HomeMy WebLinkAbout02-5035
SHANNON L. DETTER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant.
: 2002 - .503:>' CIVIL TERM
: 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 in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty A venue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
SHANNON L. DETTER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant.
: 2002 -!)() :3 ~/ CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(0 AND ill} OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Shannon L. Detter, by and through her attorneys, Irwin,
McKnight & Hughes, and files this Complaint in Divorce against the Defendant, Chad P. Detter,
representing as follows:
1. The Plaintiff is Shannon L. Detter, an adult individual residing at 329 2nd Street,
Apt. C, New Cumberland, Cumberland County, Pennsylvania 17070.
2. The Defendant is Chad P. Detter, an adult individual currently residing at 140
Kennedy Lane, Etters, York County, Pennsylvania 17319.
4. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least
six months prior to the filing ofthis action in divorce.
5. The Plaintiff and the Defendant were married on February 14, 1998 III
Mechanicsburg, Pennsylvania.
6. The Plaintiff and the Defendant have lived separate and apart since February 1,
2001.
7. There have been no prior actions of divorce or for annulment between the parties.
8. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
9. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling. Plaintiffs signed Marriage Counseling Affidavit is attached hereto and incorporated
herein by reference as Exhibit "A."
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
COUNT II
ALIMONY, ALIMONY PENDENTE LITE AND COUNSEL FEES
1. The allegations of Paragraph I through 8 of the Divorce Complaint are
incorporated herein as if fully set forth above.
2. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs
during the pendency ofthis divorce action, and through its resolution.
3. Plaintiff is without sufficient property and otherwise unable to financially support
herself through appropriate employment.
4. Defendant is presently employed and receiving a substantial income and benefits
an is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente
lite for the Plaintiff.
WHEREFORE, Plaintiff requests the Court to enter an ordering requiring Defendant to
pay for Plaintiff s counsel fees, expenses and costs as well as providing for payment of an
appropriate alimony and alimony pendente lite to Plaintiff.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
Dated: ~/~.~
I
By:
Douglas Miller, EsqUIre
Supreme Court J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
SHANNON L. DETTER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: 2002 -
CIVIL TERM
CHAD P. DETTER,
Defendant.
: IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: October I (/J , 2002
><J/)~/ ~
SHANNON L. DETTER
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
Ai~~AWfrn ./wL2Z7
SHANNON DETTER
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SHANNON L. DETTER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION -LAW
: 2002 - 5035 CIVIL TERM
CHAD P. DETTER,
Defendant.
: IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Douglas Miller, Esquire, being duly sworn according to law, does depose and state:
1. That he is a competent adult and attorney for the Plaintiff in the captioned action.
2. That a certified copy of the Complaint was served upon the defendant, Chad P.
Detter, on October 22, 2002 by certified mail, return receipt requested, addressed to
Chad P. Detter, at his address at 140 Kennedy Lane, Etters, Pennsylvania 17319,
with return receipt number 70012510 0009 2828 4531.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 PaC.s. Section 4904, relating to unsworn
falsification to authorities.
IRWIN, McKNIGHT & HUGHES
Date: 10P..3/ Od-
By:
Do G.
Supreme C Id # 83776
60 West Pomfret Street
Carlisle,PA 17013
(717) 249-2353
Attorney for Plaintiff
Shannon Detter
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l'- ktters. PA 17319 ------hh----.hhhh.__h__hhh_____
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted DelIvery Is desil8d.
. Print your name and address on the reverse
so that we can retum the card to you.
. Attach thia card to the back of the mellplece,
or on the front If space permits.
1. Article AddresHCl to:
D. Is deIIwlry ~ dItI8r8nI from IIem 1?
If YES, enter delivery lIddMs below.
~. DETTEll.
14 KENNEDY LANE
. PA 17319
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2. Article Number
(Transfer from SfNVice label)
PS Form 3811 , March 2001
7001 2510 0009 2828 4531
Domestic Return Receipt
10259$-01-M-1424
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SHANNON L. DETTER,
Petitioner/Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Respondent/Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, comes Shannon L. Detter, by and through her attorneys, IRWIN,
McKNIGHT & HUGHES, and petitions this Honorable Court as follows:
1.
The petitioner/plaintiff is Shannon L. Detter who currently resides at 329 2nd Street, Apt.
C, New Cumberland, Cumberland County, PeI111sylvania 17070.
2.
The respondent/defendant is Chad P. Detter who currently resides at 140 KeI111edy Lane,
Etters, York County, PeI111sylvania 17319.
3.
Petitioner and respondent were married on February 14, 1998, in Cumberland County,
PeI111sylvania and were separated on February 1, 2001.
4.
Petitioner is without the ability to earn income sufficient to meet her reasonable needs.
WHEREFORE, petitioner, Shannon L. Detter, respectfully requests that this Honorable
Court order alimony pendente lite in an amount equal to the Pennsylvania State Support
Guidelines, which monthly amount of $968.00 was determined by Domestic Relations
conference with the parties present on this day, December 2, 2002.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Douglas . Miller, Esquire
60 West Pomfret Street
Carlisle, P A 17013
Supreme Court I.D. No: 83776
(717) 249-2353
Attorney for the petitioner/plaintiff
Sharon L. Detter
Date: December 2, 2002
2
SHANNON L. DETTER,
Petitioner/Plaintiff
v.
CHAD P. DETTER,
RespondentJDefendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.2002-5035 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, hereby certify that a copy of attached document was served
upon the following by depositing a true and correct copy of the same in the United States mail,
First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and
addressed as follows:
Samuel L. Andes, Esq.
525 North Twelfth Street
P. O. Box 168
Lemoyne, P A 17043
By:
Date: December 2, 2002
IRWIN, McKNIGHT & HUGHES
Doug .. M ler, E,q~
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 83776
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SHANNON L. DETTER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
CHAD P. DETTER,
DefendantJRespondent :
NO. 2002-5035 CIVIL TERM
IN DIVORCE
DR# 32159
Pacses# 544104951
ORDER OF COURT
AND NOW, this 2nd day of December, 2002, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,313.00 and Respondent's monthly net income/earning
capacity is $3,804.11, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit, $968.00 per month payable monthly as follows; $968.00 for
alimony pendente lite and $0.00 on arrears. First payment due next pay date. Arrears set at $968.00
as of December 2,2002. The effective date of the order is December 2,2002.
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 as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after
hearing, that the Respondent has willfully failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Shannon L. Detter. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
Payments must include the defendant's P ACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
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Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent
and 100% by petitioner. The petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such a.s prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notict: of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Court.
DRO: R. J. Shadday
Mailed copies on
12-3-02 to: <
BY THE COURT,
Petitioner
Respondent
Douglas Miller, Esquire
Samuel Andes, Esquire
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
j).el o/t?oJ. ~03".'i (!; P1L
State .Co~monwealth of pennsylvania //l(!>f'C; 6'Lf'f/0IT7~
Co.lCity/Dlst. of CUMBERLAND
Date of Order/Notice 12/02/02 O/<- 3d-/51
Tribunal/Case Number (See Addendum for case summary)
@Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
RE: DETTER, CHJID P.
Employee/Obligor's Name (Last, First, Mil
233-13-8820
Employee/Obligor's Social Security Number
8100101060
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mil
EmployerlWithholder's Federal EIN Number
NORTH AMERICAN VAN LINES
PAYROLL
165 LAMONT ST
NEW CUMBERLAND PA 17070-2474
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 968.00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes (R) no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 968.00 per month to be forwarded to 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 match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 223.38 per weekly pay period.
$ 446.77 per biweekly pay period (every two weeks).
$ 484.00 per semimonthly pay period (twice a month).
$ 968.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania SCOU, P.O. Box 69112, HarrisbUlrg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DEe
3 2V~Ji
BY THE COURT:r---~'''',
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.;i,~~~,.IL~D #)>cUMo t; 6/-/66 $-"'~t! Form {~:;8e.
..--.f"J..Lf{)).. OMBNo.,0970-<l1S4 WorkerlD $IATT
O,e;G.
Date of Order:
Service Type M
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If \;hecked you are required to prp\lisle a (:opy of this form to your. employee. Ifyo\lr employe!) "Yorks in.a state that is
ditterent from the state that issued this order, a copy must be prOVided to your employee even If the box IS not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4." Reporting the PaydatelDate of Wid,holding. You I"tlst report the paydatefdate of ..ithholding ..I,elo sendilog the payment. TI,e
paydaletdate of ..ithholdilog is tl.,e date 010 ..hid, al"ou"t ..as ..itl ,I ,eld hOI" the elo,ployee's ..ages. You must comply with the law of the
state of the employee'slobligor's principal place of employment with respect to the time periods within which you must implement the
wittlllolding order and forward the support payments.
5. "Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support OrderlNotices due to Federal or State withholding limits, you must follow
the law of the state of employee'slobligor's principal place of employment. You must honor all OrdersINotices to the greatest extent
possible. (See #10 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8591000044
EMPLOYEE'S/OBLlGOR'S NAME: DETTER. CHAD P.
