HomeMy WebLinkAbout00-00142
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
BARRY H. SAMPSON,
Plaintiff
No.
2000
142
VERSUS
ANNETTE SAMPSON,
Defendant
AND NOW,
DECREE IN
DIVORCE
~JZ l L-
IT IS ORDERED AND
~'1
, ,
BARRY W. SAMPSON
DECREED THAT
, PLAINTIFF,
AND
ANNETTE SAi'1PSON
, 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;
NONE
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PROTHONOTARY
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BARRY W. SAMPSON
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLV ANlA
v,
CIVIL ACTION LAW
2000-142 CIVIL TERM
ANNETTE SAMPSON
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary of the Said Court:
Kindly transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for divorce: irretrievable breakdown under S 3301(c) of the Divorce
Code,
2. Date and manner ofservice ofthe complaint:
Certified Mail, Postage Pre-paid, Restricted Delivery, Return
Receipt Requested and by United States Mail First Class Postage
Prepaid to the Defendant's last known address [Route I Box 33,
Sanborn, North Dakota 58480], which Certified letter was
forwarded to Defendant's home address [603 Holiday Park
Village, Jamestown, North Dakota 58401], and which letter was
received and signed-for on January 10, 2000, Defendant did
personally receive said Complaint in Divorce as evidenced by
Defendant's signed Acceptance of Service dated February 14,
2000, and as further evidenced by Plaintiff's Counsel's Affidavit
of Service filed in this docket on March 8, 2000,
3, Date of execution of the affidavit of consent required by Section 330I(c) of the
Divorce Code: by plaintiff, Barry W, Sampson: November 28,2001; by
defendant, Annette Sampson: February 22, 2002,
4. Related claims pending: None
,
5, Date Plaintiff's Waiver of Notice was filed with the prothonotary:
November 28,2001.
Date Defendant's Waiver of Notice was filed with the prothonotary:
February 22, 2002,
Respectfully submitted,
LAw OFFICES OF RICHARD C. GAFFNEY
~4'1A
aura A Gargiulo, E=
P A Supreme Court ill No. 86128
2120 Market Street, Suite 101
Camp Hill, P A 17011
Telephone: 717. 975,9033
Attorney for Plaintiff,
Barry W, Sampson
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BARRY W. SAMPSo.N
PLAINTIFF
IN THE Co.URT OF Co.MMo.N PLEAS
o.F CUMBERLAND Co.UNTY,
PENNSYLVANIA
v.
ANNE'f'fE SAMPSON
DEFENDANT
No...;:{~r) - /l.{;). CIVIL TERM
-
IN DIVORCE
Co.MPLAINT IN DIVo.RCE
No.TICE TO., DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages~you must take prompt action, You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
court. A judgment may also be,entered against you for any other claim or relief requested in these
papers by the plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children,
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriag.e counseling. A list of marriage counselors is available in the o.ffice of
the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania,
IF YO.U DO. No.T FILE A CLAIM Fo.R ALIMo.NY, DIVISION o.F
PRo.PERTY, LAWYER'S FEES o.R EXPENSES BEFo.RE A DIVo.RCE
o.R-ANNULMENT IS. GRANTED, YO.U MAY Lo.SE. THE RIGHT TO.
CLAIM ANY o.F THEM.
YO.U SHo.ULD TAKE TIDS PAPER TO. yo.UR LAWYER AT o.NCE.
IF YO.U DO. No.T HAVE A LAWYER o.R CANNo.T AFFo.RD o.NE,
Go..To.OR TlU,RPHONR THE o.FFICE SET Fo.RTH BELOW TO.
FIND OUT WHERE YO.U CAN GET LEGAL HELP.
Cumberland County Bar Association
Lawyer Referral Service
2 Liberty Avenue, Carlisle, PA 17013
Telephone 717-249-3166
BARRY W. SAMPSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
v.
NO. .2071/- /'/.:1.. CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff is Barry W, Sampson, who presently resides at 247 South Spring Garden
St., Box 212, Carlisle, PA 17013 since January 1992.
2. The Defendant is Annette Sampson, whose last known address is Route I, Box 33,
Sanborn, North Dakota 58480, since on or about February, 1999.
3. The Plaintiff has been a bona fide resident of the Commonwealth for at least six
months immediately previous to the filing of this Complaint,
4. The Plaintiff and Defendant were married September 21,1991, in Eugene, Lane
County, Oregon.
5. The parties to this action separated on October 27, 1998, and have continued to live
separate and apart since then.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling.
, .
Countl
Divorce Under Section 330l(c) or Section 330l(d) ofthe Divorce Code
9, The Plaintiff restates as if fully rewritten the averments contained in paragraphs one
through eight hereinabove.
10. The Plaintiff requests the court to enter a decree of divorce under Section 3301(c) of
the Divorce Code.
11. In the alternative, the Plaintiff requests the court to enter a decree of divorce action
under Section 3301(d) of the Divorce Code.
Count 2
Divorce Under Section 330l(a) ofthe Divorce Code
12, The Plaintiff restates as if fully rewritten the averments contained in paragraphs one
through eight hereinabove.
13, The Defendant committed willful and malicious desertion and absence from the
habitation of the injured and innocent spouse, without reasonable cause.
14. The Defendant committed adultery.
15. The Defendant offered such indignities to the innocent and injured spouse as to
render that spouse's condition intolerable and life burdensome.
16. The Plaintiff is the innocent and injured spouse.
17. Wherefore, the Plaintiff prays this Honorable Court to enter a decree of Divorce
under Section 3301(a)(I) of the Divorce Code or, in the alternative under Section 3301(a)(2) of
the Divorce Code or, in the alternative under Section 3301(a)(6) of the Divorce Code.
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WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce
pursuant to 23 P.S. Section 3301(c) or, in the alternative pursuant to 23 P.S. Section 3301 (d) or,
in the alternative pursuant to 23 P.S, Section 3301 (a).
Respectfully submitted,
<\)&
Richard C. Gaffney, Esquire
Supreme Court LD, No. 63313
P. 0, Box 627
101 Front Street
Boiling Springs, P A 17007
Tel: (717) 249-2525
Attorney for Plaintiff
.
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BARRY W. SAMPSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO.
CIVIL TERM
ANNETIE SAMPSON
DEFEND' ANT
IN DIVORCE
,
VERIFICATION
I verifY thatthe statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons, Stat. Ann, Section 4904,
relating to unsworn falsification to authorities.
Date: //- 2. - ''1
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BARRYW. SAMPSON,
Plaintiff
, IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
v,
, CIVIL ACTION - LAW
, IN DIVORCE
ANNETTE SAMJ>SON,
Defendant
: NO. 2000-142
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER S3301( c) AND S3301( d)
OF THE DIVORCE CODE
1, I consent to the entry of a final decree of divorce without notice,
2, I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted,
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C.S, ~4904 relating to unsworn
falsification to authorities.
Date~~.'~ is
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Annette Sampson, Defendant
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BARRY W. SAMPSON,
Plaintiff
, IN THE COURT OF COMMON PLEAS OF
, CUMBERLAND COUNTY, PENNSYLVANIA
v.
; CIVIL ACTION - LAW
, IN DIVORCE
ANNETTE SAMPSON,
Defendant
,NO, 2000-142
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~3301(c) of the Divorce Code was filed on January 7, 2000,
2, The maniage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of notice of intention to
request entry of the decree,
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C.S, ~4904 relating to unsworn
falsification to authorities,
Dat~ 16 ~
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Annette Sampson, Defendant
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BARRY W. SAMPSON
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
ANNETTE SAMPSON
Defendant
NO. _2000-142_ CIVIL TERM
IN DIVORCE
WAIVER OF NOTre]]; OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
I, I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with
the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
S 4904 relating to unsworn falsification to authorities.
Date: /1- ")?--.?/
&a~wJd'~l--
arry W,,'Sampson "
Plaintiff
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BARRY W. SAMPSoN
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
ANNETTE SAMPSON
Defendant
NO. _2000-142_ CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFlDA VIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed on January 7, 2000.
2, The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service' of notice of
intention to request entry ofthe decree.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.s.
Section 4904 relating to unsworn falsification to authorities.
Date: //-).;-0/
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BARRY W. SAMPSON
PLAINTIFF
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v.
ANNETTE SAMPSON
DEFENDANT
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
NO..20D6- 11.{::1. CIVIL TERM
.
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce.
(1llotY.S~~
tte Sampson
Defendant
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BARRY W. SAMPSON
PLAINTIFF
IN tHE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PJi;NNSYL VANIA
v.
NO. 2000-142 CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS
-COUNTY OF CUMBERLAND
Richard C. Gaffuey, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff in the above captioned divorce action; that on January I I, 2000, he mailed a
_true and correct copy of the Complaint in Divorce, duly endorsed with a Notice to Defend, to the
Defendant, by certified mail with restricted delivery, postage prepaid, return receipt requested
and evidenced by return receipt card No. Z 013 349443 to Defendant's last known address; that
on February 14,2000, Defendant did personally receive said Complaint in Divorce as evidenced
by the signed Acceptance of Service form attached hereto; and that the facts set forth in the
within Affidavit are true and correct to the best of his information and belief.
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chard C. Gaffuey G
Attorney for Plaintiff
Sworn to and subscribed before me
this 8 Day of ~OOO.
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Notarial Seal
Sue A. Gaffney. Notary Public
South Middleton Twp., CUmbe~and County
My Commlssicn Expires Oct 13.2003
Member, Pennsytvanla Associatlon of Notaries
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Z 013 344 443
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail See reverse
&ntto
Annette Sam Son
Street & Number
Route 1 Box 33
Post Offioo. State. & ZIP Cooa
Sanborn No.
S
Postage
Cerolled Fee
Dakota 5
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Special Delivery Fee
Restricted Delivery Fee
on
~ Return Receipt Showing to
Whom & Date DeJjYemd
'i5.. RetumReceipt~gtoWhom,
<( Date, &Addressee's Address
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.. SENDER:
~ -Complete items 1 and/or 2 for additional SOlVles8.
1D aComplete Items 3, 4a, and 4b.
= .Print your name and address on the reverse ollhis form 80 that we can return this
... card to you.
~ -Attach (his form to the front of the mailpiece, or an tha back if space does not
!! permit.
-Write-Return ROC8ipt Roquestoo- on the mallpiece below the article number.
.11la Retum Receipt will show to whom the article was deflV6rBd and Ihe date
delivered.
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I also wish to receive the
fanowlng services (for an
extra lee):
1, 0 Addressee's Address
2, r::r Restricted Delivery
Consult postmaster far fee.
48. Article Number
3. Article Addressed to:
Annette Samnson
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BARRY W, SAMPSON,
PlaintiWPetitioner
, IN THE COURT OF COMMON PLEAS OF
, CUMBERLAND COUNTY, PENNSYLVANIA
v,
, CIVIL ACTION - LAW
AJ'..'NETTE SAMPSON,
Defendant/Respondent
; NO. 00-142
; DIVORCE
ORDER
AND NOW, this day of ,2001, upon consideration of Plaintiffs
Petition for Bifurcation and Defendant's Answer to Plaintiff's Petition for Bifurcation, it is
ordered and directed the Plaintiffs Petition for Bifurcation is DENIED,
BY THE COURT,
J,
BARRY W. SAMPSON,
Plaintiff/Petitioner
, IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLV ANlA
v.
, CIVIL ACTION - LAW
ANNETTE SAMPSON,
DefendantlRespondent
: NO. 00-142
, DIVORCE
DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR BIFURCATION
Defendant, Annette Sampson, by and through her attorneys, The Family Law Clinic,
opposes Petitioner's Petition for Bifurcation as follows:
1. Admitted,
2, Admitted,
3. Admitted,
4, Admitted,
5. Denied, As stated in Plaintiff's Petition for Bifurcation, Defendant has raised claims
for alimony, equitable dis1ribution, and alimony pendente lite in this action, On April 26, 200 I,
this Court granted Defendant an Order for alimony pendente lite in the amount of $1200 per
month, Defendant's alimony claim has not been resolved. Defendant is unable to work due to
numerous medical problems, If this action is bifurcated, Defendant would be prejudiced by any
termination of her APL Order and would receive no payments from Plaintiff until the alimony
claim is resolved. Defendant would be further prejudiced by bifurcation because Plaintiff
currently controls all of the assets to be divided in this action, as well as the information about
them, If this court grants Plaintiffs Petition for Bifurcation, he may be less inclined to resolve
this action in an expeditious manner,
6, Admitted in part, Denied in part. It is admitted that the parties have been separated
and have lived separate and apart for at least two years. It is denied that they have been separated
since October 27, 1998, The parties have lived separate and apart since January of 1999,
7, The avermeut in paragraph 7 is a conclusion oflaw to which no responsive
pleading is required. To the extent that an answer is required, denied under the circumstances of
this case, For the reasons stated above, bifurcation would be unfair to the Defendant and would
prejudice her in defending this action,
WHEREFORE, DefendantJRespondent prays that this Court deny bifurcation of this
action,
Respectfully Submitted,
DateiliL 8,1-001
J1ctetLLfaa/JJvJ1
~Michelle L. Anders~
Certified Legal Intern
';;J- '-
~ E. Rains
Thomas M. Place
Teri L. Henning
Supervising Attorneys
1
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THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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BARRY W. SAMPSON,
Plaintiff/Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON
Defendant/Respondent
NO. 2000-142
DIVORCE
RULE TO SHOW CAUSE
AND NOW, this ':z5,.+'<l day of
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,2001, upon
consideration of Plaintiff's Petition for Bifurcation, a Rule is hereby granted upon Respondent to
show cause why the requested relief should not be granted.
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BARRY W. SAMPSON,
Plaintiff/Petitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON
DefendantlRespondent
: NO. 2000-142
: DIVORCE
PETITION FOR BIFURCATION
TO THE HONORABLE JUDGES OF THE SAID COURT:
Petitioner, Barry W. Sampson, by and through his attorney, Richard C, Gaffney, Esquire,
files this Petition for Bifurcation and respectfully represents in support thereof:
L Petitioner is the Plaintiff in this divorce action, and is residing at 247 South
Spring Garden Street, Box 212, Carlisle, Pennsylvania 17013.
2. Respondent is the Defendant in this divorce action, and is residing at 603 Holiday
Park Village, Jamestown, North Dakota 58401.
3. In the Complaint in Divorce, Petitioner averred that the marriage is irretrievably
broken and has filed an Affidavit of Consent pursuant to Section 3301(d) of the Divorce Code.
4. In the Counterclaim to the Complaint in Divorce, Respondent made ancillary
claims for economic relief. Thereafter, Respondent filed petitions for alimony, equitable
distribution of marital assets and debts, and alimony pendente lite.
5. The Petitioner has agreed that all ancillary claims are preserved by the pleadings
and no prejudice will occur if the divorce is granted prior to the adjudication of the Respondent's
ancillary claims.
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6. Petitioner and Respondent have been separated and have lived separate lives apart
from each other since October 27, 1998, a period of more than two years.
7. Pursuant to the Divorce Code, 23 Pa.C.S. S 3101, et seq., this court is empowered
to grant a divorce and to reserve jurisdiction over the remaining ancillary issues,
WHEREFORE, Petitioner prays that this Court (1) order bifurcation of this action; and
(2) Enter a Decree in Divorce pursuant to Section 3301(d) of the Divorce Code,
Respectfully submitted,
2120 Market Street, Suite 101
Camp Hill, Pennsylvania 17011
Telephone: 717-975-9033
Facsimile: 717-975-9034
Attorney for Petitioner
BARRY W. SAMPSON,
PlaintifflPetitioner
v.
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON
Defendant/Respondent
NO. 2000-142
DIVORCE
VERIFICATION
I verify that the statements made in the foregoing Petition for Bifurcation are true and
correct to the best of my knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa,C,S.A. S 4904 relating to unsworn falsification
to authorities.
Dated: J:n~'i ! 1 ti/i't'
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BARRY W, SAMPSON,
Plaintiff/Petitioner
, IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Respondent
: NO, 2000-142
, IN DIVORCE "
WIFE'S PRE-HEARING MEMORANDUM
IN OPPOSITION TO BIFURCATION
A hearing on the l'Sltition for Bifurcation of the plaintiff, Barry W. Sampson (hereinafter
"Husband"), is scheduled for July 27,2001 at 8:45 a,m. before the Honorable Edgar B. Bayley, In
anticipation of this hearing, Defendant, Annette Sampson (hereinafter "Wife"), presents the
following memorandum,
PROCEDURAL mSTORY
On January 7, 2000, Husband filed a Complaint in Divorce, citing as grounds: willful and
malicious desertion and absence from the habitation of Husband, adultery, indignities, and
irretrievable breakdown of the marriage, pursuant to 23 Pa. C.S. S3301 (a), (c), and (d).
On November 5,2000, Husband filed an Affidavit under S3301(d) of the Divorce Code, ,
stating that the parties had lived separate and apart for a period of at least two years and that the
marriage was irretrievably broken,
On December 21, 2000, the Family Law Clinic entered its appearance for Wife and filed
1
Wife's Counter-Affidavit under g330 I (d) of the Divorce Code indicating that she opposed the
entry of a divorce decree on the grounds that the parties had not lived separate and apart for at
least two years and that the marriage was not irretrievably broken, Also on December 21,2000,
Wife filed a Petition for Alimony and Equitable Distribution,
On March 15,2001, Wife filed a Petition for Alimony Pendente Lite, On ApIil 26,
2001, on the recommendation of the Domestic Relations Office, this Court issued an Order
requiring Husband to pay Wife $1200 per month in alimony pendente lite (APL), On May 14,
2001, Husband filed a Demand for Hearing on the issue of APL, and a hearing on that matter is
scheduled for August 27, 20DL
On May 21, 2001, Husband filed a Petition for Bifurcation, Wife filed an Answer
opposing Husband's Petition for Bifurcation onJune 8, 2001. On June 21,2001, this Court
issued an order scheduling a hearing on Husband's Petition for Bifurcation for July 27, 2001 at
8:45 a,m..
