4
_ lackson
crastroenterology
Specialist in Digestive and Liver Disorders
Frank WJackson. MD. FAro
.~
March 9, 1998
Cathleen Sempeles, M,D.
Good Hope Famlly Physicians
1830 Good Hope Road
Enola, PA 1702.5
Dear Cathleen:
Leeann Carlson has heen evaluated for additional therapy for chronic hepatitis C, She
Is not a candidate for the Ribavlr1n1Tnterferon study as she has herpes which Is a
disqualification, Consensus Interferon, however, Is approprhite for her, That drug Is being
used for treatment failures for the first generation Interferon. We are, therefore, starting her
on this drug.
Thank you for the opportunity to see Ms, Carlson, If you have any questions, please
call me.
Sincerely,
~
Frank W. Jackson, M.D,
FWJlkep
cc: LeeaM Carlson
Exhibit C-l
423 N,21sL Slrecl, Suite 1 00, Camp Hill. PA 17011
Te1ephone(7l7) 76J.{)930 Fax (717) 761.()465
E-mall Info@glcare.com Web IYww.g1care.c:om
. .
TIMOTHY CARLSON, IN THE COURT OF COMMON PLEAS or
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 96 - 1191 CIVIL
LIANN C. CARLSON,
Defendant IN DIVORCE
THE MASTER Today is Tuesday, August 18, 1998.
This is the date set for a Master's hearing in the above
captioned divorce proceedings. Present are the Plaintiff,
Timothy carlson, and his attorney James M. "ach, and the
Defendant, Leann c. carlson, and her attorney Timothy J. Colgan.
A divorce complaint was filed on March 5, 1996,
raising grounds tor divorce of irretrievable breakdown of the
marriage. The Master has been provided affidavite of consent
and waivers of notice of intention to request entry of divorce
deoree signed by the part lee and dated today. Those documents
will be filed with the Prothonotary by the Divorce Master's
Office. The divorce can then conclude under Section 3301(C) of
the Domsstic Relations Code.
The complaint raised the economic claim of
equitable distribution. The Master has been advised, however,
that part of an agreement reached between th6 parties involves a
claim for alimony; therefore, Mr, Colgan is going to file a
petition with the Prothonotary raising that claim of reCord.
Upon the Mast~r being notified that the claim is filed and the
signed agreement being returned to the Master, the Master will
EXHIBIT A
.
.
will b. paid by way of a payroll deduction through the
Dom..tio Relatione section of the Court of Common Pleas
of Cumberland County. Presently, there exists a support
order in the Do~estic Relations, No. 540S97 which
provides for alimony pendente lite at the rate of $877,00
per month. This order also contains a provision for
child 8upport in the amount of $474.50 for each of the
two children per month.
The parties agree that they or their counsel will
immediately notify the Domestic Relations Section of the
entry of a final decree in divorce and that the alimony
would begin the month that the divorce is issued and stay
in effect for the next 71 months. The total payment at
$877.00 per month is for 72 months.
Wife has applied for social security di.ab~lity benefits
at the present time. Wife has not received a final
approval and/or disapproval from the sooial security
administration.
In the event wife does receive benefits from sooial
security for her disability, the obligation for alimony
would be reduced by 1/2 of her disability payment. (An
example, if wife is awarded $600.00 per month, $300.00
per month would come off the alimony required payment.)
Wife agrees to immediately notify her counsel as to the
results of the disability application and advise as to an
acceptance or rejection. Further, wife agrees to do all
those things necessary and required by social seourity to
see that the entire application process is completed.
The alimony will terminate automatically 72 months after
it begins without further order of court. The alimony
will not terminate upon wife's remarriage, cohabitation,
or the death of Mr. Carlson, and upon death of husband,
if any alimony is remaining to be paid of the 72 months,
wife will have a claim against Mr. Carlson's estate. It
is further agreed that neither party will be able to
modify the alimony. The only modification being provided
nere1n 1S 1n t.ne event. t.Ilat. wIte receIves aIsatll1.1t.y
benefits from social security.
4. VEHICLES OWNED BY THE PARTW: Itusband and wife have
divided and distributed any vehicles owned by them during
the course of the marriage and each party is now
responsible for the vehicle in their possession as well
as payment and license requirements of said vshiole.
,
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ORDER/NOTICE TO WITHHOLD INCOME fON SUPPORT
'~J1 ,'Oi' . i /f'1':7
_^,. } It ..; ./ / OOflMIOJIOrcfer/Ntlfirll
Stolte Commonwedllh of Penlllylvdnid J
Co.!CilV/D,,1. 01 CUMBERLAND f)l'l. It/'ic, _/jt}1 (It It @A,no.""",jO"j"'IN"".
D.lleoIOrder/N,,!ice 12/10/02 )1 -r r 7< ". 'to"~ ,n 'orm.".,.n"ter/No""
II- c'e (. {L" 1t,)I'""
Tribunal/Cast! Number (See Adtkndum for Cdse summdry) > . .
R~ CARLSON, TIMOTHY R. SR
EmployeuWilhhulder''i Ft,lflerdl E1N NlJm~r
tmplOYl'l'fOhhMOf i N.unl! (lJ~I. hr<.!. Mil
PPL CORP AND ALL AFPrLIATED CO
C/O MR R CAROSIELLO - PAYROLL
PPL SERVICES CORP
2 N 9TH s.r
ALLENTOWN PA 18101-1139
168-48-3814
E rn~loy..t'/{)hlil(ur'\ SIK:IJI '.'(utll,; Number
3900000025
EmlJlnyt'f~i()bliKur'.. (.l;a! ldl'nlilier
rs... ~dOondum lot pI.lnti" IWm..