EMPLOYEE'S CASE IDENTIFIER: 8100101060 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
a. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govemsunle's
the obligor is employed in another State, in which case the law of the State in which he or she is employed govems.
9.. Antkliscrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
govems unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10." Withholding Limits: You may not withhold more than the lesser of: 1} the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee'slobligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly eamings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
"NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
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,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at !Zl.Zl.240-624a or
by internet wwv....childsupport.state.pa.us
Page 2 of 2
Form EN-02a
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DETTER, CHAD P.
PACSES Case Number 544104951 ) 3 (;/'79
Plaintiff Name 'I
SHANNON L. DETTER
Docket Attachment Amount
02::s035 CIVIL $ 968.00
ChHd(ren)'s Name(s):
DOB
tsli~~;;~:,~~~~;~~~;=i~~~;~ili~~~~;I~;;~)i
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
.. . . .. .....
dl~~~~~::;~~:~~~~i~:~~~~~;li~;~~;I~i;~~ii
identified above in any health insurance coverage available
through the employee's1obligor's employment.
Service Type M
OMB No.: 0970..0154
PACSES Case l'lumber
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
...................................c...............,....................'.'....,..."...,......................., ....'..........................................'....,.'.....'.....,...
.......................... ....................,. .................... .... ...............
.. ....., . .............. ...... ...... ........ ...... ... .. .... ..... ........ .", .... .. .... .
;";';'::';';';:';':;,,;,;,;,;,,';';'":';'.':':;';';';';'''-:';';";';"'::';'::':',":-":':":':'.:"':::-:':'.".'':'::::':':-:'::':-:-:':'::':-:':':-:::":.-::.:.::.:.:-...:.:-:-:.:.:.,..:.:....
...... ........................................ ... ..........................
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the ernployee's1obligor's employment.
PACSES Case Number
Plaintiff Nam{~
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
..................:..........:........................................................:.:....... ....
::::":::::::':.::::::-::::::':-::::-:::::::::;::::::::::':.:::::::.:::::'::-::::::::::.:::::::::':":-:::::::::::.:: ::::.::::
................ ................,... ..................................... ......., ......
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
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5441 O~q~J
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT 50:3 0 {All.'
()~
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 12/27/02
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
RE: DETTER, CHAD P.
Employee/Obligor's Name (Last, First Mil
233-13-8820
Employee/Obligor's Social Security Number
8100101060
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, Mil
EmployerNVithholder's Federal EIN Number
NORTH AMERICAN VAN LINES
PAYROLL
165 LAMONT ST
NEW CUMBERLAND PA ~7070-2474
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 968.00 per month in current support
$ 82.00 per month in past-due support Arrears 12 weeks or greater? Oyes @ no
$ 0.00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1,050.00 per month to be forwarded to 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 match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 242.31 per weekly pay period.
$ 484.62 per biweekly pay period (every two weeks).
$ 525.00 per semimonthly pay period (twice a month).
$ 1.050.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% 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. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittal1ce,Payable to:,PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
INADDITlON, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: I d- I 3 Did )--
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Service Type M
OMB No.: 0970-0154
Form EN-028
Worker ID $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
D If \;.hecked you are required to provide a copy of this form to your employee. If YOl,Jr employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of th is order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each .agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4. * Reporting the Pal-date/Date of 'vVithholding. You must report ti,e paydateldate of vv ithholding vvhen sending the pay" lent. The
paydatefdate of vvithholding is the date on vvhieh amount vvas vvitl,held from ti,e employee's vvages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S 10: 8591000044
EMPLOYEE'S/OBLlGOR'S NAME: DETTER. CHAD P.
EMPLOYEE'S CASE IDENTIFIER: 8100101060 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the .obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. ~ 1673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER 51
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMS No.: 0970-0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DETTER, CHAD P.
PACSES Case Number 544104951
Plaintiff Name
SHANNON L. DETTER
Docket Attachment Amount
02:s035CIVIL$ 1,050.00
Child(ren)'s Name(s):
DaB
If you are required to enroll the child(ren)
above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s);
DaB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
Service Type M
OMS No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s I\lame(s):
DaB
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
GOB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
If checked, you are required to enroll the child(ren)
above in any health insurance coverage available
the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
-.
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,.
IE 3082
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 07/01/03
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
EmployerJWithholder's Federal EIN Number
RE: DETTER, CHAD P.
Employee/Obligor's Name (last, First, MI)
233-13-8820
Employee/Obligor's Social Security Number
8100101060
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name {Last, first, Mil
NORTH AMERICAN VAN LINES
PAYROLL
165 LAMONT ST
NEW CUMBERLAND PA 17070-2474
J# ~;l -5V35 ('fIl/t
Acus 0-'1'1;0'195-/
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 968.00 per month in current support
$ 0 . 00 per month in past-due support Arrears 1 2 weeks or greater? 0 yes <Xl no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 968.00 per month to be forwarded to 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 match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 223.38 per weekly pay period.
$ 446.77 per biweekly pay period (every two weeks).
$ 484.00 per semimonthly pay period (twice a month).
$ 968.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% 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. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (sCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
GilwMJ> 6 ,:;,
::;v!JIPe
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I( checked you are required. to provi(Je a Copy of this form to you, employee. If yo~r employee works in.a state that is
different from the state that Issued thiS order, a copy must be provided to your employee even If the box IS not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribaJly-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with th is notice.
2. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of th is order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4. * Repolt;',g tile raydale!Date of VVitlILold;ng. YOu "lust lepo,t tIle paydateldate of H;tl.l.oldillg vvl.eh selld;ng tLe payn,el,t. Tile
pciydatddate of Hitl,lrold;1t5 is tIle ddk 011 Hl.;dl an,Oul,t Has Hitl,I"..:!d flO!., tl.( t:II,ployee'.:l Hage5. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #10 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8591000044
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
DETTER, CHAD p,
8100101060
DATE OF SEPARATION:
7. lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.5.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
* NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
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,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 240-6248 or
by internet www.childsupport.state.pa.us
Service Type M
Page 2 of 2
Form EN-028
Worker ID $IATT
OMB No.: 0970.0154
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DETTER, CHAD P.
PACSEs Case Number 544104951
Plaintiff Name
SHANNON L. DETTER
Docket Attachment Amount
02=5035 CIVIL $ 968.00
Child(ren)'s Name(s):
PACSE5 Case Number
Plaintiff Name
DOS
Docket Attachment Amount
$ 0.00
Child(ren)', Name(s):
DOS
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSE5 Case Number
Plaintiff Name
PACSEs Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Chlld(ren)'s Name(s):
DOS
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSEs Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOS
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Service Type M
Addendum
Form E N-028
Worker ID $IATT
OM8 No.: 097()..()154
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SHANNON L. DETTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
CHAD P. DETTER,
NO. 02-5035 CIVIL TERM
Defendant
IN DIVORCE
AND NOW comes Samuel L. Andes, attorney-at-law, and petitions the court for
leave to withdraw as counsel of record for the Defendant in the above matter, based upon
the fOllowing:
1. Petitioner herein is Samuel L. Andes, an attorney admitted to practice law
before the Supreme Court of Pennsylvania and this court. Mr. Andes maintains his office
for the practice of law at 525 North 12th Street in Lemoyne, Cumberland County,
Pennsylvania.
2. The Respondents herein are the Plaintiff, Shannon L. Detter, who is represented
by Douglas G. Miller, Esquire, and the Defendant, Chad P. Detter, who resides at 140
Kennedy Lane in Etters, York County, Pennsylvania.
3. This action was commenced in December of 2002 and shortly thereafter
Petitioner entered his appearance as counsel of record for the Defendant.
4. Defendant, by his conduct, has made it impossible for Petitioner to properly and
adequately represent the Defendant in this matter. Specifically:
A. Defendant has repeatedly failed to heed or follow Petitioner's
advice as to how to resolve this matter; and
B. Defendant has failed to communicate with Petitioner and has
failed to respond to Petitioner's communications to Defendant.
Because of Defendant's conduct, Petitioner cannot properly proceed in this matter and
represent the interest of Defendant properly.
5. Plaintiff has listed this matter for proceedings bl~fore the Master and
Defendant's failure to Cooperate with Petitioner prevent the matter from proceeding
properly.