On May 21, 2001, Husband also filed a second Affidavit under g3301(d) of the Divorce
Code stating that the parties have lived separate and apart for a period of at least two years and
that the marriage is irretrievably brokeIL On July 10,2001, Wife filed another Counter-Affidavit
in response to Husband's second Affidavit under g330 l( d) of the Divorce Code, again indicating her
opposition to the entry of a divorce decree on the grounds that the marriage is not irretrievably
broken, Plaintiff Husband has not requested a hearing on the issue of irretrievable breakdown
2
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pursuant to 23 Pa C.S. g3301(d)(I)(ii), nor on any of his asserted fault grounds for divorce.
On June 20, 200 I, Wife filed her Inventory of Property, To date, Husband has not filed
an Inventory in violation ofPa, RC.P, 1920.33. On July 11,2001, not having received an Inventory
from Husband, Wife's counsel served Husband with Interrogatories and a Request for Production
of Documents, Husband's responses are due on or before August 10, 2001.
QUESTION PRESENTED
Whether Husband's Petition for Bifurcation should be granted where Husband is the
fmancially independent spouse and controls all the marital assets, along with the information and
documentation on the marital assets and liabilities; where he has failed to provide that information
in violation of the Rules of Civil Procedure; where Wife's alimony and equitable distribution claims
have not been resolved; and where grounds for divorce have not been established.
SUMMARY OF ARGUMENT
Bifurcation of this divorce action would prejudice Wife because Husband currently
controls all ofthe marital assets to be divided in a proceeding for equitable distribution,
Husband also controls all of the information and documentation regarding the marital property
3
and liabilities, and to date has failed to file an Inventory in violation ofPa, KC.P 1920.33. If
this action is bifurcated, Husband, who is the fmancially independent spouse, will be even less
motivated to provide the information to which Wife is entitled to allow the economic issues to
either be amiably and timely settled or be resolved at a hearing,
Since grounds for divorce have not been established and Wife denies irretrievable
breakdown, bifurcation would necessitate at least two hearings rather than one.
Moreover, any Order granting bifurcation without continuing Wife's APL Order of
$1200 per month would significantly prejudice Wife,
ARGUMENT
In 1983, the Superior Court of Pennsylvania, in Wolk v. Wolk, 318 Pa. Super 311, 464
A2d 1359 (1983), set forth the test to be used in determining whether a petition for bifurcation
should be granted, Under that test, the Court must carefillly examine the facts in each case and
determine whether the consequences of bifurcating the case will be of greater b~nefit than not
bifurcating, Wolle. 318 Pa, Super at 317, 318; 464 A2d at 1362, See also Minnelli v, Minnelli.
42 Cumb, 543 (1993), The Wolk Court noted that bifurcation may create several advantages,
such as the speedy resolution of a marriage determined to be over and the recommencement of
the parties' personal lives, Bifurcation may encourage case settlement and there may also be tax
4
advantages, 318 Pa, Super at 315,316,317; 464 A2d at 1360, 3161. However, bifurcation may
also result in numerous disadvantages, including the need for additional hearings if the case does
not settle, delay in the resolution of the economic claims, tax disadvantages',and any number of
problems created if one of the parties dies before the economic issues are resolved. Ifbifurcation
will not result in a "greater benefit," the Court must deny Husband's Petition to Bifurcate.
More recently, the Superior Court noted that the entry of a divorce may delay resolution
of any outstanding economic issues where the financially independent spouse who wants only
to be divorced has little or no motivation to settle these claims, Savage v, Savage. 736 A2d 633
(Pa, Super, 1999) at 645, 646. Such is the case here.
In the present case, the parties are engaged in settlement negotiations in an effort to
resolve the economic claims, but Husband controls all of the marital assets, as well as all
information relating to those assets and the parties' liabilities, Thus far, despite requests,
Husband has not provided Wife's counsel with the necessary information, to which she is
entitled, about the marital property and liabilities, Because Husband has failed to file an
Inventory in violation ofPa. RC.P. 1920.33, Wife's cOlUlsel served Husband with
IntClTogatories and a Request for Production of Documents on July 1 1,2001. Husband's
. responses are due on or before August 10, 200 L
A weighing of the advantages and disadvantages of bifurcation leads to one conclusion,
Husband's Petition for Bifurcation must be denied due to the significant detriment to Wife and
5
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no real benefit to Husband,
Since the date of separation (February 1999), Husband has exercised exclusive dominion
over the marital assets, as well as the information relating to them. Given Husband's control
over the marital property, it is likely that bifurcation of this case would result in even more delay
in resolving Wife's legitimate economic claims, Wife is unemployed, and Husband reported
$52,006 on his 2000 federal income tax return. The Savage Court quoted with approval Joanne
Ross Wilder's observation that:
[TJhere is little motivation to settle in the familiar fact pattern where the fmancially
independent spouse who controls virtually all of the marital assets and all of the
information about them wants only to be divorced.... The device of alimony
pendente lite in such situations can encourage settlements, but only in those unusual
cases where the monthly payment is so high that it acts as an incentive to the payor
to move the case to settlement in the hope that he will pay less in equitable
distribution than in alimony pendente lite, In most cases, the financially
iltdepeltdeltt spouse gailts the most by delayiltg judgment day as loltg as possible.
In sitch cases, it is the dependent spouse who is held hostage to economics.
(emphasis added),
Savage, 736 A.2d at 645,646, (quoting Joanne Ross Wilder, PA Family Law Prac. andProc, (4th
ed), 190),
Furthermore, bifurcation would not expedite the resolution of this divorce case given
that Wife has indicated (in two Counter-Affidavits under g330l(d)) that the marriage is not
irretrievably broken, and Husband has not sought ahearing on that issue or his asserted fault grounds
for divorce. Thus, grounds for divorce have not been established, necessitating a hearing on the
divorce itself if bifurcation is granted and Husband wishes entry of a divorce decree, In a similar
6
situation, the HOD. J. Wesley Oler denied bifurcation, reasoning that:
In view of the Defendqnt's counter.::affidavit indicating that she opposes the entry of
a divorce decree, it appears to the Court that a hearing will be necessary on the issue
of separation and irretrievable breakdown; for this reason, it appears further that a
bifurcation would not appreciably speed the resolution of this divorce case and would
result in the need to hold two hearings as opposed to one,
Minnelli. supra, 42 Cumbo at 544 (1993),
It is unclear what (if any) benefit to Husband would result from a bifurcation, Wife has
no reason to believe that Husband has plans to remarry at any time in the near or distant future,
thereby necessitating the entry of a divorce decree, nor did Husband indicate any such plans in
his Petition for Bifurcation, In addition, there are no indications that the parties' personal lives have
been "held hostage to economic demands." Wolk. 318 Pa Super at 315,464 A2d at 1361.
Finally, Wife notes that if this Court grants Husband's Petition for Bifurcation, it must
also continue Wife's APL Order in the amount of $1200 per month unless and until modified by
the Court atthe August 27, 2001 APL hearing, or there is a final resolution of the alimony and
equitable distribution claims, Pa, C.S, ~ 3323(c), See DeMasi v, DeMasi. 408 Pa, Super. 414
(1991), Horn v, Horn. 388Pa, Super, 46 (1989), Wolk v, Walk, 318Pa. Super311 (1983). Wifeis
the economically dependent spouse, and any termination of her APL prior to the resolution of the
economic claims related to this divorce action would significantly prejudice Wife.
In conclusion, given that the disadvantages of bifurcating this case outweigh any possible
advantages, and in the interest of fairness, Husband's Petition for Bifurcation must be denied,
7
However, if this case is bifurcated, Wife's APL, in the amount of$1200, must continue pending
further Order ofthe Court or full termination of this litigation,
Date: ~ .tIP!.?-Oo I
Respectfully submitted,
, jj;;;jJ.J1Je/? ~
L/MichelIe L. Anderson ~
~Intem
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THOMAS M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
Counsel for Annette Sampson
8
,
i.
BARRY W, SAMPSON,
Plaintiffi'Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Respondent
,NO, 2000-142
: DIVORCE
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of
Wife's Pre-Hearing Memorandum in Opposition to Bifurcation for Defendant, Annette Sampson,
on the following person, counsel for Plaintiff, by facsimile to 717-795-9034 and by depositing a
copy of the same in the United States mail, postage prepaid, this 26tl, day ofJuly, 2001:
Richard C. Gaffuey, Esquire
2120 Market Street
Suite 101
Camp Hill, PA 17011
~
J/?JJjjll :}pdlA.4IL-
ichelle L. Anders.
Certified Legal Intern
FAMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
...
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BARRY W, SAMPSON,
PJaintiffi'Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Petitioner
,NO, 2000-142
, DIVORCE
ORDER OF COURT
AND NOW, this 2] day of ~ ,2001, upon consideration of the
Petition to Allow Defendant to Testify by Telephone at the July 27, 2001 Bifurcation Hearing, it
is hereby ordered and decreed that Petitioner may testify by telephone at the July 27, 200 I
hearing on Plaintiffs Petition for Bifurcation,
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BARRY W, SAMPSON
Plaintiff /Respondent
: IN THE COURT OF COMMON PLEAS OF
, CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Petitioner
: NO, 2000-142
: DIVORCE
PETITION TO ALLOW DEFENDANT TO TESTIFY BY TELEPHONE
AT THE JULY 27.2001 BIFURCATION HEARING
The Petitioner, Annette Sampson, by her attorneys, the Family Law Clinic, hereby
petitions this Honorable Court to allow her to testify by telephone at the Hearing on Defendant's
Petition for Bifurcation, scheduled for July 27, 200 I, at 8:45 a.m.. In support of her petition,
Petitioner represents the following,
1. The Petitioner is Annette Sampson (hereinafter "Wife"), the defendant in the
above-captioned divorce action, She has resided in North Dakota since February 1999,
2. On May 21,2001, Respondent, Bany W. Sampson (hereinafter "Husband"), filed
a Petition for Bifurcation.
3, On JlUle 8, 2001, Wife filed an Answer in opposition to Husband's Petition
for Bifurcation, on the grolUlds that Wife would be prejudiced by bifurcation because
Husband currently controls all of the marital assets, as well as infonnation on them, and because
Wife would be prejudiced by any termination of her April 26, 2001 APL Order as a result of
bifurcation,
4, 011 June 21, 2001, this Court issued an order scheduling a hearing on Husband's
Petition for Bifurcation for July 27, 2001 at 8:45 a.ill..
5, Wife resides in North Dakota and has significant physical impairments. It
would be burdensome for Wife to personaIly attend hearings in Cwnberland County on both
July 27,2001 and August 27,2001.
6, Pursuant to PaRC.P. 1930.3, the Court may permit a party to testify by telephone
in domestic relations matters,
7, Husband, by his attorney, Richard C. Gaffney, Esquire, has informed the
Family Law Clinic that he does not oppose Wife testifying by telephone at the July 27, 2001
bifurcation hearing,
WHEREFORE, Petitioner prays that this Court allow her to testify by telephone at the
July 27, 2001 bifurcation hearing,
RespectfuIly Submitted,
Date, ~h~ to /2-00 {
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/;jlllL . (J)(iJ L!JIl
..JcheIle L. Ander
Certified Legal Intern
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TH~S M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
,).. ------
VERIFICATION
I verifY that the statements made in the Petition to Allow Defendant to TestifY
by Telephone at the July 27,2001 Bifurcation Hearing are true and correct I understand that
false statements herein are made subject to the penalties of 18 PaC.S, g4904 relating to unsworn
falsification to authorities,
Date:
Ci \C\ .""'-""01
. .
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Annette Sampson, Defen tlPetitioner
BARRYW, SAMPSON,
Plaintiff/Respondent
, IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
y,
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
DefendantJPetitioner
: NO, 2000-142
: DIVORCE
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and con-ect copy of
the Petition to Allow Defendant to Testify by Telephone at the July 27, 2001 Bifurcation Hearing
for Defendant, Annette Sampson, on the following person, counsel for Plaintiff, by
depositing a copy of the same in the United States mail, postage prepaid, this 20th day of
July, 2001:
Richard C, Gaffuey, Esquire
2120 Market Street
Suite 101
Camp Hill, PA 17011
cJ!d1!:t.if};tf4dJMI1-
Certified Legal Intem
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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BARRY W. SAMPSON
PLAINTIFF'
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 2000-142 CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
AFFIDAVIT OF SERVICE
C0MJ'v10NWEAL TH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Richard C. Gaffney, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff in the above captioned divorce action; thaton November 20,2000 he mailed
a true and correct copy of Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code and a
true and correct copy of Plaintiff's Affidavit of Non-Military Service, both of which were duly
filed with the prothonotary of the said court on November 14,2000, to the Defendant by certified
mail, postage prepaid, return receipt requested and evidenced by Return Receipt Card No. 7000
0600002138559323 to Defendant's home address; that on November 25,2000, Defendant did
personally receive said Affidavits as evidenced by the signed Return Receipt Card No. 7000_ 0600
002138559323 attached hereto; and that the facts set forth in the within Affidavit are true and
correct to the best of his information and belief
J?&~~S)~
Richard C. Gaffney, A, re
Attorney for Plaintiff ..'
Sworn to and subscribed before me
this a'2> Day of /'bJernJ.:y,r2bOO. .
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NOTARIAl SEAl.
SARAH G. PRUNOSKE, NolIIy NIle
CIlIll!lt B<:Jro, ClIIilIrlInd Ccmy, PA
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ID -Write"Return Rocs/pt RoqUSS/oo" on the maHplece below the 8J1lc1e number.
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48. ArtIcle Number
!,~. fL~nette Sampson
603 Holiday Par', Villages
Ja;r,estmm, lID 58401
7000 0600 0021 3855 037.3
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7. Date of Delivery
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BARRY W. SAMPSON
PLAINTIFF
:
IN THE COURT Q.F COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
:
v.
NO. 2000-142 CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
AFFIDAVIT OF NON-MILITARY SERVICE
I, the undersigned, certifY that neither ofthe parties in the above-captioned action
is in the miIitary or naval service or in any branch of the armed furces ofthe United
States of America or its allies or is otherwise within the provisions of the Soldiers' and
Sailors' Civil Relief Act of Congress of 1940 and its amendments.
Date: 11- ,<( - dTr
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BARRY W. SAMPSON
PLAINTIFF
:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
:
: NO. 2000-142 CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
:
IN DIVORCE
AFFIDAVIT OF NON-MILITARY SERVICE
I, the undersigned, certifY that neither of the parties in the above-captioned action
is in the military or naval service or in any branch ofthe armed forces ofthe United
States of America or its allies or is otherwise within the provisions of the Soldiers' and
Sailors' Civil Relief Act of Congress of 1940 and its amendments.
Date: 11- ,) - ot""'
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BARRY W. SAMPSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. Zoco - 142. CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
CERTIFICATE OF SERVICE
I certify that on this L day of J~ , 2000, I served a true and correct
copy of the Plaintiff's Complaint in Divorce on the p'ersons and in the manner set forth below,
which service of process satisfies the requirements ofPA.R.C.P. No. 1930-4:
By: Certified Mail, Restricted Delivery
Return Receipt Requested
And By: United States Mail
First Class Postage Prepaid
To: Annette Sampson
Route I, Box 33
Sanborn, N. D. 58480
Dated: .ILl -..,""'" 2.cco
.
~-&~ ,.bC\~~_
Richard . Gaffney, s ui e
PA. LD. No. 63313
P. O. Box 627
101 Front Street
Boiling Springs, PA 17007-0627
Telephone (717) 249-2525
Attorney for Plaintiff
. /
. ,
........---. ~
BARRY W. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-142
DIVORCE
ANNETTE SAMPSON,
Defendant
PRAECIPE TO ENTER APPEARANCE
To the Prothonotary:
Please enter the appearance of the Family Law Clinic on behalf of Annette Sampson,
the Defendant in the above captioned matter.
December 21, 2000
~
~~rN1>/ ,
THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
FAMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
717/243-3639
.".---' '
BARRYW. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-142
DIVORCE
ANNETTE SAMPSON,
Defendant
CERTIFICATE OF SERVICE
I, Julie Miller, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving
a true and correct copy of Praecipe to Enter Appearance on Richard C. Gaffney, Esquire, P.O.
Box 627,101 Front Street, Boiling Springs, PA 17007, by depositing a copy of the same in the
United States mail, First Class, postage prepaid, this 21st day of December, 2000.
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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BARRY W. SAMPSON,
Plaintifti'Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANTA
CIVIL ACTION - LAW
v.
ANNETTE SAMPSON,
DefendantIPetitioner
. NO. 2000-142
DIVORCE
DEFENDANT'S COUNTER AFFIDAVIT UNDER 633011d)
OF THE DIVORCE CODE
1. Check either <a) or (b):
( ) (a) I do not oppose the entry of a divorce decree.
(XX) (b) I oppose tbe entry of a divorce decree because (Check (I), (ii) or both):
(X) (i) The parties to.):his action have not lived separate and apart for a period of at least
two years.
~ (Ii) The marriage is not irretrievably broken.
2. Check either <a) or (b):
() <a) I do not wish to make any claims for economic relief 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. -
( XX) (b) I wish to claim economic relief which may include alimony, division of property,
or expenses or other important rights.
lawyer's fees
I understand that in addition to checking (b) above, I must also file all of my economic claims with the
prothonot81Y in writing and serve them on the other party. If I fall to do so before the date set forth on the Notice of
Intention to Request Divorce Decree. the divorce decree may be entered without further notice to me, and I shall be
unable thereafter to file any economic claims.
I verifY that the statements made in this counter-affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.e.S. ~4904 relating to unsworn falsification to
euthorities.
Date.l~\~\~ O\k.>>-~~~
Annette Sampson
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO
NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF. YOU SHOULD .l':illI FILE THIS
COUNTER-AFFIDAVIT.
~.
,- ,
BARRY W. SAMPSON,
PlJUntiIDR..pondep.!
