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HomeMy WebLinkAbout02-4799 SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS-AT-LAW 26 W. High Street Carlisle, P A JOHN J. PITMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2002 . 'I79f CIVIL TERM IN DIVORCE Plaintiff V5. CAROL G. PITMAN, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other c1airn or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSeAT'LAW 26 W. High Street Carlisle. P A JOHN J. PITMAN, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2002 - '-t'1lf'l CIVIL TERM IN DIVORCE Plaintiff Y5. CAROL G. PITMAN, Defendant COMPLAINT JOHN J. PITMAN, Plaintiff, by his attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is John J. Pitman, who currently resides at 205 Parker Street, Carlisle, Cumberland County, Pennsylvania, where he has resided since November 20, 1999. 2. The Defendant is Carol G. Pitman, who currently resides at 686 Valley View Drive, Boiling Springs, Cumberland County, Pennsylvania, where she has resided since 1975. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 27, 1966 in Athens, Georgia. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. SAIDIS SHUFF, FLOWER & LINDSAY ATIURNEYS-AT-LAW 26 W. High Street Carlisle. P A 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: (Jit1A. 2- ~ ~~ SAlOIS, SHUFF, FLOWER & LINDSAY, P.C, Attorneys for Plaintiff By: SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT'LAW 26 W. High Street Carlisle, P A VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. --=?:J;::-~ Date: b/;;' 0/01.-- t r - (.J ~ ~i~ --~~ ~ B ~ 1. o c: z vl'';~: Q"lf-;' .; ;<' uj ~, r::CC " f;"l ~~( :>~~ 'j -< c:) f',,J C) ,-, ..... I :"',' .- E-,) ("') -1', :11 8 ,-. :.)-1 -< , SAlOIS SHUFF. FLOWER & LINDSAY ATIORNEYS.AT-LA.W 26 W. High Street Carlisle, P A JOHN J. PITMAN. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff VS. : CIVIL ACTION. LAW NO. 2002 - 4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE Now comes JOHN J. PITMAN. by and through his counsel, SAIDIS, SHUFF, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on May 27,1966. 2. The parties separated on or about November 20, 1999. 3. Petitioner is without the ability to earn income sufficient to meet his reasonable needs and to pay attorney's fees. WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: Carol J. n 10#446 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 ~ ~ ~ ----- "}- ~ ~ ~ (') ~; ,...., <=> <=> ..,. en '" -0 N \.D ~ ~-;l i{'i~ :gs: ClO ::-~.::.r1 ;:t'" (~o :)~~ {~rn -- '}E (f1 .<.. CJ1 PETITIONER: DOS: AoDRESS: PHONE: ATTORNEY: JOHN J. PITMAN OfJ/05/42 SSN: 190-32-2857 205 PARKER STREET, CARLISLE, PA 17013 (717) 241-9758 CAROLJ. LINDSAY, ESQUIRE How LONG? PETITIONER'S EMPLOYMENT: SINCE SEPTEMBER 2003 NET PAY: JOB TITLE: RETIRED $3812.64 PER MONTH OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) RETIRED NAVAL RESERVE RETIREMENT $1550.00 PER MONTH DOS: 09/14/45 RESPONDENT: CAROL G. PITMAN 164-36-891 0 ADDRESS: PHONE: ATTORNEY: SSN: 686 Valley View Drive Soiling Springs, PA 17007 258-1502 ROBERT S. LIBERMAN, ESQUIRE How LONG? RESPONDENT'S EMPLOYMENT: PHARMERICA @10YEARS NET PAY: ESTIMATED @ $4,500.00 JOB TITLE: PER MONTH OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) WHEN MARRIED: DATE SEPARATED: MAY27,1966 WHERE: ATHENS NOVEMBER 20, 1999 WHERE LAST LIVED TOGETHER: 686 VALLEY VIEW DR. Soiling Springs, PA FOR DRS INFORMATION ONLY Cl S; -0 (:' ;-Y1\' ;;:; ~i? r;: "1::, ~'~' ,..., = <= .s:- (-" r" -0 N <.D ~::j -<.. ;t::'l, :::r. o ""'t'1 :i!--n [11h~' :89 00 :T' -r. ",.,,"n Q(~ ::< \~n ~- j ::~ "D- o'!") :..-:: 01 U1 JOHN J. PITMAN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE CAROL G. PITMAN, Defendant/Respondent NO. 2002-4799 CIVIL TERM IN DIVORCE PACSES # 14210(j838 ORDER OF COURT AND NOW, this 22,d day of October, 2004, upon consideration of the attached Petition for Alimony Pendente Lite andlor counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on December 7. 2004 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Retum, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11~ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 10-22-04 to: < Petitioner Respondent Carol Lindsay, Esquire Robert Lieberman, Esquire 11 ., . J / I / ,- J /1 1 / i,/ r/1 A 7!~ f\/' f,. '--~-.~ -<---,:j' " --..-'>.-',- ~ ~.--:;- R. J. Shadday, Conference Officer r i \ - ./ Date of Order: October 22, 2004 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 "" 'j? = <::,-, "'- (":':J :r::n C') f'n~ --..J -,,1Tj :'"', :Y)=J _J 'Jo ..,.j~r"j -0 "l'--n i _,,:i.. '2c') :-'~. rn c,,;- C) -.'" '..J '-~J W ~ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JOHN J. PITMAN ) Docket Number 02-4799 CIVIL Plaintiff ) vs. ) PACSES Case Number 142106838 CAROL G. PITMAN ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 22ND DAY OF DECEMBER, 2004 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other ALIMONY PENDENTE LITE filed on SEPTEMBER 29, 2004 in the above captioned matter is dismissed without prejudice due to: THE PARTIES AGREEING NOT TO PURSUE THE MATTER THROUGH THE DOMESTIC RELATIONS SECTION. DRO: RJ Shadday xc: plaintiff defendant Carol Lindsay, Esquire Robert Lieberman, Esquire ~"'"",,"'i;" \-""" 1III;!''i''f ~r;7" ~,,'.I'I.,...,~ '. ,."\ t....,. (;l ;-"'[1 :,~ _\ "'..'~/~:f~'~09 ....,. JUDGE Service Type M Form OE-505 Worker ID 21005 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA JOHN J. PITMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2002 . 47'99 CIVIL TERM Plaintiff vs. CAROL G. PITMAN, Defendant IN DIVORCE PETITION TO COMPEL DISCOVERY NOW COMES John J. Pitman, by and through his counsel, Said is, Shuff, Flower & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife having been joined in marriage on May 27.1966 and having separated on or about November 20,1999. 2. A Complaint in Divorce was filed on October 2, 2002. 3. On October 3, 2002 the Plaintiff served upon Defendant a Request for Production of Documents and a set of Interrogatories. A copy of the document request and the interrogetories are attached hereto as Exhibit "A" along with the October 3, 2002 letter of service. 4. Since October 3, 2002 the documents requl3sted have not been provided and the interrogatories have not been answered. 5. Defendant retained counsel in the early part of 2003. Despite repeated requests to counsel by telephone and by letter the discovery propounded has not been provided. 