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT
"
WHEREFORE, Petitioner prays this court to grant him leave to withdraw as
Defendant's counsel in this matter and to stay all proceedings until such time as the
matters raised in this petition have been resolved.
s&~~
Attorney-at-Law
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 11'043
(717) 761-5361
/I
I verify that the statements made in this document are true and correct. I
understand that any false statements in this document are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: \, \\brc'mb.er 03'
(~rt~~
/I
CERrlFICA rE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon counsel for
the Plaintiff and the Defendant herein by regular mail, postage prepaid, addressed as
follows:
Douglas G. Miller, Esquire
60 West Pomfret Street
Carlisle, PA 17013
Chad P. Detter
140 Kennedy Lane
Etters, PA 17319
Date:
11 November 2003
~~."-kh A J'AJlj) )
Amy M.(8 rkins
Secretary for Samuel L. Andes
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II
SHANNON L. DETTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 02-5035 CIVIL TERM
CHAD P. DETTER,
Defendant
IN DIVORCE
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT
AND NOW comes Samuel L. Andes, attorney-at-law, and petitions the court for
leave to withdraw as counsel of record for the Defendant in the above matter, based upon
the following:
1. Petitioner herein is Samuel L. Andes, an attorney admitted to practice law
before the Supreme Court of Pennsylvania and this court. Mr. Andes maintains his office
for the practice of law at 525 North 12'h Street in Lemoyne, Cumberland County,
Pennsylvania.
2. The Respondents herein are the Plaintiff, Shannon L. Detter, who is represented
by Douglas G. Miller, Esquire, and the Defendant, Chad P. Detter, who resides at 140
Kennedy Lane in Etters, York County, Pennsylvania.
3. This action was commenced in December of 2002 and shortly thereafter
Petitioner entered his appearance as counsel of record for the Defendant.
4. Defendant, by his conduct, has made it impossible for Petitioner to properly and
adequately represent the Defendant in this matter. Specifically:
A. Defendant has repeatedly failed to heed or follow Petitioner's
advice as to how to resolve this matter; and
B. Defendant has failed to communicate with Petitioner and has
failed to respond to Petitioner's communications to Defendant.
Because of Defendant's conduct, Petitioner cannot properly proceed in this matter and
represent the interest of Defendant properly.
5. Plaintiff has listed this matter for proceedings before the Master and
Defendant's failure to cooperate with Petitioner prevent the matter from proceeding
properly.
II
WHEREFORE, Petitioner prays this court to grant him leave to withdraw as
Defendant's counsel in this matter and to stay all proceedings until such time as the
matters raised in this petition have been resolved.
&~~
Attorney-at-Law
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
I verify that the statements made in this document are true and correct. I
understand that any false statements in this document are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: \ \ "-b.te mb.er 03'
~~~
I L. An es
II
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon counsel for
the Plaintiff and the Defendant herein by regular mail, postage prepaid, addressed as
follows:
Douglas G. Miller, Esquire
60 West Pomfret Street
Carlisle, PA 17013
Chad P. Detter
140 Kennedy Lane
Etters, PA 17319
Date:
11 November 2003
Onur.~'JJVJ )
Amy M.(H rkins
Secretary for Samuel L. Andes
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SHANNON L. DETTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 02-5035 CIVIL TERM
CHAD P. DETTER,
Defendant
IN DIVORCE
, 200 .3 , upon
consideration of the attached Petition, a Rule is hereby issued upon the Plaintiff and her
counsel and the Defendant, Chad P. Detter, to show cause, if any they have, why
Samuel L. Andes should not be granted leave to withdraw as counsel for Defendant in this
matter.
Said Rule shall be returnable do
ORDER OF COURT
dayof~~
~
AND NOW this d I.
J.
Distribution:
Douglas G. Miller, Esquire (Attorney for Plaintiff)
60 West Pomfret Street, Carlisle, PA 17013
Chad P. Detter (Defendant)
140 Kennedy Lane, Etters, PA 17319
~ arw:&c;L. o/-b3
Samuel L. Andes, Esquire (Petitioner)
525 North 12th Street, Lemoyne, PA 17043
~~
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30f:J:.,...,. ..a rl.:;j
SHANNON L. DETTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the statements
will be admitted.
PLAINTIFF'S AFFIDA VIT UNDER SECTION 3301 (d)
OF THE DIVORCE CODE
I. The parties to this action separated on or about February 1, 2001 and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. of 4904 relating to
unsworn falsification to authorities.
Date: December 31 ,2003
_ /)7ja""~_ 17.'/7;1;;.
SHANNON L. DETTER
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
SHANNON L. DETTER,
Plaintiff
vs.
CIVIL ACTION - LAW
CHAD P. DETTER,
NO. 02-5035 CIVIL TERM
IN DIVORCE
MOTION TO MAKE RULE ABSOLUTE
AND NOW comes Samuel L. Andes, Attorney-at-Law, and moves this Court to make
absolute the Rule issued on his Petition for Leave to Withdraw as Counsel for Defendant,
based upon the following:
1. The movant filed his Petition for Leave to Withdraw as Counsel for Defendant on
20 November 2003.
2. This Court entered an Order, issuing a Rule returnable 20 days from service, on
26 November 2003.
3. Movant duly served a copy of his Petition and this Court's Rule on Douglas G.
Miller, Esquire, counsel for the Plaintiff, and the Defendant, Chad P. Detter, by depositing
copies of those documents in the U.S. Mail, postage prepaid, addressed to the addresses
listed on the Distribution set out in this Court's Rule. Those envelopes were not returned
and Movant believes they were received by Mr. Miller and Mr. Detter.
4. On 4 December 2003, Movant attempted to serve a copy of this Court's Rule
upon the Defendant, Chad P. Detter, by certified mail by mailing it in that form to the
Defendant at the address listed in the Distribution portion of this Court's Rule. The
"
certified mail was returned to Movant marked "unclaimed." Attached hereto and marked
as Exhibit A is the certified mail envelope and documents mailed to Defendant.
5. Neither Plaintiff through her counsel nor Defendant have made any response to
this Court's Rule or to Movant's Petition for Leave to Withdraw as Counsel for Defendant.
WHEREFORE, Movant moves this Court to make absolute its Rule of 26 November
2003 and to grant him leave to withdraw as counsel for the Defendant, Chad P. Detter, in
this matter.
Samuel L. Andes
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
I verify that the statements made in this document are true and correct. I understand
that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
DATE:
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CERTIFICATE OF SERVICE
13
I hereby certify that on Y January 2004, I served a copy of the foregoing document
i upon the Defendant and upon counsel for Plaintiff by U.S. Mail, postage prepaid, addressed
as follows:
Douglas G. Miller, Esquire
60 West Pomfret Street
Carlisle, PA 17013
Chad P. Detter
140 Kennedy Lane
Etters, PA 17319
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Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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Exhibit
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SAMUEL L. ANDES
ATTORNEY AT LAW
525 NORTH TWELFTH STREET
P. O. BOX 16B
LEMOYNE, PENNSYLVANIA 17043
4 December 2003
Douglas G. Miller, Esquire
60 West Pomfret Street
Carlisle, PA 17013
Chad P. Detter
140 Kennedy Lane
Etters, PA 17319
TE1.EPHONE
(717) 7el'~361
FAX
(717) 761-143~
(SENT BY REGULAR & CERTIFIED MAIL)
RE: Detter VS. Detter
No. 02-5035
Dear Mr. Detter & Mr. Miller:
Although I believe you have already received it, I enclose and serve upon you
the Rule issued by the court on my Petition for Leave to Withdraw as Mr. Detter's
attorney.
Sincerely,
a~ L ;'od..
amh / Enclosure
II
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Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
SHANNON L. DETTER,
Plaintiff
vs.
CIVIL ACTION - LAW
NO. 02-5035 CIVIL TERM
CHAD P. DETTER,
IN DIVORCE
ORDER OF COURT
AND NOW this ;,! /,. ~ day ofYl..Mx~ , 200 J , upon
consideration of the attached Petition, a Rule is hereby issued upon the Plaintiff and her
counsel and the Defendant, Chad P. Detter, to show cause, if any they have, why
Samuel L. Andes should not be granted leave to withdraw as counsel for Defendant in this
matter.
Said Rule shall be returnable.;L() days from service.
BY THE COURT,
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J.
Distribution:
Douglas G. Miller, Esquire (Attorney for Plaintiff)
60 West Pomfret Street, Carlisle, PA 17013
Chad P. Detter (Defendant)
140 Kennedy Lane, Etters, PA 17319
Samuel L. Andes, Esquire (Petitioner)
525 North 12th Street, Lemoyne, PA 17043
TRUE COPY FROM RECOnO
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SHANNON L. DETTER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO. 02-5035 CIVIL TERM
IN DIVORCE
ORDER
AND NOW this J,.J. day of -r" y ,2004, upon the
motion of Samuel L. Andes, it appearing that our Rule dated November 26, 2003, was duly
served and no response has been filed to oppose Mr. Andes' Petition for Leave to
Withdraw as Counsel for Defendant, that Rule is made absolute and Mr. Andes is hereby
granted leave to withdraw as counsel for Defendant, Chad P. Detter, in this matter.