IN TIlE COURT OF COMMON PLEAS Of
. Ct'MBERLA.'ID CO\J'NTY, PENNSYL V AN'.A
ClVlLACnON-1AW
~O 2000-142
DIVORCE
v.
ANNETTE SA;.fPSON,
Defend3atIPetitioner
11l'J'I\:-lDA!'1"TS COUNTER AFFIDA vcr l!l'o"DER i330Hdl
OF'fRE D.lVORCE C9DE
Checic either (a, Of (b).
i) (a} I do no; oppose tJl~ enr.ry ofa divorce decree.
rx,x) f~) 1 oppOte the emry Or& divorce decree beceuu (Check (i), (il) or both):
(X ) OJ The partie. to lbi. a<:t!on have f!Ol :iwd sepllrate ilIld ajlart fer a period of l\\ leas!
Xl (ii I The marriage i. not irretrievably broker..
two Yf)an.
2. . Cillo,k eIlher ,a) or (b)
( ) (a) I do not ''\'ii!h to ntake !Iil., ~laun; for economic' tdie! I underotaod IMI I may 10.. right,
concorning alL'71ony. divioion c.f propeny, lawyer's fees '" ~pe,.e. if I do ""I claiIll tlu;m before e
diyer", i. grant~.d.
( X)':) (b) 1 wish tv dah-n economic rtlief wmch may mcl~de alimony, division of propeny.
or expellBe1 or ofuer importalit rigltts.
lawyer! fee.
: cnd~rsta!id that in a1dition to checkir.g (b) above, I mU.t also file aU of II.'! economic cll!ims with the
l"mhOllC1af'j in writing .rod Iel''ie them on llie other party. if I fill to do 90 L'etbre the date Set ftlrtl: on the Notice of
lntennon tI.l Request Divor~ Decree. the divc..c~ ~ecree rnny !)e entered withOllI further noti.re :0 rr.e, lI!Id I wall be
uIUlbl< thereafter to me lIII\' economic claires.
I -;ent'.! that the sl,at.rr.er,m mooe in t.'!is cvull!cr-al!id~vil a.... true f.nd ccrr..ct. I undtfS'.m:1 1l1at fillse
!tatemen:s Oel'elr. are made subject :0 tile pemtl:ies of i~ Pi.C.S. fWa4 reh!ting to ucswcm taWn~1itiol1 tc
authorilie~
D.tej~, ;:)0 ' ~rx'":O _ () l,\lI\! kj) '~\I'\I.~
A."llJe!te Sampwn
~OnCE: IF YOU DO NOT WISH 1'0 OPPOSE THE ~TRY OF A DlYOlK'E DECREE A."'lD YOU DO
NOT WISH 'f0 MAl'iE .\1\"1 CL...1M fOR ECONOMIC nUEF. YOU SHOC1-D :l52I FILE THIS
COUNTER-AFFIDAVIT.
oA.Y
BARRYW. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-142
DIVORCE
ANNETTE SAMPSON,
Defendant
CERTIFICATE OF SERVICE
I, Julie Miller, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving
a true and correct copy of Defendant's Counter-Affidavit under 3301(d) of The Divorce Code on
Richard C. Gaffney, Esquire, P.O. Box 627, 101 Front Street, Boiling Springs, PA 17007, by
depositing a copy of the same in the United States mail, First Class, postage prepaid, this 21st day
of December, 2000.
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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BARRY W. SAMPSON,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-142
DIVORCE
v.
ANNETTE SAMPSON,
Defendant/Petitioner
PETITION FOR ALIMONY AND EOUITABLE DISTRIBUTION
AND NOW comes Annette Sampson, the defendant/petitioner in the above-captioned
divorce action, by and through her attorneys, the Family Law Clinic, and sets forth the
following petition for alimony and equitable distribution, pursuant to Pa.R.C.P. No.
1920. 15(b):
ALIMONY
I. On or about January 7, 2000, the respondent Barry W. Sampson filed a
complaint in divorce.
2. Petitioner and respondent were married in March 1991.
3. Petitioner is 47 years old and has significant medical problems, including
asthma and carpal tunnel syndrome, which interfere with her ability to work.
4. Petitioner is not gainfully employed.
5. Petitioner did not have a regular income during the parties' marriage. She
worked sporadically, and spent most of the marriage as a homemaker, in accordance with
plaintiff/respondent's wishes.
6. Petitioner does not have a college education or any other post-high school
training.
7. Respondent is employed and is financially able to provide for the reasonable
needs of the petitioner.
8. Petitioner requires reasonable support to adequately maintain herself in
accordance with the standard of living established during the marriage.
9. Respondent engaged in maritai misconduct during the marriage.
~
10. Petitioner lacks sufficient property to provide her reasonable needs and is
unable to support herself through full-time employment.
WHEREFORE, petitioner requests the court to enter an award of reasonable alimony,
and such other relief as the Court deems just.
EQUITABLE DISTRIBUTION
11. The parties have acquired marital assets and debts subject to equitable distribution
under the Divorce Code, including, but not limited to the following:
a) Plaintiff/respondent's pension, 401k accounts, retirement accounts, bank
accounts ;
b) Petitioner's medical bills;
c) Various items of personal property.
WHEREFORE, defendanUpetitioner requests that this court equitably divide the
marital property and debts between the parties and grant such other relief as the Court deems
just.
Respectfully submitted,
Date r l-- ( 2-- II () ()
(
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Robert E. Rains
Teri L. Henning
SUPERVISING ATTORNEYS
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax; (717) 243-3639
LISA .;c";u~ 12
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VERIFICATION
r \'enty rhil1 thtt srsfemerrl:s made in this Pt!titiOD for Alimony and Equitable Dist.:ib.trio:?: Aft: true and
corn~Ct to toe hest of my par30~l!ll knowledBII. intc-nnsti<.'i1 an,d bclief I Utlderstand:.hat false s(aterMnts herein eT"
made ~Ilblect t,:. tJe penalties af 18 Pa CS. ~904. reiE.ti~ t.:.' unsworn falsification h.... ~u:hc--oit:~s
Date la~.;;fO~~
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ANNETTE 8M !>i,
Defendal1t'Pdilk:n~r
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v
BARRYW. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-142
DIVORCE
ANNETTE SAMPSON,
Defendant
CERTIFICATE OF SERVI<;E
I, Julie Miller, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving
a true and correct copy of Petition for Alimony and Equitable Distribution on Richard C. Gaffney,
Esquire, P.O. Box 627, 101 Front Street, Boiling Springs, PA 17007, by depositing a copy of the
same in the United States mail, First Class, postage prepaid, this 21st day of December, 2000.
~
THE FAMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243 -2968
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I verifY that the statements made in this Petition for Alimony and Equitable Distribution are true and
correct to the best of my personal knowledge, infonnation and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa..C.S. 94904, relating to unsworn falsification to authorities.
Date: \~\~~cro
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statement.) .
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INCOME STATEMENT OF
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Section I: Innn~s and Ins 1rnJlc~
INCOME:
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Payroll No. Gross Pay per Pay P~rlod S
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Itemized Payroll DeducriO-n&:
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Attach to this statement a copy ofllJ,.; follQwing documents re,1aling to the partnership, joinf \'entun:. bu~U'lcss. rrofession.
c(lrporatkm or similar entity:
(J) the most recent federai Inwh--: Tax Retum. and
(2) the moS!. rcccrd Profit and Loss Statement
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c. Name 0 f business:
Address and teleph(lne number:
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f. Annual income from business:
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BARRY W. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OE
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFICATE OF SERVICE
I, Paula K. Knudsen, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving a true and correct copy of Defendant's Income and Expense Statement on Richard C.
Gaffney, Esquire, P.O. Box 627, 101 Front Street, Boiling Springs, PA 17007, by depositing a
copy of the same in the United States mail, First Class, postage prepaid, this 23rd day of J atiuary,
2001.
:J:~et- ~
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
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JRN 19'01
14;18 No.OOl P.02
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In the Court of Common Picas of
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PlaintitT Name: B1\R\'l...'i Skn1'P.5 ON
Defendant Namc~A,^V\e.t\ce.. ::;"'-\M.~sol1
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PACSES Case Number;
Other Slate lD Number:
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Income and li:xpense Statement
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14:18 No.OOl P.O~
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BARRY W. SAMPSON,
Plaintiff
, IN THE COURT OF COMMON PLEAS OF
, CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFlCATE OF SERVICE
I, Paula K. Knudsen, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving a true and correct copy of Defendant's Amended Income and Expense Statement on
Richard C. Gaffney, Esquire, P.O. Box 627, 101 Front Street, Boiling Springs, PA 17007, by
depositing a copy of the same in the United States mail, First Class, postage prepaid, this 30th day
of January, 2001.
?~t~
Paula K. Knudsen
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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BARRY W. SAMPSON,
PlaintifflRespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ANNETTE SAMPSON,
Defendant/Petitioner
NO. 2000-142 CIVIL TERM
IN DIVORCE
DR# 30535
Pacses# 421103204
ORDER OF COURT
AND NOW, this 22nd day of March, 2001, upon consideration of the attached Petition for Aiimony
Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear
before R.J. Shaddav on Aoril 17. 2001 at 10:30A.M. for a conference, at 13 N. Hanover St., Carlisle, PA
17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax 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 Rule
1910.11@
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have avaiiabie to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
MiiIl-copies on-
3-22-0 I to:
Petitioner
< Respondent
Richard Gaflhey, Esquire
Terri Henning, Esquire
. .. .. ...
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Date of Order: March 22, 200 I
R.
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
, RLEG-DfFICE
OF T'r'E FC.;OWONOTNW
01 iiAR 22 PH 4: 09
CUI..iBEf1LN~D COUNTY
PENNSYLVf\N!A
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DR#
BARRY W. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
NOW COMES, Defendant, Annette Sampson, by and through her counsel, Family
Law Clinic, and files this Petition for Alimony Pendente Lite, pursuant to Pa. R.C.P. ~
1920.15, and in support thereof respectfully represents:
1. Defendant's mailing address is 603 Holiday Park Village, Jamestown, North
Dakota, 58401. Plaintiff's mailing address is 247 South Spring Garden St., Box
212, Carlisle, PA 17013. Defendant's birthdate is 3121!52 and her social
security number is 543-60-7411. Plaintiff's birthdate is 6/8/48 and his social
security number is 175-40-6333.
2. On January 7,2000, Plaintiff, Barry W. Sampson, filed a Complaint for
Divorce against Defendant, Annette Sampson.
3. Defendant lacks sufficient property to provide for her reasonable needs and is
unable to support herself through appropriate employment.
4. Defendant suffers from severe, chronic bronchitis; asthma; carpal tunnel
syndrome; and severe respiratory disorders (Defendant uses a breathing
machine three times per day as well as using five different inhalers) which
inhibit her ability to maintain appropriate employment.
~
, -.
5. Defendant has been unemployed and had no source of income since August
2000. The employment in August 2000 was of a duration of approximately three
to four weeks. Prior to the August 2000 employment, the last time Defendant
was employed was in 1996.
6. Defendant requires an award of alimony pendente lite to adequately maintain
herself and remain on equal footing with Plaintiff during the pendency of the
divorce proceeding.
7. The parties were married on March 23, 1991 in Lane County, Oregon and
separated in January 1999.
8. The marriage lasted almost eight years, during which time Defendant was the
homemaker and primary caretaker of her minor children, and Plaintiff was the
primary wag-ecearner,
9. Plaintiff isemployed and financially able to provide for the reasonable needs of
the Defendant.
2
WHEREFORE, Defendant prays that the Honorable Court enter an award of
reasonable alimony pendente lite.
Respectfully submitted,
~ JIS-JO)
Date I I
~~t~
Paula K. Knudsen
Certified Legal Intern
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RO R . RAINS . 'oJ
THOMAS M. PLACE
TERl L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
717/243-3639
3
ID:
MAR 02'01
13:48 No.OOl P.OS
.
VERIFl(:ATION
I hereby verifY that th~ statements made in th~ foregoing Petition for Alimony Pendente'
Lite are true and corr~e[, to the best of my knowledge. information and belief. I understand
making a false .tat~m~llt would subje,:t me ,<> the pcnaHies of 18 Pa.C S. SeenO!l 4904, relating
to unsworn falsillcatioll authorities.
t2~e~~~
7n:t t/)
Dated: /[//; i dm I
.
DR#
BARRY W. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFICATE OF SERVICE
I, Paula K. Knudsen, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving a true and correct copy of Defendant's Petition for Alimony Pendente Lite on Richard C.
Gaffney, Esquire, P.O. Box 627, 101 Front Street, Boiling Springs, PA 17007, by depositing a
copy of the same in the United States mail, First Class, postage prepaid, this 15th day of March,
2001.
~~t~
Paula K. Knudsen
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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DR 30535
PACSES ID 421103204
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
. CIVIL ACTION - LAW
BARRY W. SAMPSON,
Plaintiff/Respondent
ANNEITE SAMPSON,
Defendant/Petitioner
NO. 00-142 CIVIL TERM
ORDER OF COURT
AND NOW, this 26th day of April, 2001, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $0.00 per month and Respondent's monthly net
income/earning capacity is $3,229.21 per month, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $1,300.00 per month payable montWy as
follows; $1,200.00 per month for alimony pendente lite and $100.00 per month on arrears. First
payment due on or before the 15th day of May, 2001. Arrears set at $2,400.00 as of April 26, 2001.
The effective date of the order is March 15,2001.
Respondent is to make a lump sum payment of$1,200.00 on or before the 15th day of May,
200 I. Thereafter, the defendant can make weekly payments through an attachment of income order.
Failure to make each payment on time and in full will cause ail arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.g 3703. Further, if the Court
fmds, 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 P A SCDU to: Annette Sampson. 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:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-9110
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 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
om 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: I) the name ofthe 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 as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy ofthe 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 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 Court.
DRO: R. J. Shadday
M<!iJ~ cQJ?ies on
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BY THE COURT,
Petitioner
_ _ Respondent
Paula Knudsen: Esquire
Richard Gaffney, II
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ORDJ:R!NOTlCE TO WITHHOLD INCQME FOR SUPPORT
)./G.t" OO-Ilf C< {// Me-
State Commonwealth of Pennsvlvania ;iN'O> i/fU /03~
Co./City/Dist. of CUMBERLAND l::IC- 0{)'?~
Date of Order/Notice 04/26/01
Court/Case Number (See Addendum for case summary)
@Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
) RE, SAMPSON, BARRY W.
) Employee/Obligor's Name (last, First, M!)
) 175-40-6333
) Employee/Obligor's Social Security Number
) 0602~00504
) Employee/Obligor's Case Identifier
) (See Addendum for plaintiff names dssociated with cases on attachment)
) Custodial Parent's Name (Last, First, Ml)
)
EmptoyerlWithholder's Federal EIN Number
ROADWAY EXPRESS INC
EmployerlWithholder's Name
1077 GEORGE BLVD
EmployerlWithholder's Address
AKRON OR 44310-2408
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's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1,200.00 per month in current support
$ 100.00 per month in past-due support Arrears 12 weeks or greater? 0 yes @ 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 $ ~, 300 .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:
$ 300.00 per weekly pay period.
$ 600.00 per biweekly pay period (every two weeks).
$ 650.00 per semimonthly pay period (twice a month).
$ 1.300 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 paydateJdate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the iaws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SeOUl 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 /D (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
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Date of Order:
April 27, 2001
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Edgar B: Ba~lefF
DRO: RJ Sbadday
xc: defendant
BY THE COURT:
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Service Type M
OMS No,: 0970.0154
Expitation Date: 12.131/00
.JUroE
Form EN-028
Worker 10 $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you are required to provide a copy of this form to your employee.
1. Priority: Withholding unde.r 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.
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 identify the portion of the single payment that is attributable to
each employee/obligor.
J. * Repo,L:1l6 ti,e rc1ydi:>.te/Date o;'v'./:tlll,old:,lg. ruu iliuM lepo/nl,,,, I-'cl.y....late/da.te vi.. :Ll,l.oldillg \\'-111,);:/1 5611....1:..6 Ule payl'II:;.'IL T1,G.
payda:te,~ate o-f--witlII Iv1J:1l5 :;:. tl,e dd:'te 01, ..l,idl <:J.IUOUllt ..as ..itl,I,dJ ~OHI tI,e €.'llt-'Ly,-<:,'." ~~age5. 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/Obligorwith Multiple Support Holdings: If there i, 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 #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no iongerworking for
you. Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
WITHHOLDER'S ID: 3404926700
EMPLOYEE'S/OBLlGOR'S NAME: SAMPSON, BARRY W.
EMPLOYEE'S CASE IDENTIFIER: 0602~00504 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: jf 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
unlessJhe obligor is employed in another State, In which case the law ofthe 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
Prote'ction Act (15 U.S,c. !l1673 (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.
10.
'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.
Requesting Agency:
DOMESTIC RELATIONS SECTION
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 @
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
OMS No.: 0970.0154
Expiration Date: 12/31/00
~
,
ADDENDUM
Summary of cases on Attachment
Defendant/Obligor: SAMPSON, BARRY W.
PACSES Case Numbe,
Plaintiff Name
ANNETTE SAMPSON
Docket Attachment Amount
00-142 CIVIL $ 1,300.00
Child(,en)'s Name(s):
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PACSES Case Number
Plaintiff Name
DOB
Docket Attachment Amount
$ 0.00
Child(,en)'s Name(s):
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identified above in any health insurance coverage available
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PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
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Chila(ren)'s Name(s);
DOB
Docket Attachment Amount
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Child(ren)'s Name(s);
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tj'ii ~h'~c'k~d,'yo'~'ar~ ~equir~d to enroll the child(r~'n)"
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D 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
PACSES Case Number
praintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
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"0 if che~k~d', y~~"~~~ ~~q'~'i~~d't'~' ~~'r~ii t'h~"~h'iJd(~~~')"
identified above in any health insurance coverage available
through the employee's/obligor's employment.
ti'if'~h~~ked, 'y~~' ~re ~~qu-ired to enroll the' chjld'(;~;~')"
identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
Service Type M
OMBNo,:0970.0154
ExpirationD.1t~ 12/31/00
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BARRY W. SAMPSON,
Plaintiffi'Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CML ACTION' DIVORCE
ANNETTE SAMPSON,
DefendantlPetitioner
NO. 00-142 CIVIL TERM
IN DIVORCE
DR# 30535
Pacses# 4211 03204
DEMAND FOR HEARING
DATE OF ORDER: April 26, 2001
AMOUNT: $1,200.00 per month plus $100.00 per month on arrears
FOR: Alimony Pendente Lite
REASON(S):
1) A monthly net income/earning capacity was not attributed
to Petitioner, Annette Sampson. (2) Petitioner has medical
insurance coverage, through the state of North Dakota. HRespondent
should not be required to provide medical in~urallce coverage.