6. Substantial time has elapsed since the propounding of the discovery request and Plaintiff requests that the discovery be completed, and, further, that paragraphs 2 and 3 of the Request for Documents be amended to provide for copies of all W2's, 1099's and federal income tax returns for 2001, 2002, 2003 and 2004. " SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS.AT.LAW 26 W. High Street Carlisle, PA I , WHEREFORE, Plaintiff prays this Honorable Court to order the discovery propounded provided with updates on tax and earnings information. SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for I'laintiff n /, , , ' i ~, By: ') '. 1./ 1,--\7~ Carol J. Linds~y, squire \ ID# 44693 I 26 West ~ Street Carlisle, PA 17013 (7'17) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEVS.AT-LAW 26 W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date 21 Z-~I UJ/ I /. ;/ / cd I Carol J.. Lindsay ID # 44693 26 West High St et Carlisle, PA 17'013 (717) 243-6222 ,. J SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, PA JOHN J. PITMAN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 . 4799 CIVIL TERM Plaintiff vs. CAROL G. PITMAN, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Petition to Compel Discovery this ::1. S day of F? bl1/l ({I}(j.., '005 by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Robert Lieberman 500 North Third Street, 12th Floor P. O. Box 1004 Harrisburg, PA 17108-1004 SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Pla.intiff/)/~ I I' By: l (1t Carol . L!indsay, Esquire 10# 4 693 26 W st High Street Carrrsle, PA 17013 (717) 243-6222 AMES D. FLOWER JOHN E. SLIKE ROBERT C. SAlOIS GEOFFREY S. SHUFF JAMES D. FLOWER, JR. CAROL J. LINDSAY jOHNNA j. KOPECKY KARL M. LEDEBOHM JOSEPH L. HITCHINGS THOMAS E. FLOWER FORREST N. TROUTMAN, II LAW OFFICES SAIDIS, SHUFF, FLOWER & UNDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLlSLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6510 EMAIL: attomey@ssfl-law.com WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL, P A 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE October 3,2002 Ms. Carol G. Pitman 686 Valley View Drive Boiling Springs, PA 17007 Dear Ms. Pitman: I represent John J. Pitman who, after two years of separation, believes the time has come to conclude your divorce. To that end, I have filed a Complaint in Divorce and I am providing you a certified copy for service. I tl1ink I have a fair idea of the marital assets according to John, but there are some assets which are in your name only and for that reason, I have provided the enclosed Request for Production of Documents and Interrogatories so that we can value the assets prior to effecting a division. John's intention here is to be fair and he expects your intention is the same. I understand that Teresa Male represented you at some time in the past. If she is still representing you, please provide her a copy of these documents. If you choose other counsel, please ask him or her to be in touch with me so that we can move this matter to a speedy, fair and economical resolution. Thank you very much for your help. Very truly yours, j."~AIDIS, SHUFF, FLOWER & LINDSAY, P.C. f 'fill ( Carol {{lilj4 CJUtjb Enclosures cc: John J. Pitman SAlOIS SHUFF, FLOWER & LINDSAY AITORNEYS.AT-UW 26 W. High Street CarHsJe, P A JOHN J. PITMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 - Plaintiff Y5. CIVIL TERM CAROL G. PITMAN, Defendant IN DIVORCE REQUEST FOR PRODUCTION OF DOCUMENTS TO: Carol G. Pitman 686 Valley View Drive Boiling Springs, PA 17007 PLEASE TAKE NOTICE THAT pursuant to Pa.R.C.P. 4003.3 and 4009, you are required to furnish at our office, on or before thirty (30) days after service hereof, a photostatic copy or like reproduction of the materials concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or, in the alternative, produce the said matter at said time to permit inspection and copying thereof: 1, A copy of your most recent pay stub. 2. A copy of your W-2 form and any 1099 forms you received for 2001. 3. A copy of your 2001 Federal Income Tax Return as filed. 4. A copy of your most recent statement for any pension plan, 401 (k) plan or any other retirement plan which you may have with your present employer or any former employer. 5. Copies of documents outlining your entitlement to stock options and the number of stock options and the number of shares of stock for which you have options along with a schedule for exercise of the options and the option price. 6. Copies of statements for any bank account in any banking or investment account in which you had an interest .'\ individually or with any other person as of November 20, 1999 and the present. 7. Copies of documentation for the cash value of any life insurance policy in which you have an interest. ./ 8. A copy of the most recent statement you have for any individual retirement account which is in your name, and also a statement for the same account on November 20, 1999. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys f()r Plaintiff BY:~~ C:3rol\J. Lindsay, squire 1~693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS-AT-LAW 26 W. High Street Carlisle, P A Fll[ COPy Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JOHN J. PITMAN, vs. : CIVIL ACTION. LAW : NO. 2002. 47~99 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE FIRST SET OF INTERROGATORIES OF PLAINTIFF ADDRESSED TO DEFENDANT TO: Carol G. Pitman 686 Valley View Drive Boiling Springs, PA 17007 YOU ARE HEREBY NOTIFIED that you are required, pursuant to Pennsylvania Rule of Civil Procedure No. 4005, to serve upon the undersigned, within thirty (30) days, ~ after service of this Notice, your Answers in writing under oath to the following Interrogatories. These Interrogatories shall be deemed to be continuing and if, between the time of your Answers and the time of trial in this case, you, or any acting on your behalf, learn of any further information not contained in these Answers, you shall promptly furnish that information to the undersigned by Supplemental Answers. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plainti'ff " Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JOHN J. PITMAN, V5. CIVIL ACTION. tAW : NO. 2002 - CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE FIRST SET OF JOHN J. PITMAN, PLAINTIFF INTERROGATORIES ADDRESSED TO CAROL J. PITMAN, DEFENDANT Plaintiff, JOHN J. PITMAN, propounds the following Interrogatories to Defendant, CAROL J. PITMAN, which must be answered within thirty (30) days of service hereof. 1. If you are living separate and apart from your spouse, please state what you consider to be the date of separation. ANSWER: 'J 2. Are you presently employed? (Full and part-time employment included) ANSWER: A. If your Answer is in the affirmative, st~,te fully for each employment: 1. The full name, address and telephone number of your place of employment; 2. The date you commenced your employment; 3. Your job title or position. ANSWER: 1. 2. 3. B. Do you have any written or oral employment contracts with your present employer? ANSWER: 3. Does the business or individual or other entity owe you any money, whether resulting from loan, undistributed profit, dividend or other form of credit, to which you are now entitled or will be entitled in the future? ANSWER: 4. Are you the owner, individually or with others, or any interest in any securities, or in any mutual fund, including but not limited to, stock funds, money market funds, bonds, municipal bond funds, gold funds, etc.? If so, please list the names of said securities or funds. ANSWER: 5. Do you own, individually or jointly with another, any certificates of deposit, treasury notes, or other depository receipt of any kind? ANSWER: 6. Do you now or have you at any time since the date of marriage, maintained or had access to a safe deposit box? If so, please detail the contents at the time opened, and the date of separation? 11 ANSWER: 7. Since the date of marriage, have there been accounts at a savings or commercial banking institution, brokerage firm, or any other type of financial institution, on which your name did not appear but in which YOLl deposited any funds? If so, please designate by account number and name of financial institution, and indicate the name(s) under which the account is listed. ANSWER: 8. State whether you have during the past three years made any gift to any person other than your spouse, in cash or in kind, having a value of $500.00 or greater. ANSWER: 9. A. If you have any interest in any qualified or unqualified deferred compensation arrangement or retirement pro9ram, including, but not limited to, IRA, Keogh Plan, 401(K) Plan, Savings Plan, annuity benefits, retirement plan, pension plan, profit-sharing plan, stock bonus plan, stock option plan, or thrift plan (excluding social security benefits) with your present employer, or any previous employer, please designate and indicate the name and type of the retirement plan: B. Have you elected to receive or have you received proceeds from any retirement benefit plan(s) as set forth in 11 (A) above in the period of six months prior to the date of separation, to the present? ANSWER: " 10. Have you filed a financial statement or loan application with any lending or credit institution during the past five years? If so, please name the lending or credit institution, and attach all such financial statements or loan applications to your Answers to these Interrogatories, and state the amount, term(s) and purpose(s) of such loan(s). ANSWER: 11. List all outstanding debts which you are obligated to pay, having a balance in excess of $300.00 for each debt. ANSWER: 12. Please estimate the current market value of your household contents including, but not limited to, furnishings, personal effects or other personal property (excluding jewelry). ANSWER: 13. Do you have an ownership in any furs, gold, diamonds or other precious gems or metals or jewelry, having a value of $300.00 or more for each item? If so, please describe each item and state its current market value. ANSWER: 14. Do you receive, or have you received, during the past three (3) years, any gifts, contributions, gratuities, benefits, services, fringe benefits or perquisites from any source, business or otherwise, including family members, for any of the following expenses? Detail the source, the dates and amounts of payments or goods or services and the purpose of the payment or goods or services: A. Living accommodations, including utilities and related expenses; B. Food, household products and sundries; C. Clothing; D. Recreation and entertainment (e.g., club memberships, dues, etc.); E. Vacation or travel; F. Education; G. Automobile or other vehicle; H. Expense account or reimbursement; I. Company credit cards; J. Use of company facilities (boat, cottage, condominium, etc.); K. Company loans and salary or advance account; L. Company product discounts; M. Life, health, disability or automobile insurance; or N. Other (specify). ANSWER: 15. Do you own or have any interest in any property (real or personal, including cash), contract right, patent, chose in action, or expectancy of any kind, including an interest or right titled or held in the name of another, not previously identified in your Answers to the preceding Interrogatories? If so, describe in detail the property, contract right, patent, chose in action, or expectancy, and state: A. The identity of the person you share such interest with; B. The date you acquired your interest; C. The value at acquisition; D. Present value and how determined. ANSWER: 16. Have you ever received any monies as the result of an Inheritance or the death of another person? State the amount of money received, the date on which it was received, and the name of the estate from whom you received the money. ANSWER: 17. Please refer to Schedule A (attached hereto) Do you now, or did you at any time within three years before your separation, have any interest in any of the items listed on Schedule A? If so, please so designate by placing an "x" in the ;parentheses provided next to the items andor each designated item on Schedule A; please provide the information requested on Schedule A immediately below the designated items. Please answer on attached Schedule A. n SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: Carol J. Lindsay, Esquire 10 # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 SCHEDULE A EXPLANATION OF TERMS: Date of Acquisition: The date the item was acquired. Please be as specific as possible. Value of Acquisition: The purchase price or value