.uwcylfll..ith r.u.... on flltAdtm.nlJ
Cu~lf)di.11 P,lu'nl s NJme (I.J.,I, Fir"t, MI,
See Addendum for dftpendent ndmH dnd birth dates associated with cases on a".chment,
ORDER INFOR....IA nON: This is dn OrderlNolice 10 Wilhhold Income for Support bd'~d upon dn order for support
from CUMBERLAND Counly. Commonwedllh of Pennsylvdnid. By Idw, you dre rE'quired 10 deduct these
dmounls from the dbove-ndm~d employee'SI'obligor's ,ncom.. until further nolile even if the Order/Notice is not
issued by your Stdte.
S 1,030,00 per month in l'Urrent support
S 20.00 per monlh in pdSI-due support Arredrs 12 weeks or gredterl Oyes (X) no
S ____.Jl...Q!l.per month in medicdl support
$ 0 . 0 0 ~er monlh for genetic lesl coslS
$ per month in olher Isperify)
1<" d total of $ 1.050.00 per month to be forw.rded to p.yee below.
You do not hdve 10 Vdry your pay cycle to be in complidnce wilh the support order. Ii your PdY cycle does not mdtch
the ordered support pdyment cycle, use the following to determine how much to withhold:
$ _ ._..242 . 3 1 per weekly PdY periud.
S 484.62 per biweekly PdY period (every two weeks).
S 525.00 per semimonthly PdY period (twice d month).
$ 1. 050.00 per monthly PdY period.
REMIrT ANCE INFORMA nON:
You must begin withholding no Idter thdn the first PdY period occurring ten (10) working days dfter Ihe date of this
Order/Nolice. Send paymenl wilhin seven (7) werking ddYs of Ihe payddlelddte of withholding. You ..re enlltled to
deduct a fee to defrdY the cost of withholding. Refer to Ihe Idws governing Ihe work Sidle of your employee for the
dllowdble dmount The lotdl withheld "mount, dnd your fee, Cdnnot exceed 55% of the employee's! obligor'S
dl!8regate dispo5dble weekly edmings. For the purpose of the limltdtion on withholding, the following informdtion Is
needed (See # lOon pg. 2).
If remitting by EFT/ED!. pled5e cdll Pennsylvdnid Stdle Collertions dnd Disbursement Unil (SCDU) ~mployer
Cuslomer Service dt 1-877-676-9580 fur instruction,.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. BOll 69112, Harrisburg, Pa 17106-9112
IN ADDITION, 1',1, YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE pACSES MEMBER ID (shown
dbove as the Employ../Oblisor's Cue Iden/ifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED,
DO NOT SEND CASH BY MAtL.
Ddte at Ord..r:
,i):" i. , l ?', 2-1"1, '_
BY THE COURT.
III
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-.;J<.'Jt-e
Form E N-028
Worker ID UIITT
Service Type M
A.;::........ .-
/ ';> 1(.- ( J
n~t:I"'" (~j,'tl'Jl),t
ADOITIONAllNfORMATlON TO EMPLOYERS AND OTHER WITHHOLDERS
o I'. Chffktld you Jre ,.....'uir..d to ~ro\licfe.. ~opy or Ihl't turrn to your 11mllloy~p. II YOl,Jf t:lOlploYt,t: ".ork'l Ifl J ..'dlplh.lt I~
duferen( from the 'ildle ~hdll....ut'{llhl' ordN, J (OJJY mu..l bto pro..,llft.'ff 10 your l.mplo....t"I. t'VI'n It lilt! ho)f, 1'1 not dw(kt!'tJ.
t. We dpprec.idte lht' volunl~rv complidnc e oi Fedl'rJlly rl"tI)~nl't.'(IIf1di.m l(lilt", lrlh"Uv-ownt'cj bU'iln....'l.'. ,md Indidn-u,^,Iwd
busin~se' locJred on,) rt"iervdlion II'Jt lhuo"i.e:d wllhhnl.l III ,uTonl.lf1C.t~ wllh ItW. noIH."
2. Priotity: Withholding under ,hi., Onler/NC)lll~ h,l" prilJrll',l o"~r Jny olher leg..1I p(Utt>".. untll't ';I,llf!' I,IW JMJimllhe "..1mI;' lI1rOme.
Federdl tdX levie\ in effect before f1."t:e1pl of thlli order hdVt.,l priority. II rt1t'rt~ .Jft~ ft'fJt"'dll,t:.. 1~\lIt'., Ifl 1'"(>("' ple.he cOIlfJff lhe requtl"itlnM
d8enlY "Sled below.
J. Combininl'iY.....,": You (dn (ombintl wIthheld JOIounl"i lrom mom th.m Onl' l!mplny~t"johhMor'''i mfanle in .1 '''''Mlp. J,JJymt'nl to
e.u:h .gency reque"linM wilhhuldinM, 'You muo;l, howe\;er. o;t~p.tr,lt(~ly IIlenlif)t Ihl' portllJO ui Ihl! '!!rIMl.! p.lyml'nllh.u 1<; Jllnhuldble lu e.l(h
employe.../obligOf.
4. . Repmltl1llllt.. Payd....DatP 01 W~hhnltltn'" Ynu mu,t """"" lit.. Pavrlaft'lrii~" of wrthhnldll1ll whpn ,,,,,dlnM Ih.. PIIV'"-. F....
.,."r1.ueld..of 'Ntthhoidi"8 l!i the d~ Ort which "mount Wit.. Wllhh"ftf trnm thf" Pmployf'P"'. w"RfHI~ You mU't1 (limply with the I.tw of Ihe
stilte ot the ~mployee'.JfJbIiKor" prlnflpdl pl.lfl" of emplnymt1nl wllh rtO'pt>t t 10 the IIml' pt*rioth wlll"n whll"h you mu<;1 implemenllhp.
wilhholding order tlnd tnl'\NdRt the ",UJ.lpurt polymt'flt'\.