PARTY FILING DEMAND FOR HEARING: Plain tiff /Respondent
Harry W. Sampson
N\.~ \4- 1 2. 00 \
Date
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BARRY W. SAMPSON
PLAINTIFF
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2000-142 CIVIL TERM
v.
:
ANNETTE SAMPSON
DEFENDANT
:
IN DIVORCE
NOTICE
If you wish to deny any ofthe statementa set forth in this affidavit, you must :file a
counteraffidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
I. The parties to this action separated on October 27, 1998 and have continued to
live separate arid apart for a period of at least two years.
2. Tbe marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifl do not claim them before a divorce is granted.
I verifY that the statements made in this affidavit are true and correct. I understand
the fulse statements herein are made subject to the penalties of 18 Pa. c.S. ~ 4904 relating
to unsworn fulsification to authorities. '
Date: I J- 5" rrO
.
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any . Sampson, . tiff
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BARRY W. SAMPSON
PLAINTIFF
IN THE COURT OF
COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
v.
NO. 2000-142 CIVIL TERM
ANNETTE SAMPSON
DEFENDANT
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing document upon
the persons and in the manner indicated below, which service satisfies the requirements
of the Pennsylvania Rules of Civil Procedure, by mailing a copy of same via the United
States Postal Service, First Class Postage Prepaid addressed as follows:
Teri Henning, Esquire
Family Law Clinic
The Dale F. Shughart Community Law Center
45 North Pitt Street
Carlisle, P A 17013
By: ~(tL ~~~~""""
Richard C. Gaffney, ire ~
P A. SUPREME COURT LD. No. 3313
2120 Market Street, Suite 101
Camp Hill, PA 17011
Telephone: (717) 975-9033
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REASON(S): =<
1) A monthly net income/earning capacity was not attributed
to Petitioner, Annette Sampson. (2) Petitioner has medical
insurance coverage through the state of North Dakota. Respondent
should not be required to provide medical insurance coverage.
.......--. ..
BARRY W. SAMPSON,
PbtintifV1lespondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION -DIVORCE
ANNETTE SAMPSON,
Defendant/Petitioner
NO. 00-142 CIVIL TERM
IN DIVORCE
DR# 30535
Pacses# 421103204
DEMAND FOR HEARING
DATE OF ORDER: April 26, 2001
AMOUNT: SI,200.00 per month plus S100.00 per month on arrears
FOR: Alimony Pendente Lite
PARTY FILING DEMAND FOR HEARING: Plaintiff/Respondent
Barry H. Sampson
J2 J). ~AA&~
S gnature /
Richard C. Ga fney~
Attorney for Respondent
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BARRY W. SAMPSON,
Plaintiff
v.
, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFICATE OF SERVICE
I, Laura A. Gargiulo, Esquire, hereby certify that on the 22nd day of May 2001, I served a
true and correct copy of Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code and
_Plaintiffs Petition to Bifurcate by United States Mail, First Class Postage Prepaid, to
Defendant's cOWlSel of record, as follows:
Teri Henning, Esquire
Family Law Clinic
The Dale F. Shugart Community Law Center
45 North Pitt Street
Carlisle, PA 17013
Date: May 22, 2001
~~.
La a A. GargiUlO'~
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BARRY W. SAMPSON,
Plaintiff7Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
DefendantlRespondent
: NO. 00-142
: DIVORCE
PRAECIPE TO ATTACH VERIFICATION
To the Prothonotary:
Please attach this Verification to Defendant's Answer to Plaintiffs Petition for
Bifurcation filed on June 8, 200 I.
DateUua 1'1 2f:;O/
L!!e~d{;,J/l
Certified Legal Intern
~- L J /
L '\ /
S M. PLACE -
ROBERT E. RAINS
TBRI L. HENNING
Supervising Attorneys
~
FAMILY LAW CLIN1C
45 North Pitt Street
Carlisle, PA 17013
7] 7-243-2968
-,~---'--
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ID:
JUN 06'01
13:45 No.OO~ P.04
VERIFICATION
1 vcrifY that the slatemenls made in D<Jf"ndant's Answc!' to Plaintiff's Petition for
Bifurcation are true and correct. r understand that false statements herein are made subject to thc
penalties of 18 Pa. C.S. *4904 relating to unswol11 falsification to authorities,
Date C)l,.J/I.v~Y/J J R?a:J./
~-~
AuncUc Sampson, De ~~nt
. ~
BARRY W. SAMPSON,
Plaintiff/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Respondent
: NO. 00-142
: DIVORCE
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of the
Praecipe to Attach Verification to Defendant's Answer to Plaintiff's Petition for Bifurcation on
Richard C. Gaffney, Esquire, 2120 Market Street, Suite 101, Camp Hill, Pennsylvania 17011, by
depositing a copy of the same in the United States mail, First Class, postage prepaid, this II.' day
of June, 200 I.
Date ~/f,2001
AJJiQl1{J;@dlJw;Jt
~ichelle L. Ande
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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BARRYW. SAMPSON,
Plaintiffi'peti tioner
v.
~ IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 00-142
: DIVORCE
ANNETTE SAMPSON,
Defendant/Respondent
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and COlTect copy of
Defendant's Answer to Plaintiff's Petition for Bifurcation on Richard C. Gaffney, Esquire, 2120
Market Street, Suite 101, Camp Hill, Pennsylvania 17011, by depositing a copy of the same in
the United States mail, First Class, postage prepaid, this 11th day of June, 20.0 I.
~ll. Ubi
Date
Michelle L. An rson
Certified Legal Intern
F AMIL Y LAW CLINIC
45 N. Pitt S1.
Carlisle, PA 17013
717-243-2968
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BARRYW. SAMPSON,
Plaintiff
IN THE COURT OF COMMON I'LEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
INVENTORY
OF
ANNETTE SAMPSON
Defendant files the following inventory of all property owned or jJossessed by either
party at the time this action was coriunenced and all property transferred within the preceding
three years.
Defendant verifies that the statements made in this inventory are true and correct.
Defendant understands that false statements herein are made subject to the penalties of 18
Pa.C.S. S 4904 relating to unsworn falsification to authorities.
~5Sa~~
Defendant, Annette Sampson
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the case at bar and itemizes
the assets on the following pages.
( ) I. Real Property
( x ) 2. Motor Vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
( ) 5, Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life insurance policies (indicate face value, cash surrender value and current
benefiCiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( ) 13, Patents, copyrights, inventories, royalties
( ) 14. Personal property outside the home ,
( ) 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award
( ) 17. Profit sharing plans
(x) 18. Pension plans (iridicate employee contribution and date plan vests)
( x ) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A benefits
( ) 23. Education benefits
( x ) 24. Debts due, including loans, mortgages held
( x ) 25. Household fumishings and personalty (include as a total category and attach itemized
list if distribution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced:
Item
Number
2
Description
Of Property
Corvette
(Current disposition
unknown)
Names of
All Owners
Unknown
18
Teamster's Pension
Barry Sampson
Annette Sampson
Roadway Pension
Barry Sampson
Annette Sampson
25-
Pool Table
(Current disposition
unknown)
Unknown
Big Screen TV
(Current disposition
unknown)
Unknown
... ~.-
NON-MARITAL PROPERTY
Defendant lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item
Number
Description
Qf Property
R~ason for
Exclusion
Item
Number
PROPERTY TRANSFERRED
Description Date of Consid-
of ProIJertv Transfer eration
Person to whom
Transferred
25
Pool Table
Unknown
Unknown
Unknown
Big Screen TV
Unknown
Unknown
Unknown
Item
Number
Description
of Propertv
LIABILITmS
Names of
All Creditors
Names of
All Debtors
24
Medical Bills
(Amounts to be
provided)
To be provided
Annette Sampson
Defendant reserves the right to correct and/or supplement this Inventory to the extent that
she acquires additional information regarding assets and/or liabilities.
" -~--
BARRYW, SAMPSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
: NO, 2000-142
: DIVORCE
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of the
Inventory of Annette Sampson for Defendant, Annette Sampson, on the following person,
counsel for Plaintiff, by depositing a copy of the same in the United States Mail, postage prepaid,
this 20"' day ofJune, 2001:
Richard C. Gaffuey, Esquire
2120 Market Street
Suite 101
CampHill,PA 17011
JjJ/)J;JJjcf? (/Lff'J)MA-
Michelle L. And~n
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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BARRY W. SAMPSON,
PLAINTIFF/PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANNETTE SAMPSON,
DEFENDANT/RESPONDENT
00-142 CIVil TERM
AND NOW, this
~
ORDER OF COURT
day of June, 2001, upon review of the petition
for bifurcation and the answer filed thereto, a hearing on the merits shall be conducted
at 8:45 a.m., Friday, July 27, 2001.
Richard C. Gaffney, Esquire
For Petitioner
Teri L Henning, Esquire
Michelle L Anderson, Certified legal Intern
The Family law Clinic '
For Respondent
:saa
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Fax: 701253S471 -'"""V Jl.I;l 27'01. 07:20 .PoOl,,, ".;
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BARRY W. SAMPSON,
PLAINTIFF/PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANNETTE SAMPSON,
DEFENDANVRESPONDENT
00-0142 CIVIL TERM
ORDER OF COURT
AND NOW, this
"'21
day of July, 2001, IT 15 ORDERED that the
petition of Barry W. Sampson to bifurcate this divorce proceeding, 15 DENIED.1
Richard C. Gaffney, Esquire
For Petitioner Barry W. Sampson
Edgar B. BaYleY7
... (}r;;:/7f
Michelle L. Anderson, Certified Legal Intern
Robert E Rains, Esquire
The FamIly Law Clinic
FotRespondent Annette Sampson
:saa
I We see no reason why this case cannot be moved before a Master for an
expeditious resolution of the parties' economic dispute. A bifurcation is not
warranted at this time.
'_J;-C:': 1"\C::
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01 JUL 27 [,;111: 2.0
CU~.'/;2E.RLJ.J-~u COUNlY
PENi\SYLV/"NIA
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BARRY W. SAMPSON
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant.
: No. 00142
: IN DIVORCE
PLAINTIFF'S ANSWER TO DEFENDANT'S FIRST SET OF INTERROGATORIES
AND REQUEST FOR PRODUCTION OF DOCUMENTS
AND NOW, the lOth day of August, 2001, Plaintiff, Barry W. Sampson, by his attorney
Richard C. Gaffney answers Defendant's First Set ofInterrogatories and Request for Production
of Documents as follows:
I. LIABIL TIES
A. List all debts or liabilities that you currently owe or owed as of January 1999. Include all
debts whether owed singly or jointly with Annette Sampson. For each debt, provide the
following:
1. The name(s) and address(es) of the creditor(s) and your relationship to the
creditor(s);
Visa (address unknown)
Sears: Sears Credit
P.O. Box 818014
Cleveland, OH 44181-8014
J.C. Penney: Monogram Credit Card Bank of Georgia
7840 Roswell Road, Bldg.100, Suite 200
Atlanta, GA 30350-6875
Relationship with creditors: credit card holder
I
"
2. The name(s) of the dehtor(s).
Barry W. Sampson and Annette Sampson. However, Barry Sampson assumed,
and continues to assume, all responsibility for payment of the debts.
3. The date the debt or liability was incurred, the amount of debt or liability at the
time it was occurred, and the reason the debt or liability was incurred.
The debts occurred on or before separation of the parties. The approximate
amount of the debtlliability was as follows:
Sears: $500
J.C. Penney: $1,000
Visa: $2,200
Reason for the debtlliability: credit card purchases
4. All payments made by you since January 1999 and the present unpaid balance of
the debt or liability.
Mr. Sampson has paid off the Sears and J.C. Penney debts. He continues to pay
down the Visa card debt, making payments of approximately $75 per month. The
present balance of the Visa card is approximately $2,700.
B. For each debt or liabmty~please also identify any documents evidencing or relating to
debts or liabilities, or records of payment, including documents concerning debts that
were paid and documents concerning debts that are outstanding, which were incurred
during the time period of September 21,1991 until January 1999.
There may be credit card statements which evidence the debtlliability and payments made
thereto. Plaintiff is unaware of the location of these statements.
2. PENSIONS. RETIREMENT ACCOUNTS. PROFIT SHARING PLANS
A. Do you have any interest in any kind of retirement account, profit sharing plan, or
pension fund (Including but not limited to pensions or retirement accounts with Roadway
and Teamsters?) ,
Plaintiff has a pension fund through Central Pennsylvania Teamsters Pension Fund.
2
"
B. If so, for each account, plan or fund, state:
1. The name and description of the account, plan or fund, including the name and
address of the custodian and/or administrator of the account, plan or fund.
Pension_fund: Central Pennsylvania Teamsters Pension Fund
P.O. Box 15223
Reading, PA 19612-5223
2. The present value of the account, plan or fund and the value of the account, plan
or fund as of January 1999;
Plaintiff is in the process of obtaining documentation with respect to his pension
fund. The documentation will be submitted to Defendant's counsel upon receipt.
3. Date yoU: first participated in the account, plan or fund, and the date that you
became vested in the account, plan or fund.
Plaintiff is first participated in the account in 1992 and became vested in the
pension fund in 1997. IUs_Plaintiff's belief that all of the funds in the account
earned on or before October 28, 1998 are marital assets.
4. The date you are entitled to receive retirement or pension benefits.
It is anticipated that Plaintiff will receive pension benefits in 2005.
5. The amount of benefits receivable per month on retirement and the amount of
funds available to you and the method of obtaining them without retirement.
Plaintiff has the option of withdrawing all monies from the pension fund upon
retirement, or he can elect monthly payments, said payments to continue until the
funds are depleted. The Plaintiff is not eligible to obtain the funds until he
reaches age 57; however, if Plaintiff continues to work in the same craft, trade or
industry past the age of 57, he will not be eligible to obtain the funds until he
terminates his employment
3
.'
6. The amount of funds from any of the foregoing accounts, plans or funds that were
disbursed both during the marriage and/or after January 1999, along with a
description of how such funds were used.
N/A
C. Identify all documents relating to plaintiff's retirement accounts, profit sharing plans
and/or pensions from September 21, 1991 to the present, including, but not limited to, a
copy of each plan and all statements relating to contributions and values.
Plaintiff is in the process of obtaining documentation with respect to his pension fund.
The documentation will be submitted to Defendant's counsel upon receipt.
3. PERSONAL PROPERTY
A. Please identify all personal assets which you owned or possessed as of the date of this
action was filed (January 7, 2000) as well as all property transferred within the preceding
three years. This list should include any personal property, including, but not limited to,
any furniture, motor vehicles, household goods, appliances, jewelry, furs, artifacts, works
of art, stocks, bonds, securities, options, certificates of deposit, checking accounts,
savings accounts, money market accounts, contents of safe deposit boxes, trusts, life
insurance policies, employment termination benefits such as severance payor worker's
compensation, or other personal property in which you have or had any interest.
At the time this action was filed, Plaintiff owned or possessed:
(a) Personal clothing
(b) 1984 CQrvette automobile
(c) Hunting equipment
Prior to commencement of this action, Plaintiff owned or possessed jointly with
Defendant furniture, appliances, to include a washer/dryer set, household goods and
electronic equipment. When the parties separated, Defendant took all of these personal
assets with her.
B. Please describe each item, including whether you consider it to be marital or nonmarital
property, the date of purchase, the estimated present value, the value at the date of
separation, its present location, and the names and addresses of each other person with an
ownership interest in the items. If transferred, list the date of transfer, the amount paid
for the transfer and the person to whom the money was transferred.
4
(a) Personal Clothing: noncmarital, date of purchase unknown, value unknown, no
other person has an ownership interest.
(b) 1984 Corvette automobile: marital property that was traded for $3600 sometime
after the separation of the parties.
(c) Hunting equipment: non-marital, date of purchase and value unknown, no other
person has an ownership interest.
(d) Appliances (including washer/dryer), furniture, household goods, electronics:
marital property, purchased by the parties during the marriage, taken by
Defendant at the time of separation, value of the property is unknown.
C. Identify any and all documents relating to each item, including, but not limited to
receipts, appraisals, bills, etc.
Plaintiff is unaware of documentation regarding the foregoing items or where
such documentation is held.
4. REALPROEPRTY
A. Do you or did you own or claim an interest in any real property on the date this
action waS filed (January 7, 2001) and/or in the three years prior to that Date?
No.
B. If so, state:
I. The location of the property;
N/A
2. The type of property;
N/A
3. The deed references, the date of the purchase and the price paid;
N/A
4. The name and address of all co-owners and the extent of their interest;
5
N/A
5. The present value of the property, as well as the value as of the date of
separation (January 1999);
N/A
6. The current balance due on any mortgage, lien or encumbrance, as well as
the balance due on the date of separation and the name and address of the
mortgagee or lien holder or encumbrancer, if any.
N/A
C. Identify any and all documents relating to your ownership of or interest in any
real property identified above, including, but not limited to, deed documents,
mortgages, settlement/closing documentation, receipts, appraisals, tax bills, etc
N/A
6
BARRY W. SAMPSON,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON
Defendant/Respondent
NO. 2000-142
DIVORCE
VERIFICATION
I verify that I have read the foregoing document and verify that the statements made
therein are true and correct to the best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 9 4904 relating to
unsworn falsification to authorities.