Distribytion:
/Douglas G. Miller, Attorney for Plaintiff, 60 West Pomfret Street, Carlisle, PA 17013
..A;amuel L. Andes, Petitioner, 525 N. 12th Street Lemoyne, PA 17043
.;chad P. Detter, Defendant, 140 Kennedy Lane, Etters, PA 17319
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SHANNON L. DETTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO.2002-5035 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AMENDED COMPLAINT
IN DIVORCE PURSUANT TO SECTIONS 330Hc)
and 330Hd) OF THE DIVORCE CODE
AND EOUlTABLE DISTRIBUTION
AND NOW comes the Plaintiff, Shannon L. Detter, by and through her attorneys, Irwin,
McKnight & Hughes, and files this Amended Complaint in divorce against the Defendant, Chad P.
Detter, averring as follows:
COUNT I - DIVORCE
1. - 9. The averments set forth in paragraphs one (1) through nine (9) of Plaintiffs
Complaint are incorporated herein as if fully set forth.
COUNT II
ALIMONY. ALIMONY PENDENTE LITE AND COUNSEL FEES
1. - 4. The averments set forth in paragraphs one (1) through four (4) of Plaintiff s
Complaint are incorporated herein as if fully set forth.
COUNT III - EQUITABLE DISTRmUTION
1. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage.
2. Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiff respectfully requests the Court to enter an Order equitably
distributing the parties' marital property pursuant to Section 3502(d) of the Divorce Code and for
such further relief as the Court may deem equitable and just.
Respectfully submitted,
IRWIN & McKNIGHT
By:
Douglas . iller, Esquire
Supreme Court LD. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff,
Shannon L. Detter
Date: January 30, 2004
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
elAh7nt~ ~<~
SHANNON L DEITER.
Date: 1-:30 -0'"
SHANNON L. DETTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by hand delivery and regular U.S.
mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Chad P. Detter
140 Kennedy Lane
Etters, PA 17319
Date: January 30, 2004
IRWIN & McKNIGHT
Douglas . Miller, Esquire
Supreme Court LD. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff,
Shannon L. Detter
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SHANNON L. DETTER.
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO. 02-5035 CIVIL TERM
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw my appearance for the Defendant, Chad P. Detter, in the above-
captioned matter, pursuant to this Court's Order of 22 January 2004.
~
Sam L. Andes
Supreme Court 10 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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Plaintiff,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
: 2002 . 5035 CIVIL TERM
CHAD P. DETTER,
Defendant.
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
:SS:
COUNTY OF CUMBERLAND
NOW, Douglas Miller, Esquire, being duly sworn according to law, does depose and state:
I. That he is a competent adult and attorney for the Plaintiff in the captioned action.
2. That the Notice of Intention to Request Entry of Divorce Decree, Plaintiffs
Affidavit, Counter-Affidavit as well as a copy of the Praecipe to Transmit and
Notice of Hearing scheduled for April 6, 2004, were served upon the defendant,
Chad P. Detter, on or about February 4, 2004. Pursuant to Rule 1930.4(c), these
documents were mailed to Chad P. Detter, at his address at 140 Kennedy Lane,
Etters, Pennsylvania 17319, via certified mail, return receipt requested and via
regular United States maiL
3. That a copy of the certified mail envelope showing that it was unclaimed by the
Defendant is attached hereto and made a part hereof.
4. That a copy of the Certificate of Mailing by regular mail dated February 4, 2004 is
also attached hereto and made a part hereof.
5. That more than fifteen (15) days have elapsed without the regular mail being
returned pursuant to Rule I 930.4( c)(1).
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
IRWIN & McKNIGHT
Date: 3. c;-o'1
B~'~_ ~A
Douglas Mill~r, Esquire
Supreme Court Id # 83776
60 West Pomfret Street
Carlisle, P A 17013
(717) 249-2353
Attorney for Plaintiff
Shannon Detter
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Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 17, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date:
L/ -(.. - D,-/
$ .4Y/t\-
SHANNON L. DETTER
Plaintiff
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION. LAW
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
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 of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
,
Date:
4-(;~oLj
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SHANNON L. ET ER
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO.2002-5035 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 17, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: _II" C~ 200 4-
&f~k~
CHAD FDETTER
Defendant
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: 1/p/ U fIf 2f:n I.[
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CHAD P. DETTER
Defendant
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 06/2B/04
Tribunal/Case Number (See Addendum for case summary)
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
RE: DETTER, CHAD P.
Employee/Obligor's Name (Last, First, MI)
233-13-8820
Employee/Obligor's Social Security Number
8100101060
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EmployerlWithholder's Federal EIN Number
NORTH AMERICAN VAN LINES
PAYROLL
165 LAMONT ST
NEW CUMBERLAND PA 17070-2474
'bJI ;)fJO)..I)6 3';- (' {/
fJl76fS 6-YVlo'19<::1
See Addendum for dependent names and birth dates associal'ed with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Qyes (jS) no
$ 0 . 00 per month in medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0.00 per month to be forwarded to 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 match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0 . 00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (sCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAMIE AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifil1ftP~L SfCURIT1( NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. '_~~-
7-(",'0'/ BY THE COLlRT: c-.. '2
Date of Order: JUL - 6 200~ ~.
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Form EN-028
Service Type M OM'No..O'7()"J1S4 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If (;hecked you are required to provide a copy of this form to your employee. if yo~r employee works in a state that is
ditterent from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. We appreciate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and Indian-owned
businesses located on a reservation that choose to withhold in accordance with this notice.
2. priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
3. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
4.' Repu,til '511 ,e Paydatc/D&. of Withl,old;"g. You I..u'( lepOlt II" P'rdatc::datt: of ~;t1,I,oldi..g ..I,e" It! ,d;"g II" pay..'., ,t. TI,e
f-'dydblddbl<:. vf nill.1.oldihg ;.sll.{, d~ VII nl.id, alllOdht nas uitl.I.!.ld (,0111 tile ell,plo:lee';, vvago. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
5.' Employee/Obligor with Multiple Support Holdings: if there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #1 0 below)
6. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 8591000044
EMPLOYEE'S/OBLlGOR's NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
DETTER, CHAD P.
8100101060
DATE OF SIEPARATION:
7. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
8. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor;s employed in another State, in which case the law of the State in which he or she is employed governs.
9. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsyivania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
10.' Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.5.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or youI' employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (1171 240-62411 or
by internet ~vww.childsupport.state.pa.us
Page 2 of 2
Form EN-028
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Sh"'1"'r,,, Qp+4-pr
Plaintiff
Vs
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IN DIVORCE
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Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one 6y marking ''x'']
~ prior to the entry of a Final Decree in Divorce,
or _ after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior sumame of E 6.,. 0 h" of , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P,S, 704.
Date: 7--n-oL/ A.//7~1/>"YJ o/J",777;:;-
Signature
AA/7/n.m/>?? f'kk~-/-
Signature of name being resumed
Notary Public
NOTARiAl SEAL
IICWfl. R. CNW<<:I. := Nll1c
IAlnoyne BollI. ClI.1IIlll ColJII.Y
Mr Cu....duk.n ExpiIS June 15, 2lXII
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In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: CHAD P. DETTER
Member ID Number: 8100101060
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Alttachment
Plaintiff Name
SHANNON L. EBERHART
PACSES
Case Number
544104951
Docket
Number
02-5035 CIVIL
Attachment Amount/FreQuencv
$
I
$
$
I
$
968.00 jMONTH
'l
/
/
%
'/
/
/
TOTAL A'ITACHMENT AMOUNT: $
968.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 223.38
per week, or 50 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
CHAD P. DETTER Social Security Number 233 -13 - 8 8 2 0 , Member
ID Number 8100101060 . BUCBA is ordered to remit the amount attac:hed to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attaehed by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673
(b)(2) and 23 Pa. C.S.A. ~ 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated DECEMBER 12, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to 1he Domestic Relations Section of this
Court.
BY THE COURT
~ LJLe:rJ4.124() b.
JUDGE
Date of Order:
,DEe 2 J 2(W\
Service Type M
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In the Court of Common Pleas of CUMBERLAND County, Pennsyl ania
DOMESTIC RELATIONS SECTION
SHANNON L. EBERHART ) Docket Number 02-5035 CIVIL
Plaintiff )
vs. ) PACSES Case Number 54410 951
CHAD P. DETTER )
Defendant ) Other State ID Number
PETITION FOR MODIFICATION
OF AN EXISTING. AP Iv. ORDER
1. The petition of
CHAD PAUL DETTER
resp
Ily
represents that on DECEMBER 2. 2002
1/I/I?1OttY ~de-t.:k !..Jc. foJ.
SHANNON LYNN EBERHART
, an Order of Court was~d crt
A true and correct copy of the order is attached to this petition.
Service Type M
Form M.50!
Work r ID 21205
EBERHART
V. DETTER
PACSES Case Number: '44104951
2. Petitioner is entitled to 0 increase 0 decrease . termination 0 reinstat~ ment
I
o other of this Order because of the following material and substantial chan e(s) in
I
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circumstance:
(Please complete this section by listing the reasons for your
~ +
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est. )
WHEREFORE, Petitioner requests that the Court modify the existing order ~ r ;4j?L .
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Attorney for Petitio er
I verify that the statements made in this complaint are true and correct. I u derstand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 490 relating to
unsworn falsification to authorities.