of the item which it was acquired. Separation Value: The value of the times as of the date you can determine to be the date of separation. Current Value: The current and/or present value of the time as of the date of answering these Interrogatories. () A. STOCK OPTIONS 1. Please state the name of the grantor and a description of the option, including the date of acquisition and option price. a) b) c) d) e) 2. Current value of stock. a) b) c) d) e) () B. FINANCIAL INSTITUTIONS, CHECKINC; ACCOUNTS, SAVINGS ACCOUNTS, ETC. 1. Please state the name of the financial institutions, and addresses thereof, as well as your account number, and the current balance. a) b) c) d) e) 2. Balance of account at the date of separation. a) b) c) d) e) () C. LIFE INSURANCE POLICIES 1. Name and address of insurance company and type of policy (ordinary life, term, annuity, etc.) and identifying number. a) b) c) d) e) 2. Face value, and current cash surrender value: a) b) c) d) e) 3. Indicate loans against each policy, Including date, amount, and purpose of loan. a) b) c) d) e) 4. Name of owner and name of insured. a) b) c) d) e) 5. Name, address and relationship, if any, of beneficiary. a) b) c) d) e) 6. Annual premium. a) b) c) d) e) 7. Has your interest in any insurance policy been canceled, allowed to lapse, liquidated or otherwise been terminated in the last five years? ANSWER: 8. Designate any change or transfer of beneficiary designation as to any policy listed in (F) above, over the past five years. ANSWER: VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Carol G. Pitman Date: n ~"') ( ,.~~ C) C.." 'Tl :;:t: ~:;,;,'" :;t.J I -tl ::-lr '" 't_<) <..,,;,\ - SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA JOHN J. PITMAN, Plaintiff VS. CAROL G. PITMAN, I "\ MAR 0 3 ZOOS,^ {\, t : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2002 - 4799 CIVIL TERM Defendant : IN DIVORCE AND NOW, this ORDER OF COURT 10 > day of yY)~ , 2005, upon consideration of the within Petition a Rule is issued upon the Respondent to Show Cause why the discovery requested, updated through the end of 2004 should not be provided. Rule returnable "z--o days from the date of service hereof. Byth, COO"'/? J.. J. I. tiC :8 ~ ""1 (I.d JOHN J. PITMAN, PLAINTIFF : IN THE COURT OF COMMON PL AS OF : CUMBERLAND COUNTY, PENNS LVANIA : CIVIL ACTION - LAW : NO. 2002 . 4799 CIVIL TERM VS. CAROL G. PITMAN, DEFENDANT : IN DIVORCE ATTORNEY'S ACCEPTANCE OF SERVICE I, Robert Lieberman, Esquire, attomey for Defendant, Carol G. Pi an, in the above captioned action, hereby accept service of the Divorce Complaint i the above action this il day of O~", zoot on Defendant's behalf and hereby acknowledge that I am authorized to do so. ATTORNEY FOR DEFENDANT By: ,~~~ -~ ROBERT liEBERMAN 500 NORTH THIRD STREET, 1 H FLOOR P. O. Box 1004 HARRISBURG, PA 17108-100 c ,...., Cl .' c::> '- c~ -" ;-," ,~fl .., =? -1~; :;:"-' nl p:- - ::00 -::1 en ~-) ,:,"n 0 0..0 ('J (~) :-:-,'1 -, -'-.-'~ , ~0 >: 'rn j. ;:5 :.) :=, -.( r<1 j",1 ;.D .-<.: SAIDIS SHUFF, FLOWER & LINDSAY A1TQRNEYS-AT-LAW 26 W. High Street Carlisle, P A II JOHN J. PITMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V5. CIVIL ACTION - LAW NO. 2002 - 4799 CIVIL TERM CAROL G. PITMAN, Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER John J. Pitman, Petitioner, moves the court to appoint a master with respect to the following claims: (X) ( ) ( ) ( ) ( X) ( ) ( ) ( ) Distribution of Property (Equitable Distribution) Support Counsel Fees Costs and Expenses Divorce Annulment Alimony Alimony Pendente Lite and in support of the motion states: Discovery is complete as to the claim(s) for which the appointment of a master is (1) requested. (2) The Defendant, Carol G. Pitman appeared in the action and is represented by counsel, Robert B. Lieberman, Esquire. (3) The statutory ground(s) for divorce is 3301 (c) and/or (d) (4) Delete the inapplicable paragraph(s). (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: ALL The action complex issues of law or fact. The hearing is expected to take one (1) day. Additional information, if any, relevant to the~' n: r \ I J ~~ h lor II": , / (5) (6) (7) Date: Carol J. Lindsay, Atto 10 # 44693 26 W. High 5t. < Carlise, PA 17013 ORDER APPOINTING MASTER AND NOW, this day of , , Esquire, is appointed master with respect to the 2005, following claims: ( X )Divorce ( X ) Distribution of Property (Equitable Distribution) By the Court, J. ~._,") r-) c~i~, r', ' .:I' --,...~ .. ...-,".. .-- \") -- \::? ......~ o - SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS.AT.LAW 26 W. High Street Carlisle, PA JOHN J. PITMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - LAW NO. 2002 - 4799 CIVIL TERM CAROL G. PITMAN, Defendant IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLlSLE, PENNSYLVANIA 17013 (717) 249-3166 SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff ~ , / By: / c::::. Car say, squire ID# 4693 '.J6--West High Street Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEVS.AT-LAW 26 W. High Street Carlisle, PA JOHN J. PITMAN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V5. : CIVIL ACTION - LAW : NO. 2002 - CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE AMENDED COMPLAINT IN DIVORCE JOHN J. PITMAN, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is John J. Pitman, who currently resides at 205 Parker Street, Carlisle, Cumberland County, Pennsylvania, where he has reSided since November 20, 1999. 2. The Defendant is Carol G. Pitman, whose last know address is 1446 E. Windjammer Place, Valrico, Florida 33594, where she has resided since April 2005. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 27, 1966 in Athens, Georgia. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, P A 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. COUNT II - EQUITABLE DISTRIBUTION 8. The averments of Paragraph 1 through 7 are incorporated herein by reference as though set out in full. 9. The parties have, during their marriage, acquired certain property, both personal and real. WHEREFORE, Plaintiff prays this Honorable Court to equitably divide the parties' property. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Carol J. Linds y, ID # 44693 26 West Hig, Street Carlisle, PA 17013 (717) 243-6222 Date: /1 ;: (1- b, L) , I SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, P ^ VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. c.s. 9 4904, relating to unsworn falsification to authorities. Date: K/ la)o<; '0.:>C (-' /' > >... ~ ",. "" " " ~. (C. i/' C' :-l.. ;-.. N Y ... Iv o l-:' ......". o '" ~ ~ r' , \ h. ~ f>.;, ~~ C:J l~J'l Cl -d :':j' I" 1'0 JOHN J. PITMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 4799 CIVIL CAROL G. PITMAN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~ day of _ 2006, the economic claims raised in the proceedings having been resolved in accordance with a property settlement and separation agreement dated February 27, 2006, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE CO(~ cc: ,.-Carol J. Lindsay Attorney for Plaintiff )Robert B. Lieberman Attorney for Defendant -- ;-;) ..~_. '. , JOHN J. PITMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION.. LAW NO. 2002 - 4799 CIVIL TERM CAROL G. PITMAN, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this ,.9, '7 day of -hbrlJ_flLtJ. , 200$ between JOHN J. PITMAN, of 205 Parker Street, Apartment 4, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband, and CAROL G. PITMAN, of 1446 Windjammer Place, Val Rico, Florida, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on May 27, 1966 in Athens, Georgia and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 2002-4799, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable 1 --1 ;. consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lalNful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above- captioned divorce action. On the same day as the execution of this agreement, the parties shall execute and file an Affidavit of Consent and Waiver of Notice, necessary to finalize the divorce. (3) REAL PROPERTY: The parties were the owners of a house at 686 Valley View Drive, Boiling Springs, Cumberland County, Pennsylvania. The house was encumbered by a mortgage and a home equity line of credit. The parties have sold the house and equally divided the proceeds. (4) DEBT: A. MARITAL DEBT: Husband and Wife acknowledge and agree that there is no outstanding debt and obligation which is marital or for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on November 20,1999, the party who incurred said 2 debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Husband has retained the 1973 Porsche and 1982 BMW motorcycle. Wife has retained the 1994 Ford Taurus. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes 3 any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. Nevertheless, Husband acknowledges that he will transfer to wife Two Hundred Six Thousand and 00/100 Dollars ($206,000.00) against the value of his CSRS pension. The transfer shall be made by a Domestic Relations Order prepared by Harry Leister. The parties anticipate that Mr. Leister will draft the Order to set the percentage of Husband's CSRS pension value represented by Two Hundred Six Thousand and 00/100 Dollars ($206,000.00) and that such Order will call for the payment to Wife of a percentage of Husband's CSRS pension on a monthly basis. The parties acknowledge that the preparation of the DRO and the action on the DRO by the Civil Service Retirement System may require several months. The parties will promptly submit to Mr. Leister the request to prepare the DRO and, as soon as Husband is made aware of the monthly amount of the DRO, he will pay Wife directly that amount for each month commencing December 1, 2005 and continuing until the Civil Service Retirement System makes the payment to Wife directly. Because the payments made to Wife prior to direct payment shall be made out of post-tax pension payments, the parties will treat each payment as alimony, deductible by Husband in the year in which paid and reportable as income by Wife in the year in which received. Said alimony shall terminate as soon as the CSRS system directly pays Wife her share of Husband's pension. Husband shall retain his accounts with the Navy Federal Credit Union. Wife will retain her checking and savings accounts with Sovereign Bank (formerly Waypoint) and 4 . with M& T Bank. The parties shall cooperate to close the joint Members 1 sl Federal Credit Union account(s) and the Navy Federal Credit Union account. Husband shall receive any balances remaining therein. Husband will retain his IRA with lNG, his thrift savings plan, any increase in value In his thrift savings plan, the balance of his CSRS pension and his Naval Reserve retirement. Wife shall retain her Pharmerica 401 (k) plan through Merrill Lynch, any increase in value on that account, her Janey Montgomery Scott IRA, her New York Life IRA, the survivor annuity for the CSRS pension, (which survivor annuity shall be specifically set out in the Domestic Relations Order to be prepared by Mr. Leister) and a Navy Reserve Retirement survivor benefit. In order to secure Wife's interest in the Navy Reserve Retirement benefit, the parties shall request Mr. Leister to prepare any necessary Domestic Relations Order. Wife will retain her ING life insurance policy along with its cash value and Husband will retain his New York life insurance policy along with its cash value. Wife will also retain her Computershare account and her Janey Montgomery Scott investment account. Husband will transfer to Wife Ten Thousand and 00/00 Dollars ($10,000.00) as a rollover from an IRA into an IRA to Wife. Said transfer will be without tax consequences to either party. Husband shall sign any documents required to provide to Wife any right she may have to military benefits, including but not limited to, medical and prescription benefits and commissary use. (8) WAIVER OF ALIMONY: The parties acknowledge that each has income 5 and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) COSTS: The parties agree to equally share the costs incurred in the valuation of the pensions and the preparation of the Domestic Relations Orders. As of the date of this Agreement, the parties have incurred costs for pension evaluations. Within thirty (30) days of this Agreement, Wife will reimburse Husband one-half of that amount or, in the alternative, Husband may reduce the $10,000.00 IRA transfer to Wife set out in paragraph 7 above by the amount owed by Wife for costs. Upon receipt from Mr. Leister of a statement for services for preparation of the Domestic Relations Orders, Wife shall pay one-half and Husband will pay one-half. (10) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel, Husband is represented by Carol J. Lindsay, Esquire and Wife is represented by Robert B. Leiberman, Esquire, has been advised that he or she may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. 