Dated: (:jIb 11/ I
,
f3 k.
Bar~pso~
BARRY W. SAMPSON,
Plaintiff
v.
IN THE COURT O~COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Answer to Defendant's
First Set of Interrogatories and Request for Production of Documents, to Defendant's counsel of
record by mailing a copy of same via the United States Postal Service, First Class Postage
Prepaid and addressed as follows:
Michelle Anderson
Certified Legal Intern
Family Law Clinic
The Dale F. Shugart Community Law Center
45 North Pitt Street
Carlisle, P A 17013
Dated: August ID ,2001
f2!~~
EXHIBIT A
~~-~,.,'-_.
c ~.. . ,
.~
=1
36.362.58
~.192.48
512.16
6,664.36
990.11
368.sg
10.00
,~nGRlJSS
FICA
,~Ilmployee .. .-uA:RRYWsAMi>SON ...~,'>;7 i.. ~~./h
SSN .175-40-6333 - STATE ./h PA
_._.._. n' LOCAL ./h WEST SHIlRE H
Department ..135 R70 LOCAL2 ./h
Pederal Tax Status, _SINGLE, 00 Allowances 2nd srATE ./h
~Pay Beginning' -"07/01/01 --. I DI!FI!RRED CO....BNSATlON PLANS I
I=:~ Hou:~~~::L~~!!t~")~ fi~~,!:~:ONS 3.536.21
HOL 10.00 19s.1Jj' _ """""'- "'''P,'''''' -- ;;;;;;;;.!':1::YAM suP "... .....-- 74.04 UN DUES
DRIVE 1.00
, I CURRENT
lOS.,",
l'A.ll
2.83
18.71
6.41
.1.OS
Advicel A543662
1
40.00
._0-,,' -_--o,,~-"'
,---";
Net P"',Y:_~:~".".19.57
~+
REMOVE DOCUMENT ALONG THIS PERFORATION
...
I THIS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH
~
,,",,~""~7!:'"
".
A543663
-'S,,;::::-~-
Date of Pq
07/19/01
-,
'"".
. - .,,,",,,,
-i"~~,~.,
""
.-,""-,
I'l:a'l:-=-nt of paymtant t:o:
BARRYW SAMPSON
:U7SSPRING GARDEN ST BOX:U~
CARLlSLR PA 11013
,-".".."...' .
, ".. ~,f: .;.. .;' -:<{:)'f~~~.;~t~~~~"$~.......19.57
- .:'~':"~':L"'ih account number OOOB281207
,., .- at PA CENTRAL FED C1l U
t/p~"i:' ~~I!f:~:' , .:..~~t! ~Ji"k
W,'iJi< ~., ,~. III "".,..,
~NON-N.EGOTiABI..E WAGE: STA.TEMENT "~
,-~" ,"","',",,- "-~-' ,." ~ " -",---',. ,. - -'-~~-. '. ~-
,,'
.,
was deposited
-_-:='3-~~-",'
, M>.,.tion~ 135R70
i-~-' ~.% 1F~
~ ~,... ,,="" .."",---<"
-:'_'~-? :;;:~;~':~-
"'- -='_.
_.0 =,,~__;,.
~~,,~
"'........:
-'-~
PayBeginning
PayEnding
Date of Check
hYPB OF PAY
VAC
BARRYW SAMPSON
115-40-6333
135 R10
SINGLE '. 00 Allowances
01/02/01
01 /01 /OI""!JC,~\,:.:},,,
01/19/01;:;;:".,: .,
HOURS GROSSAMOUj)i.:....,.,'.. .~'::.::
1,067.65'
:...:,,:,"" "."."'.:,,"
"::::;~::::: ~!4.;:::".~;:~:.' ;::'::::',,:', ',,:::::.'"
:j:.d~:~:f~;~r:::~3Z:L~:::i:;jfh ~9::~~::':~ .;,.:
'GIlIJSS
'FICA
., I>lEDlCAllE .,
, . FEDERAL w/h
. srm w/h PA
'.. LllCAJ. w/h WEST SllJllE H'
L0CAL2 w/h
.. 2nd srATE w/h
I "DEFERRED COMPENSATION PLANS I
C:if:\F,,4Q1K. ..'.'." <,..,:,,1:....',.... ,.,.',,106.77 31536.'Zl
cURRENT
1.067.65'
66.19 ,.
., 15.48
. 185.55 .
29.85
10.65
..- , ," ,...
.".... >'''" ..
, ., YTD ' I Cliei:k #
,...:: 36.362.68
.. ~,192.48
512.76
6.664.36
.1190.11
,353.59
10.00
_ 16800
.il6ADW~~
....'.:....-. ,'T.....--exp ,.'TesS"
.. .... ,.
,Emi'I'!yee
',"SSN,. .' ':
Department .
., Federal Tax Status
" "':"::":,.-::OTHBRDEDUCTI0NS
acra.oo DRIVE
I
1.00
Net Pay $.........."..350.16
-------_._------~_.,'
IS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH
t
REMOVE DOCUMENT ALONG THIS PERFORATION
t
,.~
.
'-,'
:0~~t:=~~O~d &vinCII ~bnk
,.~ayroll
~
'"
904168001
Pa.y, th. ,1IUm, of:
Datil ofCheel:. Check Amount
i'!i!<!:;,:','I', ',):i,"r;, i,','" >,'
Pay' 'to the o:r:-d.r" of:
07 /19/01 ~"':U:~:h:U'io1IJ!1(~
vom AJ'~BR 1.80 DAYS
BARRYW SAMPSON
,.'247SSPRING GARDEN ST BOX212
'.:C\>>TT~R PA 17013
: '. " .~
,1"',.1',
.. n . _ __,,, "
.'.'.,,"', '., ",', -/
" .. ---
. ~~', .
, , > -, ~'-
# ,'.,,'.., ...'".'
,,'.' .~L_5".,'.'
':'-":':':"_-:.,:'" .~ " ,AUTliORI,ZEOSIC""'TURE ~,:~:~,
or.':"'
,
: tip 4,
lI"qo.. H.Boo ~II" ':0 7 ~q ~ 5 5Bol: o"lII:\q :\1I11:;"o'"B""
Pay Beginning
Pay Ending
Date of Check
ITYPEOFPAY
LII
REG
BARRYW SAMPSON
1.75-40-6333
135 R70
SINGLE, 00 Allowances
06/24/01
06/30/01
07/12/01
HOURS GROSS AMOUNT!-
962.00' ~ ""
9.76
GRllS3
FICA
MELiICARE
FEDERAL w/h
Sl'ATE w/h PA
LOCAL w/h WESr SHORE H
LOCAL2 w/h
2nd SIATE w/h
I DEFERRED COMPENSATION PLANS I
",SS 401IC,97.18 3,400.98
i CURRENT
971.76
60.25
14.09
162.26
27.21
, 9.72 '
YTD I
34,099.73
2,114.18
494.45
6,450.09
954.79
340.99
10.00
~~
Advice# A~9
1imployee
SSN
, Department
, Federal. Tax Status
'."".,....,..:,.'.'.,..:,::
I.." .
0.50
,'.'~ _1 ".'0"::":::,,. :~:ornERDBDUCTIONS
"FAM sup' . "',802.00 DRIVE
I
1.00
MEALS
11.78
. Net Pay $*******309.83
, THIS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH '
t
...,~
REMOVE DOCUMENT ALONG THIS PERFORATION
t
, ~: '
A 528659
Da1eol'Pa:r
07/12/01
"."
,'1"",1
'.'., " "."',.::'
Stat:4lJllent: 'of, payment:; 'eo: ., '.'. , ,
, ,'- I' ..' .',. I
, '. 'BARRYWSAMPSON
, ,2475 SPRING GARDEN ST BOX2U
CARLISLE PA 17013
, ,NetPayof $*******309.83 was deposited
in aCC01Dlt number 0008281207
at PACENTRALFEDCRU
, ' , -'.
;_ ][.Qcition '135 R70
t/p4
NON-NEGOTIABLE WAGE STATEMENT
135 BW SAMPSON
P/E 6/30/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH DRIVER TOUR WAGE DELAY
EQUIP. MILES HOURS RATE
MO. DAY IDENTIFICATION NBR. ORIG. DEST. EXTENSION DESCRIPTION
6 25 135-1763932 2DP 135 703 1 83 .25375 211 :88
6 25 1 .50 19.5200 9:76 ENRT FUEL
6 26 703-1764553 2DP 703 671 1 46 .25375 117 :99
6 26 1 .50 19.5200 9\76 PERFORM D/H
6 26 1 .41 19.5200 8\00 WAIT D/H
6 26 671-1775150 2DP 671 135 1 39 .25375 100 :23
6 26 1 .63 19.5200 12:30 MISe WAIT
6 26 1 .50 19.5200 9:76 ENRT FUEL
,
,
6 27 135-1783053 2DF' 135 703 2 83 .25375 211 !88 11.78 M/L
6 27 2 3.00 19.5200 58:56 ENRT BKDN
6 28 671-1794507 2DP 703 135 2 83 .25375 211 :88
6 28 2 .50 19.5200 9 :76 ENRT FUEL
B4 MEAL /LOD IN S 11.78 971 76
TO R aUNT 2 TOTA MIL S 336
S EEPE MIL S 336
I
L, ,---
Employee
SSN
Department" ,. . .'.
FederaJ. Tax status
Pa:y JlegiDning
Pay Ending
Date ofCbeck
ITYPEOFPAY
LH
REG
lWlRYWSAMPSON
175-40-6333
135R70 . .
,SINGLE "00 Allow;;"ces'
06/10/01
, 06/16/01 ",."""",.;,';' .,.,,,,,
;::~;r"'\:,:,(~;, '"..:,:-' .,~~1~'("~::,~,,, '
06/28/01 ",",,,,,..,..,,, ,.'". ",. ,..'
,i':':' .
. HOURS GROSS AMOUNTt .' ,". :;",::,;",;:::i.":".,"'" '::,: ,.,;:",,:,:.' \',',
901.20 .
19.52
.,
GROSS
FlCA
M'EDICARE
FEDERAL w/h
STATE w/h PA.
LOCAL w/h mrr SIllJRE H
L0CAI.2 w/h
2nd srm: w/h
I DEFERRED COMPENSATION PLANS !
~{g; ,~ ,', ;::~:;::{:::, '~'{::'!':" ;::::rn.07 3,130.84 ,
""', '_:...",
CURRENT
920.72
67.09
13.35
152.63
25.78
" 0.21.
YTDI
31,308.36
1,941.12
453.97
5,006.29
876.63
813.07
10.00
R09AJ
Advice# A504T.13
....::." ',".'1:,'."'0"".
......'... '."..:1.:....
1.00
) .'
F~S1lP
,,; '.. .000000DEDUCTIONS
. 802.00 DRIVE
I
1.00
MEALS 11.69
Net Pay $............*279.28
.
REMOVE DOCUMENT ALONG THIS PERFORATION
. .
. I . THIS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH' . ,
'.~
"''"'''',--',.;
A504723 '
Bat. alP...,.
06/28/01
S~ae.mant of paymant to:
BARRYW SAMPSON
247 S SPRlNG GARDEN ST IlOX2U
CAI>TRTR PA 17013
, lietPay of $............*279.28 was deposited
. in account number 0008281207
at PA CENTRAL FED CR U
,J[.ocation 135 R70 .
tip 4 .
NON-NEGOTIABLE WAGE STATEMENT
135 BW SAMPSON
P/E 6/16/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH EQUIP. DRIVER TOUR WAGE DELAY
MILES HOURS RATE
MO. DAY IDENTIFICATION HSR. ORIG. DEST. EXTENSION DESCRIPTION
6 III 135-1622015 2DP 135 703 1 83 .25375 211 88
6 11 1 .50 19.5200 9 76 IMPASS HWY
6 11 1 .50 19.5200 9 76 ENRT FUEL
6 12 703-1633346 2DP 703 135 2 83 .25375 211 88
6 12 2 .50 19.5200 9 76 PERFORM D/H
6 12 2 .50 19.5200 9 76 ENRT FUEL
6 12 2 .25 19.5200 4 88 MISe ENRT
I
6 13 135-1640236 2DP 135 703 3 83 .25375 211 :88
6 13 3 .50 19.5200 9:76 ENRT FUEL
,
,
6 14 703-1654850 2DP 703 135 4 83 .25375 211 :88 11.69 M/L
6 14 4 .50 19.5200 9:76 ENRT FUEL
6 14 4 .50 19.5200 9:76 PERFORM D/H
,
,
B4 MEAL /LOD IN S 11.69 920172
TO R OUNT 4 TOTA MIL S 334 I
I
,
S EEPE MIL S 334 ,
,
,
,
,
___...L, -- '- - ! --
.'-.' ';}. ,.~ '\'".' h~".-,"'". -, .'. ~.." ,'.,~; ~;._-;:,-,:,-,.-;: "
,". ~.,'.,...-- ...._-~
. .
04....".DW.. "A.Y'.
.,~,~.,,:-EXpTe.sT .
,1:" .ployee' "",:'IWlRYWSAMPSON
i ~tJ;.".';.;,~;:333.
: '-deralTaxstatuS . SINGLE 00 Allowances
{.-~ ," ,,' ..., '". .. -'.':' ':,,' '.
i\ qBegiDning: , ..05120/01
,,' ay Ending ,'" . . ~'''','05/26/01 ....; :',:,r~1::~:~::,t ,<,</?5~:t::~~" ',.'
~ :.~ ::::;ck HOU':6/0~::SSAMOU~ ~:,:~,:," ':~;~;:~::.::,::..,.:::,~::~~~~' '"
H ' 625:i6"'"' ",',,',""", "C'.-~''''.''>1-.,
,uL . .' 2).00390.40
iK PAY . &.00 156.16
CURRENT
1,172.32
72.68 . .,
17.00 '.
, .216.03:
: '<12.82
,",11.'/2
Tl'D I . Advice # A463988
2'7,664.67
1,714.59
.400Jl9
\" :". '~','i'F"';:.'
.';'f~J~i~i;".. ' .
"
"':":",",,:.':,'::':
,:'''i".
.):, ::". '''':.':~:):t;;:
":,"'::.,,:'.
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'':;:
, . '. :..~. ,
,t.oo,
~~..
MEAtS ",.. '....,:..... 6.28
NetPa:,'S"'...........41U2
..t,
REMOVE DOCUMENT ALONG THIS PERFORATION
i.
~.'
.:n.....II.ltol~~~~I::a....toI.l".,.'h'~..,i""..;I:JI'I"'~l~...U11.'llll..:r,,"'''.ltI:f''':I:
;; ,<., ~,:', :'
'<'~ ,.
.'
.
";'T <
.A463988
>>.t.otP,q
:';;~i.~,:~~,,-
Stat..~t:. of pa~t 'tot . ":"":'1:,;",
BARRYWSAMPSON '.'
2475 SPRING GARDEN STBOX2U
CARLISLE PA 17013
, ~,
::.,", '..;..'.......: ,'.,1 'I, \"
, "'l,if"':,r
.' Net~of $........''''..410;.12
in aec..tmt number . CIOO8281207
at PA CENTRAL FED CRU
06/07/0~
was deposited
, ,
',' .
. .'" - -,
Location .135R70
.. .
. ,,' " "'".. < .'. "-"(;O":,~..-"~" ,.. .':'-'..,. "
'1~"',"{'" .':"'/" ",::~:':":, ~.^ <":.
.,iMo4, .,. _ ....
~e~ ,:, ~",,' , ~;'J;"if( ~
.:.'I10N::'NEG01::IABLEWAGESrATEMENT
~'!!:;;;, :
135 BW SAMPSON
PIE 5/26/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH DRIVER TOUR WAGE DELAY
MO. DAV IDENTIFICATION NBR. EQUIP. Miles HOURS RATE
ORIG. DEST. EXTENSION DESCRIPTION
5 19 135-1393826 2DP 135 721 1 118 .25375 299 43 .
5 19 1 .50 19.5200 9 76 ENRT FUEL
5 20 721-1401833 2DP 721 135 2 118 .25375 300 95
5 20 2 .30 19.5200 5 86 WAIT D/H
5 20 2 .50 19.5200 9 76 ENRT FUEL
5 22 HOLIDAY 3 10.00 19.5200 195:20
.
.
5 23 HOLIDAY 4 10.00 19.5200 195!20
,
5 24 SICK DAY 5 .
8.00 19.5200 156 116 8.28 M/L
.
B4 MEAL /LOD S .
IN 8.28 1172:32
TO R OUNT 5 TOTA MIL S 236
S EEPE MIL S 236
--
CURRENT
ll57.22
e9.S5
13.88
-'161.85
26.80
9.57
=1
26,482.35
1.,641.91
" 883.ll!l
6.003.68
, 741.51
, ,'264.81
, 10.00
".,~, .~
," , ' ',,', ,MEDICW:
Employee ,,' ,BARRYWSAMPSllN ",:,'FEDEllAl. w}h,
,SSN " ' ", ", ,'j75-',~ 63' 33 ,,' STATE w}h PA
~-,,, LOCAL./h WES'I' SIIlRE K
'DepartmeJit ", " 135R70 ,,',tDCAL2 w/h
FederalTaxStatus SINGLE 00 Allowances 2nd STATE./h
, , Pa7llegim1iDg 05/13/01 " I DEFEllllI!D COMPENSATION PLANS I
"~~~' , ,'",. ~~i~~~ ' ';3';;' ","".,i;~~<, .I~~~:;: ~;.;~\1~:)'1'.;;';;;1.':~:,;.;1w;.73 2.648.24
I TYPE OF PAY HOURS CROSSAMOONTf .;.;,;,. ;",'.,',. ,. '......::';':';~;:":'::~::\:f)~~:::~.~) ".. ". ':.':.,.. .., 'OTHER DEDUCTIONS
IJI 937.80 FAM SUP 302.00 DRIVE
!lEG 1.00 ' 19.52
Advice I A45215<
I
1.00
lI!:AI.S ,11.78
Net Pay $...........298.91
, THIS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH 0
+:
~
REMOVE DOCUMENT ALONG THIS PERFORATION
..