5.' EmployeelOblllJOt with Muhiple Support Holdlnll-" If ther.. " more Ih.," one Doler/Nolic.. 10 Wilhhold In<om. ;or Support dKdinsl
this employee/obligor ..nd you dre undhl~ If) hoOt" .dl ,up~)f1 Ordl"r/NullcP't dup. 10 F~tl'r.11 or 'i(Jt~ wllhholdinM limib. you mu~1 (allow
the law of (he sidle of employee'.Jobligor''j pnncipdl pldce Of employml1nt. You muot' honor .111 ()"teN'Nntj((l'i 10 thp gredtf:SI extent
po"ible. IS"" .10 below I
D. T.nni....ion Notifk..kJ"~ You mU"i1 J.)I't)mJ.lI1v nollfy Ihe ReflUfI.,llnK AM~nfY wht'n thtl emJ,l:loYet!/obliMur IS no longer workinM lor you,
tJled~ providi"' the infurmdtion ~,ut'otl"l(I.mcJ relurn d ropy ollh", O"JL'r/Nolln-'to the AMt'nry Itli'nlllil'tJ bL'iuw.
WITHHOLDER'S 10: H09595100
EMPLOVU'SIOIUCOR'S NAME:
EMPLOVEE'S CASEIDENTIFIIR:
lAST KNOWN HOME ADDRUS:
NEW EMPlOYER'S NAMIIADDRESS:
CARLSON. TIMOTHY R. SR
39000000~5 DATI OF SEPARATION:
7. Lump Sum Paymenll: You mav be ,e'lu;red 10 report .nd withhold irom lump ,um pdvmenl, ,uch .. bonu."" commission., or
severance pay. It you hdv@dny qUP!'1ion'J dbout lump 1um pdyments. contdet the pel'\on or duthority beluw.
8. l.iDility: It' you fdillo wllhhold ineomt~ d!\ the O"ter/Notin~ direct" you dr(lliJble ior bOlh Ihe dnumul.Jllod Jmounl you should have
withheld from lh~ ~mploVl'eJobligor'o; inlome ,.II1(J other pendllle.. "er bv Penn'iylvJnid Sidle IdW. Pt'nn<iylvdni,J Stdle 1.lw Kavem!!, unl" "I
Ihe obligor is employed In dna1her ';fJte. in whl(h Cd~e thE." Id,^ Jr Ihe Sidle in which h~ or ,he j!t emplo)'f.'tJ ~U\ltPm...
9. AnIMflscrlmlnalion: You are ,ubje<:l 10. fine delennined under SIdt.. 1,1W for di.chd'lllnK.n employee/ubligor irom employment.
refuSing In employ, or tdking disciplindry dctinn dKdinsl Jny emplovt't'/obligor bee dUSt!' ot d 'iUpport wifhho!.ting. flennsylvania Stille law
go,em. unles. Ihe obligor i. emploved In dnother 51.1.., in which c.... the Idw 01 th.. 51.11.. ,n which h.. ur ,h.. is emploved 80,em..
10.' Withholding Limits: You mdV not withhold more Ih.n the I..,,", oi: tllh.. dmount. .1I0wed bV th.. Fed..r.1 Con.umer Credil
Prolection Act 115 U.S.C. ~ I b7J (bll; or 11th. dmounls dllowed bV Ih.. 51.1.. of Ihe ..mploV.....s/obliK"'.' princip.1 pldce of employment.
The Federdllimll.ppli.. to Ihe d811r..gal.. di,poSdble weeklV edrning. IADWE). ADWE i, Ihe nel inCllm.. leit .ft..r m.king mdnddtory
deductiom !luch d'S; Stolte. Fedefdl. 10('.11 rdXl'''i; So<"jJI Securily t.)Xt"i; Joel Mt'{Ji(.tIr(~ IdXtUt.
II. Addllionallnfo:
'NOTE: If you or your agenldr. served with d copy 01 Ihis order in Ihe ,Iale Ihal "sued Ihe order, you are to follow the
law of Ihe .Ial. Ih.t issued this order wilh r"'pecllo Ihese ilems.
Submitted By:
DOMESTIC RELA liONS SECTION
1] N. HANOVER ST
P.O. 80X 320
CARLISLE PA 170 II
It you or your ..mployee/obligor ha,e any queslions,
Wnld,1 WAGE ATTACHMENT UNIT
by telephone dl 171 7) HlJ.622 5 or
hV FAXdl 17t71 HQ.6248 or
bV inlernel www.rhildsupport.Sldl".pd.U'
Pdge ! 01 2
Form EN-028
Work..r 10 $IATT
S..",ice Type M
"...'Ii....; 1)'1'1,1',;
ORDER/NOTICE TO WITHHOLD INCO,\ E FOR SUPPORT
lYj 1Yt, !J / 9 'J 7
Stale Commonwealth of pennsylVdni.. 'c " (', "IL
Co./City/Dht. of CUMBERLANC _ iYI. "hr.- -1111 "
Dott.. of Ord..r/Noli,... 12/Jo/OJ ) (<:
f ribundl/Cd"" Numher (SH Add.ndum lot ca.e summ.J'~) I I-K'.;.v <:;,
o ()flMln.l1 Ordpr/NuUle
6) ,.\tfltmded Order/NI>liftl
P ((',mlt"ll!! (JUlt!f/Nlltlr"
7 :,Ice t. e c ~
ElIliJlo.,~t/Wilhhuldt""" h.dt'fdl ~JN NUfllhl!r
HI CARLSUN, TtMOTHY R. SR
lrnJjll)'t't>f'/Ublll4u(" N.lltl~ (I .1.,1, fll'''t. - 111
158-48-3814
Emplu','t!L'iOlJli)l()('" 'iu(ioll ~I'('ufil", ,....u'"~
PPL CORP All!) ALL AFFtLtATED CO
C/O MR R CAROSIELLO - PAYROLL
PPL SERVICES CORP
2 N 9TH ST
ALLENTOWN PA 18101-1139
3900000025
f mployt~t'/()bliRur''i (J!>t' Id~nljljer
ISH Add."du", lot plI/.tlN .......