3-:),2~
Date
Page 2 of2
Form 0 -501
Worker D 21205
Service Type M
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PEN N STATE
~
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Office of the University Registrar
(814) 865-6357
rcgistrnr@psu_edu
www,psu.edu/regislrnr
The Pennsylvania Slale University
112 Shields Building
University Park, PA 16802-1292
TO:
Strictly Concrete
810 Marie Ave
Lewisberg PA 17339
DATE:
RE:
PSU IDlSSN:
1/20/2005
Shannon L Jetter
***-**-1055
We h.wp. received your request; hut ::trp lJn~ble to provide tht:!' ~ervice you reqtde-sted. Pleas.. p~ovide the
following information:
Student's signature is missing on the document
To research your request it is necessary for us to have the following informati n:
Complete Name (include all former names):
PSU IDISocial Security Number:
Date of Birth:
Dates of Attendance:
Major and lor Degree (if any):
Type of Program:
(Undergrad, Grad, Medical, Real Estate, Insurance, CEU's)
Campus Location:
Daytime Telephone Number:
Your request/fax is being returned for the following reason(s):
_ Official transcripts cannot be faxed
_ Incorrect credit card type (must be VISA or MasterCard)
Credit card account number error
-
__ Missing credit c"rd expiration date
Credit card was declined
-
__ Course Description requests must include payment
1-10 descriptions = $6.00
11-20 descriptions = $12.00
21+ descriptions = $18.00
Transcript and Enrollment Verification requests must include $6.00 per set paym nt
Penn State does not recognize a University class rank
Your request and payment is being returned for the following reason(s):
Incorrect amount submitted. Resubmit request with full payment of
Incorrect payee on check (checks should be made payable to Penn State)
Check was not signed
Amount on check has been altered
Payment exceeded the charge. A refundch"cI< for
$
w!!! be mailed t you in-S-a weeks.
XX Other: Courses were cancelled for above individual, therefore we have no en ollment
_.
status.
Please return requested information to: Verification Department
112 Shields Building
University Park, PA 16802-1271
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In the Court of Common Pleas of
CUMBERLAND
County Pennsylvania
DOME!'-TIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
F x: (717) 240-6248
Defendant Name: CHAD P. DETTER
Member ID Number: 8100101060
Please note: All correspondence must include the Member ID Numbe
MODIFIED ORDER OF ATIACHMENT OF UNEMPLOYME
BENEFITS
Plaintiff Name
SHANNON L. EBERHART
Financial Break Down of Multiple Cases on Attachment
P ACSES Docket
Case Number Number
544104951 02-5035 CIVIL
Attac ment AmountJFre uene
$
I
$
$
~
$
,050.00 /MONTH
;
/
/
;
!
/
/
TOTAL ATIACHMENT AMOUNT: $
,050.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of nemployment
Compensation Beneftts and Allowances (BUCBA), is hereby directed to attach the lesser f $ 242.31
per week, or 50 . 0 %, of the Unemployment Compensation benefits otherwise payable 0 the Defendant,
CHAD P. DETTER Social Security Number 2 3 -13 - 8820 , Member
ID Number 8100101060 . BUCBA is ordered to remit the amount attached to the De artment of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by anothe Court or Courts for
support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount
attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S C. ~ 1673(b)(2) and 23
Pa. C.S. ~ 4348(g).
This Order shall be effective upon receipt of the notice of the Order by the BUC A and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefns, under t e Application for
Benefits dated DECEMBER 12, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subseq ent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Re ations Section of this
Court.
BY THE COURT
Date of Order:
/..7? - i) 2005,
JUDGE
Service Type M
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SHANNON L. EBERHART,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF'
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CtVIL ACTION - DIVORCE
CHAD P. DETTER,
Defendant/Respondent
NO. 2002-5035 CIVIL TERM
IN DIVORCE
PACSES # 544104951
ORDER OF COURT
AND NOW. this II ," day of April, 2005. a petition has been filed against you. Shillmon L.
Eberhart, to terminate an existing Alimony Pendente Lite Order. You are ordered to appear in person at the
Domestic Relations Section, 13 North Hanover Street. Carlisle. Pennsylvania. on Mav ]0, 2005 at 9:00
A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this
Order, an Order of Court may be entered against you.
Yau are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, 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 the 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 Of bring the required documents. the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Copies mailed
4-11-05 to:<
Petitioner
Respondent
Douglas Miller, Esquire
Samuel Andes, Esquire
t I fJL~ZL
R.. J. Sha ay, Conference Officer . ... - U
Date of Order: Avril II. 2005
YOU HAVE THE RIGHT TO A LAWYER, WHO MA Y 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 ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: CHAD P. DETTER
Member ID Number: 8100101060
Please note: AU correspondence must include the Member ID Number.
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases OP Attachment
Plaintiff Name
SHANNON L. EBERHART
PACSES
Case Number
544104951
Docket
~
02-5035 CIVIL
Attachment Amount/Freauency
$
!
$
$
!
$
203.00 I MONTH
;
/
/
;
/
/
I
TOTAL ATTACHMENT AMOUNT: $
203.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 46.85
per week, or 50.0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
CHAD P. DETTER Social Security Number 233 -13 - 8 820 , Member
10 Number 8100101060 . BUCBA is ordered to remit the amount attached to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount
attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673(b)(2) and 23
Pa. C.S. ~ 4348(g).
This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
llenefits dated DECEMBER 12, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges oc obligations to this Order shall be directed to the Domestic Relations Section of this
Court .
BY THE COURT
Date of Order:
MAY 1 0 20DS-
JUDGE
Service Type M
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Worker ID $IATT
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SHANNON L. EBERHART,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
CHAD P. DETTER,
Defendant/Respondent
NO. 2002-5035 CIVIL TERM
IN DIVORCE
PACSES# 544104951
ORDER OF COURT
AND NOW, this 10th day of May. 2005, based upon the Court's determination that Petitioner's
monthly net income/earning capacity is $1,093.90 and Respondent's monthly net income/earning
capacity is $1,998.40, it is hereby Ordered that the Respondent pay to the Pennsylvania State
Collection and Disbursement Unit. $203.00 per month payable bi-weekly as follows; $93.69 tor
alimony pendente lite and $0.00 on arrears. First payment due next unemployment compensation
benefit payment. Credit set at $925.46 as of May ] 0,2005. The eftective date of the order is Aprit2,
2005.
This order is based upon the fact that the defendant has an obligation tor the support of a child.
The retroactive credit can be used in the marital distribution settlement.
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 as provided by 23 Pa.C.S.s 3703. Further, if the Court
finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order, including,
but not limited to, commitment of the Respondent to prison tor a period not to exceed six months.
Said money to be turned over by the P A SCDU to: Shannon Eberhart. Payments must be made by
check or money order. All checks and money orders must be made payable to P A SCDU and mailed
to:
P A SCDU
P.O. Box 69110
Harrisburg, PA 17106-91]0
Payments must include the defendant's PACSES Member Number or Social Security Number in
order to be processed. Do not send cash by mail.
.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid as follows: 0% by
Respondent and 100% by Petitioner. The Petitioner is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Neither party to provide medical insurance coverage.
This Order shall become final ten days after the mailing of the notice of the entry of the Order to the
parties unless either party files a written demand with the Prothonotary for a hearing de novo before
the Couli.
DRO: R. J. Shadday
Mailed copies on
5.]2.05: <
BY THE COURT,
Petitioner
Respondent
Douglas Miller, Esquire
Thomas Clark. Esquire
Edward E. Guido
J.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Ppnnsvlvania
Co.lCity/Disl. of CUMBERLAND
Date of Order/Notice 05/31/05
Case Number (See Addendum for case Summary)
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
EmpJoyerM!ithholder's Federal EIN Number
RE: DETTER, CHAD P.
CHAD PAUL DETTER
PO BOX 233
LEWISBERRY PA 17339-0233
Employee/Obligor's Name (last, First, MI)
233-13-8820
EmploYee/Obligor'S Social Security Number
8100101060
Employee/Obligor'S Case Identifier
(See Addendum for plaintiH names
associated with cases on attachment)
Custodial Parent's Name (last, First, MI)
.1:#, ~ik'J, -50.3s-(!.y
;:J1}~g Sl/l/ I ()'19S I
See Addendum for dependent names and birth dates associated with Cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, yOU are required to deduct these
amounts from the above-named employee's!obligor'S income until further notice even if the Order/Notice is not
issued by your State.
$ 203.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? ayes @ no
$ 0.00 per month in current and past-due medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 203 . 00 per month to be forwarded to 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 match
the ordered support payment cycle, use the fOllowing to determine how much to withhold:
$ 46.85 per weekly pay period.
$ 93.69 per biweekly pay period (every two weeks).
$ 101.50 per semimonthly pay period (twice a month).