'OI.':",~ ..
","'-,,-
'=',.
: ~,{t \:~-'':-,-,'.:,: :::~, -
=',""::,,'._,'.;.-,',
"." '
~ ':
"
"
A4S2750
.'.."--.
Dateo:fP..,.
"
. :,'i~
05/31/0J.
Stat~t of payaant to:
" ,
BARRYW SAMPSON
247 5 SPRlNG GARDEN STlIOX:lU
CARLISLE PA 1'1013
,~',:,:," '.
~ I ' ,~,: , ,
,',:!tet Pay of ' $...........298.91
'in account number 00ll8:lIlU07
, at PACI!lITRALFEDCRU
"!"" deposited
"
"",.,,)
Location 135R1U
ttP4
C""
· , NON":NEGarlABLE WAGE STATEMENT
135 BW SAMPSON
P/E 5/19/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH DRIVER WAGE DELAY
EQUIP. TOU MILES HOURS RATE
MO. OAY IDENTIFICATION NBR. ORIG. DEST, EXTENSION DESCRIPTION
5 14 135-1335554 2DP 135 703 1 83 .25375 211 88
5 14 1 2.00 19.5200 39 04 ENRT BKDN
5 14 1 .50 19.5200 9 76 ENRT FUEL
5 15 703-1353253 2DP 703 135 2 83 .25375 211 88
5 15 2 .50 19.5200 9 76 ENRT FUEL
5 15 2 .50 19.5200 9 76 PERFORM D/H
5 16 135-1361012 2DP 135 703 3 83 .25375 211 88
5 16 3 .50 19.5200 9 76 ENRT FUEL
.
,
5 17 703-1375836 2DP 703 671 4 46 .25375 117:99 11.78 M/L
5 17 4 .50 19.5200 9 :76 PERFORM D/H
5 17 671-1370854 2DP 671 135 4 39 .25375 100 '23
5 17 4 .50 19.5200 9 76 ENRT FUEL
5 17 4 .30 19.5200 5 86 MISe ENRT
B4 MEAL /LOD IN S 11.78 957 32
TO R OUNT 4 TOTA MIL S 336
S EEPE MIL S 336
.
.
,
--, " - - -'
, DOA.DW.
----. -:EXPress
Employee
:SSH
Department. .,
Federal Tax status
Pay BeginniDg
Pay Ending
Date of Check
TYPE OF PAY
LlI
REG
BARRY W SAMPsoN
175-40-6333
i35 R70
. ,SINGLE . 00 Allowances
04/15/01
04/21/01
. 05/03/01
CURRI!NT
478.42
29.66.
6.93
56.94
, 13.40
4.78
YTD
2:>,541.69
1,Zl3.58
:;97.85
3.787.61
575.18
=.41
10.00 n
Advice# A400849
HOURS
DRlVE
~~'*}:~~
~,i:,fj :-::,,,''- ., ..., " . .,.".
";,,:'-':'~~;:'~,: I " I
.' '^ ';~::~:~:::)~, ~::: :::.:' :'::,;, ,'; ::"
I
GROSSAMO
468.66
9.76
:.:....'.::~01'IlIffl.DEDUCTIONS
1.00 .
0.50
NetPay $.......317.87
.t
REMOVE DOCUMENT ALONG THIS PERFORATION
"
THIS DOCUMENT CONTAINS A WATERMARK AND VOID PANTOGRAPH
~
":;:,'.! ";:'
", ,",'
.' '-r,""
St:at:ma.ut of ,paymant to:
. A400849
Date of P...,.
. ~,"
'.'
05/03/0J.
"," ,
.",",
BARRYW SAMPSON "
247SSPRlNGGARDENSTBOX:u2 '
CARLISLE PA 17013
"NetPayof ,$.......317.87
inaccount'number 000828U07
at PACENTRALFEDCRU
was deposited
tip 4
. ' .
. :r:.;cation~Us R7D
, .,','
. NON-NEGOTIABLE WAGE STATEMENT 'n
~
BARRY W SAMPsoN
175-40-6333
135 R70
SINGLE
04/29/01
05/05/01 , ,.
05/17/01 ,',
HOURS GROSSAMO~ ,=~~ ,'"
946.6'T
19.52
Employee
SSN
Department
Federal Tax status
PayBeginning'
Pay Ending
Date of Check
ITYPE OFPAY
LlI
REG
,~
Stat:U1IInt of. paymant. to:
._;. ">5t.w.......~'\.
CURRENT
966.19
59.90
14.01
164.09
ZUJ5
9.66
=1
23,568.77
1.460.64
341.60
4,408.52
659.65
235.58
10.00
Advicel A425069
00 Allowances
GROSS
ncr.
MEDICARE
FEDERAL w/h
STATE w/h PA
LOCAL w/h WEST SHORE H
L0CAL2 w/h
2nd srAIE If/h
I DEFERRED coMPENSATION PLANS !
;:~;"SS'401K ':! ".:96.62 2,366.88
r..:":'" '1"
"'J
. FAM SUP
. .. ':'~"",,:': OTHERDEDUCTlONS
.,. 302.00 DRIVE
I
1.00
1.00
MEALS 11.87
Net Pay $.......303.73
, --r-
J
REMOVE DOCUMENTALONG THIS PERFORATION
"
.:'U..~;I~:~I;":I~~~'~~~I~~'~"I;~'~'I:"~~~;llrl;":I:...~I...ll.]II.:I.'~...le1:"':l;
A425069 ..
',:".
D_t.o1'P.q
05/J.7/0J.
Tn'EOFPAY
1Jl
BOURS
CURRENT
1.152,24
11.43
16.70
210.97. '
32.2<>
1Ui:2",
YTD I Advice # A360240
17,216.2:1
1,067.4.0
24.9.63
3.165.74
482,00
',172.16
10.00
~
Employee ' BARRYWSAMPSQN
SSN 175-4fr-6333
Depart:nient. .:,:::" .135R70
Federal Taxsta~,: S.I!i"g~":,>
~Beginning "":::" .'-03125/0"1
Pay Ending '.". , il313I/Ol
Date of Check 04/i2/01
Net Pay $*.11:....693..14
,,-.
F\Ef>::!ClVEE()CUMENTAL()I:I(3.~IS PERFORATION
. .,
.:1""01.1101.',' ',"~..II."'."""'''''''''.'''''~I''.' "...-"..'.,.,..'..,..."'.,'.I.l",.'.1:1:
~
A360240
:stat..~t .;.~ pa.ym.nt. to.
, BARRYWSAMPSON
, 247SSPRINGGARDENSTBOX212
~ PA 17013
Dataa[Pa.:r
- ,:, Net Pay of $.......693..14 wasdeposited
. inacccnmt number 0008281207
, at. PA CENTRAL FED CR U
, I.dca:6on . 135 R7D
tip 4
"r-_
--
-
'~';';'
NON-NEGOTIABLE WAGE~ATEMENT
:r
135 BW SAMPSON
P/E 3/31/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH DRIVER TOU MIL.ES HOURS RATE WAGE DELAY
IDENTIFlCATION NBR. EQUIP.
MO. DAY ORIG. DEST. EXTENSION DESCRIPTION
3 25 135-0844515 2DP 135 671 1 39 .48375 191:08
,
,
3 26 671-0852718 2DP 671 135 2 39 .48375 191 :08
,
3 28 135-0872241 135 ,
2DP 671 3 39 .48375 191:08
3 28 3 .50 19.1700 9:59 MlSC ENRT
,
3 29 671-0883110 2DP 671 135 4 39 .48375 191108
,
3 30 135-0890802 lRT 135 671 5 37 .47375 177:66
,
3 31 671-0902015 135 6 .48375 ,
2DP 671 39 191 :08
3 31 6 .50 19..1700 9159 IMP ASS HWY
,
84 MEAL /LOD IN S 0..00 1152124
TO R OUNT 6 TOTA MIL S 235
I
,
,
,
,
~ rI'~..!:..."""'.
AApress
Employee BARRYWSAMP'SON
SSB . :" 115-4(1-6333
Department, - .135 R70
~~''!~~~'': "~~GLE -,OOAllowances
hy~ ::1" ':~,:o3ils/of
h;J'Ending: . ..,. ?:':'03l24/(U,'" .'."'."...:.
DateofChecl( ",:::;.04/05101
ITYPB:OFrAY HOuRs "_CROSSAIIOUNt\"
Nf . :,.1'.00 ,<:':':'i::::~:'.':,,~M:~
......-.-............ ..........:O{J.
=...
"".52
11.35
117.73
21.91
7."
16,053.96
"".07
232.93
2,944.TT
449."
160.M
10.00..
DEDUC1'IONS
Dm!:
1.00
Net Pay $.~Bf.JI..456.82
.,:c~~t
REMOVE DOCUMENT ALONG THIS PERFORATION
t
'~
-.<".,..:-'
1:1~""".'''''~I''''''.''.'tl''11~1.-'''..'''''"'''.'"''.'-';'''l.1tl.'~.'I"..N"'".!~."':J:
A34897~
. .,
$t.atULa!l;t.'o:t,~t't::clot
BARRYW SAMPSON
, 241SSPRINGGARDEN'STBOX212
. CARLlSLE PA 17013
HctPayof $.......456.82 wasdeposited
inaccountnumber OOD828l207
at.PA~FEJ)CRU
'Location", 135 R70
tfp4
NON-NEGOTIABLE WAGE STATEMENT
135 BW SAMPSON
PIE 3/24/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DRIVER WAGE D"-AY
DATE DISPATCH EQUIP. TDU MILES HOURS RATE EXTENSION OESCRIPTtON
MO. DAY IDENTIACATlON HaR. ORICO. DEST.
3 21 135-0805231 1RT 135 671 1 39 .47375 187!13
,
,
3 22 671-0813718 2DP 671 135 2 39 .48375 191 :08
,
,
3 23 135-0820019 20P 135 671 3 39 .48375 191:08
.
,
3 24 671-0832Q46 20P 671 648 4 12 .48375 59:02
3 24 671-0832104 2DP 648 135 4 27 .48375 134:97
4 1. 00 19.1700 19:17 PERFORM D/H
3 24 ,
B4 MEAL ILOD IN S 0.00 782:45
,
TO R OUNT 4 IOTA MIL S 158 i
i
:
,
,
,
,
,
,
,
,
,
,
.
,
:
:
,
,
,
,
,
,
,
,
""'"
'"''
","!CAllE
FmEltALwlb.
, SlATE will PA
ux:AL wf) W[SI' SHlRE 11
I.OC:M.2w/h .
. 2nd STATE ,,/h .
.. I .:'. DEP'ERREDCOlolPRNSA110NPLANS 1.;: .~::,
"jR!:i!~~~Z!:~!~~:noNS ..528....
DRIVE ~., UXl"
CURRENT
1,025.34
63.53
14.88
179.24~
'28.74.
10.26 .
YTDI
15,2131.61
lU.7.4fi
:m.SO
2.826.09
'4ZT.B9
"".82
,10.00
~
Adrice# A336CB3
Employee BARRYWSAMPSON
SSN ' i75-40-6333
Department _ ,:',.,':,::. .'J35R70 ." ,. .
FederalT.u:St3.tns '$jINGLE ~OOAliDwD.ces '.
Pay Beginning' ',03/11/01 '., .:;" ::.:..... :,'
Pa;yEnding "'. ",,' 0,:::.:03117/01 ':-":':.:,:",~
DatcofCbcck . ': ',03/29/01 - ': .~",,'~~'f
ITYPEOFPAY . HOURS GROSSAMOl1N'I1-":"'~
IJI ;1.026.3C
NelPay $.......62536
t
REMOVE DOCUMENT ALONG THIS PERFORATION
-t
." ~~;:.,..: I \.I~-,'I~,.~~I~if"I~""".,,'r.."=-'LIJr'1-""'""'..".11,..L.,,'.'.'<1""""
~
~":r'
A336083
Stat__t ot! p.y...at"1:ot
BARRYWSAMPSON
2475 SPRIRGGARDEN STBOX2U
CARLISLE PA 1'lD13
':".
NetPayof $.......625.96 wasdcposited
in a.ccoant number 00082Bl207
at PACENTRALFED CRU
:LOca.tfon . 135 R1D tip 4
..NON-NEGOTIAm.E WAGE STATEMENT
135 BW SAMPSON
P/E 3/17/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
DATE DISPATCH ORIVER WAGE OELAY
MO. OAV IDENTIFICATION NBR. EQUIP. TOU MILES HOURS RATE
OR1G. DEST. EXTENSION DESCRIPTION
3 11 671-0692904 20P 671 135 1 39 .48375 191 i08 .
3 12 135-0711622 2DP 135 671 2 39 .48375 191:08
,
3 13 671-0724251 2DP 671 135 3 39 .48375 191 :08
3 13 3 1.50 19.1700 28:76 MISe WAIT
,
3 14 135-0732407 2DP 135 671 4 39 .48375 191:08
3 14 4 !. 70 19.1700 32:59 WAIT EQ REP
.
3 ,
15 671-0741057 2DP 671 135 5 39 .48375 191:08
3 15 5 .50 19..1700 9:59 MIse WAIT
84 MEAL /LOD IN ,
S 0.00 1026:34
TO R aUNT 5 TOTA MIL S 197 .
,
,
.
.
,
,
,
,
!
,
,
,
,
,
!
,
,
,
,
,
I
,I CURRENT
947.50
53,74
13.74.
"159.38
26;53"
oIt.48
TI'D I ", Advice # A321165
14,255.17
883.82
2)6.70
: 2,64.7.75
"SW.15
"; 142.56
10.00-.
. .
~
Employee ,B,\RRYWSAMPSON
SSM . ~ .. '. :175-40-63a3
Departmcu.i .:. _, )3S R70 - .. "0",". "".'" -: ,.
Federal Tax~ .,~GLE, - 00 Allow:m.ces
Pa;y-.;nnn;" ... .';3/04/01
PayEnding . "'03/10/01
Date of Check . 03/22101
I TYPE OFPAY HOURS GROSSAl(OUN'li.
LB 94.7.50 .
. Net Pay $.......583.88
t
.REMOVE DOCUMENT ALONG THIS PERFORATION
t
~
1:1.......II.I..lt.'rl:;~.III01.I~.f..I~~'.','I....::I.1 T,r'1'1;".1,11'.'.leII..:.r'1~II.l~"f":.r:
",,. ,
A32J.J.68
-.,,'
st:a,t.--.=t of p.~t to:
BARRYWSAMPSON
2475 SPRING GAlWENSTBOX2U
aDr T<:r ll' PA 17013
'Net P3y of $........583.88 ~ deposited
inaccountnumber' 0008281207
-at PA CENTRAL fED CR U
Location 135 R70
.~,,, ~:'"
tip,
.NON-NEGOTIABLE WAGE'STATEMENT
135 BW SAMPSON
P/E 3/10/01
ROADWAY EXPRESS, INC.
ROAD DRIVER'S PAYROLL SUMMARY
175-40-6333
OAT< DISPATCH DRIVER WAGE DELAY
EQUIP. TOU MILES HOURS RATE EXTENSION DESCRIPTION
MO. OAY IDENTIFICATION NSR. ORIG. DESi.
3 06 135-0653217 lRT 135 671 1 39 .47375 187:13
:
3 07 671-0665738 2DP 671 .48375 ,
135 2 39 191108
,
3 08 135-0674612 lRT 135 671 3 39 .47375 187:13
,
,
3 09 671-0683320 2DP 671 135 4 39 .48375 191:08
,
,
3 10 135-0695747 2DP 135 671 5 39 .48375 191:08
,
,
B4 MEAl /lOD IN S 0.00 947:50
TO R aUNT 5 TOTA MIl S 197 ,
,
I
,
,
,
,
,
,
.
'"
",
< 1,:., _, .~ ~".~;:;::.<~~,~~;. ,-;' ,',';',:;;' ..'-:'c),'.....' ....'", ,,-' '"
~
Advice # A.297l53
TrP!tOF'I"AY
"'"
tll
GRlES
nct.
""""""
FEDmAL ."/h
STAn: w/h PA
'.LOCAL w/b. WESrSll:UtEfi
LCIC:At2..,,/b. . ..
'''~SUI'E.'''/h.
'1' DEPERRBDCQIlPENSATlONPLANS I.
r.,;.~..:~;},~411!ll'f}'f!;tj104'01 , '.,~."
. .:.':';':;,+;~';~DEDucnONS
"' VII JJms 39.00 DRIVE
CURRENT
1,040.08
1S4.49
'1~:~.
".12
~o.4D
YTD I'
11,llS7.52
736.11
171.gs
" !:l.lOQ.OB
. 332.02
l1S.58
'+0.00
Employee BARRYWSA.MPSOH
SSH' '.'. : ,"175-40-6333: . , . ,
Department ."..':":135R70' ';.....,;.; -;'.-.' "".'.',
FedcralTaxstatus SINGLE_, ::,::;':'(10 Ari~ccS
Pay Beginning ;.02/18/01'
Pa,yEndmg. 02124101'
Date ofd1eck' ... 03/08/01
HOURS
9.75
I
1.00
,- , .
Net Pay $.~..!If..594.27
...
REMOVE DOCUMENT ALONG-THIS PERFORATION
...
~
...u ,
I:'........,.~..I,' l::o,...:..~:'"~:.'~,~-:"".""'n::o-'" ,..-,;....,'....,I..:1.1,'...ret.'..,,:
"'"'."' ,
A297~53
','
Stat...nt crl! paymaDt to:
BARRYW SAMPSON
2475 SPRING GARDEN Sl" BOX 212
CARLISLE PA 11013
..
. NetPay~f .$......*594.27 wasdeposited
maCCOtmtnumber '0CJ08281207 "'-
at PACERTRALFEDCRU
LocatiOn. 135 R1D
tip,
,,--
. NON-NEGOTIABLE WAGE STATEMENT
135 BW SAMPSON
P/E 2/24/01
175-40-6333
ROADWAY EXPRESS, INC.