6 . (11) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (12) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (13) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (14) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, 7 the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (15) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (16) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (17) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: 8 'I' A All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obli[)ations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, 9 state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (18) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (19) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (20) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (21) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever. other than those herein contained. 10 'l.,~" (22) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: y!J~ /Jlf!1J 7 7rL/M-;YAA ;~~ ~ ~ ~_(~L _, Jo J. Pitm a r-', Gfi,OuY J t;;O-AJ Carol G. Pitma 11 SAID IS SHUFF, FLOWER & LINDSAY ATJ"ORNEYSoAToLAW 26 W. High Street Carlisle. P A " JOHN J. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2002 - 4799 CIVIL TERM v. CAROL G. PITMAN, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on October 2, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: '1! 0/0 (, \).p ~....- ~tman PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER6 3301 (e) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: '1/u { (')( a ~~4__ Jo n . Pitma , Q ) -;:.1 JOHN J. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 2, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATED: ~ / '2~ !tt, ~~G~ Carol G. Pitman, Defendant . ...,.., I"",.) -..--; JOHN J. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this Waiver of Notice are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: 0/::1';;' jtJto {l~'i~ Defendant , _~,_,d --..., C.~~; .< '- - 'I SAlOIS, FI..OWER & LINDSAY ~'IAW 26 West High Street Carlisle, PA JOHN J. PITMAN,. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 - 4799 CIVIL TERM v. CAROL G. PITMAN, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on October 18, 2002. Proof of service was filed with the Court on March 29, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: July 6,2006 and filed with Prothonotary on July 7,2006. By Defendant: June 22, 2006 and filed with Prothonotary on July 7, 2006. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated February 27, 2006 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: July 6, 2006 and filed with Prothonotary on July 7, 2006. By Defendant: June 22, 2006 and filed with Prothonotary on July 7, 2006. SAIDIS, SHUFF, FLOWER & LINDSAY .. SAIDIS7 FLOWER & LINDSAY Ja1~EYS'~J'olAW 26 West High Street Carlisle, PA " CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor P. O. Box 1004 Harrisburg, PA 17108-1004 SAlOIS, SHUFF, FLOWER & LINDSAY Dated: July 7,2006 f"-_."' ('-t - 11 \..:~'~I IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . . PENNA. STATE OF JOHN J. PITMAN . No. 2002-4799 VERSUS CAROL G. PITMAN . . DECREE IN DIVORCE . . . . . . . . AND NOW, 1~ JOHN J. PITMAN II" , 'UOOc... , IT IS ORDERED AND DECREED THAT , PLAINTIFF, . AND CAROL G. PITMAN , DEFENDANT, . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated February 27, . 2006 are incorporated, but not merged, into this Decree in Divorce. . . . BY THE . T:~.~~ ~ ?.-X/~. YAy PROTHONOTARY J. . . . . . ....... " . . . . . . . . . . . . . . . . . . . . ~ ~:? ~ '?!)"~ 10 i!1'{. ~p~~ ~Y? 1~.eIL ... JOHN J. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE MOTION TO ENTER QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this ~ ~ day of ~ , 2006, comes Plaintiff, JOHN J. PITMAN, by and through his attorney, CAROL J. LINDSAY, ESQUIRE and Defendant, CAROL G. PITMAN, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represent as follows: 1. JOHN J. PITMAN is the Plaintiff in the above captioned divorce action represented by CAROL J. LINDSAY, ESQUIRE. 2. CAROL G. PITMAN is the Defendant in the above captioned divorce action represented by ROBERT B. LIEBERMAN, ESQUIRE. 3. Plaintiff and Defendant entered into a Property Settlement and Separation Agreement under date of February 27, 2006 which Agreement provides for the division of Defendant's Military Retirement Pension pursuant to a Qualified Domestic Relations Order. 4. The Qualified Domestic Relations Order has been executed by both Plaintiff and Defendant. ,.. ' . .. 5. In order for the Qualified Domestic Relations Order to be implemented by the appropriate authorities, it is required that the Order be entered by this Honorable Court. WHEREFORE, Plaintiff, JOHN J. PITMAN and Defendant, CAROL G. PITMAN respectfully requests this Honorable Court to enter the Qualified Domestic Relations Order as attached hereto. ~k, Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Defendant . "'" . , ::::n c_: (...:..1 #"" JOHN 1. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE MOTION TO ENTER QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this :;.., day of ~ ,2006, comes Plaintiff, JOHN J. PITMAN, by and through his attorney, CAROL 1. LINDSA Y, ESQUIRE and Defendant, CAROL G. PITMAN, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represent as follows: 1. JOHN J. PITMAN is the Plaintiff in the above captioned divorce action represented by CAROL J. LINDSAY, ESQUIRE. 2. CAROL G. PITMAN is the Defendant in the above captioned divorce action represented by ROBERT B. LIEBERMAN, ESQUIRE. 3. Plaintiff and Defendant entered into a Property Settlement and Separation Agreement under date of February 27, 2006 which Agreement provides for the division of Defendant's Civil Service Retirement Pension pursuant to a Qualified Domestic Relations Order. 4. The Qualified Domestic Relations Order has been executed by both Plaintiff and Defendant. .. ,.. 