$ 203.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and YOur fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 On page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SeDU) Employer
Customer Service at 1-B77-676-95BO for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
'I.7C.;1.,&l- '1''' 'Ill:~ THE COURT:
~--~i!%J~1I
Date of Order: JUN - 1 JOIl5 ~ t4 -I-Cb'
l-L)u;; ~D
Service Type M
OMB No.: 0970..0154
Form EN-02B
Worker 10 $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o ,,~oc,~ ,~ ~ "'"." " 0"'.' · '"'" '" ." ,~ "'~"' ~o''''~. "",,"mo""""~",', 0 ,"".. ,
different from the state that iSsued this order, a copy must be provided to your employee eVen if the box is not checked.
,. """" w'.'o.", ,"'" ." 0"'"","" ,. 0",'" -, '"' ","" "", "~~ ,",,, ,""... ...""., "m, ,,_,
'-"m' '" ''''" " ,"'" """" ~'. 0'.', """ ~~ ,".". ".,... '-" '" ..." " '""" 0.... '00",," ""~.,,
agency listed below.
L '..."., ~-~ '00., -b;'''~h.. 'm~~,~ m"" <h," 0% ,mo''''''''''''""" ,,_ ,,' ,''''', _,,,,,
."" -. """", w~h.",,,. '00 m", h_" .~.., ","h"., oo.~ 0'" """ _,,,..,, .~",_" "'"
employee/obligor.
3. *
. You must comply with the law of the
''''' "'.. .."""""''''''''~" ."d~, ""'" '" ~"'-' w~ ~_".. "m, "'roo, w~" "''' "" m" 'mo'm~,.,
Withholding order and forward the support payments.
'" ....,-,~, .,. -. "'- '""'... "..." mo. """ 0% 0__" w~""" '~m. '. '",00' ...',,,
." 'mo'''''''''''''~, ,", ,"0 '. """'." hoo.." ._ om''''.'re, '"''' ,_" ''''' w~h"'"" "mID, "" m" ""~
., ,~"., ''''''' ~"''''~''''''''~'' ."d", """'" ~"''''_'' '00 m" hoo.., O"'"_re, "., .-.,....
Possible. (See #9 below)
,. '......... ."'"..." '00 m,,, o"mod, ,,,"" <h, ''''0"""""", "'''' .. ~_"""." h 00 '00," ~'"" '''"''
Please provide the information requested and retum a COpy of this Order/Notice to the Agency identified below.
THE EMPlOYEf/OBlIGOR NO lONGER WORKS FOR: 2331388200
EMPlOYEf'S/OBlIGOR'S NAME: DETTER. CflAD p.
EMPLOYEE'S CASE IDENTIFIER:::: 8100101060
lAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
DATE OF SEPARATION:
" '"'"... '..- ,~~, '" "'.,."" - ,"' ..."". "'m 'omo.m '"-~ "". ""'''oc, -m'",oo,,",
severance pay. If you have any questions about lump SUm payments, contact the person or authority below.
, ,"".'" """ '" "' w~""" '~m'" <h, O"""'.'re "'_, "" .. ,,"',. b;,"", ., ""'om".., -~"'o ,""," '_
".h,. ,~ <h, ~".'""""""" ,,,~, '"' - "'"'.... ,,' '" "","'",'"" ,"".... ''""~'"'"' ,". ,'w _, ""'"
the obligor is emplOYed in another State. in Which case the law of the State in which he or she is employed governs.
.. "'..""......." '00 '. .';.., ,", 0", '-'", 00'" ''''' ,.. ",,",,"''''"'' '" 'm",_,,~,,~ ~,."",~
..,,"' '" .m'...., "''''''' "'>d,,,00" ""00 .".,,, 0" ~o'_"~, ..,~. 0" '"'"" w'."".",. ''"",'Mo;,,," "w
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is emplOYed govems.
,. " W........, ,"'.. '00 m" '''~h.," _ "', ., '_0' ".. -OM ....., " ."",., ",",0_'"""
"""""00 ~ '" "5.< "." .", "''' .. ''''0'" ...., '" """" 0'" ~"'_""""~" o;,,'~, ,"'" 0' ~"'_'
''''' ''*c,' "m" '0",'" '"., -~. "-... "'''' ~m',., ''''wn "'''' " ., '" ,,,_.. ,.., m~',. m."""",
'~"'oo, w" ., 'Mo, '-"", ..., "''' 'oc,., ,~". "'., ,", Moo",. "'oc ,,' ""'" """, ",0 m., 00' w,."". "'.
""' .. -0", '''- ""'" <h, "w "'., "'"'''.'' '''W,", ~o'''''' ..., _,,, . .." 0",,,, "" m" '''~h'', "'.
than the amounts aI/owed under the law of the state that iSsued the order.
10. Additional Info:
~
"NO", "'00", "'"' ""'". .- ... 0 """ '" "', _, " ",""'''''" '''.'''"eooi", "" ore .. 'o"~ ..
law of the state that iSSued this order with respect to these items.
11. Submitted By:
EOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
~
If you Or YOur employee/obligor have any questions,
Contact WAGE ATTACHMENT UNIT
by telephone at {717) 240-6225 or
by FAX at !7171 74()..6248 or
by internet www.childsuPport.state.pa.us
Service Type M
Page 2 of 2
OMS No.: 0970-0154
Form EN-028
Worker 10 $IATT
."~, ,.-. .~, (,..., i....~ ~.:? t:-l
PACSES Case Number 544104951
Plaintiff Name _
Siu.NNON L: EBERIU\RT
Qoclw !Lttachment AmoY!J!
02-5035 CIVIL$ 203.00
Chi/d(ren)'s Name(s):
IiDDfNDUM
~ummarv of Cases on Attachme.!!!
Defendant/Obligor: DETTER, CHAD p.
PACSE5 Case Number
E1aintiff Na~ -
DOB
Qockfi
Attachment Amount
$- 0.00-
Chi/d(ren)'s Name(s):
DOB
o If checked. You are required to enroll the chi/d(ren)
identified above in any health insurance COverage available
through the emp/oyees/ob/igor's employment.
DOB
PACSES Case Number
E1aintiff Na~ -
" "" ......... """"-""-"'"
:-co,.:,::.":":"""._.:"",__.,,:,:,__,__,:,,,,.:.,':"""';';';""',"';':""""',"";-""':-""-""-"""-""':"";";,,::,
.
o If checked. You are required to enroll the child(ren)
identified above in any health insurance COverage available
through the emp/oyee's/obligor's emploYment.
Doclw
DOB
PACSES Case Number
fl.aintiff Naill!! -
Qockfi Attachment Amount
$ 0.00-
Child(ren)'s Name(s);
Attachment Amount
$ 0.00-
Child(renYs Name(s):
o If checked, You are required to enroll the child(ren)
identified above in any health insurance COverage avai/able
through the employee's/ob/igor's employment.
'ACSES Case Number
~.intiff Na'!J..g -
o If checked. You are required to enroll the child(ren)
identified above in any health insurance Coverage availab/e
through the employee's/obligor's employment.
Qoclw
DOB
PACSES Case Number
f!aintiff Na'!]g -
Doclw d1tachment AmoUnt
$ 0.00-
Child(ren)'s Name(s):
Attachment Amount
$ 0.00-
:hild(ren)'s Name(s);
DOB
checked. you are required to enroll the chi/d(ren)
'ied above in any health insurance COverage available
h the employees/Ob/igor's employment.
Addendum
o If checked. you are required to enroll the child(ren)
identified above in any health insurance COverage available
thrOugh the emp/oyee's/obligor's emploYment.
Type M
OMBNo.;0970..0J54
Form EN-028
Worker 10 $IATT
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MARRIAGE SETTLEMENT AGREEMENT
.,4
THIS AGREEMENT made this ~ day of December, 2005, by and between
SHANNON L. DETTER, kin/a SHANNON L. EBERHART, (hereinafter referred to as
"WIFE") and CHAD P. DETTER, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on February 14, 1998, and
separated on or about February 1, 2001; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their
rcspective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against thc other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. 11 is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
-'
2.
The parties have attempted to divide their matrimonial property In a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carryon and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(I) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND IS
represented by Thomas M. Clark, Esquire of The Wiley Group; WIFE IS
represented by Douglas G. Miller, Esquire of Irwin & McKnight;
2
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
asset" and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
[t is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to
the other of all of his or her property interests of any nature, including any mortgage, pledge,
lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each
3
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marrIage.
7.
REAL ESTATE: The parties acknowledge that the marital property located at 140
Kennedy Lane, Etters, York County, Pennsylvania, 17319 and any improvements thereon were
foreclosed upon by the mortgage lender. To the best of their knowledge, neither party is aware
of any outstanding obligation of the parties with regard to the foreclosure of the marital
residence.
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay spousal support, alimony, alimony pendente lite, or any other financial support to WIFE,
following the entry of the Divorce Decree in this matter, and that WIFE will not be required to
pay spousal support, alimony, alimony pendente lite, or any other financial support to
HUSBAND. HUSBAND, however, shall remain responsible for and shall continue to pay
alimony pendente lite in accordance with the Order of Court at Cumberland County Docket No.