ROAD DRIVER'5 PAYROLL SUMMARY
DATE DISPATCH EQUIP. DRIVER TO" MIL.ES HOURS RATE WAGE DELAY
MD. DAY IDENTIFICATION NBR. ORIG. OEST. EXTENSION DESCRIPTION
2 20 135-0515947 2DP 135 671 1 39 .48375 191 l08
,
,
2 20 671-0511028 2DP 671 135 2 39 .48375 ,
191:08
.
,
2 21 135-0523151 2DP 135 680 3 37 .48375 180 :92
2 22 680-0531959 B/T 680 671 3 9 .47375 45:95
2 22 3 .50 19.1700 9:59 IMPASS HWY
2 22 3 .75 19.1700 14!38 PERFORM D/M
.
2 23 671-0543503 2DP 671 135 4 39 .48375 191:08
2 23 4 1.30 19.1700 24:92 LAYOVER
.
.48375 .
2 23 135-0540718 2DP 135 671 5 39 191:08
,
B4 MEAl /LOD IN S 0.00 1040:08
TO R aUNT 5 TOTA MIL S 205
~ If' ?-::
c:: z
l;;:; -" 3:='
1[{~~:~ . ::::: Ll~
Tt---..t-- C)..~ 03
{:?r.. c' 2;fn
0'-' ~z
t..!--1c" .~ ,,~
eE L~.l. s;~ \DL
~. UJO-
F.' :z
L' :::l
u 0 CJ
,
BARRY W. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
INVENTORY OF PLAINTIFF
Plaintiff:, Barry W. Sampson files the following Inventory of all property owned or
possessed by either party at the date of separation and the present date and all property
transferred within the preceding tluee years from the date of separation.
Plaintiff, verifies that the statements made in this Inventory are true and correct to the
best of his knowledge, information and belief.
Plaintiff understands that these statements are made subject to the penalties of 18 Pa.C.S.
g 4904 relating to unsworn falsification to authorities.
f~/ ~0~_
Barry . Sampson,lPlaintiff
Assets of Parties
Plaintiff lists below those items applicable to the case at bar and itemizes the assets on the
following pages. If an item has been appraised, a copy of the appraisal report is attached.
[] 1. Real Property
[ x ] 2. Motor Vehicles
[] 3. Stocks, bonds, securities and options
[] 4. Certificates of deposit
[] 5. Checking accounts, cash
[] 6. Savings accounts, money market and savings certificates
[] 7. Contents of safe deposit boxes
[1 8. Trusts
[] 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
[] 10. Annuities
[] 11. Gifts
[] 12. Inheritances
[] 13. Patents, copyrights, inventions, royalties
[] 14. Personal property outside the home
[] 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
[] 16. Employment termination benefits-severance pay, workman's compensation
claim/award
[] 17. Profit sharing plans
[ x ] 18. Pension plans (indicate employee contribution and date plan vests)
[] 19. Retirement plans; Individual Retirement Account
[] 20. Disability payments
[] 21. Litigation claims (matured and unmatured)
[] 22. MilitaryNA benefits
[] 23. Educational benefits
[] 24. Debts due, including loans, mortgages held
[x] 25. Household furnishings and personalty (include as a total category and attach itemized
list of distributions of such assets is in dispute)
[] 26. Other-collections
Marital Property
Plaintiff lists all marital property in which either or both spouses have a legal or equitable
interest, individually or with any other person, as of the date of separation and the present date.
Description
of Property
Names of All Owners
Date of Acquisition
Item Number
2
1984 Corvette
Barry W. Sampson
Unknown
2
1985 Plymouth
Annette Sampson
Unknown
18
Central PA Teamsters
Pension Fund
Barry W. Sampson!
Annette Sampson
1992 (approx.)
25
Household goods to
include washer/dryer
and other appliances,
furniture, electronics,
etc.
Barry W. Sampson!
Annette Sampson
During marriage
,
Item Number Cost or Value as of Value as of Date Amount of Anv Lien
Date of Acquisition Action Commenced
2 Unknown $3600 (value it was N/A
traded for)
2 Unknown Unknown N/A
18 Unknown $65,007.86 (approx) N/A
25 Unknown Unknown N/A
Non-Marital Property
Plaintiff lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
None
Liabilities of Parties
Plaintiff lists below those items applicable to the case at bar and itemizes the liabilities on
the following pages.
[] I. Secured Mortgages
[] 2. Judgments
[] 3. Liens
[] 4. Other secured liabilities
[ x ] 5. Unsecured credit card balances
[] 6. Purchases
[] 7. Loan payments
[] 8. Notes payable
[] 9. Other unsecured liabilities
[] 1 O. Contingent or deferred contracts or agreements
[] II. Promissory notes
[] 12. Lawsuits
[] 13. Options
[] 14. Taxes
[] 15. Other contingent or deferred liabilities
Liabilities
Plaintiff lists all liabilities of either or both spouses alone or \Vith any other person as of
the date of separation and the present date:
Item Nwnber
Description
of Liabilitv
Names of All
Creditors
Names of All Debtors
5
Credit card purchases
Sears, Visa, J.C.
Penney
Barry W. Sampson!
Annette Sampson
Item Nwnber
Date Liability was
Incurred
Amount of Liability on Date Incurred and
Action was Commenced
5
During marriage
Sears: $500, Visa: $2,200, J.e. Penney: $1,000
Item Nwnber
Date Balance is Due
Periodic Pavment and Amount
5
Monthly
Approx.$150/month
Property Transferred
Plaintiff lists all property in which either or both spouses had a legal or equitable interest
individually or with any other person and which has been transferred within three years
preceding the date of separation:
Item Nwnber Description of Names of All Date of Date of Transfer
Property Owners Acquisition
2 1984 Corvette Barry W. Unknown After separation
Sampson
Item Nwnber
Cost or Value as of
Date of Acquisition
Value as of Date
Action Commenced
Amount of Anv Lien
at Date of Transfer
2
Unknown
$3,600 (amount
traded for)
N/A
Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that
he acquires additional information regarding assets and/or liabilities.
Respectfully submitted,
LAW OFFICES OF RICHARD C. GAFFNEY
\---.....
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Richard' C. Gaffne, SqllU e
,
PA Supreme Court IDNo. 3313
Laura A. Gargiulo, Esquire
PA Supreme Court ID No. 86128
2120 Market Street, Suite 101
Camp Hill, PA 17011
Telephone: 717-975-9033
Facsimile: 717-975-9034
Attorneys for Plaintiff
BARRY W. SAMPSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
VERIFICATION
I verify that the statements made in the foregoing Inventory are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to unsworn falsification to
authorities.
Dated: \\-L<;'-CI
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arry . '. Sampson"
.
BARRY W. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NO. 2000-142
DIVORCE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he/she deposited a true and correct copy of the
foregoing Inventory of Plaintiff in the United States Mail, at Camp Hill, Pennsylvania, postage
prepaid and addressed as follows:
Michelle J. Anderson
Certified Legal Intern
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
Dated: Ii /2.<:'/0'
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OIlDfRfNOTJCf TO WITHHOLD INCOME fOR SUPPORT
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State Commonwealth of Pennsvlvania nJ(1$f'S q (X/.'/ 15 3 :;itJl!'
CCt/City/Dist. of CUMBERLAND ^
Date of Order/Notice 01/31/02 ...uK. 36535'
Court/Case Number (See Addendum for case summary) .
- - 0 Original Order/Notice
@ Amended Order/Notice
o Terminate OrderlNotic~
) RE, SAMPSON, BARRY W.
) -- Employee/Obligor's Name (Last, First, MI)
)
)
)
i
)
)
)
175-40-6333
Employee/Obligor's SociaL Security Number
0602100504
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names assodated with CifSes on attachment)
Custodial Parent's Name (last, First, M1)
Employer/VVithholder's Federal EIN Number
RnnnWAY EXPRESS INC
Erriployer/Withholder's Name
1077 GEORGE BLVD
Employer/Withholder's Address
AKRON OM 44310~2408
See Addendum for dependent names and birth dates assodated with cases on attachment.
ORDER INFORMA TION: This is dI1 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 in_come until further notice even if the Order/Notice is not
issued by your State.
$ 700.00 per month in current support
$ O.ooper month in past-due support Arrears 12 weeks or greater? Qyes @ 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 $ 700 .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:
$ 161.54 per weekly pay period.
$ 323 08 per biweekly pay period (every two weeks).
$ 350 00 per semimonthiy pay period (twice a month).
$ 700.00 per monthly pay period.
REMITTANCE INFORMA TION:
Yoo must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
OroJ:!r/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
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 pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDUl Employer
Cusfomer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send checlcto: Pennsylvania SCOU, 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.
fES
,
1 2od~
Form EN-Q 8
Worker ID $IATT
Date of Order:
Service Type M
B8 ~I~ ~.~ OMBNo.:0970.01H
~.. .i;'S.~':. . ExpirationDate:12f31100
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o \~ cne'C\<.ed you ate required to pmvide a copy of this form to your employee.
1. :- Priority: Withholding under this Order/Notice has priority over any other legal process Linder 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 requestin-g
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 identify the portion ofthe single payment that is attributable to
each employee/obligor.
3. * _ Repe.ting tIle. Paydateleate--o-fWithlluldillg. 'I<OU 111U5t repott~paydate!da.f~ of v~itlJl.o,ldjl.g yyl1~.l 5end:.lg the pa.~,n<!.nt. The.
paydate!date of yyitLLoldh,g i3 the-date-Oh yyll;c1. alllOUllt ~~a5 >Yitl,I.~Jd fromtl,o;:;; o;:;;ulI..Aoyee1s yyag~j. You mus-t comply with the law ofthe
state of the employee~s1obligor~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
againsfthis 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/obfigor's principal place of employment. You must honor all Orders/Notices to the greatest
extent possible. (See #9 below)
5. =- 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: 3404926700
EMPLOYEE'S/OBLlGOR'S NAME: SAMPSON. BARRY W.
EMPLOYEE'S CASE IDENTIFIER: 0602100504 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
severaoce 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 the Order/Notice directs, you are liable for both the accumulated amount you should
have wJtbheld 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 otthe 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 emploYI 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
Protection Act (15 U.S.c. S1673 (b) 1 ; or 2) the amo-unts allowed by the State of the employee'slobligor's principal piace of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
de'ductions such as: State, Federal, local taxes; SociaI Security taxeS; and Medicare taxes.
10.
"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 orderwi.tbjespecuo these items.
Requesting Agency:
DOMESTIC RElATIONS SECTION
13 N HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contad WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (7171 24()"6248 or
by Intermit @
Page 1 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970.0.154
ExpirationD~12131/o0
~-
"
ADDENDUM
Summarv of Cases on Attachment
Defendant/Obligor: SAMPSON, BARRY W.
/;
42 n 0 3 2 0 I :.?0:;7:7~
PACSES Case Number
Plaintiff Name
ANNETTE SAMPSON
Docket Attachment Amount
00-1.42 CIVIL $ 700.00
Child(ren)'s Name(s):
DOB
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blf~hec"~d;y~~ are req~i;~dt~~nr~H thechild(ren)'" .
identified above in any health insurance coverage avaflable
through the employee's/obligor's employment
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
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b If ~'h~~ked, you are required to en~~1I the ~hild(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)', Name(s):
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identified above in any health insurance coverage available
through the employee's/obligor's employment.
Addendum
Service Type M
OMBNo.:0970.o154
Expiration Date: 12/31100
PACSES Case Number
Plaintiff Name
Attachment Amount
$ 0.00
Child(ren)'s Name(s):
Docket
DOB
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D If che~ked, you are required to enroll the chiJd(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
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D 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(,):
DOB
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D 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.
Form EN-028
Worker ID $IATT
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BARRY W. SAMPSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant
NQ.JOOO-142
DIVORCE
CERTIFICATE OF SERVICE
I, Carol Verish, Certified Legal Intern, Family Law Clinic, hereby certify that I served
a true and correct copy of the Defendant's Waiver of Notice and Affidavit of Consent on Laura
Gargiulo at the Law Offices of Richard Gaffney, 2120 Market Street, Suite 101, Camp Hill, PA
17011 by depositing a copy of the same in the United States mail, First Class, postage prepaid,
this 22ud day of February, 2002.
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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BARRY W. SAMPSON,
Plaintiflj'Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
Defendant/Respondent
: NO. 00-142
: DNORCE
DEFENDANT'S COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE
L Check either (a) or (b):
o '(a)' I do not oppose the entrY'of a divorce decree.
~ (b) I oppose the entry of a divorce- decree because (Check (i), (ii) or both):
o (i) The parties to this action have not lived separate and apart for a period of at
~t two years.
JSJ.. (ii) The marriage is not irretrIevably broken.
2. Check either (a) or (b):
o (a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them
before a divorce is granted,
lllr (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the prothonotary in writing and serve them on the other party. If I fail to do so
before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree
may be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
RECEIVED JUL 0 6 2001
'- - -- . -
VERIFICATION
I verify that the statements made in this counteraffidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904
relating to unsworn falsification to authorities.
D"~UA' ",q, "'CO ,
Q1H~rt1~~~~
nnette Sampson, D endant
#0. . ~
BARRY W. SAMPSON,
PlaintiWPetitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SAMPSON,
DefendantIRespondent
: NO. 00-142
:DNORCE
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certifY that I am serving a true and correct copy of
Defendant's Counter-Affidavit Ullder S3301(d) of the Divorce Code for Defendant, Annette
Sampson, on the following person, cOUllsel for Plaintiff, be depositing a copy of the same in the
United States mail, postage prepaid, this lOth day of July, 200 I:
Richard e. Gaffuey, Esquire
2120 Market Street
Suite 101
CampHill,PA 17011
I
i
Michelle L. Anderson
Certified Legal Intern
FAMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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BARRY W. SAMPSON,
PlaintifflPetitioner
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANNETTE SAMPSON
DefendantlRespondent
NO. 2000-142
DIVORCE
NOTICE
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.
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on October 27, 1998 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 in 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.A. S 4904 relating to
unsworn falsification to authorities.
Date:'~ !7' ~ppl
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Barry W. ampson'
Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO.,J(}1J{)- /1/2 CIVIL TERM
IN DIVORCE
BARRY W. SAMPSON
PLAINTIFF
ANNETTESAMP~ .
DEFENDANT
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaintin divorce under Section 3301(c) of the Divorce Code was filed on
,L:;/lvt>-'~ ~ :JO()D . ",.,. ,
D e.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn fulsIDcation to authorities.
Date: .rI' a ,{ I S-.J ~ 0 () ()
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BARRY W. SAMPSON
PLAINTIFF
:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
ANNETTE SAMPSON
DEFENDANT
No.tl600-/</ Q CIVIL TERM
IN DIVORCE
PLAINTIFF'S 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 veritY that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: M <\. Y g :J ()()O
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Barry W. pson (Plainti~
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FEB 2 2 2002 J!---
DR # 30535
PACSES ID 421103204
BARRY W. SAMPSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ANNETTE SANlPSON,
Defendant
: NO. 2000-142
: DIVORCE
AGREEMENT AND ORDER
This Agreement (hereinafter "Agreement"), made effective this J.La... day of
~~)UAeY
, 200Uy and between Plaintiff, Barry W. Sampson (hereinafter
"Husband"), and Defendant, Annette Sampson (hereinafter "Wife"), concerns the resolution of
the equitable distribution, alimony pendente lite and alimony claims in this action.
WHEREAS, Husband and Wife desire to enter into an agreement as to all economic
issues between the parties, except as set forth below, and to have this agreement made an Order
of Court.
NOW, THEREFORE, Wife and Husband, each intending to be legally bound hereby,
agree as follows:
DIVORCE
1. The parties have lived separate and apart since January 1999.
2. Each party will execute an Affidavit of Consent and a Waiver of Notice of Intent
to Request Divorce Decree within ten (10) days of the execution of the Qualified Domestic
Relations Order ("QDRO") contemplated by this Agreement.
1
/'
FINANCIAL DISCLOSURE
3. Attached hereto as Schedule "A" and "8" are the financial disclosures of the
parties with respect to their assets, liabilities and income. Each party confirms that he or she is
relying upon the substantial accuracy of the other's financial disclosure as an inducement to the
execution of this Agreement. No representations or warranties have been made by either party to
_ the other, or by anyone else as to financial status of the other, except as expressly set forth in this
Agreement and Schedules "A" and "B".
DEBTS
4. Except as otherwise identified in this Agreement (and Schedules "A" and "B"
attached hereto, and incorporated by reference), the parties represent and warrant to one another
that they are not aware of any other items of marital debt.
ASSETS
5. Except as otherwise provided in this agreement, all clothing, personal propelty and
household furnishings have been divided between the parties to their mutual satisfaction, and
neither party will make any claim to such items that are now in the possession or control of the
other.
ALIMONY PENDENTE LITE (APU / ALIMONY
6. The parties agree that the April 26, 2001 APL Order shall remain in effect
until August 22, 2001. Effective August 22, 2001, Husband shall pay to Wife the swn of$700
2
'.
.per month. As of August 22, 2001, Husband was in arrears on his APL in the amount of $2,477.
Husband paid wife $2,568 during the period of August 22, 2001 through October 22, 2001; this
amount is allocated by the parties as $1,400 APL and $1,168 towaro arrears on APL. As of
October 22,2001, Husband is in arrears on APL by $1,309. The arrears will be paid by Husband
in addition to his APL / alimony obligation to Wife in no more than seven (7) monthly
installments, six (6) of $200 each, one (I) of $1 09. Thus, Husband will pay Wife no less than
'\
$900 per month for the months of November 2001 through April 2002, and no less than $80,0 for
the month of May 2002. Not\Vithstanding the foregoing, however, Husband shall have the right
to pay down his arrears balance sooner.
7. Monthly payments made by Husband shall be treated as APL until the divorce
decree is entered and thereafter they shall be treated as alimony.