5. In order for the Qualified Domestic Relations Order to be implemented by the appropriate authorities, it is required that the Order be entered by this Honorable Court. WHEREFORE, Plaintiff, JOHN J. PITMAN and Defendant, CAROL G. PITMAN respectfully requests this Honorable Court to enter the Qualified Domestic Relations Order as attached hereto. Respectfully submitted, Respectfully submitted, L~uf- ~, ) ~ieberman, Esquire 500 North Third Street, 12th Floor Harrisburg, P A 17101 (717) 236-1485 Attorney for Defendant Carol J. Linds y, lts uire SAIDIS, FLO R LINDSAY 26 West High et Carlisle, P A 17013 (717) 243-6222 Attorney for Plaintiff r--.' .~:..;,.... ..-~ (...) (,.) t,,'~. .. ", 7'-t1 , .. . " . ',," ;,I"") ~ ... , ",' ,] BY: ~v JohnJ. Pitman Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW Carol G. Pitman Defendant NO. 2002-4799 DOMESTIC RELATIONS ORDER 1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the Alternate Payee's right to receive a portion ofthe benefits payable with respect to the Participant. It is intended to constitute a Qualifying Court Order under the Uniformed Services Former Spouse's Protection Act, 10 U.S.C. Section 1408 and following. 2. This DRO is entered pursuant to authority granted under the applicable domestic relations laws of the State of Pennsylvania. 3. This DRO applies to the Military Retirement System ("Plan") and any successor thereto. John J. Pitman ("Participant") is a Participant in the Plan. Carol G. Pitman ("Alternate Payee"), the former spouse, is the Alternate Payee for the purpose of this DRO. 4. The Participant's name, mailing address, Social Security number and date of birth are: JohnJ. Pitman 285 PM'kGI Street ~ P.O. Box 941 Carlisle, PA 17013 Social Security No.: 190-32-2857 Date of Birth: August 5,1942 5. The Alternate Payee's name, mailing address, Social Security number and date of birth are: Carol G. Pitman 1446 Windjammer Place Valrico, FL 33594 Social Security No.: 164-36-8910 Date of Birth: September 14, 1945 It is the responsibility of the Alternate Payee to keep a current mailing address on file with DFAS. 6. The Participant is currently receiving a monthly pension under the PIan. Upon retirement he elected to provide survivor benefits to his spouse, Carol G. Pitman, under the Survivor Benefit PIan. ... , , (l"' ,r: 11'1' g. I i\<r CFinl .} l" ,_ \>.f\., \. _, : ~ Il~ '-' ~ ,. , . . DRO Page 2 7. The sole purpose of this DRO is to provide that, upon the death ofthe Participant, the Alternate Payee shall receive a survivor annuity in accordance with the Survivor Benefit Plan election made by the Participant upon his retirement. 8. The Participant's rights under the Soldiers' and Sailors' Civil Relief Act of 1940 (50 U.S.C. ~521) were observed by the Court as evidenced by the presence of his legal counsel at the proceedings. 9. The jurisdictional requirements of 10 U.S.C. Section 1408 have been complied with, and this Order has not been amended, superseded, or set aside by any subsequent order. 10. The Participant and the Alternate Payee acknowledge that they have been married for a period of more than ten years during which time the Participant performed more than ten years of creditable military service. The parties were married on May 27, 1966, and separated on November 20, 1999. 11. The parties acknowledge that the following items must be sent by the Alternate Payee to DFAS, U.S. Military Retired Pay, P.O. Box 7130, London, KY 40742-7130. The Participant agrees to provide any of this information to the Alternate Payee at the Alternate Payee's request and to make all necessary efforts to obtain any of this information that the Alternate Payee is unable to obtain. a. Deemed Election Letter. b. A certified copy of the Divorce Decree. c. A certified copy of this Domestic Relations Order. d. A copy of the Marriage Certificate of Mr. And Mrs. Pitman. e. An executed copy of Form 2656-1 entitled Survivor Benefit Plan (SBP) Election Statement for Former Spouse Coverage. ," " '. . DRO Page 3 12. The Court shall retain jurisdiction to enter such further orders as are necessary to enforce the award to the Alternate Payee of the military retirement benefits awarded herein. EXECUTED this I f'" day of 1'-'1 CONSENT TO ORDER: PLAINTIFFIPARTICIPANT Signat~ ~ 6 ,1 1~/6 , Date ATTORNEY FOR PLAINTIFF/ PARTICIP Olo (\ ,\4>' o , ..z.~c~. BY THE COURT .~d DEFENDANT/ALTERNATE PAYEE A ('}lA.W 9;Q;I;;;;:) Signature u ~'z/~ , Date ATTORNEY FOR DEFENDANT/ ALTERNATE PAYEE //:;:;! l. ~a~'Jl'" -.'''' " . ~ JOHN 1. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE MOTION TO ENTER OUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this :l.? day of ~ , 2006, comes Plaintiff, JOHN J. PITMAN, by and through his attorney, CAROL J. LINDSAY, ESQUIRE and Defendant, CAROL G. PITMAN, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represent as follows: 1. JOHN J. PITMAN is the Plaintiff in the above captioned divorce action represented by CAROL 1. LINDSAY, ESQUIRE. 2. CAROL G. PITMAN is the Defendant in the above captioned divorce action represented by ROBERT B. LIEBERMAN, ESQUIRE. 3. Plaintiff and Defendant entered into a Property Settlement and Separation Agreement under date of February 27, 2006 which Agreement provides for the division of Defendant's Civil Service Retirement Pension pursuant to a Qualified Domestic Relations Order. 4. The Qualified Domestic Relations Order has been executed by both Plaintiff and Defendant. .,,04- . _ \> . 5. In order for the Qualified Domestic Relations Order to be implemented by the appropriate authorities, it is required that the Order be entered by this Honorable Court. WHEREFORE, Plaintiff, JOHN 1. PITMAN and Defendant, CAROL G. PITMAN respectfully requests this Honorable Court to enter the Qualified Domestic Relations Order as attached hereto. Respectfully submitted, Respectfully submitted, , ps uire R LINDSAY 26 West High et Carlisle, P A 17013 (717) 243-6222 Attorney for Plaintiff L..tA.f ~ . ) ~ieberman, Esquire 500 North Third Street, 12th Floor Harrisburg, P A l7l 0 1 (717) 236-1485 Attorney for Defendant .,.. . ....'". o (~~ -;-, ~, c;~ .,.:; j:;,;>.... ~ 'o>' r - w - -' -' . () -n .-' ^.~_t: -'''' n1 ~:; ,. <.;.1 ," ~.,' \ \.;::,) . RECElvr-<:b V\ j! il ." "' 2...."c ....v~ .k <., .uU\J , . f BY: 1A\rt- John J. Pitman Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW Carol G. Pitman Defendant NO. 2002-4799 DOMESTIC RELATIONS ORDER 1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the Alternate Payee's right to receive a portion of the benefits payable with respect to the Participant. It is intended to constitute a DRO Acceptable For Processing under final regulations issued by the Office of Personnel Management ("OPM"). 