S;::."'CW" .~ .,...~. _...4'11"....<<
2002 - 5035 and dated December 2,2002, until the .M.l.) ~f tlla Dh~MQ nQAfUU iR ll,:o .u"H~.,
ICft"lI.<r_T ...,.........,..
which responsibility shall include the payment of any and all arrears even in the event said
c:.O
)t
payments continue beyond the entry of the Divorce Decree. Other than the responsibility of
HUSBAND provided above, the parties thereby waive any rights they have to receive spousal
4
support, alimony or alimony pendente lite payments from the other following the entry of the
Divorce Decree in this matter. .,.-.... PAft........ TMc--V Wll'CVC II..,., "c,"""'" "nIC1
....,. "I'll Me..".. ~... _. {p*, .,.. ....... ~. ~
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest
which she may have in any personal property of the HUSBAND. HUSBAND likewise waives
any right, title and interest which he has in the personal property of WIFE. Henceforth, each of
the parties shall own, have and enjoy independently of any claim or right of the other party, all
items of personal property of every kind, nature and description and wherever situated, which are
then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power
to HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as if he or she were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the future, and within thirty (30) days of this
Agreement agrees to execute all documents necessary to transfer title of any jointly titled
vehicles that HUSBAND may have in his possession. HUSBAND shall hold WIFE harmless
for any and all liability associated with the use and purchase of any vehicle he may own, and
shall be solely responsible for all insurance and other financial responsibility associated with said
vehicle HUSBAND hereby waives all right, title and interest in any vehicle that WIFE
currently owns or may own in the future. HUSBAND hereby waives all right, title and interest
in any vehicle that WIFE currently owns or may own in the future, and within thirty (30) days of
this Agreement agrees to execute all documents necessary to transfer title of any jointly titled
vehicles that WIFE may have in her possession. WIFE shall hold HUSBAND harmless for any
5
and all liability associated with the use and purchase of any vehicle she may own, and shall be
solely responsible for all insurance and other financial responsibility associated with said
vehiclc.
II.
MARITAL DEBTS: It is further mutually agreed by and between the parties that WIFE
shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has not contracted or incurred any debt or liability for which
HUSBAND or his estate might be responsible and WIFE further represents and warrants to
HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify
and save HUSBAND harmless from any and all claims or demands made against him by reason
of debts or obligations incurred by her. In addition, WIFE will further agree to assume all
remaining liability for and pay and indemnify HUSBAND against the consolidation loan through
Mcmbers J" Federal Credit Union.
In exchange for WIFE'S assumption of the consolidation loan and the legal fees incurred
by WIFE in the prosecution of the divorce action, HUSBAND agrees to pay the principal sum
of~ <<awr _."",,~. 1M_1Uld no/lOO ($ 2.. .00.." ) Dollars, which shall be paid
.
in monthly installments of -r:Ho 1I..~.RtM.. --"~'lIand no/lOO ($ 200.-
) Dollars. The
the Di vorce Decree, and each consecutive payment shall be made every thirty (30) days until the
principal sLIm is paid. (PIt1"""'" .vcu. l.IC4r"" ~..._)' I. a_c.)
HUSBAND shall assume all liability for and pay and indemnify the WIFE against all
debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants
eta
Sf,
first payment by HUSBAND to WIFE shall commence thirty (30) days following the entry of
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
6
and warrants to WIFE that he will not contract or incur any debt or liability after the execution
of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
indemnify and save WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him. In addition, HUSBAND will further agree to
assume all liability for and pay and indemnify WIFE against any outstanding bill owed to Direct
TV, together with all accrued interest and late charges.
The parties further agree to assume all liability for and pay and indemnify the other party
for any credit cards and associated balances in their possession or used primarily by them, and
further agree that within thirty (30) days of this Agreement to remove the other parties' name
from any and all such joint credit card accounts.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
In particular, WIFE agrees to waive all right, title and interest in the 401 (k) Plan of
HUSBAND.
13.
BENEFITS. STOCK AND BANK ACCOUNTS: WIFE agrees to waive all right, title
and interest which she may have in the savings or checking or any other bank accounts of
HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
7
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall
be responsible for payment of legal fees and costs incurred by the other"in enforcing their rights
under this Agreement.
16.
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
Agreernent.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
8
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein. This Agreement specifically supercedes the prior negotiations of the
parties as evidenced by the proceedings before the Divorce Master of Cumberland County,
Pennsylvania on April 6, 2004.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PA YMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
9
.
.
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, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and 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.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
~ ~. (SEAL)
SHANNON L. DETTER, kin/a SHANNON L.
EBERHART
~~-"
CHAD P. DETTER
(SEAL)
10
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SHANNON L. DETTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION. LA W
CHAD P. DETTER,
Defendant
NO. 2002-5035 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
decree:
TrJllsmit the record, together with the following information, to the court for entry of a divorce
Code.
I. Ground for Divorce: irretrievable breakdown under Section 3301(c) and/or (d) of the Divorce
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was
served upon the defendant, Chad P. Detter by certified mail, restricted delivery, on or about October 22.
2002. The Affidavit of Service was filed with the Protbontoary on or about October 23,2003.
3. Complete either paragraph (3) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301 (CI of the
Dimrcc Code: by plaintiff: April 6, 2004 by defendant: April 6, 2004
Code:
(b)( I) Date of execution of the affidavit required by Section 3301 (d) of the Divorce
(b)(2) Date ofjj]jng and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of 1ntention to file Praecipe to Transmit
Record. J copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 330] (c) Divorce was Wed with the
Protbonotary: April 6, 2004
Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonutary: April 6, 2004
Date: December 19, 2005
Douglas G.
Attorney for
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SHANNON L. DETTER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 02 - 5035 CIVIL
CHAD P. DETTER,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
~'i4-
(d day of
/ ,
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2005, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated December 12, 2005, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
Geor(e
cc: ,ouglas G. Miller
'Attorney for Plaintiff
Thomas M. Clark
Attorney for Defendant
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this 12~"day of December, 2005, by and between
SHANNON L. DETTER, kin/a SHANNON L. EBERHART, (hereinafter referred to as
"WIFE") and CHAD P. DETTER, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on February 14, 1998, and
separated on or about February I, 200 I; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and final! y their
respective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
I.
The parties intend to maintain separate and permanent domiciles and to live apart from
cach other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property 1ll a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carryon and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(I) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND is
represented by Thomas M. Clark, Esquire of The Wiley Group; WIFE IS
represented by Douglas G. Miller, Esquire of Irwin & McKnight;
2
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 40 I (e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Propelty in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to
the other of all of his or her property interests of any nature, including any mortgage, pledge,
lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each
3
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marnage.
7.
REAL ESTATE: The parties acknowledge that the marital property located at 140
Kennedy Lane, Etters, York County, Pennsylvania, 17319 and any improvements thereon were
foreclosed upon by the mortgage lender. To the best of their knowledge, neither party is aware
of any outstanding obligation of the parties with regard to the foreclosure of the marital
residence.
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay spousal support, alimony, alimony pendente lite, or any other financial support to WIFE,
following the entry of the Divorce Decree in this matter, and that WIFE will not be required to
pay spousal support, alimony, alimony pendente lite, or any other financial support to
HUSBAND. HUSBAND, however, shall remain responsible for and shall continue to pay
alimony pendente lite in accordance with the Order of Court at Cumberland County Docket No.
s;:.""c..J" ._ ""'1:1 ~....C
2002 - 5035 and dated December 2, 2002, until the .tilt.} ~f IRa DiF~f~f nf~-10 in n.:., u._lt~.
~_,. A:6lU'r......,..
which responsibility shall include the payment of any and all arrears even in the event said
c.()
)t
payments continue beyond the entry of the Divorce Decree. Other than the responsibility of
HUSBAND provided above, the parties thereby waive any rights they have to receive spousal
4
support, alimony or alimony pendente lite payments from the olher following the entry of the
Di vorce Decree in this matter. -r-... f'Aft........ "l'Mc-av """"_. M.rI llC.","" "r1IC'f
IoWC 'TlI Mc..". ........- -. I ~... ...... -. ~
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest
which she may have in any personal property of the HUSBAND. HUSBAND likewise waives
any right, title and interest which he has in the personal property of WIFE. Henceforth, each of
the parties shall own, have and enjoy independently of any claim or right of the other party, all
items of personal property of every kind, nature and description and wherever situated, which are
then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power
to HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as if he or she were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the future, and within thirty (30) days of this
Agreement agrees to execute all documents necessary to transfer title of any jointly titled
vehicles that HUSBAND may have in his possession. HUSBAND shall hold WIFE harmless
for any and all liability associated with the use and purchase of any vehicle he may own, and
shall be solcly responsible for all insurance and other financial responsibility associated with said
vehicle. HUSBAND hereby waives all right, title and interest in any vehicle that WU'E
currently owns or may own in the future. HUSBAND hereby waives all right, title and interest
in any vehicle that WIFE currently owns or may own in the future, and within thirty (30) days of
this Agreement agrees to execute all documents necessary to transfer title of any jointly titled
vehicles that WIFE may have in her possession. WIFE shall hold HUSBAND harmless for any
5
and all liability associated with the use and purchase of any vehicle she may own, and shall be
solely responsible for all insurance and other financial responsibility associated with said
vehicle.