8. Husband's alimony obligation shall terminate upon:
a. Wife's remarriage;
b. Wife's cohabitation in the same residence with any adult male, other than
a member of her family within the degrees of consanguinity set forth in 23
Pa. C.S. S3706 and 23 Pa. e.S. s1304(e), for a period of sixty days, which
days need not be consecutive;
c. The later of Husband's retirement or July 1,2005;
d. the death of either Husband or Wife, although Wife or Wife's estate may
recover any arrearages due at the time of death; or
e. Wife actually receiving her interest in Husband's Teamster's Retirement
Income Plan 1987 (whether payments or lump swn disbursement).
3
9. Notwithstanding paragraph 8, Husband may petition for a decrease in the alimony
amount if, and only if, Husband is so disabled, mentally or physically, that he is unable to
perform his usual occupation for a period of six (6) months or more. In the event that there is a
dispute concerning Husband's disability, Wife shall have the right to have Husband examined by
a medical doctor for the purpose of detennining whether or not such disability exists.
PENSION
10. Husband participates in the Central Pennsylvania Teamster's Pension Fund
Retirement Income Plan 1987 ("Plan"). Husband shall assign to Wife an interest in the Plan (as
set forth below), through the vehicle of a Qualified Domestic Relations Order ("QDRO").
11. Both Husband and Wife shall cooperate in good faith in the preparation,
execution, and filing of a QDRO. Husband is obligated to take all necessary and appropriate
actions in the drafting, filing, and execution of a QDRO.
12. Counsel for Wife, the Family Law Clinic, shall be responsible for drafting,
submitting, and obtaining approval of the QDRO.
13. The amount of benefit to be assigned to Wife shall equal fifty percent (50%) of
Husband's account balance in the Plan as of December 31, 1998, together with any investment
results thereon from December 31, 1998 until the date of distribution. Such account balance
shall be determined without regard to any outstanding plan loans.
14. It is contemplated that the Plan will create a separate account to hold Wife's
interest in the Plan. The parties agree that the creation of a separate account shall not constitute
Wife "receiving her interest" in Husband's Retirement Income Plan. Thus, the creation of a
4
:
-separate account shall not affect wife's right to alimony under Paragraph 8.
15. According to the terms of the Plan, and after giving reasonable written notice to
Husband, Wife may begin to receive the assigned benefits any time that she wishes to receive
them.
16. Wife may elect to receive benefits in any form of benefit payment that is available
to Husband, so long as such form of benefit is available to Wife pursuant to the terms of the Plan.
17. Death of Husband shall have no effect on the payment of the benefits to Wife,
except to the extent that said payments are restricted pursuant to the Plan.
18. In the event that Wife predeceases Husband, benefits shall be paid to Wife's
estate, or any other beneficiary selected by Wife under and pursuant to the tenns of the Plan.
19. In the event that Husband files for bankruptcy, Wife's interest in the Plan shall be
protected, to the extent of applicable laws, rules, and regulations, and to the extent that any such
protections are available under and pursuant to the Plan.
20. Husband shall not withdraw, assign or otherwise alienate the Plan funds to the
extent that any such withdrawal, assignment, or alienation would reduce the amount of benefits
available to Wife under and pursuant to the Plan. To the extent that Husband does take such
actions and they reduce the amount of benefits to which Wife is entitled, Husband shall make
payment directly to Wife of an amount that is the equivalent of what Wife would have received if
Husband had not interfered with the assignment of bene fits. Husband cannot, and does not,
guarantee against market risk, currency fluctuations, acts of God, acts of war, and any other force
majeure events. Husband cannot, and does not, warrant the operation of the terms of the Plan.
21. This order shall be enforceable by the power of this Court for contempt and shall
5
.be treated also as an Order of Court purSUlmt to the APL case filed as 2000-142 and PACSES#
421103204 for purposes of any necessary wage attachment.
REMEDIES
22. If either party breaLhes any provision of this agreement, the other party shall have
the right, at his or her election, to sue for damages for such breaLh, and seek any other remedy
allowed under Pennsylvania or Federa11aw.
23. Any party breaching this agreement shall be responsible for the payment of all
legal fees and costs incurred by the other in enforcing his or her rights under this agreement, or
seeking such other remedy or relief that may be available to him or her.
FULL AND FINAL SETTLEMENT OF ALL CLAIMS
24. Except as provided herein, Husband and Wife agree that the execution of this
1Jj(S DJ1d #It QDRO -prov (ded fOr n.ertin
~eement\s a full and fmal settlement of all economic and other claims between them,
including, without limitation, the ownership and equitable distribution of marital property, the
past, present and future spousal support, alimony, alimony pendente lite and/or maintenance of
either of them, and in general, any and all claims and all other possible claims by one against the
other or against their respective estates.
BlNDlNG ON PARTIES AND OTHERS
25. This agreement shall be binding on the parties and their respective heirs,
executors, administrators and assigns.
6
INCORPORATION
26. The parties intend this agreement to be incorporated, but not merged, into the
divorce decree. This agreement shall continue in full force and effect after such time as a final
decree in divorce rnay be entered with respect to the parties.
,. IS 27. The parties intend to be legally bound by the terms of this agreement, and intend
6J'll lWld -I!1w.{ort9:l/ii l\>DIW
that it"be fIled with the Court as satisfaction of all claims relating to Equitable Distribution, APL
or alimony. However, the parties agree that failure to file this agreement with the Court shall
have no effect on the parties' obligations or the ability to utilize any remedy for enforcement.
MODIFICATION TO BE IN WRITING
28. No modification or waiver of any of the terms hereof shall be valid unless in
writing and signed by both parties.
LAW OF PENNSYLVANIA APPLICABLE
29. This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania.
INTEGRATION
30. This Agreement constitutes the entire understanding of the parties and supersedes
any and all prior agreements and negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
7
, "
OTHER DOCUMENTATION
31. Within ten (10) days after demand thereof, the parties will execute any and all
written instrwnents, assignments, releases, satisfactions, deeds, notes or such other writings as
may be reasonable, necessary or desirable for the proper effectuation of this Agreement. The '
parties further agree that time shall be of the essence.
NO WAIVER OF DEFAULT
32. This Agreement shall remain in full force and effect unless terminated under the
terms of this Agreement. The failure of either party to insist upon strict performance of any of
the provisions of this Agreement shall in no way affect the right of such party thereafter to
enforce the same, nor shall the waiver of any breach of any provision hereofbe construed as a
waiver of any subsequent default of the same or similar nature, nor shall it be construed as a
waiver of strict performance of any other obligations herein.
ADDRESSES OF PARTIES
33. As long as any obligations remain to be performed pursuant to the provisions of
this Agreement, each party shall have the affirmative obligation to keep the other informed of his
or her residence address, and shall promptly notify the other in writing of any change of address
by giving the new residence address.
WARRANTY AS TO EXISTING AND FUTURE OBLIGATIONS
34. Wife and Husband each warrant that neither has heretofore contracted for any
8
liability for which the other or the estate of the other may be responsible except as specifically
disclosed and provided for by the terms of this Agreement. The parties further warrant that each
will now and at all times hereafter save harmless and indemnify the other and the estate of the
other from all liabilities incurred after the execution date hereof, except as may be otherwise
specifically provided herein, as well as from all1iabilities of every kind which have been
incurred heretofore by either party, including those for necessities, except for obligations
identified in or arising out of this Agreement. Except as may be otherwise -expressly provided
herein, the parties agree that all joint credit and/or charge accounts shall be terminated
immediately, and)ilo c4arges shall be incurred by either party against any joint account from the
~jt15 . ,
date of execution hereof lfusfoond s\1all bt. solei,} vt.sp:ms ible.. {w pOl'liVl3 an~ vemarYlo~
t?o.lQI1Ce5 6V\ -lt1e.. yiYl+ Cr.ecUf- cavd debt iwnl-rwd iil hiS Ivlvev1fvrj', o:tJotLtucl
ClS &heduJe A .
ADVICE OF COUNSEL
35. The provisions of this Agreement and their legal effect have been fully explained
to the parties by their respective counsel, The Family Law Clinic, for Wife and Richard Gaffney,
Esquire for Husband. Each party confirms that he or she fully understands the terms, conditions
and provisions of this Agreement and believes them to be fair, adequate and reasonable under the
existing facts and circumstances. The parties further confirm that each is entering into this
Agreement freely and voluntarily and that execution of this Agreement is not the result of any
duress, undue influence, collusion, or improper or illegal agreements.
36. Each of the parties has carefully read and fully considered this Agreement and all
of the statements, terms, conditions, and provisions thereof prior to signing below.
9
f__' ...
-
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and
year frrst written above.
~~UJ 2aurJW'
arry . Sampsoi{, Plaintiff
QllM'~~~ )
nnette Sampson, De endant
~''-\J)...J.ll.\~
Richard C. Gaf , uire
Laura Gargiulo, Esquire
2120 Market Street
Suite 101
Camp Hill, PA 17011
717-795-9033
Counsel for Plaintiff
--
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. helle L. Anderson
Certified Legal Intern for Defendant
~!;-,LAf;/
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle; PA 11013
717-243-2968
ORDER
AND NOW this ~ day of
~
ove
Agreement is approved and entered as an.Order of Court.
tOpies J'f')n:ll-eJ
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02 MAR -4 MUD: 57
GUMBEiilA!'>iO COUNTY
PENNSYLVPNIA
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FEB2 2 2002 )J
Barrv W. Sampson
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DIVORCE CIVIL ACTION -LAW
Annette Sampson
NO. 2000-142
CENTRAL PENNSYLVANIA TEAMSTERS RETffiEMENT INCOME PLAN
QUALIFIED DOMESTIC RELATIONS ORPER
I. Identifying Information
1. The Participant is Barry Sampson.
The Participant's Social Security number is 175-40-6333.
The Participant's address is P.O. Bo)< 212, 247 S. Spring-Garden Street, Carlisle, PA
17013-2565.
2. The Alternate Payee is Annette Sampson.
The Alternate Payee's Social Security number is 543-60-7411.
The Alternate Payee's address is 911 Cheyenne Street, West Fargo, ND 58078.
The Alternate Payee's date of birth is March 21,1952.
3. The parties were married on September 21, 1991, and separated in February 1999.
4. The parties have raised claims of equitable distribution of marital property pursuant to
the Pennsylvania Divorce Code.
II. Method of Dividing Participant's Benefits
1. The Central Pennsylvania Teamsters Retirement Income Plan shall pay to the
Alternate Payee a portion of the Participant's vested accrued benefit under the Plan.
The Alternate Payee shall receive a benefit equal to 50% of the Participant's vested
account balance as of December 31, 1998.
2. _The Fund shall separately account for the benefits awarded in Paragraph 1 of this
Section II as soon as administrable after this Order is determined to be a QDRO. The ..
Alternate Payee shall be credited with net income, loss or expense from December 31,
1998.
3. The Alternate Payee may elect to receive payment from the Plan in any form in which
benefits may be paid under the Plan to the Participant (other than in the form of a joint
and survivor annuity),
4. The Alternate Payee may select a beneficiary to receive her benefits in the event the
Alternate Payee should die prior to receivingall of her benefits by filing a beneficiary
designation form with the Fund Office. In. the event the Alternate Payee should die
prior to receiving benefits, the Plan shall pay benefits to a beneficiary selected by the
Alternate Payee on a beneficiary form provided by the Fund Office on request, or if no
beneficiary is selected, to the Alternate Payee's estate.
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Q.DRO
Page 2
5. The Altemate Payee may elect to receive payment from the Plan at the Participant's
earliest retirement age or, if earlier, at the earliest date permitted under the Plan. For
purposes of this paragraph, the Participant's earliest retirement age means the earlier
of (i) the date on which the Participant is entitled to a distribution under the Plan, or
(ii) the later of (a) the date the Participant attains age 50 or (b) the earliest date on
which the Participant could begin receiving benefits under the Plan if the Participant
separated from service.
IlL Other Provisions
1. This Order is intended to constitute a qualified domestic relations order within the
meaning of Section 414(p) of the Intemal Revenue Code of 1986, as amended and
Section 206(d) of the Employee Retirement Income Security Act of1974, as amended,
and shall be interpreted in a manner consistent with such intention.
2. The Court shall retain jurisdiction to amend this Order to the extent necessary to
establish or maintain its status as a qualified domestic relations order.
3. It is recognized that the Altemate Payee may elect to commence receiving benefits
before the Participant retires. If the Alternate Payee so requests, the Participant will
cooperate with the Alternate Payee in substantiating a claim or application to the Fund
and shall provide any documentation or information reasonably necessary to establish
their eligibility for benefits.
EXECUTED this t( 4- day of
t opi.e.S rf)c.:\ \ed
03-0t.J-O{). l ~5
to:
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C~SENT TO ORDER:
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Judge
PLAINTIFFIPARTICIPANT
DEFENDANT/ALT, E, R" NA~
GAlA' ,,'tl:. ~CUtw\
Signature _' .
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Page 3
ATTORNEY FOR PLAINTIFF/
PARTICIPANT
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Laura A. Gargiulo
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Date
2120 Market street
Suite 101
Camp Hill, PA 17011
(717)795- 9033
ATTORNEY FOR DEFENDANT!
ALTERNATE PAYEE
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~ture It:> NO ,z.o'\ <0
Teri L. Henning
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Date
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
In the Court of Common Pleas of CUMBERLAND County. Pennsylvania
DOMESTIC RELATIONS SECTION
ANNETTE SAMPSON ) Docket Number 00-142 CIVIL
Plaintiff )
-
vs. ) PACSES Case Number 421103204
BARRY W. SAMPSON )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit, on this
8TH DAY OF APRlL, 2003
IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or o Suspended or
(i)Terminated without prejudice or 0 Terminated and Vacated,
effective DE-CEl'lBER 4, 200:1 ,-due to:
THE DEMlSE OF THE DEFENDANT ON DECEMBER 4, 2002. THERE lS NO BALANCE DUE THE
PLAINTIFF.
BY THE COURT:
DRO: RJ Shaddav
xc: plaintiff'
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Service Type M
Form OE-S04
Worker ID 21005
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ORDER/NOTICE TO ~/V:lHOLD INCOME FO,R SUPP, ORT
. j)'J', ~O-/Vd{!/WL
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Date of Order/Notice 04/08/03
Tribunal/Case Number (See Addendum for case summary)
RE, SAMPSON, BARRY W.
Employee/Obligor's Name (Last, First, MI)
o Origi~a( ~rder/Notice
o Amended OrderlNotice
o Terminate Order/Notice
EmployerNVithholder's Federal EIN Number
ROADWAY EXPRESS INC
l077 GEORGE BLVD
AKRON OR 443l0-2408
"175-40-6333
Employee/Obligor's Social S....ecuri:Ly .Number
0602100504
fmployeelObligor's Case Identifier
~ - .(See Addendum for plaintiff 'lames
assOciilt(!d with cases on attachment)
Custodial Parent's Name (Last. First, Ml)
See Addendum for dependenf names and birth dafes associated with cases on atfachmenf.
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 dedu,ct these
amounts from the above-named empioyee'sfobligor's income until further notice even if the Order/Notice is not
issue~d 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 @ no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for:"total of $ 0 . 0 0 per month to be forwarded to payee below.
Yoa-:do not have to vary your pay cycle to be in compliance with the support orde.c, If your pay cycle does not match
the ordered support payment cycle, us_e theJ9110wing 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).
$ Q ..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
Oeder/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
ded_uct a fee to defray the cost of withholdin.g. 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
Ci1510mer Service at 1-877-676-9580for iristructions.'
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADOlf/ON, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as fhe Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BYT
is
Date of Order: H.::: g ,flfJif
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Service Type M
Form EN-028
Worker 10 21005
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~hecked you are required. to prpvide a ~py-oftnis form to your. employee. If YOl,lr employe~ "Yorks in.a state that is
ditterent from the state th_at IS5ue.d this order, a copy must be prOVided to your employee even If the box IS not checked.
1. We appredate the voluntary compliance of Federally recognized Indian tribes, tribally-owned businesses, and lndian-owned
business_es located on a reservation that choose to withhold in a<:.cordance with this notice.
2. prio_dty: Withholding under this Or:derlNotice has priority over any.other legal process unde.LSt~te law against the same income.
Federal tax levies in effect before recejpt ofthis order have priority. If there are Federal tax levie5 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 ofthe:;ingle payment that is attributable to each
employee/obligor.
4..-Rep<>rtingthe~Withhold+ng::-Vott ,,,uS[ ,.po,tthe-~witl,l,oldli,g ..I.e, , '.hctingihep.""OI,t. TI,. ,
paydatefdate-ofwithtrotding-is-the<late'OO'whiel, ., "auht ~wilhhektfrorrr1he-empI."e.'g ...,,"'. You must comply with the law of the
state of the employee's1obligor's prindpal 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 OrderINotice to Withhold Income for Support against
this employee/obligor and you are unable to honor, all support Order/Notices due to Federal orState withholding limits, you must follow
the law of the state of employee's1obligor's principal place of employment. You must honor all Orders/Noti,ces to the greatest extent
possible,. (5ee #10 below)
6. TermJnation 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 OrderlNotice to the .Agency identified below.
WITHHOLDER'S ID: 3404926700
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
SAMPSON, BARRY W.
060:l100504 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. liabIUty: If you fail to withhold income-as the QrderlNQtice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income al)d other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the oblfgor is employed In another 5tate, in whiCh case the law of the State in which he or she is employed govems.
9. Anti..<Jiscrimination: Vou are subject to a fine determined under State law for discharging an employee!obUgorfrom employment,
refusing-to employ, or taking discipIinary action agaInst any employee/obligor becaus.e of a support withholding. Pennsylvania State law
govem~unless the obligor is emplOyed in another State, in which case the law of the 5tate in which he or she is employed govems.
10.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit -
ProtectiJ:m 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 employmenL
The Fed,erallimit applies to the aggregate disposable weekly eamlngs (ADWE). ADWE is the net income left after making mandatory
deducttons such as: State, Federal, local taxes; Social Security taxeSi 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 oTthe 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 (717) 240.6248 or
by internet www.~hildsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID 21.005
SelVice Type M
OMS No.: 0970.Q1S4