...ocilttd with C.uft on .It.J...hmMIJ
CLJ~lndio.ll pJ(enl'o; N.IOlt" (1..i!l1, r ~, ,\11
SH Addendum fo, defM!ndenl names .Jnd bi,th dat.. associated with ca.e. on attachment,
ORDER INFORMA nON: fhis i, dn Order/Noti,e to Withhold In(Ome for Support bd,ed upon dn order for support
from CUMBERLAND County. Commonweotlth of Pt.nmylvdniot. By IdW. you dre rl'quired to deducl the,e
dmount, from the dbove-named employee.s/obligor', ill( ome unlillurth..r nolice even if the Order/Nolice is not
issued by your Sidle.
S 1. OJO. 00 per month on rur'ent 'upporl
S 10.00 per flnonth in pdsl-due ,upport Am'drs 12 weeks ur gredter( Oyes G) n"
S O. 00 ~er month in medicdl support
S 0 .00 per month for g..netic test <osts
S per month in other (sperify,
for a tolal of $ 1. 040 . 00 per month 10 be fOMarded 10 p.Jyee below.
Yuu do not h.lVe to Vdry your pay <"VI I.. to b.. in romplidn..... with the support order. If your ,!.Iy ,yde does not mol'
the ordered sUPfJOrt pdyment cyel,'. u". the following to d..termine how much to withhold:
S 240.00 per weekly PolY period.
S 480.00 per biweekly poly period (evl'ry two w....k,'.
S 520.00 per semimonthly poly period (twice .I month).
S 1. 040 . 00 per monlhly poly period.
REMITTANCE INFORMATION:
You must hegin withholding no Idle' thdn the first poly period occurring ten (101 working ddYS dtter the ddte ollhis
Order/NotlLe. ~cnd pdyment within 'even (7) working day' of the pdyddtelddte of wlthhold,n!!. You drl' "nlitl.." tn
deduct d tee to detrdY Ihe cosl of withholding. ~et..r to th.. IdWS !!ov..rnin!! the work st,lte of your eml"oye" it r th.
allowdble donount. I h..lotdl wilhheld dmounl, ,IOd your t..e. rdnnol eXleed 55"!,. of Ihe employe..."; ubligor's
duregdle di>~usdhle weekly eotrnin.". For the purp""" of the limltdli '" on wilhholdil1l\. the following inform-ltIon is
needed (S.... ~ lOon pg. 2),
If rem,tting by ~F f/EDI. pled'" Colli Penn'ylvotnid ~tdte (ollHtions oint! [J"bu"emenl Unit (SCOUI Emplov"r
Cuslomer Service 0111-1177-676-95/111 ror in'tru",ons.
Make Remittance Payable to: PA SCDU
Send check 10: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pol 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
above aJ the Employee/Obli/lo,'. Case Iden/ifi",) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED,
DO NOT SEND CASH BY MAIL.
Service r ype M
/-/Se')
BY fHE COl,JRJ: / / 1
-~, ;L,0;,~(; ~ -'''''.'
, . ~orm FN 0.'8
". ,j Wvrk..r IJ zrl\'l"~
Ddte of Order:
J.. ,
4l. - .
".H"'ll .;;l'
"
r
...
i.
,
.
~ .J.
I
J
.>>
,
ADDITIONAL INfORMATION TO EMPLOYERS AND OTHER h'ITHHOlDERS
o If Cht"<<:k.,t Vuu .Ire /'fJ'quirL'fJ 10 prfJ"t(h~ J 1 up',' of Illl'i lorrn to your ....Ji1fIOyt".. If yo"" t.mJJll)yl.t:.....l)rk~ in,J ')1.111', rhJt is
ditterenllrum Ihll ~r.J(l" ,h,.t ,....lIt..j Ihl\ un llr, .Il opy nUI'i1 ht. prlJ\mltlf fo ',lour ~m"loyee t.'vt>1l11 Uw box IIf nut (ht...ked.
1. We dpprecidle the vOluflt,UY fumpli.tn(tt of ft,'fh'r.llly fPt ()Mfll/l'fllnltiJlllrlUP'i, lrtb.IIIY-iJwlwd bU'I"ll".'iI''i. Jnlt tlutiJn-owned
busine'\ses IIXJlf'd on d rtl't>rw"dllon IhJI ,-hou'il' to wllhr.ollllfl .1nurtl.Jnfe '."lIlh till'. nellit e
2. Priority: Wilhholdlng under Ih,"! ()niN/Nolin' h.h ,.)(jonry I)\(I;'( ,my nthN It'R,JI pron','i umh., 'Idle I.IW dKdlO'it the 'iJme income.