2. This DRO is entered pursuant to authority granted under the applicable domestic relations laws ofthe State of Pennsylvania. 3. This DRO relates to the provision of marital property rights to the Alternate Payee. 4. This DRO applies to the Civil Service Retirement System ("Plan") and any successor thereto. JohnJ. Pitman ("Participant") is a Participant in the Plan. Carol G.. Pitman ("Alternate Payee"), the former spouse, is the Alternate Payee for the purposes of this DRO. 5. The Participant's name, mailing address, Social Security number and date of birth are: John J. Pitman 2eg PMkE.F Stl'89t ~ P.O. Box 941 Carlisle, PA 17013 Social Security No.: 190-32-2857 Date of Birth: August 5,1942 6. The Alternate Payee's name, mailing address, Social Security number and date of birth are: , \ "r.""'r"" I: 11.) ~~.! C' > ~,"" j :rtl. , . f DRO Page 2 Carol G. Pitman 1446 Windjammer Place Valrico,FL 33594 Social Security No.: 164-36-8910 Date of Birth: September 14, 1945 It is the responsibility of the Alternate Payee to keep a current mailing address on file with the Plan at all times. 7. The Participant is currently receiving a monthly pension under the Plan. 8. The Alternate Payee is entitled to a portion of the Participant's Gross Monthly Annuity under the Plan as set forth below. The OPM is hereby directed to pay Alternate Payee's share directly to Alternate Payee. 9. This DRO assigns to Alternate Payee an amount equal to 21.37% ofthe Participant's Gross Monthly Annuity. In addition to the above, when COLA's are applied to Participant's retirement benefits, the same COLA shall apply to the Alternate Payee's share. 10. Payments to Alternate Payee shall commence as soon as administratively feasible following the date this DRO is approved by OPM. Participant agrees to arrange or to execute all forms necessary for the OPM to co=ence payments to the Alternate Payee in accordance with the terms of the DRO. 11. Payments shall continue to Alternate Payee for the remainder of the Participant's lifetime. If the Alternate Payee dies before the Participant, the Alternate Payee's share ofthe Participant's pension shall be paid to her estate. 12. Upon the death of the Participant, the Alternate Payee shall receive a survivor annuity in accordance with the survivor annuity election made by the Participant upon his retirement. 13. In no event shall the Alternate Payee have greater benefits or rights other than those which are available to the Participant. The Alternate Payee is not entitled to any benefit not otherwise provided by the Plan. The Alternate Payee is only entitled to the specific benefits . i DRO Page 3 offered by the Plan as provided in this Order. All other rights, privileges and options offered by the Plan not granted to Alternate Payee are preserved for the Participant. 14. The Alternate Payee assumes sole responsibility for the tax consequences of any payments made to her under this DRO. 15. In the event that the Plan inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms ofthis DRO, the Participant shall i=ediately reimburse the Alternate Payee to the extent that he has received such benefit payments, and shall forthwith pay such amounts so received directly to the Alternate Payee within ten (10) days of receipt. In the event the Plan inadvertently pays to the Alternate Payee any benefits that are not assigned to her pursuant to the terms ofthis DRO, the Alternate Payee shall immediately reimburse the Participant to the extent she has received such benefit payments and shall forthwith pay such amounts so received directly to the Participant within ten (10) days of receipt. 16. If Participant takes any action that prevents, decreases, or limits the collection by Alternate Payee ofthe sums to be paid hereunder, he shall make payments to Alternate Payee directly in an amount sufficient to neutralize, as to Alternate Payee, the effects of the actions taken by Participant. , . , DRO Page 4 17. The Court ofCo=on Pleas of Cumberland County, Pennsylvania shall retain jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order, provided, however, that no such amendment shall require the Plan to provide any form of benefit or any option not otherwise provided by the Plan, and further provide that no such amendment or right of the Court to so amend will invalidate this Order. EXECUTED this 18" day of {'"'1 ,200" . BY THE COURT CONSENT TO ORDER: ,.Ai PLAINTIFFIPARTICIPANT FENDANT/ALTERNATE PAYEE Signat~ ~..d;_ 1/1 '-I.Il.L Date ~ (1$JULO fa/~ (p~tk Signature Date ATTORNEY FOR DEFENDANT/ ALTERNATE PAYEE /~.~ jsignature to /Z%f. I Date J 010 0<\" \'bf " . . JOHN J. PITMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. 2002-4799 CIVIL TERM CAROL G. PITMAN, Defendant : IN DIVORCE MOTION TO ENTER OUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this ~ ~ day of ~ , 2006, comes Plaintiff, JOHN J. PITMAN, by and through his attorney, CAROL J. LINDSAY, ESQUIRE and Defendant, CAROL G. PITMAN, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and respectfully represent as follows: 1. JOHN 1. PITMAN is the Plaintiff in the above captioned divorce action represented by CAROL J. LINDSAY, ESQUIRE. 2. CAROL G. PITMAN is the Defendant in the above captioned divorce action represented by ROBERT B. LIEBERMAN, ESQUIRE. 3. Plaintiff and Defendant entered into a Property Settlement and Separation Agreement under date of February 27, 2006 which Agreement provides for the division of Defendant's Military Retirement Pension pursuant to a Qualified Domestic Relations Order. 4. The Qualified Domestic Relations Order has been executed by both Plaintiff and Defendant. ., ' 5. In order for the Qualified Domestic Relations Order to be implemented by the appropriate authorities, it is required that the Order be entered by this Honorable Court. WHEREFORE, Plaintiff, JOHN J. PITMAN and Defendant, CAROL G. PITMAN respectfully requests this Honorable Court to enter the Qualified Domestic Relations Order as attached hereto. ~~. Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Defendant ,~ i .~ . .;~\ t-:, ~,::;..; - '-'-' -:'<1 .-"-