11.
MARITAL DEBTS: It is further mutually agreed by and between the parties that WIFE
shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has not contracted or incurred any debt or liability for which
HUSBAND or his estate might be responsible and WIFE further represents and warrants to
HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify
and save HUSBAND harmless from any and all claims or demands made against him by reason
of debts or obligations incurred by her. In addition, WIFE will further agree to assume all
remaining liability for and pay and indemnify HUSBAND against the consolidation loan through
Mcmbers lq Federal Credit Union.
In exchange for WIFE'S assumption of the consolidation loan and the legal fees incurred
by WIFE in the prosecution of the divorce action, HUSBAND agrees to pay the principal sum
of~ cwwr _.,.,.,.. 4lM~nd no/100 ($ a, "GO'''' ) Dollars, which shall be paid
in monthly installments of or:o.llwutHatMa... "lJIand no/100 ($ 2100'- ) Dollars. The
first payment by HUSBAND to WIFE shall commence thirty (30) days following the entry of
the DivorCe Decree, and each consecutive payment shall be made every thirty (30) days until the
principal sLIm is paid. Ittc,,,,,,.,,,. ~ 4<<'<&'Z""" "::nooI_)f I, aoe6)
HUSBAND shall assume all liability for and pay and indemnify the WIFE against all
debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
<::b
Sf,
6
and warrants to WIFE that he will not contract or incur any debt or liability after the execution
of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
indemnify and save WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him. In addition, HUSBAND will further agree to
assume all liability for and pay and indemnify WIFE against any outstanding bill owed to Direct
TV, together with all accrued interest and late charges.
The parties further agree to assume all liability for and pay and indemnify the other party
for any credit cards and associated balances in their possession or used primarily by them, and
further agree that within thirty (30) days of this Agreement to remove the other parties' name
from any and all such joint credit card accounts.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
In particular, WIFE agrees to waive all right, title and interest in the 401 (k) Plan of
HUSBAND.
13.
BENEFITS. STOCK AND BANK ACCOUNTS: WIFE agrees to waive all right, title
and interest which she may have in the savings or checking or any other bank accounts of
HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
7
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
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.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
8
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein. This Agreement specifically supercedes the prior negotiations of the
parties as evidenced by the proceedings before the Divorce Master of Cumberland County,
Pennsylvania on April 6, 2004.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PA YMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
9
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, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and 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.
IN WITNESS WHEREOF, the parties hereunto have s,~t their hands and seals the day
and year first above written.
WITNESSES:
/1~
",8. ~ (SEAL)
SHANNON L. DETTER, kin/a SHANNON L.
EBERHART
( (/<
)., ~ ""-
/ ~ .~
,
~~-"
CHAD P. DETTER
(SEAL)
10
~ ~~~++ + ++ ++ +++ + +++ +.+ ~ :+.:+. +++++++++++++++ +++ +++~
, '
~ IN THE COURT OF COMMON PLEAS .
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OFCUMBERLANDCOUNTY
STATE OF
PEN NA.
SHANNON L. DETTER,
No.
2002 501')
Plaintiff
VERSUS
CHAD P. DETTER,
Defendant
DECREE IN
DIVORCE
..:r t():t 04.... .
'jot!: " IT IS ORDERED AND
AND NOW,
~J(
DECREED THAT
SHANNON L. DETTER
, PLAI NTI FF,
AND
CHAD P. DETTER
, 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 Marriage Settlement A2reement dated December 12. 2005. arid si2lled bv
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++++ ++++++++++++++?
the parties is hereby
not merged.
ATIES(1 ~
< ~ ~PROTHONOTARY
Of.:+: :+.
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+:f +:+:+ '+:+; + ++
++++ :f.'f.++
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(,yp -& /1;('1"r11 c1~t-.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 02/16/06
Case Number (See Addendum for case summary)
544104951
02-5035 CIVIL
o Original Order/Notice
o Amended Order/Notice
@ Terminate Order/Notice
RE: DETTER, CHAD P.
EmpJoyerlVVithholder's Federal EIN Number
CHAD PAUL DETTER
PO BOX 233
LEWISBERRY PA 17339-0233
Employee/Obligor's Name (last, First, Ml)
233-13-8820
Employee/Obligor's Sodal Security Number
8100101060
Employee/Obligor's Case Identifier
(Su Addendum for plaintiff names
4ssociiJted with cases on attachment)
Custodial Parent's Name (Last, First, Mil
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 0.00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes QS) no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (spedfy)
for a total of $ 0.00 per month to be forwarded to 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 match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0 . Doper weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFr/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED,
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order:
.jr'.,if)
".V'...c
Edward E. Guido,
Judge
Form EN-028
Worker 10 $IATT
DRO: R. J. Shadday
Service Type M
OMBNo.:0970-0154
....
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~hecked you are required. to provi(le a ~opy of Ihis form to your. employee. If your employee works in.a slate that ieds
ditterent from the state that ISSUed thiS order, a copy must be provided to your employee even If the box IS not check .
1. Priority: Withhold ing under th is Order/Nolice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal lax levies in effect please contacl the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately idenlify Ihe portion of Ihe single payment thai is attributable to each
employee/obligor.
3.* RctJvlliI1511,e raydalefDate ufW';tl,l,vIJ;"g. YOu IlIu;,llei"'vll tile payJate/datc of yvitl,llvld;1I5 wyllell S€r,di,,511Ie jJdylllellL Tile
payddlcA1ah::: vf vv;ll,l,old;llg iSll,e da.tt: VII vvL;\.J. dlllUJllt vva5 vv;tlllll;:::ld flVll1 tLc: dllploy'Cc':) VV<15d. You must comply with the law of the
state of the employee's!obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you musl follow
the law of the state of employee's/obligor's principal place of employment. You musl honor all Orders/Nolices to the grealest extent
possible. (See #9 below)
5. Termination Notification: You musl prompily notify Ihe Requesting Agency when Ihe employee/obligor is no longer working for you.
Please provide the information requested and retum a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 2331388200
EMPLOYEE'SIOBLlGOR'S NAME: DETTER, CHAD P.
EMPLOYEE'S CASE IDENTIFIER: 8100101060 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as Ihe Order/Notice direcls, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania Stale law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Prolection Act (15 U.s.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregale disposable weekly earnings (ADWE). ADWE is the nel income left after making mandatory
deductions such as: State, Federal, local taxesi Social Security taxesi and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE; If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By:
DOMESTIC RELA nONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717\ 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-02B
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
...
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: DETTER, CHAD P.
PACSES Case Number 544104951
Plaintiff Name
SHANNON L. EBERHART
Docket Attachment Amounl
02-5035 CIVIL$ 0.00
Child(ren)'s Name(s):
DOB
If you are required 10 enrolllhe child(ren)
above in any health insurance coverage available
through Ihe employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Addendum
Service Type M
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachmenl Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachmenl Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Form EN-028
Worker ID $IATT
(',
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In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: CHAD P. DETTER
Member ID Number; 8100101060
Please Dote: All correspondence must include the Member ill Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
SHANNON L. EBERHART
PACSES
Case Number
544104951
Docket
Number
02-5035 CIVIL
Attachment Amount/Freauency
$
~
$
$
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$
203.00/MONTH
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TOTAL ATIACHMENT AMOUNT: $ 0.00
The prior Order of this Court directing the Department of Labor and Industry, Bureau of
Unemployment Compensation Benefits and Allowances (BUCBA), to attach $ 0.00
or 50 % per week of the Unemployment Compensation benefits of
CHAD P. DETTER
, Social Security Number 233-13-8820,
Member ID Number 8100101060 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order:
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Edward E. Guido,
JUDGE
DRO: R. J. Shadday
Service Type M
Form EN-035
Worker ID $IATT
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In the Court of Common Pleas of CUMBERLANlJ County, Pennsylvania
DOMESTIC RELATIONS SECTION
SHANNON L. EBERHART ) Docket Number 02-5035 CIVIL
Plaintiff )
vs. ) PACSES Case Number 544104951
CHAD P. DETTER )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
21ST DAY OF FEBRUARY, 2006
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
Ii! Terminated without prejudice or 0 Terminated and Vacated,
effective DECEMBER 21, 2005 , due to:
THE PARTIES' DECREE IN DIVORCE ON DECEMBER 21, 2005. THE ALIMONY PENDENTE
LITE ACCOUNT HAS A CREDIT/OVERPAYMENT OF $507.49.
Ed",
JUDGE
ORa: R.J. Shadday
Service Type M
Form OE-504
Worker ID 21005
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