FederdlldX It'viei in eftt~1 bl'lort> (p(elp! 0; Ih,'1 oRiN h.l'IL' J.>rtOrlry. If Ihf'ft" .Ire Fetlt~rJI lalx Il'VIP' in ..ift'tl J11t'al"t' runldl-t Ihe rellue~ling
agency li\tl'l' beluw,
J. Combinln, '.yment!l: You r.1O r:omhinec wllhht~ld dmounl.. ;Illm mow Ih.U1 one t'mploYlll~/()hliMor', in,-onw In d "'"Hie pdyment In
each agenc,;, requl"iling wilhholdinM, You mu'I, hovlever, 't'J1dr.llt'ly i<<h'nllfy tilt' portion oj Ihe ~jnMll' fJdymenr Ih.u j<; Jttribuldhle to tMch
employeelobligor.
4. . RepMi..g m.. r'r,I.ldom. of WIthhold,,,,,: You mu,1 "'POrt Ih.. paydatrltfat.. 01 w,'hhohfing wh"" ",ndinl! Ih.. PlI'/mPOt. The
pard.I"'dateof withholding;., th.. do,", on which amnunl wa, wllhh..l& 10'"' Ih.. emplnyt'<'" Willi"'. You mu" rom ply w,th Ihe law ollhe
state of the employee'vobliMor'o; principdl fJlolc~ at em piny men I wllh rt"pl~CI lu Ihe lime fJeriod., with," which you must implement the
wilhholding order dnd iOlWdru the o,ulJfJort p.lyml'nl"
5. . EmployHlObllgor wilh Mulliple Support Holdins" Illher." mort. Ihan on. Order/Nolio' 10 Withhold Income lor Support alld'lSl
this employee/obligor dnd you dre un.lbll1lo honor .III support OrrlN/Nolir!!'t dut' 10 Fl'fIt"rJI or Sl.i.lt~ withholding limil~, you must follow
the law of the sidle of employee'v'obligor''i princip.II'JIJlt' of pmvloymtmf. You mU'lt honor .III ()nh.r;JNotin" to Iht' grp.dlt."it extent
possible. (See *10 below)
6. Terml""Uon Nolif,ullon: You mu,t prompily notify Ih,' Reque,'ing Agency when Ihe employeefobligor is no longer working lor you
Pledse provide the intom1dhon l't'Que'ited dnd return ,I copy ot this OrderJNotice to lhe A.gency idenlified helow,
WITHHOlDER'S 10: ~J09595900
EMPlOYEE'SlOIILlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
lAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRUS:
CARLSON. TIMOTHY R. SR
39000000H DATE OF SEPARATION:
7, lump Sum Paymenl.: You may be ""lui."d 10 report and withhold fmm lump 'U01 p.lyments ,uch a' b"nuse" commission" or
severanCt~ PdY. If yoU h.I\.t:' .1ny qUl-,rlon" Jhr,llt lump sum pdympnl~, contJct the per,on or Julhority belo\\.
8. liability: II you tail 10 wilhhold income a, Ihe Onler/Notice direct" you are ',.,blelor both the accumul~led amounl you ,houlu I: ,."
withheld (rom lh~ pmt,JloYt:'e1obligor''i inCOnlt> Jncl other pendllies sellly PennsylvJniJ Stolte IdW. PennsylvJnid SIdle law govenl'} Iml .'\
the obUsor i... emJ.Jloyed In dnother Stdle, in which CJse lhe Law of the Sl.llt~ in whi,.h he or she is employed !Jovems.
9. AnlHlllCrlminaliom You are ,ubject 10 a fine delermined under Slate law for di,eharging an employeelobligor lrom employn,enl,
refusil'1g tu employ, or taking disciplindty rltllon dgJlOst JOY employee/obligor betduse of d 'iUpport Withholding. PennS'IIViJntil Sl.Ite '..w
govt!mli unless Ihe obligor is employed In .motht'r "itJte. in whICh CJ'ie Ihe IdW 01 the Stolle in which he or she Iii employed governs.
10.. Withholding lim~.: You may not withhold more Ihan Ih.. less", 01; I} Ihe amounts allowed by Ihe Fed",al Consumer Credil
Protection Acl115 U.S.c. ~ 1673 ibll; or 211he amounts allowed by Ihe State 01 the employe.."obligor'; principal place olemploymenl.
The t=ederdllimil dpplip<j 10 the Jggregdte dilipo~dble weekly eJrnings (ADWE), ADWE i'i the nel income Ie" dltN mJking mdnddtory
deductions such as: Sidle, Federdl, IOCdl tdXP'i; SOCi.11 Sl'Curity I.JXl"o;; .Inri Ml>(lit"dn~ tdXe'i.
11. Addillonallnlo:
.NOTE: If you or your agenl are ,erved wilh a copy 01 this order in the 'tale that issued Ihe order. you are to ,ollow Ih~
law of the slate Ihal issued Ihis order with re'peclto Ihe,e item,.
Submitted By:
DOMESTIC IlELATlONS SECTION
13 N. HANOVEIl ~T
P.O 80X 320
CARLISLE PA 17013
II yuu or your employee/obligor have any questions.
lOntan WAGE ArTACHMENr UNIT
hy telephune al (717) 24Q.&225 or
by fAX at /7171 24Q.&H8 or
by internel www.rhildsupport..tal...pa.us
P.JMt' 1 ot .!
Form E'I-028
Worker 10 J tAn
Service Typ.. M
"...It..." ''"1'1)<11,..
ORDER/NOTICE TO WITHHOLD INCOME fOR SUPPORT
Sr.te Commonwealth of pennsylvania
Co.lCitylDist. of CUMBBRLAND
Ddte of OrderlNotice 09/01/04
fribundllCdse Number (SH Addendum for case summary)
RE: CARLSON,
OthiKIO,II()rcl('r/Nnllrt'
6) "m..ntl~c1 Ollh'r/Nnliu'
o fl.'nnIlMI~ Ullh'r/NoUre
PPL CORP AND ALL AII'II'ILIATED CO
C/O MR R CAROSIELLO - PAYROLL
PPL SBRVICES CORP
2 N 9TH ST
ALLENTOWN PA 18101-1139
'!)I
/11&'-
61/0 !l (/7
736C('I.rl):J.1
TIMOTHY R. SR
fnlp!oyt.p/ObIIROf'<t Name IlJ~I. fir.,., MI.
,
168-48-3814
EmpluyceIObliKot''i SociJI Se(urily Number
3900000025
EmploYl!r/Obligor'<t C.I~ Idenlilier
ISH Mdondum /01 ,wlnll<< ..m..
4uoddft/ with en.. on .n.chm,nl)
CmlcxliJI Parent's Name (Lois!. fir...!, Mil
EmpluyerlWithholde,'s FederJI fiN Number
lit
/JI&S
Iey;~ -I/~' ~, /III..
'):J.(J (1{JCJ(J)...1
SH Addendum for dependent names and birth dates associated with cases on attachment,
ORDER INFORMA TION: This is an OrderlNotice to Withhold Income for Support based upon an order for support
from CUMBBRLAND County, Commonwealth of Pennsylvania. By Idw, you .Ire required to deductlhese
amounts from the above-ndmed employee's!obligor's income unlil further notice even it the OrderlNotice is not
issued by your Stolte.
S 1,030.00 per month in current support
S 10.00 per month in past-due support Arrears 12 weeks or greaterl 0 yes (Xl no
S 0.00 per month in medical support
S 0.00 per month for genetic test costs
S per month in other (specify)
for a total of $ 1,040.00 per month to be forwarded 10 payee below,
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not malch
the ordered support payment cycle, use the following to determine how much to withhold:
S 240.00 per weekly pay period.
S 480.00 per biweekly pay period (every two weeks).
S 520.00 per semimonthly pay period (twice a month).
S 1.040.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after lhe date of this
OrderlNotice. Send payment within seven (7) working days of the pdyddtl'/dale of withholding. You are entitled to
deduct a fee to defray the cosl of withholding. RefN to the laws governing the work stolte of your employee for the
dllowdble amount. The total withheld amount, dnd your fee, cannot exceed 55"10 of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following Information is
needed (See # 10 on pg. 21.
If remitting by EFlIEDI, pll'ase call Pennsylvania St,lte Collections dnd Disbursement Unit (SCDUl Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.Q, Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, I'A YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE I'ACSES MEMBER ID (shown
above as rhe Employee/Oblisor's Caseldl'ntifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE I'ROCESSED.
DO NOT SEND CASH BY MAIL.
SEP - 2 200~
"" - --lr"".. r"".' -T IlY THE COURT;
" ~'.' ~ - 'J .
-tt:.- -~ -':;'-.; - . "
-Ay.. - r,
._ - "CI // /"
/'--.
C">-tf:VC(~,; ~.
Date of Ordl'r:
Service Type M
O"'B/'ol) tl",.(~11141.
Form E N.02B
Worker 10 $IATT
ADOlTlONAlINFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If c.hecked you .Ire re(~LJired 10 prp\tide J (:op,;, ur this form 10 your em),lloyee. If yo!)r employet:."Yorks in ,01 <;tJle lholt is
different from the sidle Ihdllssued ,hi" ord~r, J copy must be provldl."lf lu you!' emJJloyee even Illht- bo:( IS nof checkllCl
1, We dpprN"i.ue the volunt~II'Y compliance ot Fee-ferally rt'('ogniled Imlld" lribeo;. lribdlly.ownf!(J bU<;llle"l'ie"i, .u,d Intfi.m-ownl>d
bU5ine'i!te'i IOCdled on .. reservdtion thdt choose to withhold in dt"contdnre wllh lhi~ notict:'.
J. PrkJ,ilV: Wirhholdins under this Order/Notice hdS priority Q\;er ,.my other leRdl pl'Ol"esot unlier Sidle IJW JK.linSllhe 'jdme income,
Federdl [.IX Itvies in effecl before ret:eiJ.>1 of this onter hd\le priorllY. I; tht"";' Jre Federulldx le\lies in ertert pll!Jse contJ(:t the fe(lUesling
dgeney 1i"",llwlow.
I. Comblnlnl Paymenls: You Cdn combine wilhheld amount, from more Ihan one employee/obligor"' income in a ,;ngle pdymentlo
each dgency rec:lue!lling withholding. You must. however, !tepdrdlely jd~nllfy lilt! portion I)f Ihe ~iflMle p.lymenllhdt is dltributJble 10 edch
employee/obligor.
4.' ReportinA ~PaydateI~ofWithllolrlinlt. You mo>l "'POrt th" puyrlatl'lrial" oIwithho/rling wh.... ".nding th..payment. Fhe
pa,d'le/dale of "'lhholdinA ~ thedah>onwhich amount w... wlthhe/rl from Ih"""'ploy....'. Wdl!f'1. You mu't comply wilh Ihe Idw of the
"die of the employee'slobllllOr'S principal pldce of employment wilh relpL..IIU Ih..lIme period, wllh," which you mu,t implementlhe
withholdin8 order and forwdrd the support paymenl'.
5. ' EmploylelObIlAor ..hh Mulllple Support Holdln..: If there is more Ihdn one Order/Nolice 10 Wilhhold Income for Support d!!dinsl
this employee/obligor and you are unable 10 honor all support Order/Nolice, due to Federdl or Slale wilhholding limils. you muS! follow
Ihe law of the 'lale of employee'slobligor', principdl place of employment. You must honor dll Orders/Notices 10 Ihe gredlest extenl
possible. ISee 1110 below)
6. Termlnallon Nollllcallon: You must promptly notify Ihe Requesling Agency when Ihe emploYL't'/obligor is no longer working for you,
Please provide the infonnalion requested and relum a copy of Ihis Order/Nolice to Ihe Agency identified below.
WITHHOLDER'S lOt ~J09595900
EMPLOYEE'SIOBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIEIl;
lAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAMElADDRESS:
CARLSON, TIMOTHY R. SR
nooooooas DAfE Of SEPARATION:
7. Lump Sum PaymenlS: You may be required to report and wilhhold from lump sum pdyments such a, bunuses, commissions, or
severance pay. If you have any qU"'lions about lump ,um pilYmenlS, conlaCllhe pe"on or aUlhority below.
8. Liability: If you fail 10 wilhhold income aSlhe Order/Nolice directs, you are liable for bolh Ihe accumulaled amounl you ,hould have
withheld from the employee/obligor's income and other pendlties set hy Pennsylvania Sidle law. Pennsylvania State law governs unless
the obligor is employed in another St.ate, in which case the IdW of the Slolle in which he or 'ihe is employed govem'i.
9. AnIHllK,lmlnatlon: Vou are subject 10 a fine delermined under Stale Idw ior discharging an employee/obligor from employment,
refusing 10 employ, or taking disciplinary action againsl any employee/obligor bec,luse of a support wilhholding. Pennsylvdnia Stale law
governs unless the obligor is employed in anolher Stale, in which Cdse Ihe law of the State in which he or she is employed govern,.
10.' Whhholdina Limlls: You may not withhold more than the lesser of: 111he amounls allow",j by Ihe Federal ConsumerCredil
Protection Act (15 U.S.c. ~167J Ib)l; or 2) Ihe amounts allowed by Ihe Slale of Ihe employee's1obligor"s principal place of employment,
The Federal limit applies 10 the aggre!!dte disposable weekly earnings IADWE). ADWE is the nel income lefi afier making mandatory
deductions such as: State, Federal. local taxes; Social Security taxes; and Medic.1ft! ta,(e5.
11. Addlllonallnfo:
.NOTE: If you or your asentare SeNed with a copy of this order in Ihe slille lhilt issued the order, you ilre 10 follow the
law of the slilte thaI issued this order wilh respect 10 these ilems.
Submitted By:
DOMESTIC RELA TIONS SECTION
13 N HANOVER Sf
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor hdve ilny questions,
(ontilel WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX dt 0171 240-6248 or
by internet www.child.upport.S1dt...pil.us
PJgt- 2 of 2
Form EN-028
Worker ID $IA'!'T
SeNice Type M
OM8....'Ii'I:O..Hld
,
ORDER/NOTICE TO WITHHOLD INCO,"'E fOR SUPPORT
Stale j;ga1monwullh of P"nnsvlvanid
Co.lCily/Ol>r. 01 CUMBBRLAND
Ddtt!oIOrdt!r/Notice 1l/08/0~
Tribundl/C.se Numbt'r ISH Addendum for Cd~ summdryl
o Onsin.11 O,der/NuIICl}
@ Amendft! Order/Nutice
o r~rlTllfl..il~ Ontltr/N(lll(~
PPL CORP AND ALL APII'ILIATED co
C/O MR R CAROSIELLO - PAYROLL
PPL SERVICBS CORP
2 N 9TH ST
ALLBNTOWN PA 18101-1139
~JI /~.//'" ~y
}J(.f. sw .s 1'1"/7
~C;;U 7;J..IJt:J0t1#1..1
N~ CARLSON , TIMOTHY R. SR
fmpluYi!p./Obligor''l N",m~ llJsl. Flr..t, MI)
168-48-3814
Employ~eIObligor''l Sod.1I Security Number
3900000025
ErnployeeIOblillor', CJ~ Idenliiier
ISH A......... "" pMinliH ......
MIOCNtH with C.utl Oft .n.cItmM'J
CU'ltodidl P.lrent'i N.amfO (lolsl. First. Mil
Emplo'f'.,,,Wilhholder's f~dNJI F.IN Nurnl>t.tr
SH Alkkndum for de".,.dent n..met drld bi,th dates dJ$Ocidted with c.ues on dtt..chment,
ORDER INFOR,\'tA nON: This is .n Ordt!r/Nolire to Wilhhold Income for Support bolSed upon dn order for support
from CUMBERLAND Counly. Commonwedlrh of Pennsylvdni.. By IdW, you dre required to deduct these
amounts from the dbove-ndmed employee.s!obligor's income until further notice even if the Order/Nolice is not
issued by your Stolte.
S 416.50 per month in currenl support
So. 00 per month in pdst-due support Arred/5 12 weeks or gredterl Oyes ~ no
S 0.00 per month in medicdl support
S 0 . 00 per month for genelic tesl costs
S per month in other (specify)
for 01 lolal of S 416 . 50 p'" monlh to be forwarded to payee below.
You do nol hdve to Vdry your poly cycle to be in complidnce wiln the support order. If your PolY cycle does not match
the ordered support pdyment cycle. use the following to determine how much to withhold:
S 96.12 per weekly poly period.
S 192 .2] per I:.iweekly poly period (every two weeks).
S 208.25 per semimonthly poly period (Iwice 01 month).
S 416 .50 per monlhly poly period.
REMITTANCE INFORMA nON:
You must begin withholding no Idler thdn the fi/5t poly perioo:t occurring ten (101 working ddYS after the date of this
Order/Notice. Send pdymenl wilhin seven In working ddYS 01 the paydate/ddte of withholding. You are entitled 10
deduct 01 fee to defrdY Ihe cost of withholding. Refer to Ihe I.ws governing the work stolte of your employee for the
allowdble .1mount. The lotdl withheld .mounl. dnd your tee, Cdnnot exceed 55'!o of the employee's! obligor's
d88rel!dte dispoSdble weekly edrnings. For the purpose of the limitdtion on wilhholding, the following information Is
needed (See _lOon pg. 2).
If remining by EFT/EDI. please Colli Pennsylvani.1 Stolte Collections dnd Disbursement Unit (SCDUl Employer
Customer Service .111-677-67&-9560 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADOmON, I'A YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE I'ACSES MEMBER ID (.rbo_
o1bo..e.u /he Employet!/Ob/ilO"S Cdse Identifi",) OR SOCIAL SECURITY NUMBER IN ORDER TO BE I'ROCESSIIl,
DO NOT SEND CASH BY MAIL.
....-.......
D.te of Order:
t,uv
G 230I... ii-lA-Or
Service Type M
lIMS""J \l'I:rHJI
'-J
Form EN-02B
Worker 10 $IAn
...
ADDITIONAL INFORMATION TO EMPLOYERS AND OrHER WITHHOLDERS
o If checked you are required Iu provide a copy 01 this form 10 your ~mployee, If your employe...../orh in,a slate Ihat is
ditferenl (rom the slale lhdl issued Ihls ord~(, d copy mU!l1 be providl;l(f 10 your employee even lithe box IS not checklltt.
I. We appreciate Ihe voluntary compliance of Fl'llerally recogniled Indian tribes, lriballY<lwned businesses, and Indian-owned
businesses located on d reservJllon lholt choose 10 withhold in ,IHordllO,e with this nolice.
2. Priority: Wilhholding under Ihis Order/Notice has priority over any nlher leg.,1 process under Slale law aRainst Ihe same income.
Federal tax levies in effect before r~ceipt of this order h.we priority. If there dr..- Fedt1ral IdX levies in eifert pll!Jse conlact the reque<iling
agency Iisled below,
3. Combining Paymenls: You can combine wilhhelci amounlS irom more Ihan one employee/obligor's income In a single payment to
each agency requesting withholding. You muS!, however. separately identify Ihe ponion of Ihe single payment thaI Is attributable 10 each
employee/obligor.
4.' Rl!pmti~~Paydat"'em..ofWitItholding:' YOttmU!t"'JlOltth..paydal1!fda~otwitlthofdinll wlm-tWldingtht. paymt!f1t; Th..-,
pll'rJal~..I. of withholdi"ll ;, th.. dat..ort which amount.....n withheld from th.. employ,"", ""'g.... You must comply wilh Ihe law of the
slate of the employee'slobligor's prinCipal place of employment wilh respect to the time periods wilhin which you musl implemenl the
wllhholdin~ order and forward the suppon paymenlS.
5.' Employee/Obligor with Mulliple Support Holding.: If Ihere is more Ihan one Order/Nolic~ to Withhold Income for Suppon a.ainst
this ~mployee/obligor and you are unable 10 honor all suppon Ord~r/Notices due to Federal or Stale wilhholding Iimils. you musl follow
th~ law of Ihe stat~ of employ~e.slobligor's principal plac~ 01 ~mployment. You musl honor all OrderslNollc~s 10 Ihe gr~at~sl ext~nl
possible. (See # I 0 below)
6. Termination NoURcatlon: You muS! promplly notify the R~qu~sting Ag~ncy when the ~mploy~e/obligor is no longer workin8 for you.
Please provide Ihe informallon requ~sled and retum a copy of Ihis Order/Nolice 10 Ihe Agency id~nlifi~d b~low.
WITHHOLDER'S 10: ~309595900
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
CARLSON, TIMOTHY R. SR
3900000025 DATE OF SEPARATION:
7. Lump Sum Paym~nts: You may be required to repon and wilhhold from lump sum paymenls such as bonuses, commissions, or
sev~rance pay. If you hav~ any questions about lump sum payments. contact Ih~ p~,,;on or aulhority below.
8. Liability: If you fail to withhold income as the Order/Notic~ directs, you are liable for both the acrumulatl'll amounl you should have
withheld from the ~mployeelobligor's income and oth~r penallles sel by Pennsylvania State law. P~nnsylvania Stale law govems unless
the obligor Is ~mployed in another Slate, in which case (h~ law of Ih~ Stale in which he or sh~ is employed govems.
9, Anti-dlscrimlnation: You are subject to a fine det~rminl'll und~r Slate law for discharging an employee/obligor from employmenl,
refusing to employ, or taking disciplinary action against any ~mployee/obligor because of a suppon withholding. Pennsylvania Slale law
govems unless Ihe obligor is employed in anolher Slat~, in which case the law of Ihe Stal~ in which he or she is ~mployed governs.
10.' W1mhoJding Limit.: You may nol wilhhold mure Ihan Ihe I~sser of: I) the amounts allowed by the Federal Consum~r Credit
Prolection Act (1 S U.S.c. 51673 (b)1: or 2) the amounts allowed by the Slale of the employee'slobligor's principal place of employm~nl.
The Federallimil applies to the aggregate disposable weekly eamings IADWE). AOWE is Ihe net incomelefi afier making mandalory
deductions such as: Slate, Federal, local taxes; Social Securily taxes: and Medicare taxes.
11. Addllionallnfo:
'NOTE: If you or your agent are served with a copy of Ihis order in the state Ihal issued Ihe order, you are to follow the
law of the state Ihal issued Ihis order with respect to these lIems.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N.HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contacl WAGE AITACHMENT UNIT
by telephone al (7171 240-6225 or
by FAX at 17171 240-6248 or
by inlernet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker 10 $IA'l"1'
O....SNa-O.PIMII'i-l